City of Pacifica General Plan 2040
The City of Pacifica General Plan 2040, adopted by the Pacifica City Council in July 2022, is a policy document for the long range development of the City. It provides for future growth and articulates a vision for what Pacifica aspires to be. The General Plan draws it’s ideas form residents, business owners, elected officials and City staff, and translates these ideas into a set of policies and actions to guide present and future generations. The Land Use Element and Open Space and Community Facilities Element of the General Plan include the following policies which are relevant to the proposed Project.
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• LU-I-23: Esplanade. Establish appropriate zoning for privately-owned, undeveloped land on the west side of Esplanade Avenue to ensure minimal development consistent with the General Plan designation New development shall preserve the view corridor to the ocean along Bill Drake Way and shall be sited and designed to ensure that any proposed development could with-stand erosion resulting from a 100-year seismic or storm event and in accordance with LCLUP Policy CR-I-44 and preserve the view corridor to the ocean along Bill Drake Way.
• OC-G-5: Open Space Preservation. Preserve open space that protects natural resources, visual amenities, and public health and safety. The top priority areas for conservation are beaches, oceanfront bluffs, ridgelines, hill-sides areas adjacent to existing open space, and areas that support critical wildlife habitat and endangered species. • OC-I-16: Northern Coastal Bluffs. Promote the permanent conservation of private land on the Northern Coastal Bluffs to protect sensitive natural communities and protect against coastal erosion. Managed protected land together with adjacent GGNRA land. • OC-I-22: Open Space Preservation. Continue to support local volunteer or community service organizations in implementing revegetation programs on the City’s greenbelts or elsewhere to reduce erosion potential and enhance the visual quality of these areas for adjacent neighborhoods.
• OC-I-46: Northern Coastal Bluffs. Promote potential trail improvements by GGNRA to create controlled public access to the bluffs, while protecting Northern Coastal scrub and other vegetation.
• OC-I-47: Esplanade Bluff. Develop a small public park or viewing area and a trail on Cityowned bluff top land along the 400-block of Esplanade Avenue, if such improvements are feasible.
Pacifica Zoning Ordinance
The Pacifica Zoning Ordinance can be found under Title 9 of the Municipal Code. The Zoning Ordinance has been amended many times (most recently in 2021), to address changes to Pacifica’s growth and planning legislation. The Zoning Ordinance provides development standards, identifies allowable land uses, and specifies other regulations related to development within the City. The following are the most applicable provisions relevant to the proposed Project.
Article 43 - Coastal Zone Combining District, Sec. 9-4.4300. – Purpose. The purpose of this article is to establish a Coastal Zone Combining District, known as the Coastal Zone District, for the entire Pacifica Coastal Zone. This District will be superimposed over the underlying basic zones and will supplement the regulations and requirements of those zones. Consistent with the California Coastal Act, the intent of these regulations is to:
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(a) Protect, maintain and, where feasible, enhance and restore the overall quality of the coastal zone and its natural and built resources;
(b) Assure orderly, balanced use and conservation of resources within the coastal zone, taking into account the social and economic needs of the people of the state; (c) Maximize public access to and along the coast and maximize public recreational opportunities in the coastal zone consistent with sound resource conservation principles and constitutionally protected rights of private property owners; (d) Assure priority for coastal-dependent and coastal-related development over other types of development in the coastal zone;
(e) Encourage state and local initiatives and cooperation in procedures used to implement coordinated planning and development for mutually beneficial uses, including educational uses, in the coastal zone.
Sec. 9-4.4406. - Shoreline protection.
(a) Intent. The provisions of this section shall apply to all new development requiring a coastal development permit in the Coastal Zone District and shall be subject to the regulations found in Article 43, Coastal Zone Combining District. The intent of these provisions is to minimize erosion and to stabilize the shoreline in areas along the coastal bluff where ocean wave and tidal action create potentially hazardous or damaging conditions. (b) Required survey. A site stability survey, prepared by a qualified soils engineer or engineering geologist, shall be required for new development proposed on coastal bluffs. (c) Development standards. The following standards apply to all new development along the shoreline and on coastal bluffs.
(1) Alteration of the shoreline, including diking, dredging, filling and placement or erection of a shoreline protection device, shall not be permitted unless the device has been designed to eliminate or mitigate adverse impacts on local shoreline sand supply and it is necessary to protect existing development or to serve coastal-dependent uses or public beaches in danger from erosion or unless, without such measures, the property at issue will be rendered undevelopable for any economically viable use; (2) Consistent with the City's Seismic Safety and Safety Element, new development which requires sea-walls as a mitigation measure or projects which would eventually require seawalls for the safety of the structures shall be prohibited, unless without such seawall the property will be rendered undevelopable for any economically viable use; (3) Required shoreline protection devices shall be designed and sited to consider and reflect:
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(i) Maximum expected wave height,
(ii) Estimated frequency of overtopping,
(iii) Normal and maximum tidal ranges,
(iv) Projected erosion rates with and without a shoreline protection device, (v) Impact on adjoining properties,
(vi) Design life of the device,
(vii) Maintenance provisions, including methods and materials, and (viii) Alternative methods of shoreline protection, including "no project"; (4) The impact on beach scouring and sand replenishment shall be minimized; (5) Water runoff from beneath existing seawalls shall be minimized; (6) Existing unauthorized rubble or protective devices shall be removed prior to the approval of additional development in such areas; and
(7) A geotechnical engineer shall certify that the shoreline protection device will withstand storms comparable to the major winter storms of 1982 and 1983 along the California coast. (8) The seawall shall be designed to minimize impacts upon existing lateral and vertical access and in any case shall not result in the blocking of an accessway. In cases where it is not possible to engineer a wall without blocking access, then appropriate mitigation measures shall be incorporated into the design. These measures can include a stairway over the seawall to provide continuous vertical access or a platform over the seawall to provide continuous lateral access.
4.8.3 Thresholds of Significance
The Project would result in a significant land use impact if it would:
a) Physically divide an established community; or
b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.
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4.8.4 Impacts and Mitigation Measures
This section analyzes potential land use impacts that would result from implementation of the Project. It begins with the criteria of significance which establish the thresholds to determine whether an impact is significant (see Section 4.8.3, above). The latter part of this section describes potential impacts associated with the Project and identifies mitigation measures to address these impacts, as needed.
It should be noted that policy conflicts do not, in and of themselves, constitute a significant environmental impact unless it is a policy adopted for the purpose of avoiding or mitigating an environmental effect and the inconsistency would result in a significant adverse physical impact.
Please note that planning documents that pertain to specific technical topics (e.g., Noise) are discussed in those topical sections of this Draft EIR.
Impact LAND-1: The Project would not physically divide an established community. (No Impact)
The proposed Project would construct a seawall along the toe of the coastal bluff. The Project does not include any physical barriers such as new roads or barriers such that existing land use patterns would change resulting in a division of an established community. There is an “SS cable fence” that is included in the Project to protect trail users from the edge of the cliff, however, this fence would not physically divide a community.
Impact LAND-2: The Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. (Less Than Significant Impact) The Project is the construction of a seawall to protect the toe of the coastal bluff from further erosion and compromising the City’s infrastructure. The Project would not conflict with the goals and policies in the City’s General Plan or the City’s Local Coastal Program with incorporation of the fugitive dust and water quality BMPs described in Chapters 3.0 (Project Description), 4.2 (Air Quality), 4.3 (Biological Resources), and 4.7 (Hydrology and Water Quality), and with compliance with applicable laws and regulations and implementation of the mitigation measures contained in this document.
The Project is consistent with Article 43 Coastal Zone Combining District Section 9-4.4406 - Shoreline protection as the Project includes the following:
1) A Geotechnical report as required by provision (b) to prepare a site stability survey prepared by a qualified soils engineer or engineering geologist, as required for new development on coastal bluffs.
The Project is consistent with the Development Standards presented in provision (c)(1) which require that erection of a shoreline protection device shall not be permitted unless the device has been designed to eliminate or mitigate adverse impacts on local shoreline
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sand supply and is necessary to protect existing development or to serve coastal dependent uses or public beaches in danger from erosion or unless, without such measures, the property at issue will be undevelopable for any economically viable use. Provision (c)(2) is not applicable because the Project’s purpose is to mitigate an existing condition and protect existing infrastructure; and without the proposed Project, the blufftop would remain undevelopable.
Provision (c)(3) requires that shoreline protection structures shall be designed and sited to consider and reflect maximum wave height, estimated frequency of overtopping, normal and maximal tidal ranges, projected erosion rates with and without a shoreline protection device, impact on adjoining properties, design life, maintenance provisions (including methods and materials) and alternative methods of shoreline protection including “no project”. The Project’s design is based on a site specific Geotechnical Investigation prepared by Cotton, Shires, and Associates (April 2019, included here as Appendix B) and addresses these consideration. In addition to the Geotechnical Investigation, Cotton, Shires, and Associates prepared a memorandum in 2020 that presented calculations of the proposed seawall's impacts on beach sand supply. The calculated volume of beach quality sand that would have been supplied to the beach if natural erosion continued is 2,145 yards.
Based on comparisons of bluff material sand beach sand sieve analyses, the bluff material was determined to be significantly finer than the beach sand material. Consequently, the memorandum concluded that the bluff materials compose zero or a very small fraction of the beach sand. Chapter 5 in this EIR addresses alternative methods for shoreline protection.
Provision (c)(4) states that beach scouring and sand replenishment shall be minimized.
Provision (c)(5) states that runoff from beneath existing seawalls shall be minimized.
Provision (c)(6) states existing rubble or protective devices shall be removed prior to approval of additional development. The Project includes removal of riprap and prior application of shotcrete on the bluff face at the proposed seawall location.
Provision (c)(7) states a geotechnical engineer shall certify that the shoreline protection device shall withstand storms comparable to the major winter storms of 1982 and 1983 along the California coast.
Provision (c)(8) states the seawall shall be designed to minimize impacts on existing lateral and vertical access and in any case shall not result in blocking of any accessway. There is no existing vertical access at the proposed seawall location. Vertical access currently exists just north of the proposed seawall at the Ocean Aire Apartments and this access will not change as a result of the Project. Lateral access north and south of the site along the beach shall be maintained with the Project and lateral access across the blufftop will be permitted once construction activities cease. Currently, lateral access across the blufftop is not allowed for safety reasons and a chain link fence is in place to keep people off the blufftop
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above the proposed seawall.
No new uses are proposed. Mitigation is included with the Project, as described in this EIR to reduce potential environmental effects of the Project to less than significant levels.
4.8.5 References
City of Pacifica. 2022. General Plan 2040. July
City of Pacifica. 1980. Local Coastal Land Use Plan.
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4.9 NOISE
This EIR chapter provides background information on the nature of sound and vibration transmission; describes the existing noise environment in the Project area; summarizes applicable noise guidelines, standards, and regulations; and evaluates potential noise and vibration impacts that could result from the implementation of the proposed Project. The information on the existing noise environment in the Project area and the magnitude of the proposed Project’s potential noise and vibration effects is based, in part, on ambient noise data collected by MIG in December 2022 and construction noise and vibration modeling conducted by MIG for this EIR. Technical noise data collection and modeling results are attached as Appendix E to this EIR. Where necessary, this section includes mitigation measures that would reduce potential noise and vibration impacts associated with the Project.
4.9.1 Fundamentals of Environmental Acoustics
Noise is generally defined as unwanted sound and is widely recognized as a form of environmental degradation. Airborne sound is the rapid fluctuation of air pressure above and below atmospheric pressure. The frequency (pitch), amplitude (intensity or loudness), and duration of a sound all contribute to the effect on a listener, or receptor, and whether or not the receptor perceives the sound as “noisy” or annoying. A summary of the key environmental noise and vibration analysis terms used in this chapter is provided in Table 4-9.
Pitch is the height or depth of a tone or sound and depends on the frequency of the vibrations by which it is produced. Sound frequency is expressed in terms of cycles per second, or Hertz (Hz).
Humans generally hear sounds with frequencies between 20 and 20,000 Hz and perceive higher frequency sounds, or high pitch noise, as louder than low-frequency sound or sounds low in pitch.
Sound intensity or loudness is a function of the amplitude of the pressure wave generated by a noise source combined with the reception characteristics of the human ear. Atmospheric factors and obstructions between the noise source and receptor also affect the loudness perceived by the receptor. Sound pressure levels are typically expressed on a logarithmic scale in terms of decibels (dB). A dB is a unit of measurement that indicates the relative amplitude (i.e., intensity or loudness) of a sound, with 0 dB corresponding roughly to the threshold of hearing for the healthy, unimpaired human ear. Sound levels in decibels are calculated on a logarithmic basis. An increase of 10 dBs represents a ten-fold increase in acoustic energy, while 20 dBs is 100 times more intense, 30 dBs is 1,000 times more intense, and so on. In general, there is a relationship between the subjective noisiness or loudness of a sound and its intensity, with each 10 dB increase in sound level perceived as approximately a doubling of loudness. Due to the logarithmic basis, decibels cannot be directly added or subtracted together using common arithmetic operations:
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Instead, the combined sound level from two or more sources must be combined logarithmically.
For example, if one noise source produces a sound power level of 50 dBA, two of the same sources would combine to produce 53 dB as shown below.
Table 4-9: Noise and Vibration Terms Used in the EIR
Term Definition
Decibel (dB) A decibel is one-tenth of a bel. It is a measure on a logarithmic scale that indicates the squared ratio of sound pressure to a reference sound pressure (unit for sound pressure level) or the ratio of sound power to a reference sound power (unit for sound power level.)
Frequency or Hertz
(Hz)
The number of oscillations per second of a periodic wave sound and of a vibrating solid, expressed in units of Hz; formerly, cycles per second.
A-Weighted Sound
Level (dBA)
Expressed in dBA or dB(A). Frequency-weighted sound pressure level approximating the frequency response of the human ear.
L01, L10, L50, L90 The energy-average of the A-weighted noise levels that are exceeded 1%, 10%, 50%, and 90% of the time during the measurement period.
Equivalent Noise
Level (Leq)
The equivalent steady-state sound level that in a given period of time would contain the same acoustical energy as the time-varying sound level during the same period.
Community Noise
Equivalent Level
(CNEL)
A noise level that accounts for all the A-weighted noise energy from a source during 24 hours and weights the evening (7:00 PM to 10:00 PM) and night (10:00 PM to 7:00 AM) noise by adding 5 and 10 dBA, respectively, during these periods.
Day/Night Noise
Level (DNL or Ldn)
The energy average of the A-weighted sound levels occurring during a 24-hour period, with 10 dB added to the A-weighted sound levels occurring from 10:00 PM to 7:00 AM
Lmax, Lmin The maximum and minimum A-weighted noise level during the measurement period.
Ambient Noise All-encompassing noise at a given place and time. This is usually a composite of sounds from all sources near and far, including any specific sources of interest.
Atmospheric Effects Sound absorption by air molecules and water vapor, sound refraction caused by temperature and near-ground wind gradients, and air turbulence are collectively called atmospheric effects. Although atmospheric effects are mostly responsible for substantial noise fluctuations at distant receivers, they also can have a significant effect at distances within 330 feet.
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Table 4-9: Noise and Vibration Terms Used in the EIR
Shielding A noise reduction at the receiver because of the placement or existence of natural or artificial barriers (e.g., walls, berms, rows of buildings, or trees, if thick and dense enough).
Vibration An oscillation wherein the quantity is a parameter that defines the motion of a mechanical system.
Peak Particle Velocity The peak signal value of an oscillating vibration velocity waveform.
Usually expressed in inches/second in the United States.
Source: Caltrans 2013
In general, when one source is 10 dB higher than another source, the quieter source does not add to the sound levels produced by the louder source because the louder source contains ten times more sound energy than the quieter source.
Sound Characterization
Humans generally can hear sounds with frequencies between 20 and 20,000 Hz. Most of the sounds humans are normally exposed to do not consist of a single frequency, but rather a broad range of frequencies that are perceived differently by the human ear. In general, humans are most sensitive to sounds with frequencies in the range of 1,000 to 8,000 Hz; the human ear perceives sounds within that range better than sounds of the same amplitude at higher or lower frequency ranges.
Therefore, instruments used to measure sound include an electrical filter that enables the instrument's detectors to replicate human hearing. This filter, known as the "A-weighting" or "Aweighted sound level," filters low and very high frequencies, giving greater weight to the frequencies of sound to which the human ear is typically most sensitive. Most environmental measurements are reported in dBA, meaning decibels on the A-scale. See Table 4-10 for a list of common noise sources and their A-weighted noise levels.
Sound levels are usually not steady and vary over time. Therefore, a method for describing either the average character of the sound or the statistical behavior of the variations over a period of time is necessary. The continuous equivalent noise level (Leq) descriptor is used to represent the average character of the sound over a period of time. The Leq represents the level of steady-state noise that would have the same acoustical energy as the time-varying noise measured over a given time period. Leq is useful for evaluating shorter time periods over the course of a day. The most common Leq averaging period is hourly, but Leq can describe any series of noise events over a given time period.
Variable noise levels are the values that are exceeded for a portion of the measured time period.
Thus, the L01, L10, L50, and L90 descriptors represent the sound levels exceeded 1%, 10%, 50%, and 90% of the time the measurement was performed. The L90 value usually corresponds to the background sound level at the measurement location.
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When considering environmental noise, it is important to account for the different responses people have to daytime and nighttime noise. In general, during the nighttime, background noise levels are generally quieter than during the daytime but also more noticeable due to the fact that household noise has decreased as people begin to retire and sleep. Noise exposure over the course of an entire day is described by the day/night average sound level, DNL (or Ldn), and the community noise equivalent level, or CNEL, descriptors. Both descriptors represent the 24-hour noise exposure in a community or area. For DNL, the 24-hour day is divided into a 15-hour daytime period (7:00 AM to 10:00 PM) and a 9-hour nighttime period (10:00 PM to 7:00 AM), and a 10 dB “penalty” is added to measure nighttime noise levels when calculating the 24-hour average noise level. For example, a 45 dBA nighttime sound level would contribute as much to the overall day-night average as a 55 dBA daytime sound level. The CNEL descriptor is similar to DNL, except that it includes an additional 5 dBA penalty for noise events that occur during the evening time period (7:00 PM to 10:00 PM). The artificial penalties imposed during DNL and CNEL calculations are intended to account for a receptor’s increased sensitivity to noise levels during quieter nighttime periods.
Table 4-10: Typical Noise Levels
Common Outdoor Activities Noise Level (dBA) Common Indoor Activities 110 Rock Band
Jet flyover at 1,000 feet 105
100
Gas lawn mower at 3 feet 95
90 Diesel truck at 50 feet at 50 mph 85 Food blender at 3 feet 80 Garbage disposal at 3 feet
Noise urban area, daytime 75
Gas lawnmower, 100 feet 70 Vacuum cleaner at 10 feet
Commercial area 65 Normal speech at 3 feet
Heavy traffic at 300 feet 60
55 Large business office
Quiet urban daytime 50 Dishwasher next room
45 Quiet urban nighttime 40 Theater, large conference room Quiet suburban nighttime 35
30 Library
Quite rural nighttime 25 Bedroom at night
20 15 Broadcast/recording studio
10 5
Typical threshold of human hearing 0 Typical threshold of human hearing Source: Caltrans 2013
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Sound Propagation
The energy contained in a sound pressure wave dissipates and is absorbed by the surrounding environment as the sound wave spreads out and travels away from the noise-generating source.
The strength of the source is often characterized by its “sound power level.” Sound power level is independent of the distance a receiver is from the source and is a property of the source alone.
Knowing the sound power level of an idealized source and its distance from a receiver, the sound pressure level at a specific point (e.g., a property line or a receiver) can be calculated based on geometrical spreading and attenuation (noise reduction) as a result of distance and environmental factors, such as ground cover (asphalt vs. grass or trees), atmospheric absorption, and shielding by terrain or barriers.
For an ideal “point” source of sound, such as mechanical equipment, the energy contained in a sound pressure wave dissipates and is absorbed by the surrounding environment as the sound wave spreads out in a spherical pattern and travels away from the point source. Theoretically, the sound level attenuates, or decreases, by 6 dB with each doubling of distance from the point source. In contrast, a “line” source of sound, such as roadway traffic or a rail line, spreads out in a cylindrical pattern and theoretically attenuates by 3 dB with each doubling of distance from the line source; however, the sound level at a receptor location can be modified further by additional factors. The first is the presence of a reflecting plane such as the ground. For hard ground, a reflecting plane typically increases A weighted sound pressure levels by 3 dB. If some of the reflected sound is absorbed by the surface, this increase will be less than 3 dB. Other factors affecting the predicted sound pressure level are often lumped together into a term called “excess attenuation.” Excess attenuation is the amount of additional attenuation that occurs beyond simple spherical or cylindrical spreading. For sound propagation outdoors, there is almost always excess attenuation, producing lower levels than what would be predicted by spherical or cylindrical spreading. Some examples include attenuation by sound absorption in air; attenuation by barriers; attenuation by rain, sleet, snow, or fog; attenuation by grass, shrubbery, and trees; and attenuation from shadow zones created by wind and temperature gradients. Under certain meteorological conditions, like fog and low-level clouds, some of these excess attenuation mechanisms are reduced or eliminated due to noise reflection.
Noise Effects
Noise effects on human beings are generally categorized as:
• Subjective effects of annoyance, nuisance, and/or dissatisfaction • Interference with activities such as speech, sleep, learning, or relaxing • Physiological effects such as startling and hearing loss
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Most environmental noise levels produce subjective or interference effects; physiological effects are usually limited to high noise environments such as industrial manufacturing facilities or airports.
Predicting the subjective and interference effects of noise is difficult due to the wide variation in individual thresholds of annoyance and past experiences with noise; however, an accepted method to determine a person’s subjective reaction to a new noise source is to compare it with the existing environment without the noise source, or the “ambient” noise environment. In general, the more a new noise source exceeds the ambient noise level, the more likely it is to be considered annoying and to disturb normal activities.
Under controlled conditions in an acoustical laboratory, the trained, healthy human ear is able to discern 1‐dB changes in sound levels when exposed to steady, single‐frequency (“pure‐tone”) signals in the mid‐frequency (1,000–8,000 Hz) range. In typical noisy environments, changes in noise of 1 to 2 dB are generally not perceptible. However, it is widely accepted that people are able to begin to detect sound level increases of 3 dB in typical noisy environments. Further, a 5 dB increase is generally perceived as a distinctly noticeable increase, and a 10 dB increase is generally perceived as a doubling of loudness that would almost certainly cause an adverse response from community noise receptors.
Groundborne Vibration and Noise
Vibration is the movement of particles within a medium or object such as the ground or a building.
Vibration may be caused by natural phenomena (e.g., earthquakes, volcanic eruptions, sea waves, landslides) or humans (e.g., explosions, machinery, traffic, trains, construction equipment).
Vibration sources are usually characterized as continuous, such as factory machinery, or transient, such as explosions.
As is the case with airborne sound, groundborne vibrations may be described by amplitude and frequency; however, unlike airborne sound, there is no standard way of measuring and reporting amplitude. Vibration amplitudes can be expressed in terms of velocity (inches per second) or discussed in dB units in order to compress the range of numbers required to describe vibration.
Vibration impacts to buildings are usually discussed in terms of peak particle velocity (PPV) in inches per second (in/sec). PPV represents the maximum instantaneous positive or negative peak of a vibration signal and is most appropriate for evaluating the potential for building damage.
Vibration can impact people, structures, and sensitive equipment. The primary concern related to vibration and people is the potential to annoy those working and residing in the area. Vibration with high enough amplitudes can damage structures (such as crack plaster or destroy windows).
Groundborne vibration can also disrupt the use of sensitive medical and scientific instruments, such as electron microscopes.
Common sources of vibration within communities include construction activities and railroads.
Groundborne vibration generated by construction projects is usually highest during pile driving,
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rock blasting, soil compacting, jack hammering, and demolition-related activities. Next to pile driving, grading activity has the greatest potential for vibration impacts if large bulldozers, large trucks, or other heavy equipment are used.
Groundborne noise is noise generated by vibrating building surfaces such as floors, walls, and ceilings that radiate noise inside buildings subjected to an external source of vibration. The vibration level, the acoustic radiation of the vibrating element, and the acoustical absorption of the room are all factors that affect potential groundborne noise generation.
4.9.2 Environmental Setting
The proposed Project is located along the Pacific coast, west of Esplanade Avenue, between approximately West Beaumont Boulevard and West Manor Drive. The noise environment near the Project area is most influenced by the ocean waves and the amount of vehicles traveling on State Route (SR) 1, which is approximately 780 feet east of the Project. Using noise contours developed for use in preparing the City’s General Plan 2040, the Project site is located within the 60-65 dB noise contour. The nearest airport, San Francisco International Airport, is approximately 5.6 miles southeast of the Project.
Measured Ambient Noise Levels
MIG conducted ambient noise level monitoring at and near the proposed Project area from approximately 2:00 PM on Tuesday, December 6, 2022, to approximately 2:00 PM on Wednesday, December 7, 2022. The results of the monitoring are included in Appendix E of this EIR. A summary of the methodology and results for the ambient noise survey is provided below.
Ambient noise levels in the vicinity of the Project area were digitally measured and stored using two (2) Larson Davis SoundTrack LxT sound level meters that meet American National Standards Institute requirements for a Type 1 integrating sound level meter. Each sound meter was calibrated immediately before and after the monitoring period using a reference one kilohertz (1kH) check frequency and 114 dB sound pressure level and found to be operating within normal parameters for sensitivity. Measurements were continuously collected over the sample period in 1-minute intervals. This interval was selected to capture short-term noise events and increases in noise levels above typical background conditions. Weather conditions during the monitoring were partly cloudy during the daytime and clear and cool during the nighttime. Temperatures ranged from the mid 40’s (overnight) to the mid 50’s (in the later afternoon). Winds were generally light and ranged from approximately 5 to 10 miles per hour (mph) all day.
The ambient noise monitoring conducted for this EIR included three (3) short-term (ST) and one long-term (LT) measurements at locations selected to:
• Provide direct observations of existing noise sources in and in the vicinity of the Project area;
• Determine ambient noise levels in the vicinity of the Project area; and
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• Evaluate potential noise levels at nearby sensitive receptors (see "Noise Sensitive Receptors" below).
The ambient noise monitoring locations are shown on Figure 4-6 and described below. • Location LT-1 was at the northwestern corner of the property at 340 Esplanade Avenue.
This location was approximately 11 feet from the northern façade of the building and 18 feet from the sandbags adjacent to the edge of the bluff. The ambient noise levels measured at location LT-1 are considered representative of background noise levels at residential land uses on Esplanade Avenue.
• Location ST-1 was located along the bluff west of Esplanade Avenue. This location was approximately 4 feet from the bluff edge and 40 feet from the long-term measurement location. The ambient noise levels measured at ST-1 are considered representative of background daytime noise levels associated with sound generation from the beach and bluff adjacent to the northern staging area.
• Location ST-2 was located on the beach west of location ST-1. This location was approximately 22 feet west of the rocks at the toe of the bluff and approximately 80 feet below ST-1. The ambient noise levels measured at ST-2 are considered representative of background daytime noise levels along the beach.
• Location ST-3 was located northwest of the Esplanade Avenue and Manor Drive intersection. This location was approximately 10 feet from the bluff edge. The ambient noise levels measured at ST-3 are considered representative of background daytime noise levels associated with sound generation from the beach and bluff adjacent to southern staging area.
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310-330 Esplanade Avenue Infrastructure Preservation Project, City of Pacifica
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Based on observations made during the ambient noise monitoring, the existing noise environment in the project area consists primarily of ocean, air traffic, and local vehicle traffic noise sources.
Table 4-11 and Table 4-12 summarize the results of the long- and short-term ambient noise monitoring conducted for this EIR, respectively.
Table 4-11: Measured Long-term Ambient Noise Levels in the Project Area Day/
Site Duration Lmin Lmax
Measured Leq Range (dBA)(A)
CNEL(B)
Daytime
(7 AM - 7 PM)
Evening
(7 PM - 10 PM)
Nighttime
(10 PM - 7 AM)
Tuesday, December 6 to Wednesday, December 7, 2022
LT-1 24 Hours 43.7 81.6 53.5-59.5 55.3-57.9 54.0-56.7 62.5 Source: MIG, 2022 (see Appendix F)
Values are the lowest and highest measured average hourly values during the listed time.
CNEL calculated from 2:00 PM on December 6th to 2:00 PM on December 7th Table 4-12: Measured Short-term Ambient Noise Levels in the Project Area Day / Site Start Time Duration
Measured Noise Level (dBA)
Leq Lmin Lmax
Tuesday, December 6, 2022
ST-1 1:51 PM 30-minutes 64.7 60.8 72.3
LT-1 1:51 PM 30-minutes 59.0 53.0 71.8
ST-2 2:36 PM 30-minutes 63.3 59.3 71.1
LT-1 2:36 PM 30-minutes 59.6 54.1 75.9
ST-3 3:30 PM 30-minutes 63.2 59.2 68.3
LT-1 3:30 PM 30-minutes 57.8 53.2 71.0
Source: MIG, 2022 (see Appendix F)
As shown in Table 4-11 and Table 4-12, the ambient noise environment in the Project area is relatively steady during the evening and nighttime (varying by 3 dBA Leq) and somewhat variable during the daytime (varying by 6 dBA Leq). The evening and nighttime noise steadiness is likely associated with ocean noise, while the daytime noise variability is likely associated with local activity on Esplanade Avenue (i.e., pedestrian activity, etc.) and higher daytime traffic noise levels associated with SR 1. The measured daytime noise levels were lower at LT-1 than at ST-1, ST-2, and ST-3. This is likely because LT-1 was farther back from the bluff edge, with no direct line of site to the waves breaking on the beach, while ST-1, ST-3, and ST-3 had a direct line of sight to the surf zone. The short-term monitoring occurred when tides were approaching the daily low, which was expected around 3:55 PM on December 6th, 2022 (NOAA, 2022). Based on the difference in measured noise levels between the short-term and long-term locations, the bluff provided between approximately 3 to 6 dBA of noise attenuation between the toe of the bluff and the top of the bluff.
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Noise Sensitive Receptors
Noise-sensitive receptors are buildings or areas where unwanted sound or increases in sound may have an adverse effect on people or land uses. Noise sensitive land uses are locations where people reside or where the presence of noise could adversely affect the use of the land, including places where people live, sleep, recreate, worship and study. In general, potential noise-sensitive receptors in the vicinity of the Project area include:
• A publicly accessible beach (Pacifica Esplanade Beach) bordering the Project to the south. • Multifamily residences on the west side of Esplanade Avenue, approximately 20 feet south of the Project’s northern staging area.
• Multifamily residences across Esplanade Avenue, approximately 70 feet east of the Project’s northern staging area.
• Pacifica Nursing and Rehab Center, approximately 320 feet east of the Project. • Esplanade Beach Overlook Trail, approximately 580 feet south of the Project. • Ocean Shore School, an elementary school, approximately 930 feet east of the Project.
4.9.3 Regulatory Setting
Federal
No federal regulations apply to noise or vibration from the proposed Project.
State
Caltrans
The California Department of Transportation's (Caltrans) Transportation and Construction Vibration Guidance Manual provides a summary of vibration criteria that have been reported by researchers, organizations, and governmental agencies (Caltrans 2020). Chapters 6 and 7 of the aforementioned guidance manual summarizes vibration detection and annoyance criteria from various agencies and provides Caltrans' recommended guidelines and thresholds for evaluating potential vibration impacts on buildings and humans from transportation and construction projects.
These thresholds are summarized in Table 4-13 and Table 4-14.
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Table 4-13: Caltrans' Vibration Threshold Criteria for Building Damage Structural Integrity Maximum PPV (in/sec)
Transient Continuous
Historic and some older buildings 0.50 0.12 to 0.2
Older residential structures 0.50 0.30
New residential structures 1.00 0.50
Modern industrial and commercial structures 2.00 0.50
Source: Caltrans 2020
Table 4-14: Caltrans' Vibration Threshold Criteria for Human Response Human Response Maximum PPV (in/sec)
Transient Continuous
Slightly perceptible 0.035 0.01
Distinctly perceptible 0.24 0.04
Strongly perceptible 0.90 0.10
Severe/Disturbing 2.0 0.7 (at 2 Hz) to 0.17 (at 20 Hz)
Very disturbing -- 3.6 (at 2 Hz) to 0.4 (at 20 Hz)
Source: Caltrans 2020
Local
City of Pacifica Municipal Code
Title 5, Public Welfare, Morals, and Conduct, Chapter 10, Loud, Disturbing, Unusual, and Unnecessary Noises, establishes that loud, unnecessary, unnatural, or unusual noises which are prolonged, unusual, and unnatural in their time, place and use are a detriment to the public health, comfort, safety, and welfare of the City’s residents. The chapter includes the following standards that are relevant to the proposed Project:
• Section 5-10.02 (Unlawful) sets forth that it shall be unlawful for any person to make or continue, or cause to be made or continues, any loud, disturbing, unnecessary or unusual noises or any noise which annoys, disturbs, injures, or endangers the comfort, health, repose, peace, or safety of other persons within the City. • Section 5-10.03 (Enumerated), declares the following noises, among others, to be loud, disturbing, unnecessary, and unusual noises in violation of the Municipal Code:
o Exhausts: The discharge into the open air of the exhaust of any steam engine, stationary internal combustion engine, motorboat, or motor vehicle, except through a muffler or other device which will effectively prevent loud or explosive noises therefrom (Section 5-10.03(g));
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o Defective or loaded vehicles: The use of any automobile, motorcycle, or vehicle so out of repair, so loaded, or in such manner as to create loud and unnecessary grating, grinding, rattling, or other noise (Section 5-10.03(h)); o Loading and unloading vehicles and opening boxes: The creation of loud and excessive noise in connection with loading or unloading any vehicle or the opening and destruction of bales, boxes, crates, and containers (Section 5-10.03(i)); o Pile drivers, hammers, and similar equipment. The operation, between the hours of 8:00 PM and 7:00 AM, of any pile driver, steam shovel, pneumatic hammer, derrick, steam or electric hoist, or other appliance, the use of which is attended by loud or unusual noise (Section 5-10.03(m)); and
o Blowers, fans, and combustion engines. The operation of any noise-creating blower, power fan, or internal combustion engine, the operation of which causes noise due to the explosion of operating gases or fluids, unless the noise from such blower or fan is muffled and such engine is equipped with a muffler device to deaden such noise (Section 5-10.03(n)).
• Section 8-1.05 (Amendments: Section 105.8 “Hours of construction”), the hours of construction for any project for which a building permit is required within the City of Pacifica shall be limited to the hours of 7:00 a.m. to 7:00 p.m. on Monday, Tuesday, Wednesday, Thursday, and Friday. The hours of construction shall be limited to 9:00 a.m. to 5:00 p.m. on Saturday and Sunday.
City of Pacifica General Plan 2040
The City’s General Plan Noise Element identifies noise issues within the City and establishes goals and policies to minimize noise conflicts. The following guiding and implementing policies from the Noise Element are relevant to the proposed Project. • NO-G-2: Acceptable Noise Environment. Strive to achieve an acceptable noise environment for the environmental, health and safety needs of present and future residents of Pacifica.
• NO-G-3: Sensitive Land Uses. Protect noise sensitive land uses, such as schools, hospitals, and senior care facilities, from encroachment of and exposure to excessive levels of noise. • NO-I-6: Construction Noise. Continue to limit hours for certain construction and demolition work to reduce construction-related noises.
In addition to the above policies, the City’s General Plan includes land use compatibility standards for community noise environments and allowable noise exposure limits for new land uses. These standards establish 45 dBA DNL/CNEL and 65 dBA DNL/CNEL as the normally acceptable interior and exterior noise exposure limits, respectively, for multi-family residential land uses; the
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conditionally acceptable and normally unacceptable exterior noise standards for multi-family residential land uses are 70 and 75 dBA DNL/CNEL, respectively (City of Pacifica 2022, Table 9-1 and Table 9-2).
The City’s General Plan also establishes 70 dBA DNL/CNEL, 75 dBA DNL/CNEL, and 80 dBA DNL/CNEL as the normally acceptable, conditionally acceptable, and normally unacceptable limits for office and commercial land uses, respectively, and sets 45 dBA Leq (based on the worstcase hour during periods of use) as the allowable interior noise level for office buildings (City of Pacifica 2022, Table 9-1 and Table 9-2).
4.9.4 Significance Thresholds
Per the CEQA Guidelines, project implementation would have a significant impact related to noise or vibration if it would:
a) Generate a substantial temporary or permanent increase in ambient noise levels in excess of the standards established in:
• City Municipal Code Title 5, Chapter 10 (Loud, Disturbing, Unusual, and Unnecessary Noises);
• City Municipal Code Title 8, Chapter 1, Section 8-1.05 (Building Permit) b) Generate excessive ground-borne vibration or ground-borne noise levels; or c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, expose people residing or working in the project area to excessive noise levels.
With regard to criterion (a) and potential temporary, construction-related noise levels, the City considered the nature and general applicability of Municipal Code and General Plan standards for the proposed Project (e.g., is the standard intended to apply to intermittent, non-transportation noise sources such as construction activities), and determined the City’s General Plan noise and land use compatibility guidelines are not applicable to construction activities because they are 24- hour noise standards intended to evaluate a development project’s compatibility with typical noise exposure levels, and not standards intended to evaluate temporary, short-term noise levels that would occur for part of a day. With regard to criterion (a) and potential long-term, operational noise levels, the proposed Project would not result in long-term operational noise and, therefore, does not have the potential to generate a permanent increase in ambient noise levels above the City’s standards. This topic is not discussed further in this EIR.
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With regard to criterion (b), the proposed Project would result in a significant construction and/or operational vibration impact if it would:
• Generate construction-related vibration levels that exceed Caltrans' guidance for potential building damage (see Table 4-13) at any time; or • Generate construction-related vibration levels that exceed Caltrans' criterion for human annoyance response to slightly perceptible vibrations (0.01 PPV in/sec; see Table 4-14) during the nighttime (10:00 PM to 7:00 AM).
With regard to criterion (c), the proposed Project is not within two miles of any public or private airport or airstrip, or a planning area associated with an existing airport land use plan. The closest airport is San Francisco International Airport, located approximately six miles southeast of the Project area). The City is not located in a noise contour zone associated with San Francisco International Airport. The Project, therefore, would not expose people working in the Project area to excessive airport-related noise levels. This topic is not discussed further in this EIR.
4.9.5 Impacts and Mitigation Measures
This section evaluates potential noise and vibration impacts and recommends mitigation measures, as needed, to reduce potentially significant impacts.
Impact NOI-1: The construction of the Project could result in the generation of a substantial temporary increase in ambient noise levels in excess of applicable standards established in the City’s General Plan and Municipal Code (Less Than Significant with Mitigation Incorporated) Implementation of the Project would involve construction activities that temporarily increase ambient noise levels, primarily from the use of heavy-duty construction equipment. Project construction would occur over a 200-day period for the initial installation of the sea wall, and then over a 60-day period for restoration after monitoring of the sea wall was completed. Construction activities would include site preparation, sheet pile wall installation, pile cap installation, tieback installation and testing, shotcrete wall installation, barrier restoration and riprap removal. Project construction activities would generate noise and vibration from the following sources:
• Heavy equipment operations at different work areas (e.g., northern and southern staging areas on the top of the bluff, tieback installation on the bluff face, and sheet pile wall installation at the bluff toe). Some heavy equipment would consist of mobile equipment such as a loader and excavator that would move around work areas; other equipment would consist of stationary equipment (e.g., cranes or material hoists/lifts) that would generally operate in a fixed location until work activities are complete.
Heavy equipment generates noise from engine operation, mechanical systems and components (e.g., fans, gears, propulsion of wheels or tracks), and other sources such as backup alarms. Mobile equipment generally operates at different loads, or power
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outputs, and produces higher or lower noise levels depending on the operating load.
Stationary equipment generally operates at a steady power output that produces a constant noise level.
• Vehicle trips, including worker, vendor, and haul truck trips. These trips are likely to primarily occur on Esplanade Avenue and on the beach between the northern and southern staging areas (for hauling soil/debris to and from the work sites).
The anticipated construction sequencing and work activity duration, and typical equipment that would be used to conduct the work activities are summarized in Table 4-15.
Table 4-15: Project Construction Schedule and Phasing
Phase Duration (Active
Days)
Equipment / Work Area
Blufftop Bluff Toe or Face
Site Preparation 10 Concrete Pump Truck, Material
Handler, Generator
Excavator, Loader, Dozer, Pump
Sheet Pile Wall
Install 50 Material Handler, Generator Vibratory or Impact Pile Driver, Excavator, Loader, Dozer, Pump Pile Cap Install 28 Concrete Pump Truck,
Generator
Excavator, Loader, Water Pump,
Dozer
Tieback Install and
Testing 56 Crane, Material Handler, Generator
Auger or Impact Tieback Drill
Rig (bluff face), Man Lift
Shotcrete Wall
Install 60 Crane, Concrete Pump Truck, Generator
Man Lift
Restoration 30 Loader --
Riprap Removal 30 -- Crane
Source: Cotton Shires 2022
As shown in Table 4-15, equipment operations would occur in different work areas (i.e., at the top of the bluff and at the bluff toe) at the same time during each sea wall construction phase. During the blufftop restoration phase, other equipment may be used for planting and trail construction.
However, noise levels associated with equipment for this activity would likely be similar to those of professional landscaping equipment. For example, noise levels associated with a typical trail construction equipment rig would be similar to those associated with a smaller construction backhoe operating at a lower maximum load. According to the Caltrans typical construction equipment noise table, a backhoe would generate similar noise levels to those of a loader (Caltrans 2013, Table 7-2). However, the noise profile associated with the proposed Project would mainly be attributed to the heavy equipment operating during each phase. Therefore, the noise impact analysis presented in this report is focused on noise generating construction activities associated with heavy equipment. The Project’s design and engineering team estimates that equipment operations would usually be limited to between 6 and 8 hours of daily daytime operation because of high tide concerns and concerns involving the ability of construction crews to safely maneuver and operate equipment on the bluff face and at the toe of the bluff in the dark. Construction activities would be limited to 7:00 AM to 7:00 PM Monday through Friday, and 9:00 AM to 5:00 PM on Saturday and Sunday, in accordance with City Municipal Code Section 8-1.05.
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The Project’s potential construction noise emissions were estimated using the Federal Highway Administration’s (FHWA) Roadway Construction Noise Model (RCNM), Version 1.1. The RCNM is a computer program that uses empirical data and sound propagation principles to predict noise levels from a variety of construction equipment and operations. For the Project, potential construction noise levels were modeled separately for each construction activity. The noise modeling was based on the Project-specific equipment information compiled by the Project’s design and engineering team. During sheet pile wall installation, a vibratory pile driver would be used initially, and an impact pile driver would only be used if it was determined that the vibratory pile driver was not able to sufficiently penetrate the bedrock for wall installation purposes. Up to two pile drivers would be in operation at the same time during the sheet pile wall installation phase.
The RCNM was used to model noise levels at eight (8) different receptor locations meant to be representative of the noise-sensitive receptors that could be impacted by the Project’s construction activities. The locations of the modeled construction noise receptors are shown on Figure 4-7 and summarized in Table 4-16.
Table 4-16: Modeled Construction Noise Receptors
Receptor ID Receptor Type Location
R1 Residential 360 Esplanade Avenue
R2 Residential 340/350 Esplanade Avenue
R3 Residential 335 Esplanade Avenue
R4 Residential 325 Esplanade Avenue
R5 Residential 305 Esplanade Avenue
R6 Residential 8 Esplanade Avenue
R7 Residential 100 Esplanade Avenue
R8 Commercial 5 Manor Drive
Receptors R1 through R7 represent the closest sensitive receptors to the northern staging area, while R8 represents the closest sensitive receptor to the southern staging area. Noise-generating equipment used during site preparation, sheet pile wall installation, tieback installation and testing, and shotcrete wall installation would operate intermittently along the sea wall area and throughout the northern staging area for receptors R1 – R7. Receptor R8 was only modeled for the site preparation phase equipment at the top of the bluff in the southern staging area as R8 is at least 1,100 feet away from the northern staging area and seawall installation activities.
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Packet Pg. 526 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Figure 4-7: Ambient Noise Monitoring Locatio
310-330 Esplanade Avenue Infrastructure Preservation Project, City of Pacifica
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Construction equipment noise was modeled from the typical work area as well as a “worst-case” scenario from the closest edge of the work area to the receptor. For each phase, equipment noise was modeled based on the respective distances between the equipment operating at the top of the bluff, on the face of the bluff, or at the toe of the bluff and each receptor. Specifically for the sheet pile wall installation phase, two worst-case scenarios were modeled, one scenario with one impact pile driver in operation and one scenario with two impact pile drivers in operation. Under the worst-case scenario with two pile drivers, one pile driver was modeled from the closest edge of the work area and the other was modeled from the typical work area (in the approximate center of the work area). Typical noise levels during the sheet pile wall installation phase were modeled for one pile driver only as it is unknown at the time of this report whether one or two pile drivers would be operated for the proposed Project.13 The RCNM input distances between work areas and receptors are shown in Table 4-17.
Table 4-17: Distance Between Work Areas and Modeled Noise Receptors Construction Work Area
Typical Distance Between Work Area and Receptor (feet)(A) R1 R2 R3 R4 R5 R6 R7 R8(B)
Site Preparation 239 105 110 125 145 210 395 105
Sheet Pile Wall, Pile Cap,
Tieback, Shotcrete Wall
Install
206 107 210 197 192 316 493 -
Restoration 310 105 110 125 145 210 395 -
Riprap Removal 239 125 210 197 257 316 493 -
Construction Work Area
Worst-case Distance Between Work Area and Receptor (feet)(C) R1 R2 R3 R4 R5 R6 R7 R8
Site Preparation 97 20 65 70 70 95 265 -
Sheet Pile Wall, Pile Cap 79 61 65 70 70 95 265 -
Tieback, Shotcrete Wall 77 51 65 70 70 95 265 -
Source: MIG (see Appendix F)
(A) Typical case scenario is based on the distance between the receptor and the center of the work area. (B) Receptor R8 was only modeled for the site preparation phase at the top of the bluff in the southern staging area because it is more than 1,000 feet away from the northern staging area and seawall installation activities. (C) Worst-case scenario is based on the distance between the receptor and closest edge of work area. 13 Although typical noise levels were modeled for one pile driver only, two scenarios were modeled, one scenario using an impact pile driver and one scenario using a vibratory pile driver. These scenarios were modeled to reflect the fact that the proposed Project may require either an impact or a vibratory pile driver, it is unknown at the time of this report which type equipment would be required for the proposed Project.
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The resulting construction equipment noise levels at modeled noise receptors are summarized in Table 4-18. Based on the ambient noise monitoring conducted for the Project (see Section 4.9.2), the bluff face was assumed to provide 3 dBA of noise attenuation for equipment operating on the bluff face or at the toe of the bluff.
Table 4-18: Potential Hourly Construction Noise Levels at Sensitive Receptors Construction
Phase Days Potential Typical Hourly Construction Noise Level (dBA Leq) (A)
R1 R2 R3 R4 R5 R6 R7 R8
Site Preparation 10 68.9 76.1 74.1 73.5 71.9 69.2 64.4 73.2 Sheet Pile Wall
(Impact Pile
Driver)
50 79.4 85.2 79.8 80.2 80.3 76.1 72.1 --
Sheet Pile Wall
(Vibratory Pile
Driver)
50 79.0 84.9 79.5 79.8 79.9 75.7 71.7 --
Pile Cap Install 28 70.9 77.9 75.3 74.7 73.9 70.3 65.5 -- Tieback Install
and Testing 56 68.2 75.9 74.0 73.2 72.3 68.8 63.8 --
Shotcrete Wall
Install 60 65.5 74.6 74.1 73.0 71.7 68.5 63.0 --
Restoration 30 59.3 68.7 68.3 67.2 65.9 62.7 57.2 --
Riprap Removal 30 56.0 61.6 57.1 57.7 55.4 53.6 49.7 -- Construction
Phase Days Potential Worst-Case Hourly Construction Noise Level (dBA Leq) (A)
R1 R2 R3 R4 R5 R6 R7 R8
Site Preparation 1-2 75.8 87.9 78.0 77.6 77.5 75.2 68.0 -- Sheet Pile Wall
(One Impact Pile
Driver)
2-3 85.9 89.7 81.9 82.3 81.7 80.4 75.8 --
Sheet Pile Wall
(Two Impact Pile
Drivers)
2-3 86.7 90.9 83.6 84.1 83.8 81.6 77.1
Sheet Pile Wall
(Vibratory Pile
Driver)
2-3 85.5 89.5 81.6 81.9 81.4 80.1 75.4 --
Pile Cap Install 1-2 76.8 89.1 79.2 78.8 78.7 76.3 69.0 -- Tieback Install
and Testing 2-3 73.9 88.1 78.1 77.6 77.6 75.1 67.3 --
Shotcrete Wall
Install 2-3 69.3 88.8 78.6 78.0 78.0 75.3 66.5 --
Source: MIG (see Appendix F)
(A) Modeled noise levels would occur during the daytime only (7 AM to 7 PM) periods. Restoration and riprap removal would not involve worst-case equipment operations at property lines. Therefore, worst-case noise levels for these phases are not provided.
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As shown in Table 4-18, Project’s construction activities could:
• Generate temporary exterior noise levels that would be approximately 15 dBA Leq to 35 dBA Leq higher than ambient noise levels in the surrounding area. • Generate temporary exterior noise levels of approximately 72 dBA Leq or higher during all typical sea wall construction phases (200 days) at modeled receptors R2 (360 Esplanade Avenue), R3 (335 Esplanade Avenue), R4 (325 Esplanade Avenue, and R5 (305 Esplanade Avenue).
• Generate temporary exterior noise levels of 75 dBA Leq or higher during typical sheet pile wall installation activities (50 days) at R1 (360 Esplanade Avenue), R2, R3, R4, R5, and R6 (8 Esplanade Avenue).
• Generate temporary exterior noise levels of 80 dBA Leq or higher during worst-case sheet pile wall installation activities (2 to 3 days) at all receptors except R7. • Generate temporary noise levels above 85 dBA Leq during worst-case sheet pile wall installation activities at R1 (2 to 3 days) and during all worst-case sea wall construction activities at R2 (up to 16 total days).
The above noise level estimates are exterior noise level estimates. Typical residential and school construction in California typically provides at least 12 dBA of exterior to interior noise attenuation with windows open and 20 dBA of exterior to interior noise attenuation with windows closed.
14 Interior noise level would, therefore, be approximately 12 dBA Leq to 20 dBA Leq lower than exterior noise levels.
If the Project would require the use of an additional pile driver during the sheet pile wall installation phase, nearby sensitive receptors could be exposed to noise generated from a pile driver operating at a worst-case scenario distance and a pile driver operating at a typical scenario distance at the same time. Based on the results presented in Table 4-18, worst case noise levels at the nearest sensitive receptors could be approximately 1 to 2 dBA louder with two impact pile drivers in operation than those with one impact pile driver in operation during the sheet pile wall installation phase. A scenario with two vibratory pile drivers was not modeled as, based on Table 4-18, the difference in worst-case noise levels at nearby sensitive receptors between operating an impact pile driver and a vibratory pile driver is relatively small (approximately 0.2 dBA). It is assumed that a modeled scenario with two vibratory pile drivers would yield similar (likely slightly lower) 14 The U.S. Department of Housing and Urban Development Noise Guidebook and supplement (2009a, 2009b) includes information on noise attenuation provided by building materials and different construction techniques. As a reference, a standard exterior wall consisting of 5/8-inch siding, wall sheathing, fiberglass insulation, two by four wall studs on 16-inch centers, and 1/2-inch gypsum wall board with single strength windows provides approximately 35 dBs of attenuation between exterior and interior noise levels, provided windows do not occupy more than 30% of the exterior wall space.
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noise levels as those presented in Table 4-18 for the modeled scenario with two impact pile drivers.
Therefore, the modeled results presented in Table 4-18 are considered representative of worst-case noise levels at nearby receptors.
The magnitude of the Project’s predicted construction noise levels at modeled receptor locations is primarily a function of the anticipated construction activities, equipment usage, and distance between modeled receptors and the proposed construction activities; however, there are other factors that could influence sound propagation and the Project’s predicted construction noise levels, including:
• The RCNM model computes predicted noise levels based on a fixed point of equipment operation and a direct line–of-sight between the construction activity and the receiver; however, as construction proceeds, equipment moves around the work area and may increase or decrease slightly from modeled locations.
• The RCNM model does not compute predicted noise levels that include potential effects associated with the reflection and/or diffraction of sound waves off of or around hard, reflective surfaces such as roads and buildings, etc. Conversely, the RCNM model does not compute noise levels that include potential effects associated with excess attenuation from soft ground cover.
• The RCNM model does not account for prevailing wind direction, which is generally from southwest to northeast near the staging areas, wind turbulence, or other atmospheric conditions that can influence sound propagation such as temperature gradients, humidity, etc.
The above factors, which are not accounted for in the RCNM modeling results, would likely result in an overestimation of construction noise levels at specific receptor locations. Thus, although there is some uncertainty regarding the potential construction noise levels associated with the Project, the values shown in Table 4-18 are considered to be a conservative, worst-case estimate (i.e., likely to overestimate) of potential construction equipment noise levels at modeled receptor locations.
Significance Determination
Consistent with the City’s Municipal Code and General Plan Noise Element (see Section 4.9.3), the City is evaluating the significance of the Project’s potential construction noise levels based on the following factors:
• Loudness: The City’s Municipal Code considers loud noises a detriment to the City’s residents. As described above, the Project’s construction noise levels could routinely exceed 72 dBA Leq at most residential receptors near the Project area. Project construction activities could also exceed 75 dBA Leq at most residential receptors during typical sheet pile wall installation activities, 80 dBA Leq at most residential receptors during worst-case
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sheet pile wall installation activities, and 85 dBA Leq during worst-case sheet pile wall installation activities at R1 (360 Esplanade Avenue) and R2 (340/350 Esplanade Avenue).
During certain times, instantaneous maximum noise levels (Lmax) from specific equipment such as an impact pile driver could be several decibels higher than sustained (hourly Leq) construction equipment noise levels. In general, the Project’s temporary construction noise levels could be between approximately 15 dBA Leq to 35 dBA Leq above existing measured ambient noise levels and constitute more than a quadrupling of loudness. This temporary increase in noise levels is considered a substantial temporary increase in noise levels.
• Need: The project is necessary to protect and maintain infrastructure along Esplanade Avenue, including the street and underground utilities. Therefore, the Project’s construction activities and the noise generated by these activities is not unnecessary. • Duration: Project construction activities are anticipated to occur seven days a week for approximately 200 days, then again for another 60 days (for restoration and riprap removal) following monitoring and verification of the sea wall’s performance. The daily nature of Project construction activities, as well as the total duration of sea wall installation activities (200 days) would result in the temporary but prolonged exposure of receptors to construction noise levels.
• Unusual or Unnatural in time, place, and affect: Construction activities occur throughout the City as part of typical development, maintenance, and other activities and, therefore, are not necessarily an unusual or unnatural occurrence. Sheet pile and tieback installation activities, however, are less common and are likely to be construed by nearby receptors as unusual noises.
• Compliance with Municipal Code Construction Hours: The proposed Project would limit construction activities, as allowed by Municipal Code Section 8-1.05, to the hours of 7:00 AM to 7:00 PM Monday to Friday and 9:00 AM to 5:00 PM Saturday and Sunday. • Compliance with Other Municipal Code Enumerations: The City anticipates all Project construction equipment and deliveries would comply with the Municipal Code’s exhaust (Section 5-10.03(g)), defective or loaded vehicle (Section 5-10.03(h)), loading and unloading vehicle (Section 5-10.03(i)), and blowers, fans, and combustion engine (Section 5-10.03(n)) requirements because construction equipment and vehicles include standard mufflers, engine covers, etc. and will be maintained accordingly.
Based on the above factors, the Project’s construction noise levels are considered a potentially significant impact because the Project has the potential to result in a substantial temporary increase in ambient noise levels on a daily and prolonged basis.
Although Project construction may result in a substantial temporary increase in ambient noise levels, it is not anticipated to result in physical harm (e.g., temporary or permanent hearing loss or
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damage) to any sensitive noise receptor near the Project area for several reasons. First, worst-case noise levels are anticipated to occur for no more than 16 total days (not necessarily consecutive) at any specific receptor location, while typical exterior noise levels during the remaining 248 construction days would be 72 dBA Leq to 75 dBA Leq or less. In addition, most construction activities and equipment would occur for six (6) to eight (8) hours per day, so receptors would not be continuously exposed to elevated noise levels (i.e., noise levels would return to ambient conditions when construction ceases for the day). Finally, modeled construction noise level values presented in Table 4-18 are exterior noise levels, whereas receptors would be likely to be inside residential buildings. Interior noise levels associated with the Project’s construction at nearby sensitive receptors would be approximately 12 dBA to 30 dBA lower depending on façade construction and whether windows or doors were open or closed. Physiological effects occur when the human ear is subjected to prolonged exposure to high noise environments. For example, to protect workers from noise-induced hearing loss, the U.S. Occupational Safety and Health Administration (OSHA) limits worker noise exposure to 90 dBA as averaged over an 8-hour time period (29 CFR 1910.95). Similarly, the National Institute for Occupational Safety and Health (NIOSH) recommends workers limit noise exposure to no more than 85 dBA over an 8-hour period to protect against noise-induced hearing loss (NIOSH, 1998). Although hourly construction noise levels may approach 85 dBA Leq or 91 dBA Leq, such noise levels would not be sustained over an 8-hour period (due to movement of equipment and changes in operations that occur during daily construction activities). Therefore, at worst-case, noise from construction activities may pose a temporary interference or annoyance effect on nearby sensitive receptors but would not result in adverse physiological effects on human receptors in the surrounding area.
To reduce the potential for Project construction activities to result in a substantial temporary increase in ambient noise levels at receptors near the Project area, the City is incorporating Mitigation Measures into the Project.
Mitigation Measure NOI-1a: Provide Notification of Construction Activities. To ensure receptors in the vicinity of the Project are aware of the Project and its planned construction activities, the City and/or its designated contractors, contractor’s representatives, or other appropriate personnel shall:
1. Notify Residential and Commercial Land Uses of Planned Construction Activities.
This notice shall be provided at least 14 calendar days prior to the start of any construction activities, describe the planned schedule of construction activities, describe the noise control measures to be implemented by the Project, and include the name and phone number of the designated contact for the City of Pacifica and its construction contractor responsible for handling construction-related noise complaints (per Mitigation Measure NOI-1b). This notice shall be provided to the owner/occupants of all residential dwelling units within 1,000 feet of construction work areas and the owner/occupants of commercial buildings within 500 feet of construction work areas.
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2. Notify Trail and Beach Users of Construction Activities. The City shall post signs along overlook trails and trails leading to publicly accessible beaches within 500 feet of work areas warning of potential temporary elevated noise levels during construction. Signs shall remain posted throughout the duration of all sea wall installation activities.
Mitigation Measure NOI-1b: Reduce Construction Equipment Noise Levels. To reduce potential noise levels associated with Project construction activities, the City and/or its designated contractors, contractor’s representatives, or other appropriate personnel shall:
1) Control Construction Traffic and Site Access. Construction truck traffic, including soil and debris and riprap hauling, equipment deliveries, and concrete and other vendor deliveries shall follow City-designated truck routes. Pursuant to City Municipal Code Section 4-7.1601, current designated truck routes in the City include Skyline Boulevard and State Highway Route 1. Pursuant to Municipal Code Section 4-7.1402(b), ingress and egress for the purpose of picking up or delivering construction-related materials shall occur via a direct route between the designated truck route and the Project site. Construction truck traffic shall avoid routes that contain residential dwelling units to the maximum extent feasible given specific Project location and access needs. 2) Construction Equipment Selection, Use, and Noise Control Measures. The following measures shall apply to Project construction equipment:
a. Contractors shall use the smallest size equipment capable of safely completing work activities.
b. Construction staging activities such as receipt of deliveries, equipment and material storage, etc. shall occur as far away from residential land uses as possible.
c. All stationary noise-generating equipment such as pumps, compressors, and welding machines shall be shielded and located as far from sensitive receptor locations as practical. Shielding may consist of trailers, stored materials, or a three- or four-sided enclosure provided the structure/barrier breaks the line of sight between the equipment and the receptor and provides for proper ventilation and equipment operations.
d. Heavy equipment engines shall be equipped with standard noise suppression devices such as mufflers, engine covers, and engine/mechanical isolators, mounts, etc. These devices shall be maintained in accordance with manufacturer’s recommendations during active construction activities. e. Pneumatic tools shall include a noise suppression device on the compressed air exhaust.
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f. The applicant/project representative and/or their contractor shall connect to existing electrical service at the site to avoid the use of stationary power generators (if feasible).
g. No radios or other amplified sound devices shall be audible beyond the property line of the construction site.
Mitigation Measure NOI-1c: Install Temporary Noise Barrier along Esplanade Avenue. To reduce potential construction noise levels at receptors on the east side of Esplanade Avenue, the City and/or its construction contractor shall install a temporary, sixfoot-tall noise barrier along the eastern perimeter of the northern staging area. To the maximum extent feasible given site constraints and existing road/curb conditions, vehicular access to this staging area shall occur at the northern terminus of the barrier at Beaumont Avenue. The barrier shall consist of nominal 0.5-inch plywood with a minimum material density of 1.7 pounds per square foot installed at grade (or mounted to structures located at-grade, such as a K-Rail) and free of openings or gaps other than weep holes).
Alternatively, commercially available acoustic panels or other products such as acoustic barrier blankets that have a minimum sound transmission class or transmission loss value of 20 dB may be attached to a chain link or other security fence. The noise barrier may be removed following the completion of sea wall installation (i.e., it is not necessary during restoration or riprap removal phases).
Mitigation Measure NOI-1d: Prepare Construction Noise Complaint Plan. To prepare for unanticipated or unexpected construction noise issues, the City and/or its designated contractors, contractor’s representatives, or other appropriate personnel shall prepare a Construction Noise Complaint Plan that shall:
1) Identify the name and/or title and contact information (including phone number and email) for designated City and construction contractor representatives responsible for addressing construction-related noise issues.
2) Include procedures describing how the designated Project representative will receive, respond, and resolve construction noise complaints. At a minimum, upon receipt of a noise complaint, the designated representative shall notify the City, verify and determine the nature of the complaint (e.g., identify the noise source generating the complaint), and take steps to resolve the complaint, such as, but not limited to, changing equipment operations, installing a temporary noise shield, etc.
The implementation of Mitigation Measures NOI-1a to NOI-1d would reduce construction noise levels by 5 dBA to 10 dBA at individual receptors locations during the daytime. Based on the modeled worst-case scenario exterior noise levels of 91 dBA (see Table 4-18) with the above measures incorporated, exterior noise levels at individual receptors could reach 81 to 86 dBA.
Such construction noise levels would be similar to the maximum measured daytime noise levels in the project vicinity, but noticeably louder (20 to 30 dB) than the typical measured daytime noise
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levels (see Table 4-11). Noise levels during typical construction activities would typically be at least 10 dBA to 20 dBA lower than worst case conditions and would not annoy or interfere with the use of adjacent residential properties.
Although worst-case construction noise levels could be noticeably louder than typical hourly daytime noise levels (approximately 53 dBA Leq to 60 dBA Leq), Mitigation Measures NOI-1a to NOI-1d would require the City to provide advanced warning of the proposed Project’s potentially noisy construction activities, restrict work hours to periods when period humans are less sensitive to elevated noise levels as in accordance with Municipal Code requirements, implement equipment noise control measures, install temporary noise barriers at impacted receptors, and prepare and plan for unanticipated or unexpected construction noise issues. By providing advanced notice of loud construction activities and implementing equipment control and temporary noise barriers, the potential for receptors to be surprised or annoyed by loud exterior noises would be substantially reduced. In addition, daytime noise levels inside residential buildings would be approximately 12 dBA to 20 dBA lower, depending on whether windows and doors were open or closed (see footnote 2). Thus, interior noise levels at individual residential receptors could potentially reach 61 dBA Leq to 74 dBA Leq during daytime hours when humans are less sensitive to higher noise levels. At no time are the proposed Project’s exterior or interior construction noise levels estimated to result in physical harm to a receptor. Finally, although worst-case construction noise levels could be noticeably louder than typical conditions, this worst-case temporary increase would occur intermittently (no more than 6 to 8 hours per day) for a period of no more than 2 to 3 days, which would not constitute sustained or prolonged exposure to temporary noise increases.
The implementation of these Mitigation Measures NOI-1a to NOI-1d would lower overall Project construction noise levels, reduce the potential for Project construction noise levels to annoy residential receptors, and reduce the potential for Project construction noise levels to interference with normal use of residential properties. The implementation of Mitigation Measures NOI-1a to NOI-1d would, therefore, render the Project’s construction noise levels less than significant with mitigation.
Impact NOI-2: The construction of the Project could result in the generation of excessive groundborne vibration or groundborne noise levels. (Less Than Significant) Construction activities have the potential to result in varying degrees of ground vibration, depending on the specific construction equipment used and activities involved. Vibration generated by construction equipment spreads through the ground and diminishes with increases in distance. The effects of ground vibration may be imperceptible at low levels, result in low rumbling sounds and detectable vibrations at moderate levels, and can disturb human activities such as sleep and vibration sensitive equipment at high levels. Ground vibration can also potentially damage the foundations and exteriors of existing structures even if it does not result in a negative human response.
Construction vibration impacts generally occur when construction activities occur in close proximity to buildings and vibration-sensitive areas, during evening or nighttime hours, or when construction activities last extended periods of time. The construction activities associated with
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the proposed Project would occur in phases over approximately 265 total active workdays and, as described under Impact Noise-1, occur at the blufftop, along Esplanade Avenue, where noise and vibration-sensitive uses occur, as well as the bluff face and toe, below Esplanade Avenue. The Project’s construction work areas are, in general, located close to existing residential buildings that would be sensitive to groundborne vibration, including buildings addressed at 360, 340/350, 335, 325, 305, 100, and 8 Esplanade Avenue (Receptors R1 to R7, respectively; see Table 4-19).
Potential construction equipment vibration levels were estimated using construction phasing and equipment usage provided by the Project’s design and engineering team and reference vibration levels documented and contained in Caltrans’ Transportation and Construction Vibration Guidance Manual and the Federal Transit Administration’s (FTA) Transit Noise and Vibration Impact Assessment Manual (Caltrans 2020 and FTA 2018). Vibration estimates are provided for equipment operating at the top of the bluff, the middle of the bluff face, and the toe of the bluff for both typical and worst-case construction activities. Refer to Appendix F for detailed information regarding groundborne vibration estimates.
Like the construction noise estimates discussed in Impact Noise-1, the magnitude of the Project’s construction-related groundborne-vibration levels at modeled receptor locations is also a function of the anticipated construction activities, equipment usage, and distance between modeled receptors and the proposed construction activities. The vibration impact assessment prepared for this EIR is a generalized assessment that estimates groundborne vibration levels primarily as a function of distance; however, there are other factors that could influence vibration transmission and the Project’s predicted grounborne vibration levels, such as subsurface geologic conditions that reduce or promote vibration propagation (e.g., changes in strata, depth to bedrock, etc.) and the building foundation where vibrations may be of interest (lighter buildings are more prone to vibration effects). The above factors would likely result in an overestimate of groundborne vibration levels at specific receptor locations. Thus, although there is some uncertainty regarding potential groundborne vibration noise levels associated with the Project, the values presented in this EIR are considered worst-case estimates.
Groundborne Vibration from Equipment at the Top of the Bluff As shown in Table 4-19, the construction equipment that would operate at the top of the bluff during all phases except riprap removal would include material handers, cranes, etc. This type of equipment does not include specific impact or vibration-inducing components and does not generate substantial ground borne vibrations.
During typical construction periods, the equipment at the top of the bluff would operate at least 105 feet from all residential buildings (see Table 4-19); however, in certain instances, equipment operations at the top of the bluff could occur closer to a receptor. For example, as installation of the shotcrete wall proceeds, the concrete pump truck used to pump the shotcrete down to the bluff face would move from one end of the northern staging area to the other end, moving away from R1 and R2 and getting closer to R5, R6, and R7 (or vice versa). During worst-case construction activities, the equipment at the top of the bluff would temporarily operate close to residential
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buildings, within approximately 20 feet of R2 (340/350 Esplanade Avenue), 65 feet of R3 (335 Esplanade Avenue), 70 feet of R4 (325 Esplanade Avenue) and R5 (305 Esplanade Avenue), and 95 feet of R6 (8 Esplanade Avenue). During these worst-case periods, equipment would operate for short periods of time (i.e., a few minutes to a few hours). The number of days that construction activities at the top of the bluff could occur closest to any single receptor is estimated to be 10 total days of construction across all planned phases.
The ground-borne vibration levels generated by the type of equipment that would be used at the top of the bluff are shown in Table 4-19.
Table 4-19: Estimated Typical and Worst-Case Construction Groundborne Vibration Levels - Top of Bluff Equipment Operations
Equipment Days(C)
Typical Vibration Level (PPV, in/sec) at Modeled Receptor(A),(B) R1
(310 ft)
R2
(105 ft)
R3
(110 ft)
R4
(125 ft)
R5
(145 ft)
R6
(210 ft)
R7
(395 ft)
R8
(105)
Truck 98 0.003 0.012 0.011 0.009 0.008 0.005 0.002 0.012 Loader 10 0.003 0.014 0.013 0.011 0.009 0.006 0.002 0.014 Crane 116 0.003 0.014 0.013 0.011 0.009 0.006 0.002 0.014 Equipment Days(E)
Worst-case Vibration Level (PPV, in/sec) at Modeled Receptor(B),(D) R1
(210 ft)
R2
(20 ft)
R3
(65 ft)
R4
(70 ft)
R5
(70 ft)
R6
(95 ft)
R7
(265 ft)
R8
(--)
(F)
Truck 10 0.005 0.102 0.022 0.020 0.020 0.013 0.004 N/A
Loader 10 0.006 0.119 0.026 0.023 0.023 0.016 0.004 N/A Crane 10 0.006 0.119 0.026 0.023 0.023 0.016 0.004 N/A
Source: MIG (see Appendix F)
(A) Typical vibration level is based on the distance between receptor and center of closest staging/ work area. (B) Italicized, underlined, and bold text indicates the estimated vibration level would exceed Caltrans’ “slightly perceptible” (0.01 PPV in/sec), “distinctly perceptible” (0.04 PPV in/sec), and “strongly perceptible” (0.1 PPV in/sec) guidelines, respectively, for human detection and annoyance from continuous vibration sources (see Table 4-14).
(C)Typical vibration exposure duration excludes tieback installation, shotcrete wall installation, and rip-rap removal because these phases would not include vibration inducing construction equipment at the blufftop. (D) Worst-case vibration level is based on the distance between receptor and edge of closest staging/ work area. (E) Worst-case vibration exposure duration assumes equipment only operates in the part of the staging/work area directly opposite the receptor for no more than 10 days total during site preparation, tieback installation, shotcrete wall installation, and restoration phases. Worst-case vibration estimates exclude sheet pile wall and pile cap installation phases because these phases would not include the use of vibration inducing construction equipment at the top of the bluff.
(F) Receptor R8 is a commercial receptor adjacent to the southern staging area where worst-case equipment operations would not occur. Therefore, no worst-case vibration estimates are provided for R8. .
As shown in Table 4-19, the typical temporary but continuous operation of construction equipment at the top of the bluff could exceed Caltrans’ “slightly perceptible” guideline for human detection and annoyance from continuous vibration sources (0.01 PPV in/sec, see Table 4-14) at R2 (340/350 Esplanade Avenue), R3 (335 Esplanade Avenue), R4 (325 Esplanade Avenue), and R8 (5 Manor Drive), but not at R1 (360 Esplanade Avenue), R5 (305 Esplanade Avenue), R6 (8 Esplanade Avenue), or R7 (100 Esplanade Avenue). The potential groundborne vibration levels
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during typical equipment operations at the top of the bluff would not exceed Caltrans’ “distinctly perceptible” (0.04 PPV in/sec) or “strongly perceptible” (0.1 PPV in/sec) guidelines for human detection and annoyance at any receptor location.
Also as shown in Table 4-19, the worst-case operation of construction equipment at the top of the bluff could exceed Caltrans’ slightly perceptible guideline for human detection and annoyance from continuous vibration sources (0.01 PPV in/sec) at R2 (340/350 Esplanade Avenue), R3 (335 Esplanade Avenue), R4 (325 Esplanade Avenue), R5 (305 Esplanade Avenue), and R6 (8 Esplanade Avenue), but not at R1 (360 Esplanade Avenue) R7 (100 Esplanade Avenue), or R8 (5 Manor Drive). The operation of construction equipment at the top of the bluff could also exceed Caltrans’ “distinctly perceptible” and “strongly perceptible” guidelines for human detection and annoyance (0.04 PPV in/sec and 0.10 PPV in/sec, respectively, see Table 4-14) at R2 only. During worst-case operations, potential groundborne vibration levels at R3, R4, R5, and R6 would not exceed Caltran’s distinctly or strongly perceptible guidelines.
The operation of the equipment at the top of the bluff would not exceed Caltrans’ criterion for structural damage to older residential buildings from a continuous vibration source (0.3 PPV in/sec, see Table 4-19) at any receptor building during typical and worst-case operations.
Groundborne Vibration from Equipment on the Face of the Bluff As shown in Table 4-20, the construction equipment that could operate on the bluff face below Esplanade Avenue would be limited to a tieback drill rig, which is a portable auger or hammer drill device that would install the tieback rods necessary to support the shotcrete wall.
During typical tieback installation periods, the equipment at the top of the bluff would operate at least 105 feet, and usually approximately 190 feet or more, horizontally away from all residential buildings (see Table 4-20); however, certain tieback installation activities would occur closer to receptors at certain times. For example, the installation of the southernmost tieback rods would occur closest to R1 (360 Esplanade Avenue) and R2 (340/350 Esplanade Avenue), and farthest from R5 (305 Esplanade Avenue), R6 (8 Esplanade Avenue), and R7 (100 Esplanade Avenue). At worst-case, the tieback drill rig could operate within approximately 77 horizontal feet of R1 and 51 horizontal feet of R2. All other tieback installations would occur at least 164 feet from all other receptors. The tieback drill rig equipment would directly contact the bluff face at least 30 feet below the surface of the blufftop. The vertical difference between receptors on the blufftop and the contact point of the tieback drill rig on the bluff face increases the distance vibrations must travel and would likely limit or alter the potential for surface (or Rayleigh) waves, the primary wavefront of concern from construction activities, to form above the vibration source (i.e., the tieback drill rig) and affect the receptor closest to the drill rig contact point.15 The tieback 15 Groundborne vibrations consist of compression or primary waves, shear or secondary waves, and Rayleigh or surface waves. Rayleigh waves are considered the most significant disturbance, particularly for construction (Caltrans 2020).
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installation phase would involve the placement of approximately 128 tieback rods over 56 days, or approximately 2.3 tieback rods per day. Therefore, during worst-case operations, the tieback drill rig could operate close to any single receptor for up to 8 hours per day for approximately 1 to 3 days.
The ground-borne vibration levels generated by the tieback drill rig are shown in Table 4-20.
Table 4-20: Estimated Typical and Worst-Case Construction Groundborne Vibration Levels – Bluff Face Equipment Operations
Equipment Days(C)
Typical Vibration Level (PPV, in/sec) at Modeled Receptor(A),(B) R1
(206 ft)
R2
(107 ft)
R3
(210 ft)
R4
(197 ft)
R5
(192 ft)
R6
(316 ft)
R7
(493 ft)
R8
(--)
(D)
Tie-back drill
rig 56 0.006 0.013 0.006 0.006 0.006 0.003 0.002 N/A
Equipment Days(F)
Worst-case Vibration Level (PPV, in/sec) at Modeled Receptor(B),(E) R1
(83 ft)
R2
(59 ft)
R3
(178 ft)
R4
(164 ft)
R5
(178 ft)
R6
(199 ft)
R7
(321 ft)
R8
(--)
(D)
Tie-back drill
rig 3 0.019 0.023 0.007 0.008 0.007 0.006 0.003 N/A
Source: MIG (see Appendix F)
(A) Typical vibration level is based on the distance between receptor and center of tie back area. The typical vibration estimates do not account for any vertical elevation differences between the equipment and receptor. (B) Italicized text indicates the estimated vibration level would exceed Caltrans’ “slightly perceptible” (0.01 PPV in/sec) guideline for human detection and annoyance from continuous vibration sources (see Table 4-14). (C)Typical vibration exposure duration would occur for entire tieback installation phase. (D) Receptor R8 would be more than 1,000 feet away from tieback installation activities, which is far enough away from work areas for vibrations to be null/imperceptible. (E) Worst-case vibration level is based on the distance between receptor and edge of closest tieback area.
Distances for R1 and R2 account for vertical elevation differences between the equipment and receptor. (F) Worst-case vibration estimate assumes 2 to 3 tie backs installed per day and that equipment operates closest to the receptor for no more than 3 days.
As shown in Table 4-20, the typical tieback drill rig operation on the bluff face would not exceed Caltrans’ slightly perceptible guideline for human detection and annoyance from continuous vibration sources (0.01 PPV in/sec, see Table 4-17) at all receptors except R2 (340/350 Esplanade Avenue). At R2, potential vibration levels would slightly exceed Caltrans’ slightly perceptible guideline for human detection and annoyance, but not Caltrans’ distinctly perceptible guideline (0.04 PPV in/sec).
Also as shown in Table 4-20, the worst-case tieback drill rig operation could exceed Caltrans’ slightly perceptible guideline for human detection and annoyance from continuous vibration sources (0.01 PPV in/sec) at R1 (360 Esplanade Avenue) and R2 (340/350 Esplanade Avenue), but not Caltrans’ distinctly perceptible guideline (0.04 PPV in/sec). All other receptors would be subject to vibrations below Caltrans’ slightly perceptible guidelines for human detection and annoyance during worst-case operation of the tieback drill rig.
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The operation of the tieback drill rig would not exceed Caltrans’ criterion for structural damage to older residential buildings from a continuous vibration source (0.3 PPV in/sec, see Table 4-13) at any receptor building during typical and worst-case tieback drill rig operations.
Groundborne Vibration from Equipment at the Toe of the Bluff As shown in Table 4-21, the construction equipment that would operate at the toe of the bluff during all phases except restoration would include but not be limited to excavators, loaders, dozers, pumps, material handlers, and vibratory or impact pile drivers. With the exception of the pile drivers, the type of equipment that would operate at the bluff toe does not include specific impact or vibration-inducing components and does not generate substantial ground borne vibrations.
During typical construction periods, the equipment at the toe of the bluff would operate at least 105 feet horizontally away from all residential buildings (see Table 4-17); however, the installation of certain sheet piles would occur closer to receptors at certain times. For example, the installation of the southernmost sheet pile would occur closest to R1 (360 Esplanade Avenue) and R2 (340/350 Esplanade Avenue), and farthest from R5 (305 Esplanade Avenue), R6 (8 Esplanade Avenue), and R7 (100 Esplanade Avenue). At worst-case, a pile driver could operate within approximately 79 horizontal feet of R1 and 61 horizontal feet of R2. All other sheet pile installations would occur at least 164 feet from all other receptors. The pile driver could include noise and vibration-generating equipment such as a hammer, pile cap, engine, etc. mounted approximately 30 feet above the surface of the bluff toe. However, from a groundborne vibration perspective, the pile driver would contact the ground at the toe of the bluff at least 90 feet below the surface of the blufftop. The vertical difference between receptors on the blufftop and the contact point of the pile driver increases the distance vibrations must travel and would likely limit or alter the potential for surface waves to affect the receptor closest to the pile driving (see footnote in subsection “Groundborne Vibration from Equipment on the Face of the Bluff”). The sheet pile phase would involve the placement of approximately 195 pairs of sheet piles over 50 days, or approximately 4 pairs of sheet piles per day (approximately 16 to 20 feet of linear wall length). Therefore, during worst-case operations, the pile driver could operate close to any single receptor for up to 8 hours per day for approximately 1 to 2 days.
The ground-borne vibration levels generated by the type of equipment that would be used at the toe of the bluff are shown in Table 4-21.
Table 4-21: Estimated Typical and Worst-Case Construction Groundborne Vibration Levels – Bluff Toe Equipment Operations
Equipment Days(C)
Typical Vibration Level (PPV, in/sec) at Modeled Receptor(A),(B) R1
(225 ft)
R2
(140 ft)
R3
(228 ft)
R4
(217 ft)
R5
(212 ft)
R6
(329 ft)
R7
(501 ft)
R8
(--)
(D)
Pile Driver(E) 50 0.037 0.069 0.037 0.039 0.040 0.023 0.013 N/A Equipment Days(G)
Worst-case Vibration Level (PPV, in/sec) at Modeled Receptor(B),(F) R1
(120 ft)
R2
(109 ft)
R3
(199 ft)
R4
(187 ft)
R5
(197 ft)
R6
(218 ft)
R7
(333 ft)
R8
(--)
(D)
Pile Driver(E) 2 0.085 0.096 0.044 0.048 0.044 0.039 0.022 N/A
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Source: MIG (see Appendix F)
(A) Typical vibration level is based on the distance between receptor and center of tie back area. The typical vibration estimates account for any vertical elevation differences between the equipment and receptor. (B) Italicized, underlined, and bold text indicates the estimated vibration level would exceed Caltrans’ “slightly perceptible” (0.01 PPV in/sec), “distinctly perceptible” (0.04 PPV in/sec), and “strongly perceptible” (0.1 PPV in/sec) guidelines, respectively, for human detection and annoyance from continuous vibration sources (see Table 4-14).
(C) Typical vibration exposure duration would occur for entire sheet pile wall installation phase. (D) Receptor R8 would be more than 1,000 feet away from sheet pile installation activities, which is far enough away from work areas for vibrations to be null/imperceptible. (E) Although vibratory pile drivers typically generate lower groundborne vibration levels, Caltrans guidance (2020) identifies a 0.65 PPV (in/sec) reference groundborne vibration level for both impact and vibratory pile drivers. Therefore, no distinction is made between vibratory and impact drivers in this analysis. (E) Worst-case vibration level is based on the distance between receptor and edge of closest tieback area.
Distances for R1 and R2 account for vertical elevation differences between the equipment and receptor. (F) Worst-case vibration estimate assumes 4 sheet piles installed per day and that equipment operates closest to the receptor for 2 days.
As shown in Table 4-21, the typical pile driver operation at the bluff toe would exceed Caltrans’ slightly perceptible guideline for human detection and annoyance from continuous vibration sources (0.01 PPV in/sec, see Table 4-14) at all modeled receptors. At R2 (340/350 Esplanade Avenue) and R5 (305 Esplanade Avenue), potential vibration levels could also exceed Caltrans’ distinctly perceptible guideline for human detection and annoyance (0.04 PPV in/sec), but not Caltrans’ strongly perceptible guideline (0.10 PPV in/sec). During typical operations, potential groundborne vibration levels at R1 (360 Esplanade Avenue), R3 (335 Esplanade Avenue), R4 (325 Esplanade Avenue), R6 (8 Esplanade Avenue), and R7 (100 Esplanade Avenue) would not exceed Caltrans distinctly perceptible guideline.
Also as shown in Table 4-21, the worst-case pile driver operation could exceed Caltrans’ slightly perceptible (0.01 PPV in/sec) and distinctly perceptible (0.04 PPV in/sec) guidelines for human detection and annoyance from continuous vibration sources at R1 (360 Esplanade Avenue), R2 (340/350 Esplanade Avenue), R3 (335 Esplanade Avenue), R4 (325 Esplanade Avenue) and R5 (305 Esplanade Avenue). At R6 and R7, worst-case operations would only exceed Caltrans’ slightly perceptible guideline (0.01 PPV in/sec).
If the proposed Project would require an additional pile driver during the sheet pile wall installation phase, the cumulative effect in terms of vibration would be relatively small. Peak vibration levels are short-lived and pass very quickly, and so the peak particle velocity at each nearby receptor would not significantly change with more than one pile driver in operation. Having more than one pile driver in operation would likely result in a greater number of peak velocities during the pile driving activity, however the cumulative peak velocity would likely remain relatively unchanged compared to the scenario with one pile driver in operation. Potential vibration levels are not expected to exceed Caltrans’s strongly perceptible guideline (0.10 PPV in/sec) if more than one pile driver would be operating during the sheet pile wall installation phase.
Pile driver operations would not exceed Caltrans’ criterion for structural damage to older residential buildings from a continuous vibration source (0.3 PPV in/sec, see Table 4-13) at any receptor building during typical and worst-case tieback drill rig operations.
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310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 4.9-34 September 2023
Significance Determination
As described above, most Project construction activities could generate groundborne vibration levels that would be slightly to distinctly perceptible, particularly during worst-case conditions, when equipment operates at its closest point to modeled receptors. These vibration levels do not exceed Caltrans’ guidance for potential building damage during the day. The proposed Project would not include nighttime construction activities, thus the Project would not exceed Caltrans’ criterion for human annoyance response to slightly perceptible vibrations (0.01 PPV in/sec) during nighttime (see Table 4-13 and Table 4-14). Furthermore, typical and worst-case vibrations during the daytime would not be excessive because they would be intermittent (occurring only when equipment is in use), occur during the daytime (when people are less sensitive to vibration effects), and would not result in damage to existing structures near the Project area. This impact is less than significant.
Impact NOI-3: The Project would not cause substantial adverse cumulative impacts with respect to noise or vibration. (No Impact)
The proposed Project would involve construction activities along the west side of Esplanade Avenue. For the purposes of this cumulative noise and vibration impact analysis, the geographic context is limited to the extent the potential noise impacts caused by the proposed Project that could combine with other relevant cumulative developments. Although construction noise may, theoretically, be audible far from the source, in practice ambient noise from wind and other land uses is substantially louder than construction equipment operating 1,000 feet away or further.
Therefore, the geographic context is limited to the area within 1,000 feet of the proposed construction work areas and primary roads used to access the Project area site (Esplanade Avenue).
Although the proposed Project would result in potentially significant construction noise (Impact Noise-1) and vibration (Impact Noise-2) impacts, it does not have the potential to result in a cumulative construction noise or vibration impact because there are not projects located within 1,000 feet of the proposed Project that could generate construction noise and vibrations that would combine with the proposed Project. The proposed Project, therefore, would not result in a cumulative considerable contribution to cumulative noise and vibration impacts.
4.9.6 References
California Department of Transportation (Caltrans). 2013. Technical Noise Supplement to the Traffic Noise Analysis Protocol. Sacramento, California. September 2013. _______. 2020. Transportation and Construction Vibration Guidance Manual. Sacramento, California. April 2020.
National Institute of Occupational Safety and Health (NIOSH) 1998. Criteria for a Recommended Standard Occupation Noise Exposure. NIOSH Publication 98-126. Cincinnati, OH. June 1998.
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National Oceanic and Atmospheric Administration (NOAA). 2022. Tides and Currents. Accessed January 4, 2023.
<https://tidesandcurrents.noaa.gov/noaatidepredictions.html?id=9414275&units=standard &bdate=20221206&edate=20221207&timezone=LST/LDT&clock=12hour&datum=ML LW&interval=hilo&action=dailychart>
City of Pacifica. 1980. General Plan.
City of Pacifica 1980. Local Coastal Land Use Plan. March 24.
City of Pacifica 2022. “General Plan 2040” July 2022.
Cotton Shires 2022. “Re: Esplanade Infrastructure Preservation Project questions.” Email from David Schreir, Cotton Shires, to Christina Lau, MIG. November 16, 2022.
U.S. Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. FTA Report No. 0123. Prepared by John A. Volpe National Transportation Systems Center. Washington, DC. September 2018.
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Packet Pg. 545 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 4.10 Public Services and Recreation
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 4.10-1 September 2023
4.10 PUBLIC SERVICES AND RECREATION
This EIR section address the Project’s potential impacts on public services and recreation and suggests mitigation measures, if necessary.
4.10.1 Environmental Setting
The following describes the existing public services and recreation setting within the Project area.
Fire protection and medical emergency services in Pacifica are provided by the North County Fire Authority. The closest fire station to the site is Fire Station 71, located at 616 Edgemar Avenue in Pacifica. Fire Station 71's primary response area is the Pacifica Manor District and north end of Pacifica, including the Project site.
The Pacifica Police Department is responsible for public safety in the Project area. The Police Department has an office at 2075 Pacific Coast Highway, approximately three miles south of the Project site.
Several school districts serve the residents of Pacifica. These include the Jefferson Union High School District and Pacifica School District. The nearest school to the Project site is Ocean Shore Elementary School, approximately 0.2 mile southeast of the Project site.
The beach at the toe of the bluff is noted as “beach” in the City’s 2040 General Plan and also notes dogs are allowed off-leash at this beach. The General Plan shows Esplanade Avenue as an existing on-street trail route known as the Coastal Trail. Other recreational facilities in the Project area include the coastal bluffs to the north operated by the Golden Gate National Recreation Area as well as the area near 400 Esplanade Avenue which is identified as Regional Open Space and a park opportunity site on the City’s Parks and Open Space System map.
4.10.2 Regulatory Setting
State
Coastal Act Policies
Chapter 3, Article 2 Public Access of the Coastal Act contains the following policy sections related to recreation and public access that are relative to the proposed Project.
Public Resources Code Section 30210. In carrying out the requirement of Section 4 of Article X of the California Constitution, maximum access, which shall be conspicuously posted, and recreational opportunities shall be provided for all the people consistent with public safety needs and the need to protect public rights, rights of private property owners, and natural resource areas from overuse.
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Public Resources Code Section 30211. Development shall not interfere with the public's right of access to the sea where acquired through use or legislative authorization, including, but not limited to, the use of dry sand and rock coastal beaches to the first line of terrestrial vegetation.
Public Resources Code Section 30223. Upland areas necessary to support coastal recreational uses shall be reserved for such uses, where feasible.
Local
City of Pacifica Local Coastal Land Use Plan 1980
The LCLUP lists the following Coastal Act Policies related to public services and recreation:
• Policy 1: Maximum access shall be conspicuously posted and recreational opportunities shall be provided for all the people consistent with public safety needs and the need to protect public rights, rights of property owners, and natural resource areas from overuse. • Policy 5: lower cost visitor and recreational facilities and housing opportunities for persons of low and moderate income shall be protected, encouraged, and, where feasible, provided.
Developments providing public recreational opportunities are preferred. New housing in the Coastal Zone shall be developed in conformity with the standards, policies, and goals of the local housing elements adopted in accordance with the requirements of subdivision (c) of Section 65302 of the Government Code.
• Policy 6: Coastal areas suited for water-oriented recreational activities that cannot readily be provided at inland water areas shall be protected for such uses. • Policy 7: Oceanfront land suitable for recreational use shall be protected for recreational use and development unless present and foreseeable future demand for public or commercial recreational activities that could be accommodated on the property is already adequately provided for in the area.
• Policy 11: Marine resources shall be maintained, enhanced, and where feasible, restored.
Special protection shall be given to areas and species of special biological or economic. significance. Uses of the marine environment shall be carried out in a manner that will sustain the biological productivity of coastal waters and that will maintain healthy populations of all species of marine organisms adequate for long-term commercial, recreational, scientific, and educational purposes.
• Policy 18: Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values, and only uses dependent on such resources shall be allowed within such areas. Development in areas adjacent to environmentally sensitive habitat areas and parks and recreation areas shall be sited and designed to prevent impacts which would significantly degrade such areas, and shall be compatible with the continuance of such habitat areas.
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City of Pacifica General Plan 2040
The General Plan 2040 includes the following applicable guiding and implementation policies. • OC-G-6: Coastal Areas Suited for Water-Oriented Recreation. Continue to protect coastal areas suited for water-oriented recreational activities. • OC-G-8: Coastal Access and Recreational Opportunities. Provide maximum coastal access and recreational opportunities for all people consistent with public safety and the need to protect public rights, rights of property owners, and natural resource areas from overuse, including access at each point identified on Figure 6-3. • OC-G-9: Management of Public Access. Regulate the time, place, and manner that public access is provided, based on such factors as topographic and site constraints; the fragility of natural resources; public safety; and the privacy of adjacent residential uses. • OC-I- 38: New Development and Coastal Access. Require that new development along the coastline provide public access from the nearest public roadway to the shoreline and along the coast, and be designed to minimize impacts to public coastal access and recreation.
Ensure that impacts are mitigated through the dedication of access or trail easements or the provision of improvements to other public access points. The City may grant exceptions to this requirement where public access would pose a safety risk or threat to fragile resources, or where adequate access exists nearby.
• OC-I-42: Structures on Public Beaches. Limit structural development on public beaches to that which is necessary for public access or safety, such as lifeguard towers, waste receptacles, or wheelchair accessways. Such development shall be able to be removed or relocated, and shall be sited and designed to minimize adverse impacts on public access, recreation, and coastal resources.
• OC-I-47: Esplanade Bluff. Develop a small public park or viewing area and a trail on Cityowned bluff top land along the 400-block of Esplanade Avenue (Point 5 on Figure 6-3 of the General Plan), if such improvements are feasible.
4.10.3 Thresholds of Significance
The Project would have a significant impact with regard to public services and recreation if it would:
a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the following public services:
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1. Fire protection;
2. Police protection;
3. Schools;
4. Libraries; or
5. Parks and Recreation Facilities.
b) Result in increased use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.
c) Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.
4.10.4 Impacts and Mitigation Measures
This section describes potential impacts related to public services and recreational facilities that would result from implementation of the Project.
Impact PUB-1: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection, police protection, schools, libraries, or parks and recreation facilities. (No Impact)
The proposed Project is the construction of a new seawall along the toe of a coastal bluff.
Construction could restrict access in the area during construction, however the construction site would be managed in accordance with established mandates regarding access for emergency service vehicles and would not necessitate the alteration of any other facilities, including fire protection, police protection, schools, libraries or parks, and recreation facilities to accommodate the construction process.
The proposed Project does not include new housing and would not induce population; therefore, it would not increase enrollment at local schools, or require the provision of new or physically altered schools nor increase the use of local and regional parks or require the provision of new or physically altered parks, or other governmental facilities.
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Impact REC-1: The Project would not increase the use of existing neighborhood or regional parks or other recreational facilities such that significant physical deterioration of the facility would occur or be accelerated or include recreational facilities or require or expansion of recreational facilities which might have an adverse effect on the environment. (Less than Significant Impact)
The City proposes to construct a seawall to protect the coastal bluff from further erosion and would not involve or effect parks or recreational facilities. The blufftop will be restored with native coastal bluff plantings. Passive recreation will be allowed in the area through the provision of a paved walkway with pedestrian amenities such as benches. The bluff edge include a fence for safety.
The Project may restrict some adjacent beach uses during construction, as the existing access ramp to the beach from Esplanade Avenue near Manor Drive (currently closed to the public) would be used for construction vehicle and equipment access and would remain closed to the public during construction. However, these impacts would be temporary, lasting only for the duration of construction, and would only impact roughly 650 linear feet of beach. It is likely that the access will be improved following the project construction in conjunction with the City’s planned park and infrastructure preservation improvements for the adjacent 400 block of Esplanade Avenue. (City of Pacifica, 2023).
Therefore, it would not increase the use of existing neighborhood and regional parks or other recreational facilities and would not include or require the construction or expansion of recreational facilities.
4.10.5 References
City of Pacifica 1980. Local Coastal Land Use Plan. March 24.
City of Pacifica. 2022. General Plan 2040. July
City of Pacifica. Police Department website.
https://www.cityofpacifica.org/depts/police/default.asp City of Pacifica. Fire Department website. https://www.cityofpacifica.org/depts/fire/default.asp
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Packet Pg. 551 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-1 September 2023
5 ALTERNATIVES TO THE PROPOSED PROJECT
Section 15126.6 of the CEQA Guidelines requires an EIR to "describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project, but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” The section also states that “the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if those alternatives would impede to some degree the attainment of the project objectives, or would be more costly.” Under Section 15126.6(a) of the CEQA Guidelines, an EIR does not need to consider alternatives that are not feasible, nor does it need to address every conceivable alternative to the Project. The range of alternatives “is governed by the ‘rule of reason’ that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice” (CEQA Guidelines § 15126.6(f).)
Pursuant to Section 15126.6, this chapter describes four alternatives to the Esplanade Avenue Infrastructure Preservation Project: 1) the CEQA-mandated No Project Alternative; 2) Grading of the Bluff Alternative; 3) Sand Replenishment Alternative; and 4) Rock Revetment Alternative.
The impacts of each alternative are compared to the Project. The ability of each alternative to meet the basic project objectives is also described, and the “environmentally superior” alternative among the four alternatives is identified, as required by the CEQA Guidelines.
5.1 IMPACTS OF THE PROPOSED PROJECT
CEQA requires the alternatives discussion to describe alternatives to the Project that would avoid or substantially lessen any of the significant effects of the Project. This EIR has identified the following significant but mitigable impacts that could result from the proposed infrastructure preservation project.
5.1.1 Less Than Significant with Mitigation Project Impacts Impact BIO-1: The Project would not have a significant adverse effect, either directly or through habitat modifications, on any species listed as candidate, sensitive or special status species in local or regional plans, policies, or regulations by the California Department of Fish and Game or U. S.
Fish and Wildlife. Implementation of Mitigation Measures BIO-1a through BIO-1c would reduce potential impacts to a less than significant level.
Impact CUL-1: The Project could inadvertently encounter cultural resources. Implementation of Mitigation Measure CUL-1 would reduce the potential impact to a less than significant level.
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Impact NOISE-1 – The construction of the Project could result in the generation of a substantial temporary increase in ambient noise levels in excess of applicable standards established in the City’s General Plan and Municipal Code. Implementation of Mitigation Measures NOI-1a through NOI-1d would reduce potential impacts to a less than significant level.
5.2 RATIONALE FOR ALTERNATIVE SELECTION
In accordance with CEQA Guidelines Section 15126.6(a), an EIR does not need to evaluate every conceivable alternative. Section 15126.6(c) of the CEQA Guidelines states, “Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental effects.” CEQA Guidelines Section 15126(f)(2) indicates that alternatives that are remote or speculative, or the effects of which cannot be reasonably predicted, need not be considered.
CEQA Guidelines Section 15126.6(f) indicates that the Lead Agency should consider site suitability, economic viability, availability of infrastructure, general plan consistency, other regulatory limitation, jurisdictional boundaries, and the proponent’s control over alternative sites in determining the range of alternatives to be evaluated in an EIR.
With respect to alternative sites, CEQA Guidelines Section 15126.6(f) indicates that alternative locations need not be evaluated in every case. For this Project, examining an alternative location for the Project is not a feasible alternative since the purpose of the Project is to protect a coastal bluff from further erosion and preserve existing City infrastructure at a specific location (310-330 Esplanade Avenue). Therefore, this chapter does not discuss an alternative project location.
A feasible range of alternatives has been evaluated that will allow decision-makers to make a reasoned choice and that meets most of the project objectives. The project objectives included in Chapter 3, Project Description, are:
Project Objectives:
1. Halt bluff toe erosion toward Esplanade Avenue and its critical infrastructure (roadway, water, sewer, and other utilities), to prevent infrastructure collapse due to bluff erosion for at least 30 years.
2. Minimize impacts to sensitive resources, such as, sand supply, beach access, ecological function, water quality, and shoreline aesthetics.
3. Provide public access to ocean views from Esplanade Avenue, except where public access would endanger public safety or fragile coastal resources.
While selecting alternatives to be considered for analysis, the City focused on alternatives which could potentially reduce the significant effects of the Project and would also achieve most of the
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project objectives. The EIR impact analysis did not identify any significant and unavoidable impacts associated with adoption and implementation of the proposed infrastructure preservation project.
5.3 ALTERNATIVE CONSIDERED BUT REJECTED
The following alternative was reviewed but not included for further evaluation in this EIR for the reasons discussed below.
Managed Retreat Alternative
The Managed Retreat Alternative would allow the continued retreat of the coastal bluff toward Esplanade Avenue and its associated infrastructure and develop and implement a plan to relocate utilities, provide funding for the movement of residents out of harm’s way, and possibly compensate landowners for loss of assets. Under certain circumstances, managed retreat can put land to beneficial use by creating public parks, restoring wetlands to absorb floodwaters, or providing habitats for endangered species. However, this is a temporary benefit at 310-330 Esplanade Avenue since over time, wave erosion will continue, and ultimately erode the area and retreat process would then need to repeat.
The time frame for eventual undermining of Esplanade Avenue would be highly dependent on winter swell and rainfall conditions. It is estimated that current critically over steepened slopes will lay themselves back to more stable inclinations forming a top of bluff located 20 to 30 feet from the edge of roadway. However, this section of narrowed bluff would remain vulnerable to loss from one significant storm season. There is also a significant potential for impacts to utilities and pavement prior to a roadway undermining event. Along bluffs to the west of Esplanade Avenue, tension cracks have been observed anywhere from 5 to 15 feet back from the top edge of the bluff. It is therefore reasonable to assume that separation cracks and some lateral displacement of utilities will occur when the top of bluff is approximately 15 feet away from the roadway.
Regarding when such impacts may occur, much depends on the winter season intensity over future years, including projected sea level rise associated with climate change. Based on comparison of historic photographs, the average bluff retreat rate locally (over several decades prior to 2010) has been calculated at 2.5 feet per year. Also, if this section of bluff is allowed to retreat under a managed retreat plan, the stability of adjacent bluffs could be impacted making future predictions of how much area should be subject to managed retreat difficult.
For an urbanized area with existing infrastructure as well as structures, the cost of relocation and compensation may also be prohibitive. It is also uncertain when geomorphic stability would be achieved under a managed retreat plan and the continued erosion of the over steepened and unstable bluffs would also pose a continued risk to the public, especially along the beach under the bluffs. The timing for moving infrastructure such as water and wastewater lines, and planning for construction of a new pump station is lengthy, and may require acquisition of private easements, the success of which would not be guaranteed. Managed retreat would likely result in the creation of additional coastal bluff habitat, which will ultimately benefit native wildlife species,
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and may or may not provide future opportunities for public access, depending on site conditions.
However, given the urbanized land cover in the area, managed retreat and associated costs and timeframe is not a practical alternative for protecting existing infrastructure. Therefore, this alternative is rejected and is not considered for further consideration in this EIR.
5.4 ALTERNATIVES SELECTED
The following alternatives have been evaluated in comparison to the proposed infrastructure preservation project:
• Alternative 1: No Project
• Alternative 2: Grading of the Bluff
• Alternative 3: Sand Replenishment
• Alternative 4: Rock Revetment
Per CEQA Guidelines Section 15126.6(d), the discussion of impacts associated with the alternatives is less detailed than the evaluation included in Chapters 4.1 through 4.11.1. The alternatives’ potential impacts are evaluated in the following Sections 5.4.1 through 5.4.4. Also in accordance with Section 15126.6, an “environmentally superior alternative” has been identified.
5.4.1 Alternative 1: No Project
State CEQA Guidelines Section 15126.6(e) requires an EIR to analyze the specific alternative of “No Project.” The purpose of describing and analyzing the No Project alternative is to allow decision makers to compare the impacts of approving a proposed Project with the impact of not approving the proposed Project. The No Project Alternative shall discuss the existing conditions at the time the EIR notice of preparation is published, as well as what would be reasonably expected to occur in the foreseeable future if the Project were not approved, based on current plans and consistent with available infrastructure and community services.
Although the No Project Alternative does not meet any of the infrastructure preservation project objectives and is not considered a viable project alternative, it is presented below as required by CEQA for informational purposes.
Principal Characteristics
Under the No Project Alternative, the City would not construct seawalls or implement any other type of protection of the coastal bluff along Esplanade Avenue in the proposed Project area (310- 330 Esplanade Avenue). The bluff would continue to erode and retreat, and would be expected to adversely impact the Esplanade Avenue infrastructure within a short period of time. The average
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bluff retreat rate over the past 75 years at 330 Esplanade Avenue is roughly 2-1/2 feet per year, however, it is not unusual to lose ten feet per year. In 2016 the bluff at the project location retreated approximately seven feet in some locations.16
Under the No Project Alternative, the City would not replant the developed areas along the top of the bluff within the project site to restore native scrub habitat on top of the bluff within the project site, and no other passive recreational facilities (pedestrian path, benches) would be constructed.
The blufftop would remain vacant, fenced with chain link fencing, covered with base rock and eroding shotcrete with patches of non-native vegetation.
Analysis of No Project Alternative
The impacts of the No Project Alternative are examined qualitatively to allow comparison with the Project. The City does not contain agricultural, forestry, or mineral resources, and is not located in a Very High Fire Hazard Severity zone and does not represent features that would substantially alter the wildfire risk in the area. The Project also does not involve Population and Housing-related issues. Therefore, these topics are not discussed below. They are discussed in Chapter 6 - CEQA Mandated Section of this EIR.
a. Aesthetics. The DEIR analysis found the aesthetic impacts of the proposed infrastructure preservation project to be less than significant. The Project would not have a substantial adverse effect on a scenic vista, damage scenic resources within a state designated highway, conflict with applicable zoning or other city regulations governing scenic quality or create a new source of light and glare. Although no significant impact would result, the analysis notes that temporary nighttime lighting during the construction period could occur on the blufftop areas where construction equipment is staged. For this reason the No Project Alternative could result in a slight reduction of impacts compared to the Project.
b. Air Quality. The DEIR analysis found the impacts of the proposed infrastructure preservation project to be less than significant. Potential impacts were related to short-term construction vehicle emissions of criteria pollutants and fugitive dust emissions. The No Project Alterative would result in no new construction at the project site, and therefore no construction related emissions of criteria pollutants or fugitive dust compared to the Project. As such, the No Project Alternative would have no Air Quality impact, but air quality impacts would be reduced in number and level of emissions compared to the Project.
c. Biological Resources. The DEIR analysis found the impacts of the infrastructure preservation Project on biological resources to be potentially significant under Impact BIO1. However, implementation of Mitigation Measures BIO-1, BIO-2 and BIO-3 would reduce the Project’s potentially significant impacts to less than significant. The No Project 16 City of Pacifica, Public Works Department.
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Packet Pg. 556 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-6 September 2023
Alternative would not include proposed blufftop restoration activities that could improve native plant habitat, and in addition could result in soil and existing remnant pieces of shotcrete and rebar on the bluff face falling down to the beach and ocean below as erosion of the bluff proceeds unimpeded. This could potentially affect biological resources in these areas. For these reasons, the No Project Alternative could potentially have a greater, although still less than significant Biological Resources impact compared to the Project. d. Cultural Resources and Tribal Cultural Resources. The DEIR analysis concluded the Project would have a less than significant impact related to Cultural Resources and Tribal Cultural Resources. Although it is not likely that there are archaeological remains or artifacts within the project site due to its location on the beach and prior ground disturbing activities that occurred during construction of the existing buildings on the top of the bluff, the possibility exists that buried archaeological and historical resources, including tribal cultural resources could be discovered during construction of the Project. The Project therefore includes Mitigation Measure CUL-1 that construction contractors would be required to follow that would ensure the protection and proper treatment of such resources.
Under the No Project Alternative, there would be no construction activities that could potentially impact buried archaeological and historical resources, including tribal cultural resources. Thus, the No Project Alternative is considered to have a reduced level of impact compared to the Project.
e. Energy. The DEIR analysis concluded that the Project would not result in operational uses that would increase energy consumption and therefore would not result in a potentially significant environmental effect due to wasteful, inefficient, or unnecessary consumption of energy resources. In addition, as the proposed Project involves the construction of a seawall for coastal bluff fortification and would not increase energy consumption over the long term, it would neither conflict with nor obstruct a state or local plan adopted for the purposes of increasing the amount of renewable energy or energy efficiency. The No Project Alternative would result in no increases in energy consumption over existing conditions and would therefore also not result in a potentially significant environmental effect due to wasteful, inefficient, or unnecessary consumption of energy resources or conflict with or obstruct a state or local plan adopted for the purposes of increasing the amount of renewable energy or energy efficiency.
f. Geology and Soils. The DEIR analysis found that the Project’s Geology and Soils impacts would be less than significant. Under the No Project Alternative there would be no construction, and therefore impacts related to seismic conditions (faults, liquefaction, ground failure), soil erosion, landslides and expansive soils would be irrelevant. The No Project Alternative would result in lesser Geology and Soils impacts than the Project. g. Greenhouse Gas Emissions. The DEIR analysis found that the Project would generate GHG emissions from short-term construction activities, but would not generate any longterm, operational GHG emissions because it does not involve active operations or energy use following bluff stabilization. The Project also would not conflict with any plan or
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Packet Pg. 557 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-7 September 2023
policy adopted for the purposes of reducing GHG emissions, including the CARB Scoping Plan, the BAAQMD Clean Air Plan, and the Pacifica Climate Action Plan. Most of the policies and control measures contained in these plans would be implemented at the state or regional level and would not directly apply to the Project. In addition, the Project will incorporate BMP AIR-1 and Mitigation Measure BMP NOI-1, which would reduce GHG emissions from construction equipment. Therefore, these impacts would be less than significant. The No Project Alternative would not generate either short-term or long-term emissions as it proposes no construction activities, and therefore would result in no impact. h. Hazards and Hazardous Materials. The DEIR analysis found that the Project’s impacts to Hazards and Hazardous Materials would be less than significant. Construction of the Project would involve the use of hazardous materials (fuels, oils and other vehicle-related products), which would be used in relatively small quantities, and in compliance with local and state safety requirements. No construction activities would occur under the No Project Alternative, therefore no use or transport of hazardous materials would occur. For these reasons, the No Project Alternative would have a reduced impact compared to the proposed Project.
i. Hydrology and Water Quality. The DEIR analysis concluded the project’s hydrology and water quality impacts would be less than significant. The Project would not violate any water quality standards or waste discharge requirements, degrade surface or ground water quality, decrease groundwater supplies or recharge capabilities, or alter drainage patterns of the site or area. In addition, the Project was found not to risk the release of pollutants due to project inundation or conflict with the implementation of water quality or groundwater management plans. Under the No Project Alternative, no construction activities would occur, therefore the No Project Alternative would have a reduced impact compared to the proposed Project.
j. Land Use and Planning. The DEIR analysis found that the Project’s impacts to Land Use would be less than significant. The Project would not physically divide an established community or cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. As with the Project, the No Project Alternative would not physically divide an established community. The No Project Alternative would have fewer potential land use conflicts than the proposed Project because it would result in no construction of any seawall and no short-term construction impacts to the surrounding community. k. Noise. The Project would generate noise and vibration during construction. The DEIR found that the Project’s impacts related to noise would be short term and less than significant with the implementation of noise control mitigation measures as noted in Mitigation Measures NOI-1A through NOI-1G and Mitigation Measures NOI-2A and NOI-2B. Vibration impacts were found to be less than significant. Because the No Project
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Packet Pg. 558 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-8 September 2023
Alternative would not result in any construction, it would not generate any construction noise and thus would have a reduced noise impact compared to the proposed Project. l. Public Services and Recreation. The DEIR found that the Project would have less than significant impacts to Public Services and Recreation. By protecting the existing bluff face from further erosion, the proposed seawall would help to preserve recreational uses of the beach below. In addition, the Project would provide opportunities for passive recreation on the blufftop by restoring this area and installing a pedestrian path and benches. Under the No Project Alternative, the bluff would continue to erode, jeopardizing recreational uses of the beach below, and the blufftop would not be restored, providing no additional recreational opportunities for the community. For these reasons, the No Project Alternative could potentially have a greater Public Services and Recreation impact compared to the proposed Project.
m. Transportation. The DEIR found that the Project would have less than significant impacts to Transportation. The Project would not generate traffic over the long term or cause any changes to the circulation system during construction. Flaggers and/or other traffic control measures such as signage would be utilized during construction to ensure the safe transport of construction equipment and materials to and from the project site. With the exception of flaggers and traffic controls, the impacts to Transportation under the No Project Alternative would be similar compared to the Project.
n. Utilities Systems. The DEIR found that no utility connections are required to operate the Project and there would be no need to connect to utility infrastructure such as water, sewer, stormwater, electrical, natural gas or telecommunications utilities. Therefore, the Project would have no impact on utilities and would not require relocation of existing utilities.
Because it is considered a short-term construction project, it would not generate a significant demand for water or wastewater treatment, and construction waste would be expected to be minimal and not exceed the capacity of the landfill that serves the area. The Project would therefore have no impact on utilities, require relocation of existing utilities, generate a significant demand for water or wastewater treatment, generate solid waste in excess of State or local standards or the capacity of local infrastructure, and would not conflict with any federal, state or local statutes and regulations related to solid waste.
Similarly, the No Project Alternative, which proposes no construction, would result in no impact to Utilities Systems.
Attainment of Project Objectives
The No Project Alternative would not meet any of the project objectives and would not allow the City to control erosion of the bluff and protect infrastructure in the Esplanade Avenue area.
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Packet Pg. 559 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-9 September 2023
5.4.2 Alternative 2: Grading of the Bluff
Principal Characteristics
Local coastal bluffs are approximately 75 to 85 feet in height with bluff face inclinations ranging from 70 to 85 degrees. As of 2017, the top of bluff is located approximately 70 to 80 feet from the top of curb adjoining Esplanade Avenue. Local bluffs are composed of marine terrace deposits that are poorly to moderately cemented and highly susceptible to erosion from wave attack. Local long term average erosion rates (bluff retreat) have been calculated at approximately 2½ feet per year; however, it is not unusual to lose 15 or more feet of bluff during a single adverse El Nino winter season.17 This Alternative would propose to grade the top of the bluffs so that the resulting inclination would be 45 to 50 degrees and otherwise would not propose or implement any other components of the proposed Project.
Analysis of the Grading of the Bluff Alternative
The impacts of the Grading of the Bluff Alternative are examined qualitatively to allow comparison with the Project. The City does not contain agricultural, forestry, or mineral resources, and is not located in a Very High Fire Hazard Severity zone and does not represent features that would substantially alter the wildfire risk in the area. The Project also does not involve Population and Housing-related issues. Therefore, these topics are not discussed below. They are discussed in Chapter 6 - CEQA Mandated Section of this EIR.
a. Aesthetics. The DEIR analysis found the aesthetic impacts of the infrastructure preservation Project to be less than significant. The Project would not have a substantial adverse effect on a scenic vista, damage scenic resources within a state designated highway, conflict with applicable zoning or other city regulations governing scenic quality or create a new source of light and glare.
Under the Grading of the Bluff Alternative, views from these areas would be altered by the proposed grading, which would reduce the width of the blufftop between the edge of the bluff and Esplanade Avenue. No revegetation of the graded blufftop is proposed with this Alternative. Grading the blufftop under this Alternative would also result in alteration of the existing views of the bluff from the beach. There would be no riprap removal and no seawall construction and the area closer to the top of the bluff would be graded to a slope of approximately 45-50 degrees, which would result in a noticeably gentler slope than the current condition. While this Alternative would initially result in changes to existing views from above and below the bluff, the changes would be temporary, and would not obstruct views of the ocean or coastline from these areas. The Grading of the Bluff Alternative would therefore have a similar impact compared to the proposed Project. 17 Van Ocampo, Public Works Director, City of Pacifica. Geotechnical Feasibility Study and Alternative Analysis.
April 13, 2016.
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Packet Pg. 560 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-10 September 2023
b. Air Quality. The DEIR analysis found the impacts of the infrastructure preservation Project to be less than significant. Potential impacts were related to short-term construction vehicle emissions of criteria pollutants and fugitive dust emissions. The Grading of the Bluff Alternative would result in grading of the blufftop, but no seawall construction activities on the beach. There would be no excavation, sheet pile driving, or shotcrete application work involved, however, the grading required by this Alternative would generate criterial air pollutant emissions as well as fugitive dust emissions from the grading activity itself, and in addition from the haul trucks that would be required to export the soil materials from the site. Some amount of grading activity on the blufftop would be required under the Project in order to facilitate the proposed habitat restoration plan, so there could potentially be some offset in the criteria air pollutant and fugitive dust emission generation with the implementation of this Alternative, but overall, the Grading of the Bluff Alternative would have greater air quality impacts compared to the Project. c. Biological Resources. The DEIR found impacts to biological resources to be potentially significant under Impact BIO-1. However, implementation of Mitigation Measures BIO1a through BIO-1c would reduce the Project’s potentially significant impacts to less than significant. Because it proposes no revegetation/habitat restoration on the blufftop and could result in the loss of potential cliff nesting habitat, the Grading of the Bluff Alternative could potentially have a greater, although still less than significant biological resources impact compared to the Project. As described in Subsection f. Geology and Soils, below, habitat restoration goals of the bluff may not be achievable due to unstable geomorphological conditions resulting from this Alternative. d. Cultural Resources and Tribal Cultural Resources. The DEIR analysis concluded the Project would have a less than significant impact related to Cultural Resources and Tribal Cultural Resources. Although it is not likely that there are archaeological remains or artifacts within the Project site due to its location on the beach and prior ground disturbing activities that occurred during construction of the existing buildings on the top of the bluff, the possibility exists that buried archaeological and historical resources, including tribal cultural resources could be discovered during construction of the Project. The Project therefore includes Best Management Practices that construction contractors would be required to follow that would ensure the protection and proper treatment of such resources.
Under the Grading of the Bluff Alternative, construction activities that could potentially impact buried archaeological and historical resources would be limited to grading on the blufftop. Thus, the Grading of the Bluff Alternative is considered to have a reduced level of impact to Cultural Resources and Tribal Cultural Resources compared to the Project, which would also include construction activities on the beach. e. Energy. The DEIR analysis concluded that the Project would not result in operational uses that would increase energy consumption and therefore would not result in a potentially significant environmental effect due to wasteful, inefficient, or unnecessary consumption of energy resources. In addition, as the proposed Project involves the construction of a seawall for coastal bluff fortification and would not increase energy consumption over the
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Packet Pg. 561 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-11 September 2023
long term and would not conflict with nor obstruct a state or local plan adopted for the purposes of increasing the amount of renewable energy or energy efficiency. The Grading of the Bluff Alternative would result in less construction activity and therefore less energy consumption than the Project, and would similarly not result in a potentially significant environmental effect due to wasteful, inefficient, or unnecessary consumption of energy resources or conflict with or obstruct a state or local plan adopted for the purposes of increasing the amount of renewable energy or energy efficiency. f. Geology and Soils. The DEIR analysis found the Geology and Soils impacts of the proposed Project to be less than significant. The geotechnical investigation prepared for the Project determined that if the base of the bluff is adequately protected with a seawall as proposed, the unsupported portion of the bluff above the seawall would continue to experience raveling and erosion/bluff retreat until ultimately achieving equilibrium at a relatively stable static inclination of approximately 40 to 50 degrees.
The Geotechnical Report (Cotton Shires 2019, Appendix B) also concluded that the bluffs would be relatively stable under static conditions if graded at 45 to 50 degrees as proposed under the Grading of the Bluff Alternative. However, due to the highly erodible nature of the bluff materials at both the face and toe of the bluff, erosion would result from direct rainfall and wave run-up. Face and toe erosion would cause retreat of the bluff crest and ultimately result in undermining of the street and loss of infrastructure under this Alternative. Furthermore, a 45-degree slope projected up from the toe of the bluff on the beach would place the top of the graded slope within 10 to 20 feet laterally from the edge of the street at some locations. This approach would reduce failure of blocks/slabs of bluff material onto the beach below but would not provide needed protection of the public roadway and utility infrastructure. Due to surrounding private property, bluff retreat and the loss of the public road would likely result in no public access to the bluff overlook.
Additionally, habitat restoration goals of the bluff may not be achievable due to unstable geomorphological conditions. The Grading of the Bluff Alternative would therefore have greater Geology and Soils impacts compared to the Project. g. Greenhouse Gas Emissions. The DEIR analysis found that the Project’s impacts to Greenhouse Gas Emissions would be less than significant. Under the Grading of the Bluff Alternative there would be fewer sources of greenhouse gas emissions, as the amount of diesel-powered grading equipment required would likely be less than the amount of dieselpowered equipment required for the Project, in addition to fewer truck trips. The Grading of the Bluff Alternative would therefore result in reduced Greenhouse Gas Emission impacts compared to the proposed Project.
h. Hazards and Hazardous Materials. The DEIR analysis found that the Project’s impacts to Hazards and Hazardous Materials would be less than significant. Construction of the Project would involve the use of hazardous materials (fuels, oils and other vehicle-related products), which would be used in relatively small quantities, and in compliance with local and state safety requirements. Under the Grading of the Bluff Alternative there would be a
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Packet Pg. 562 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-12 September 2023
reduced number of construction activities, therefore the use or transport of hazardous materials would be less than it would be under the Project. For this reason, the Grading of the Bluff Alternative would have a reduced impact compared to the Project. i. Hydrology and Water Quality. The DEIR analysis concluded the Project’s hydrology and water quality impacts would be less than significant. The Project would not violate any water quality standards or waste discharge requirements, degrade surface or ground water quality, decrease groundwater supplies or recharge capabilities, or alter drainage patterns of the site or area. In addition, the Project was found not to risk the release of pollutants due to project inundation or conflict with the implementation of water quality or groundwater management plans. Under the Grading of the Bluff Alternative, the amount of construction activities would be limited to grading on top of the bluff. The analysis of potential erosion impacts contained in the Geology and Soils section of the Draft EIR found that following final grading on the top of the bluff resulting in uniformly graded lots that drain towards Esplanade Avenue, the potential for runoff from the lots to adversely impact the bluff face would be low. The Grading of the Bluff Alternative would therefore have a reduced impact compared to the proposed Project.
j. Land Use and Planning. The DEIR analysis found that the Project’s impacts to Land Use would be less than significant. The Project would not physically divide an established community or cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. As with the Project, the Grading of the Bluff Alternative would not physically divide an established community. It would have fewer potential land use conflicts than the Project because it would result in no construction activities on the beach and less construction activities overall. The Grading of the Bluff Alternative would therefore have a lesser Land Use impact compared to the Project. k. Noise. The Project would generate noise and vibration during construction. The DEIR found that the Project’s impacts related to noise would be short term and less than significant with the implementation of noise control mitigation measures as noted in Mitigation Measures NOI-1a through NOI-1d. Vibration impacts were found to be less than significant. Because the Grading of the Bluff Alternative would presumably be subject to the same noise mitigation requirements and would result in less construction activity, including no pile driving, and would therefore generate less construction noise, it would have a reduced noise impact compared to the proposed Project. l. Public Services and Recreation. The DEIR found that the Project would have less than significant impacts to Public Services and Recreation. By protecting the existing bluff face from further erosion, the proposed seawall would help to preserve recreational uses of the beach below. In addition, the Project would provide opportunities for passive recreation on the blufftop by restoring this area and installing a pedestrian path and benches. For the reasons explained in Subsection f. Geology and Soils, above, the Grading of the Bluff
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Packet Pg. 563 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-13 September 2023
Alternative would likely result in no public access to the bluff overlook. For this reason, the Grading of the Bluff Alternative would have a greater Public Services and Recreation impact compared to the proposed Project.
m. Transportation. The DEIR found that the Project would have less than significant impacts to Transportation. The Project would not generate traffic over the long term or cause any changes to the circulation system during construction. Flaggers and/or other traffic control measures such as signage would be utilized during construction to ensure the safe transport of construction equipment and materials to and from the project site. The Grading of the Bluff Alternative would similarly not result in long term traffic or impacts to the circulation system during the proposed grading activities, and traffic controls would be implemented to ensure safety. The number of truck trips would likely increase under this Alternative, as the proposed grading would result in off-haul trips not required under the project scenario, however, the temporary nature of these increased trips would result in a less than significant impact. The Transportation impacts under the Grading of the Bluff Alternative would be similar or slightly greater compared to the Project.
n. Utilities Systems. The DEIR found that no utility connections are required to operate the proposed seawall and would not connect to utility infrastructure such as water, sewer, stormwater, electrical, natural gas or telecommunications utilities. Therefore, the Project would have no impact on utilities or require relocation of existing utilities. Because it is considered a short-term construction project, it would not generate a significant demand for water or wastewater treatment, and construction waste would be expected to be minimal and not exceed the capacity of the landfill that serves the area. The Project would therefore have no impact on utilities, require relocation of existing utilities, generate a significant demand for water or wastewater treatment, generate solid waste in excess of State or local standards or the capacity of local infrastructure, and would not conflict with any federal, state or local statutes and regulations related to solid waste. Similarly, the Grading of the Bluff Alternative which proposes less construction than the Project, would result in no impact to Utilities Systems.
Attainment of Project Objectives
The Grading of the Bluff Alternative would meet two of the three primary project objectives identified in Chapter 3.2 Project Objectives. It would be consistent with Objectives #2 and #3, which seek to minimize impacts to sensitive resources and provide public access to ocean views from Esplanade Avenue (except where public access would endanger public safety or fragile coastal resources), respectively. This Alternative would not, however, be completely consistent with Objective #1 because it would do nothing to halt erosion at the toe of the bluff. As described in Subsection f. Geology and Soils, above, this Alternative would not provide needed protection of the public roadway and utility infrastructure, and due to surrounding private property, bluff retreat and the loss of the public road would likely result in no public access to the bluff overlook.
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Packet Pg. 564 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-14 September 2023
5.4.3 Alternative 3: Sand Replenishment
Principal Characteristics
Sand Replenishment (also known as beach nourishment) is a process by which sediment, usually sand, lost through longshore drift or erosion is replaced from other sources. A wider beach can reduce storm damage to coastal structures by dissipating energy across the surf zone, protecting upland structures and infrastructure from storm surges, tsunamis and unusually high tides. It is typically a repetitive and limitless process since it does not remove the physical forces that cause erosion but simply mitigates their effects.18 It is characterized as a soft protection strategy that relies on a sandy beach of sufficient width to provide a buffer against seasonal and storm related erosion and flooding. This alternative would require repeated application of sand to the beach to protect the bluff from wave action. It would require regular beach access for heavy equipment (trucks carrying sand). This alternative does not include any of the other components of the proposed Project such as the seawall, staging areas, or restoration of the blufftop.
Replenishing sand at the base of the bluff could potentially prevent continued wave erosion of the toe of the bluff. However, sand is rapidly removed from the beach under winter storm conditions at the project location and maintenance of an adequate beach to prevent wave run-up from reaching the toe of bluff under high tide and high swell conditions (combined with future sea level rise) would likely not be sustainable. Sand replenishment will also not provide similar lateral support to the bluff that would result from using a structural approach. Furthermore, sufficient understanding about the local sand transport directions and rates are not currently available to estimate the volume of sand required. The probable long term economic commitment may not be sustainable for the City and regular access by construction equipment would potentially result in long-term impacts to bluff and beach habitats. Furthermore finding a constant and lasting source of sand suitable for this area would very challenging. The bluffs would likely continue to retreat and would pose a threat to the public roadway and utility infrastructure, as well as pose a safety hazard for the public due to bluff material falling on the beach. Additionally, habitat restoration goals for the bluff may not be achievable due to unstable geomorphological conditions.
Analysis of the Sand Replenishment Alternative
The impacts of the San Replenishment Alternative are examined qualitatively to allow comparison with the Project. The City does not contain agricultural, forestry, or mineral resources, and is not located in a Very High Fire Hazard Severity zone and does not represent features that would substantially alter the wildfire risk in the area. The Project also does not involve Population and Housing-related issues. Therefore, these topics are not discussed below. They are discussed in Chapter 6 CEQA Mandated Section of this EIR.
18 Wikipedia. Beach Nourishment. Accessed on January 20, 2023 at https://en.wikipedia.org/wiki/Beach_nourishment.
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Packet Pg. 565 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-15 September 2023
a. Aesthetics. The DEIR analysis found the aesthetic impacts of the infrastructure preservation Project to be less than significant. The proposed Project would not impact a scenic vista, damage scenic resources within a state designated highway, conflict with applicable zoning or other city regulations governing scenic quality, or create a new source of light and glare. Although no significant impact would result, the analysis notes that temporary nighttime lighting during the construction period could occur on the blufftop areas where construction equipment is staged.
The Sand Replenishment Alternative could potentially result in scenic impacts because it would require that heavy equipment (haul trucks) repeatedly be used to bring sand to the beach, interrupting views of the coastline from the surrounding beaches and from areas above the beach. These construction impacts would be temporary, similar to the Project, however, sand replenishment requires an indefinite number of repeated deliveries and application of sand and would likely result in longer lasting visual impacts than construction of the Project. This alternative would have a greater aesthetic impact than the Project, but still less than significant.
b. Air Quality. The DEIR analysis found the impacts of the infrastructure preservation Project to be less than significant. Potential impacts were related to short-term construction vehicle emissions of criteria pollutants and fugitive dust emissions. The Sand Replenishment Alternative would also result in construction vehicle emissions of criteria pollutants and fugitive dust emissions, however using different types of construction equipment. No pile driving equipment or equipment for shotcrete application would be used for the sand replenishment operations, for example. Vehicles used for the delivery and application of the sand on the beach such as haul trucks and bulldozers would be used for sand replenishment. The duration of the sand replenishment operations is unknown, therefore the overall quantity of emissions of criteria pollutants or fugitive dust compared to the Project cannot be determined. This alternative could potentially have a greater air quality impact than the Project.
c. Biological Resources. The DEIR analysis found the impacts of the infrastructure preservation Project on biological resources to be potentially significant under Impact BIO1. However, implementation of Mitigation Measures BIO-1 and BIO-2 would reduce the Project’s potentially significant impacts to less than significant. As described in Section
4.3 Biological Resources, the intertidal habitat zone includes the sandy beach and riprap (rocky) habitats that are subject to periodic tidal inundation. There are numerous species of shorebirds that may forage in the intertidal zone, and variety of invertebrate species live in the sand and in the decaying seaweed and other detritus on the sand surface. The Sand Replenishment Alternative would extend the width of the beach towards the water, which could have the effect of shorebirds, invertebrates and other wildlife species moving away from their established habitats. That disruption may continue with ongoing wave pattern changes or other changing shore life patterns which occur. In addition, regular access by
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Packet Pg. 566 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-16 September 2023
construction equipment would potentially result in long-term impacts to bluff and beach habitats. The Sand Replenishment Alternative also proposes no revegetation/habitat restoration on the blufftop. For these reasons, the Sand Replenishment Alternative could potentially have a greater Biological Resource impacts compared to the Project. d. Cultural Resources and Tribal Cultural Resources. The DEIR analysis concluded the Project would have a less than significant impact related to Cultural Resources and Tribal Cultural Resources. Although it is not likely that there are archaeological remains or artifacts within the project site due to its location on the beach and prior ground disturbing activities that occurred during construction of the existing buildings on the top of the bluff, the possibility exists that buried archaeological and historical resources, including tribal cultural resources could be discovered during construction of the Project. The Project therefore includes Best Management Practices that construction contractors would be required to follow that would ensure the protection and proper treatment of such resources.
Under the Sand Replenishment Alternative, there would be no construction activities that could potentially impact buried archaeological and historical resources, including tribal cultural resources. Thus, the Sand Replenishment Alternative is considered to have a reduced level of impact compared to the Project.
e. Energy. The DEIR analysis concluded that the Project would not result in operational uses that would increase energy consumption and therefore would not result in a potentially significant environmental effect due to wasteful, inefficient, or unnecessary consumption of energy resources. In addition, as the proposed Project involves the construction of a seawall for coastal bluff fortification and would not increase energy consumption over the long term and would not conflict with nor obstruct a state or local plan adopted for the purposes of increasing the amount of renewable energy or energy efficiency. The Sand Replenishment Alternative could potentially result in more energy consumption than the Project due to an unforeseen number of additional future truck trips to continuously supply sand to the beach. However, because the number of truck trips is unknown, it would not be considered to be a significant environmental effect due to wasteful, inefficient, or unnecessary consumption of energy resources or conflict with or obstruct a state or local plan adopted for the purposes of increasing the amount of renewable energy or energy efficiency. The impact would be less than significant.
f. Geology and Soils. The DEIR analysis found that the Project’s Geology and Soils impacts would be less than significant. Under the Sand Replenishment Alternative there would be no construction of structures, and therefore impacts related to seismic conditions (faults, liquefaction, ground failure), soil erosion, landslides and expansive soils would be irrelevant. The Sand Replenishment Alternative would result in lesser Geology and Soils impacts than the Project.
g. Greenhouse Gas Emissions. The DEIR analysis found that the Project’s impacts to Greenhouse Gas Emissions would be less than significant. Under the Sand Replenishment Alternative there would be an undetermined number of truck trips that would generate gas14.b Packet Pg. 567 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 5 Alternatives to the Proposed Project
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 5-17 September 2023
generating emissions. This would likely result in greater emissions impacts than the Project, which would only generate greenhouse gas emissions during the short-term of the construction period. The Sand replenishment Alternative would therefore result in greater Greenhouse Gas Emission impacts compared to the proposed Project. h. Hazards and Hazardous Materials. The DEIR analysis found that the Project’s impacts to Hazards and Hazardous Materials would be less than significant. Construction of the Project would involve the use of hazardous materials (fuels, oils and other vehicle-related products), which would be used in relatively small quantities, and in compliance with local and state safety requirements. No construction activities would occur under the Sand Replenishment Alternative, therefore no use or transport of hazardous materials would occur. For these reasons, the Sand Replenishment Alternative would have a reduced impact compared to the proposed Project. Assuming that the bluff would continue to retreat under the Sand Replenishment Alternative, this would represent a public safety hazard due to bluff material falling on the beach, as it currently does. The impacts of this Alternative with respect to safety hazards would therefore be greater compared to the proposed Project. i. Hydrology and Water Quality. The DEIR analysis concluded the Project’s hydrology and water quality impacts would be less than significant. The Project would not violate any water quality standards or waste discharge requirements, degrade surface or ground water quality, decrease groundwater supplies or recharge capabilities, or alter drainage patterns of the site or area. In addition, the Project was found not to risk the release of pollutants due to project inundation or conflict with the implementation of water quality or groundwater management plans. Under the Sand Replenishment Alternative, no construction activities would occur, therefore it would have a reduced construction impact compared to the proposed Project. However, there would also be no grading or recontouring of the blufftop to direct stormwater runoff to the street. Therefore, this Alternative could result in greater impacts than the proposed project related to on-site or off-site erosion, siltation or flooding. Overall, when considering the reduced construction -related impacts and the potentially greater runoff impacts, the Sand Replenishment Alternative would have a similar impacts to Hydrology and Water Quality compared to the proposed Project.
j. Land Use and Planning. The DEIR analysis found that the Project’s impacts to Land Use would be less than significant. The Project would not physically divide an established community or cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. As with the Project, the Sand Replenishment Alternative would not physically divide an established community, however it could potentially impact the use of the beach as a recreational site for the community through the presence of haul trucks and maintenance activities on an ongoing basis. Construction activities associated with the proposed Project would be temporary. The Sand Replenishment Alternative would therefore have a greater Land Use impact than the proposed Project.
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k. Noise. The Project would generate noise and vibration during construction. The DEIR found that the Project’s impacts related to noise would be short term and less than significant with the implementation of noise control mitigation measures as noted in Mitigation Measures NOI-1a through NOI-1d. Vibration impacts were found to be less than significant. Because the Sand Replenishment Alternative would not result in any construction, and noise generated would be limited to haul truck traffic, it would have a reduced noise impact compared to the proposed Project.
l. Public Services and Recreation. The DEIR analysis found that the Project would have less than significant impacts to Public Services and Recreation. By protecting the existing bluff face from further erosion, the proposed seawall would help to preserve recreational uses of the beach below. In addition, the Project would provide opportunities for passive recreation on the blufftop by restoring this area and installing a pedestrian path and benches. Under the Sand Replenishment Alternative, erosion of the bluff would likely be reduced, and the increased width of the beach created by the additional regular sand deposition would retain and possibly enhance the existing recreational uses of the beach below. Under this Alternative the blufftop would not be restored, however, providing no additional recreational opportunities for the community in this area. For these reasons, the Sand Replenishment Alternative would have a similar less than significant Recreation impact compared to the proposed Project.
m. Transportation. The DEIR analysis found that the Project would have less than significant impacts to Transportation. The Project would not generate traffic over the long term or cause any changes to the circulation system during construction. Flaggers and/or other traffic control measures such as signage would be utilized during construction to ensure the safe transport of construction equipment and materials to and from the Project site.
Traffic controls would also likely be used under the Sand Replenishment Alternative, however, unlike the proposed Project, the Sand Replenishment Alternative could potentially result in long term traffic or impacts to the circulation system due to an indefinite number of haul truck trips accessing the beach. The Transportation impacts under the Sand Replenishment Alternative would therefore be greater compared to the Project. n. Utilities Systems. The DEIR found that no utility connections are required to operate the proposed seawall and would not connect to utility infrastructure such as water, sewer, stormwater, electrical, natural gas or telecommunications utilities. Therefore, the Project would have no impact on utilities or require relocation of existing utilities. Because it is considered a short-term construction project, it would not generate a significant demand for water or wastewater treatment, and construction waste would be expected to be minimal and not exceed the capacity of the landfill that serves the area. The Project would therefore have no impact on utilities, require relocation of existing utilities, generate a significant demand for water or wastewater treatment, generate solid waste in excess of State or local standards or the capacity of local infrastructure, and would not conflict with any federal,
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state or local statutes and regulations related to solid waste. Similarly, the Sand Replenishment Alternative which proposes the importation of sand to the beach, would result in no impact to Utilities Systems.
Attainment of Project Objectives
The Sand Replenishment Alternative would meet the first primary project objective as it would, if properly implemented, halt bluff toe erosion toward Esplanade Avenue and prevent the collapse of its critical infrastructure for some period of time. However, whether or not it would be effective for at least 30 years would depend upon the availability of the supply of the proper type of beach sand over that period of time and the City’s ability to continuously implement its delivery and application. In addition, as stated previously, this Alternative would not provide similar lateral support to the bluff that would result from using a structural approach. This Alternative would also not necessarily meet the second objective, as the regular ongoing delivery of sand to the beach would involve the use of large trucks, whose presence on the beach could potentially negatively impact sensitive resources such as bluff and beach habitats and shoreline aesthetics. This Alternative would meet the third objective, which is to provide public access to ocean views from Esplanade Avenue, except where public access would endanger public safety or fragile coastal resources.
For the reasons described above, the Sand Replenishment Alternative would not be consistent with Objectives #1 and #2 which seek a design solution that protects Esplanade Avenue from further bluff erosion and risk to critical infrastructure, and to protect sensitive resources including beach and bluff habitats and shoreline aesthetics.
5.4.4 Alternative 4: Rock Revetment
Principal Characteristics
The Rock Revetment Alternative would consist of placing buried and exposed sloping layers of large rock against the toe of the bluff at the back of the beach for the purpose of preventing bluff erosion. The rock materials used would be durable large armor stone that is similar to but bigger than the existing riprap currently located along the base of the bluff. The size of the stones would be variable but would be selected to create a stable armor layer above and below the beach to absorb and dissipate the energy of waves in order to reduce erosion of the bluff and limit scour and undermining of the revetment.
Analysis of the Rock Revetment Alternative
The impacts of the Rock Revetment Alternative are examined qualitatively to allow comparison with the Project. The City does not contain agricultural, forestry, or mineral resources, and is not located in a Very High Fire Hazard Severity zone and does not represent features that would substantially alter the wildfire risk in the area. The Project also does not involve Population and
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Housing-related issues. Therefore, these topics are not discussed below. They are discussed in Chapter 6 - CEQA Mandated Section of this EIR.
a. Aesthetics. The DEIR analysis found the aesthetic impacts of the infrastructure preservation Project to be less than significant. The Project would not impact a scenic vista, damage scenic resources within a state designated highway, conflict with applicable zoning or other city regulations governing scenic quality or create a new source of light and glare. Although no significant impact would result, the analysis notes that temporary nighttime lighting during the construction period could occur on the blufftop areas where construction equipment is staged. As with the Project, the Rock Revetment Alternative would not impact a scenic vista, damage scenic resources within a state designated highway, conflict with applicable zoning or other city regulations governing scenic quality or create a new source of light and glare. However, the placement of a large amount of additional rock at the toe of the bluff would negatively impact the scenic resources of the beach and coastline; more so than the proposed seawall, which would visually blend into the bluff. The Rock Revetment Alternative would result in greater Aesthetic impacts compared to the proposed Project.
b. Air Quality. The DEIR analysis found the impacts of the infrastructure preservation Project to be less than significant. Potential impacts were related to short-term construction vehicle emissions of criteria pollutants and fugitive dust emissions. The Rock Revetment Alterative would involve the use of heavy equipment to move and place a substantial amount of riprap on the beach, requiring more truck trips (to haul the rock) than would be expected under the project conditions, and would therefore result in more short-term emissions of criteria pollutants than would be expected for the Project. Fugitive dust emissions would likely be greater than for the Project, as well. The Rock Revetment Alternative would result in greater Air Quality impacts compared to the proposed Project. c. Biological Resources. The DEIR analysis found the impacts of the infrastructure preservation Project on biological resources to be potentially significant under Impact BIO1. However, implementation of Mitigation Measure BIO-1a though BIO-1c would reduce the Project’s potentially significant impacts to less than significant. Under the Rock Revetment Alternative, the proposed construction on the beach could potentially impact nesting birds and allow the introduction of invasive species, just as with the proposed Project, and would be required to implement the same mitigation measures as the Project to reduce impacts to a less than significant level. However, because it proposes no revegetation/habitat restoration on the blufftop, the Rock Revetment Alternative would have a greater Biological Resources impact compared to the proposed Project. d. Cultural Resources and Tribal Cultural Resources. The DEIR analysis concluded the Project would have a less than significant impact related to Cultural Resources and Tribal Cultural Resources. Although it is not likely that there are archaeological remains or artifacts within the project site due to its location on the beach and prior ground disturbing activities that occurred during construction of the existing buildings on the top of the bluff,
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the possibility exists that buried archaeological and historical resources, including tribal cultural resources could be discovered during construction of the Project. The Project therefore includes Best Management Practices that construction contractors would be required to follow that would ensure the protection and proper treatment of such resources.
Under the Rock Revetment Alternative, there would be construction activities that could potentially impact buried archaeological and historical resources at the beach, including tribal cultural resources. Thus, the Rock Revetment Alternative would have a similar level of impact to Cultural Resources and tribal Cultural Resources compared to the Project. e. Energy. The Project would not result in operational uses that would significantly increase energy consumption. Project construction would require the use of construction equipment and construction-related vehicle trips that would combust fuel, primarily diesel and gasoline. Because the amounts of energy consumed would be relatively minor, the DEIR concluded that the Project would have a less than significant impact to Energy, as it would not generate energy usage that may have a significant impact on the environment, would not conflict with an applicable plan, policy, or regulation adopted for the purposes of reducing the emissions of greenhouse gases, and would not cause substantial adverse cumulative impacts with respect to energy usage. The Rock Revetment Alternative would involve the use of construction equipment and construction-related vehicle trips similar to the proposed Project and would therefore result in similar Energy impacts compared to the proposed Project. f. Geology and Soils. The DEIR analysis found that the Project’s Geology and Soils impacts would be less than significant. Under the Rock Revetment Alternative there would also be construction activities on the beach, but those activities under this alternative would occupy a larger area than the proposed project. It would therefore result in similar or slightly greater Geology and Soils impacts compared to the proposed Project. g. Greenhouse Gas Emissions. The DEIR analysis found that the Project’s impacts to Greenhouse Gas Emissions would be less than significant. Under the Rock Revetment Alternative there would also be construction activities involving the use of greenhouse gas-generating emissions. The Rock Revetment Alternative would therefore result in similar Greenhouse Gas Emission impacts compared to the proposed Project.
h. Hazards and Hazardous Materials. The DEIR analysis found that the Project’s impacts to Hazards and Hazardous Materials would be less than significant.
Construction of the Project would involve the use of hazardous materials (fuels, oils and other vehicle-related products), which would be used in relatively small quantities, and in compliance with local and state safety requirements. Waste management and materials pollution control BMPs would also be implemented as required at the construction site. The Rock Revetment Alternative would also involve the use of construction vehicles, and waste management and materials pollution control
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BMPs would also be implemented. Therefore, the Rock Revetment Alternative would result in similar Hazards and Hazardous Materials impacts compared to the proposed Project.
i. Hydrology and Water Quality. The DEIR analysis concluded the Project’s hydrology and water quality impacts would be less than significant. The Project would not violate any water quality standards or waste discharge requirements, degrade surface or ground water quality, decrease groundwater supplies or recharge capabilities, or alter drainage patterns of the site or area. In addition, the Project was found not to risk the release of pollutants due to project inundation or conflict with the implementation of water quality or groundwater management plans. The Project includes BMPs to minimize erosion, impacts to water quality, and impacts to special-status species. Under the Rock Revetment Alternative, construction activities would occur on the beach, similar to the proposed Project, and construction would be subject to the same BMPs as the proposed Project.
However, under the Rock Revetment Alternative there would be no grading or recontouring of the blufftop to direct stormwater runoff to the street. Therefore, this Alternative could result in greater impacts than the proposed Project related to on-site or off-site erosion, siltation or flooding. The Rock Revetment Alternative would have a greater impact to Hydrology and Water Quality compared to the proposed Project. j. Land Use and Planning. The DEIR analysis found that the Project’s impacts to Land Use would be less than significant. The Project would not physically divide an established community or cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. As with the Project, the Rock Revetment Alternative would not physically divide an established community. It would temporarily impact the use of the beach as a recreational site for the community, as the beach would have to be closed during construction of the revetment. As with the proposed Project, the construction activities would be temporary. The Rock Revetment Alternative would therefore have a similar Land Use impact compared to the proposed Project.
k. Noise. The Project would generate noise and vibration during construction. The DEIR found that the Project’s impacts related to noise would be short term and less than significant with the implementation of noise control mitigation measures as noted in Mitigation Measures NOI-1A through NOI-1G and Mitigation Measures NOI-2A and NOI-2B. Vibration impacts were found to be less than significant. Construction of the Rock Revetment Alternative would involve very noise-intensive activities such as mechanical picking, placing and driving rocks down to the beach with trucks. These activities would also be expected to be short term in nature and therefore result in less than significant noise impacts. The Rock Revetment Alternative would have similar Noise impacts compared to the proposed Project.
l. Public Services and Recreation. The DEIR found that the Project would have less than significant impacts to Public Services and Recreation. By protecting the existing bluff face
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from further erosion, the proposed seawall would help to preserve recreational uses of the beach below. However, the Rock Revetment Alternative would take up more lateral beach space than the proposed Project and thus would allow less beach recreational space than the Project. In addition, the Project would provide opportunities for passive recreation on the blufftop by restoring this area and installing a pedestrian path and benches. This restoration could occur similarly under this alternative. Because the Rock Revetment Alternative would have a greater impact to existing recreational uses of the beach, it would be considered to have a greater Recreation impact compared to the proposed Project. m. Transportation. The DEIR found that the Project would have less than significant impacts to Transportation. The Project would not generate traffic over the long term or cause any changes to the circulation system during construction. Flaggers and/or other traffic control measures such as signage would be utilized during construction to ensure the safe transport of construction equipment and materials to and from the project site. The Rock Revetment Alternative would require transporting a great amount of rock using large trucks, which could result in impacts on the neighborhood streets from truck stacking and queuing. Although this impact would be less than significant because it would be temporary, it would represent a greater impact than the proposed Project.
n. Utilities Systems. The DEIR found that no utility connections are required to operate the proposed seawall and would not connect to utility infrastructure such as water, sewer, stormwater, electrical, natural gas or telecommunications utilities. Therefore, the Project would have no impact on utilities or require relocation of existing utilities. Because it is considered a short-term construction project, it would not generate a significant demand for water or wastewater treatment, and construction waste would be expected to be minimal and not exceed the capacity of the landfill that serves the area. The Project would therefore have no impact on utilities, require relocation of existing utilities, generate a significant demand for water or wastewater treatment, generate solid waste in excess of State or local standards or the capacity of local infrastructure, and would not conflict with any federal, state or local statutes and regulations related to solid waste. Similarly, the Rock Revetment Alternative which proposes the construction of a rock revetment, would result in no impact to Utilities Systems.
Attainment of Project Objectives
The Rock Revetment Alternative would only meet one of the three primary project objectives.
Although it would be a bluff protective structure designed to halt bluff erosion toward Esplanade Avenue and its critical infrastructure to prevent collapse due to bluff erosion (Objective #1), the rock revetment would not include near-surface keyway material that is resistant to erosion and undermining, such as bedrock, and would therefore be susceptible to undermining, and rock migration, both of which would leave the bluff unprotected and open to wave scour. It would result
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in potential impacts to shoreline aesthetics, given the amount of additional rock riprap that would be placed on the beach (Objective #2). The Rock Revetment Alternative would not restrict or impair public access to ocean views from Esplanade Avenue (Objective #3).
5.4.5 Environmentally Superior Alternative
If an alternative is considered clearly superior to the Project relative to identified impacts, Section 15126.6 of the CEQA Guidelines requires that alternative to be identified as the environmentally superior alternative. By statute, if the environmentally superior alternative is the No Project Alternative, an EIR must also identify an environmentally superior alternative among the other alternatives.
Table 5-1 summarizes the potential impacts of the alternatives compared to the impacts associated with implementation of the Project. The alternatives’ potential impacts are evaluated in Section
5.3. Table 5-1: Alternatives Impacts Compared to Project Impacts Impact/Resource Proposed
Project
Alternative 1:
No Project
Alternative 2:
Grading of the
Bluff
Alternative 3:
Sand
Replenishment
Alternative
4: Rock
Revetment
Aesthetics LTS Reduced LTS Similar LTS Greater LTS Greater LTS Air Quality LTS Reduced LTS Greater LTS Greater LTS Greater LTS Biological Resources LTSWM Greater LTS Greater LTS Greater LTSWM Greater LTS
Cultural Resources and Tribal
Cultural Resources LTS Reduced LTS Reduced LTS Reduced LTS SimilarLTS Energy LTS Similar LTS Similar LTS Greater LTS Similar LTS Geology and Soils LTS Reduced LTS Greater LTS Reduced LTS Greater LTS Greenhouse Gas Emissions LTS Reduced LTS Reduced LTS Greater LTS Similar LTS Hazards and Hazardous
Materials LTS Reduced LTS Reduced LTS Greater LTS Similar LTS Hydrology and Water Quality LTS Reduced LTS Reduced LTS Similar LTS Greater LTS Land Use and Planning LTS Reduced LTS Reduced LTS Greater LTS Similar LTS Noise LTS Reduced LTS Reduced LTS Reduced LTS Similar LTS Public Services and Recreation LTS Greater LTS Greater LTS Similar LTS Greater LTS Transportation LTS Similar LTS Similar LTS Greater LTS Greater LTS Utilities Systems No Impact No Impact No Impact No Impact No Impact Source: MIG, 2021
NI = No Impact. LTS = Less than Significant Impacts, LTSWM = Less than Significant Impacts with Mitigation Incorporated
Alternative 1: No Project. While the No Project Alternative would result in mostly reduced impacts compared to the Project due to the lack of any construction, the No Project Alternative
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would not provide any habitat enhancement or any additional public recreation opportunities and would not meet any of the project objectives. Furthermore, doing no project is not a reasonable alternative here as something needs to be done for the infrastructure at risk or it will begin to fail and eventually get undermined by bluff erosion. The No Project Alternative would meet none of the three project objectives.
Alternative 2: Grading of the Bluff. The Grading of the Bluff Alternative would result in reduced impacts compared the Project for all areas except Aesthetics, Air Quality, Biological Resources, Energy, and Geology and Soils. It would result in similar impacts to Aesthetics, Energy and Transportation, and greater impacts to Air Quality, Biological Resources, Geology and Soils, and Public Services and Recreation. The Grading of the Bluff Alternative would meet two of the three project objectives.
Alternative 3: Sand Replenishment. The Sand Replenishment Alternative would result in similar or greater impacts than the Project for the majority of the environmental issue areas. It would only have reduced impacts for the areas of Cultural Resources and Tribal Cultural Resources, Geology and Soils, and Noise. The Sand Replenishment Alternative would only meet one of the three project objectives.
Alternative 4: Rock Revetment. Compared to the Project, the Rock Revetment Alternative would not result in reduced impacts for any of the environmental issue areas. This Alternative would result in greater impacts than the Project in seven environmental issue areas – Aesthetics, Air Quality, Biological Resources, Geology and Soils, Hydrology and Water Quality, Public Services and Recreation, and Transportation. The Rock Revetment Alternative would only meet one of the three project objectives.
The No Project Alternative would result in reduced impacts in the most environmental issue areas compared to the proposed Project, making it the environmentally superior alternative. However, it would not meet any of the Project objectives. None of the three Alternatives other than the No Project Alternative meets all of the project objectives. However, the Grading of the Bluff Alternative (Alternative 2) would meet two of the three objectives (versus one each for Alternatives 3 and 4) and would result in similar or reduced impacts compared to the proposed Project in more environmental issue categories than Alternative 3, as shown in Table 5-1 (nine, versus five for Alternative 3). Alternative 4 would also result in similar or reduced impacts in six categories, however it would only meet one of the project objectives. Therefore, in accordance with Section 15126.6 of the CEQA Guidelines, Alternative 2 would be considered the environmentally superior alternative among the other three alternatives.
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6 CEQA MANDATED SECTIONS
6.1 IMPACTS FOUND LESS THAN SIGNIFICANT
6.1.1 Agriculture and Forestry Resources
Environmental Setting
The Project is located in the City Pacifica on land designated as ‘Other Land’ which is defined as land that is not included in any other mapping category by the California Department of Conservation Farmland Mapping and Monitoring Program. Common examples include low density rural developments, brush, timber, wetland, and riparian areas not suitable for livestock grazing, confined livestock, poultry, or aquaculture facilities, strip mines, borrow pits, and water bodies smaller than 40 acres. Vacant and nonagricultural land surrounded on all sides by urban development and greater than 40 acres is also mapped as ‘Other Land’.
Thresholds of Significance
The Project would have a significant impact on agriculture and forestry resources if it would:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use, b) Conflict with existing zoning for agricultural use or conflict with a Williamson Act contract,
c) Result in the loss of forest land or conversion of forest land to non-forest use, or d) Involve other changes in the existing environment that, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use.
Impacts
Impact AGFOR-1: The Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use. (No Impact) Impact AGFOR-2: The Project would not conflict with existing zoning for agricultural use or conflict with a Williamson Act contract. (No Impact)
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Impact AGFOR-3: The Project would not conflict with existing zoning for, or cause rezoning of forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)). (No Impact) Impact AGFOR-3: The Project would not result in the loss of forest land or conversion of forest land to non-forest use. (No Impact)
Impact AGFOR-4: The Project would not involve other changes in the existing environment that, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use. (No Impact) There are no forest or timberland trees, forest lands, or agricultural lands on or near the proposed project site, which is on a coastal bluff and beach at the shoreline. As such, the Project would not convert or cause the conversion of any farmland or forest land to non-agricultural/non-forest use.
The proposed Project would not impact Prime Farmland, Unique Farmland, Farmland of Statewide Importance, forest land, or land under a Williamson Act contract. Thus, the Project would not result in impacts to any agricultural or forestry resources.
References
California Department of Conservation. 2019. San Mateo County Important Farmland 2018.
Division of Land Resource Protection, Farmland Mapping and Monitoring Program.
September.
California Department of Fish and Wildlife. 2019. Natural Resources, NLCD 2016 Land Cover (California) Reference Layer. January 1. Accessed on May 8, 2023 at https://apps.wildlife.ca.gov/lands/
6.1.2 Energy
Environmental Setting
Energy consumption is closely tied to the issues of air quality and GHG emissions, as the burning of fossil fuels and natural gas for energy has a negative impact on both, and petroleum and natural gas currently supply most of the energy consumed in California.
Energy is primarily categorized into three areas: electricity, natural gas, and fuels used for transportation. According to the U.S. Energy Information Administration (USEIA), California is the most populous state in the U.S., representing 12 percent of the total national population, has the largest economy, and is second only to Texas in total energy consumption. However, California has one of the lowest per capita energy consumption levels in the U.S. This is a result of California’s mild climate, extensive efforts to increase energy efficiency, and implementation of alternative technologies. California leads the nation in electricity generation from solar, geothermal, and biomass resources (USEIA, 2022a).
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In 2020, the California electric system generated 272,576 gigawatt-hours (GWh) of electricity.
Approximately 70% of this generation occurred in-state (190,913 GWh), while approximately 30% was imported to the California system but generated outside the state (81,663 GWh).
Approximately one-third of California’s total power mix was from renewable sources (CEC, 2021). In 2020, San Mateo County used approximately 4,168 million kilowatt hours (kWh) of electricity, accounting for approximately 1.5 percent of statewide consumption (CEC 2022a). In 2020, California consumed about 12,332 million therms of natural gas. Approximately 39 percent of this natural gas was consumed by the residential sector. San Mateo County consumed about 200 million therms in 2020, including 82 million therms from non-residential uses. Natural gas use from San Mateo County accounted for approximately 1.6% of statewide consumption (CEC, 2022b).
Statewide taxable sales figures indicate a total of 13,060 million gallons of gasoline and 3,105 million gallons of diesel fuel were sold in the 2021 fiscal year (CDFTA 2022). The CEC estimates that in 2020 San Mateo County sold 238 million gallons of gasoline, accounting for 1.9% of statewide gasoline sales, and 19 million gallons of diesel, accounting for 1.1% of statewide diesel sales (CEC 2022c).
Regulatory Setting
Since increased energy efficiency is closely tied to the State’s efforts to reduce GHG emissions and address global climate change, the regulations, policies, and action plans aimed at reducing GHG emissions also promote increased energy efficiency and the transition to renewable energy sources. The U.S. EPA and the State address climate change through numerous pieces of legislation, regulations, planning, policy-making, education, and implementation programs aimed at reducing energy consumption and the production of GHG. The proposed Project would not involve the development of facilities that include energy intensive equipment or operations. While there are numerous regulations that govern GHG emissions reductions through increased energy efficiency, the following regulatory setting description focuses only on regulations that: 1) provide the appropriate context for the proposed Project’s potential energy usage; and 2) may directly or indirectly govern or influence the amount of energy used to develop and operate the proposed improvements.
State
CARB Low Carbon Fuel Standard Regulation (LCFS). CARB initially approved the LCFS regulation in 2009, identifying it as one of the nine discrete early action measures in the 2008 Scoping Plan to reduce California’s GHG emissions. The LCFS regulation defines a Carbon Intensity, or “CI,” reduction target (or standard) for each year, which the rule refers to as the “compliance schedule.” The LCFS regulation requires a reduction of at least ten percent in the CI of California’s transportation fuels by 2020 and maintains that target for all subsequent years. In 2018, CARB approved amendments to the LCFS regulation, which included strengthening and smoothing the carbon intensity benchmarks through 2030 in-line with California’s 2030 GHG emission reduction target enacted through SB 32, adding new crediting opportunities to promote
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zero emission vehicle adoption, alternative jet fuel, carbon capture and sequestration, and advanced technologies to achieve deep decarbonization in the transportation sector. Under the 2018 amendment, the LCFS regulation now requires a reduction of at least 20 percent in CI by 2030 and beyond.
Energy Use in a Wasteful, Inefficient, or Unnecessary Manner The CEQA Guidelines Appendix F (Energy Conservation) describes how energy conservation should be addressed in EIRs and states, “[CEQA] requires that EIRs include a discussion of the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy.” The CEQA Guidelines Appendix F also states that:
“The goal of conserving energy implies the wise and efficient use of energy. The means of achieving this goal include:
1) Decreasing overall per capita energy consumption
2) Decreasing reliance on fossil fuels, such as coal, natural gas and oil, and 3) Increasing reliance on renewable energy sources.”
Specifically, Section II(C) of the CEQA Guidelines Appendix F provides that environmental impacts associated with energy resources may include:
1. The Project’s energy requirements and its energy use efficiencies by amount and fuel type for each stage of the Project including construction, operation, maintenance, and/or removal. If appropriate, the energy intensiveness of materials may be discussed.
2. The effects of the Project on local and regional energy supplies and the requirements for additional capacity.
3. The effects of the Project on peak and base period demands for electricity and other forms of energy.
4. The degree to which the Project complies with existing energy standards.
5. The effects of the Project on energy resources.
6. The Project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives.
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Local
The City adopted the Local Coastal Land Use Plan in 1980, which was intended to meet the goals of the California Coastal Act of 1976. The Local Coastal Land Use Plan includes policies from the Coastal Act. Coastal Act Policy 26(d) requires new developments to minimize energy consumption and vehicle miles traveled.
Thresholds of Significance
In compliance with Appendix G of the State CEQA Guidelines, the Project would result in a significant energy impact if it would:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; or
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency;
Impacts
Impact Energy-1 – The Project would not generate energy usage, either directly or indirectly, that may have a significant impact on the environment. (Less Than Significant Impact) and Impact Energy2 – The Project would not conflict with an applicable plan, policy, or regulation adopted for the purposes of reducing the emissions of greenhouse gases. (Less Than Significant Impact)
The proposed Project would construct a seawall for the fortification of a bluff. The Project would not result in operational uses that would increase energy consumption. Project construction would require the use of construction equipment and construction-related vehicle trips that would combust fuel, primarily diesel and gasoline. Heavy-duty construction equipment would be required to comply with CARB’s airborne toxic control measures, which restrict heavy-duty diesel vehicle idling to five minutes. Construction activities would consume approximately 45,262 gallons of diesel fuel to power on-site, off-road heavy-duty construction equipment. Worker, vendor, and haul truck trips during construction activities are anticipated to consume 12,395 gallons of gasoline, 286,213 gallons of diesel, and 3,952 kWh of mobile source electricity (see Appendix C for fuel consumption calculations, which are based on a fuel consumption factor contained in the CARB Carl Moyer Program Guidelines (2017 Revisions) and fuel consumption rates for on-road vehicles derived from EMFAC2021 V1.0.2 data). The proposed Project involves structures to preserve and protect coastal infrastructure residential structures along the western side of Esplanade Avenue from erosion. Since fuel use during construction would be temporary and needed to prevent the retreat of the coastal bluff, it would not be wasteful or unnecessary. In terms of construction equipment selection, as part of Mitigation Measure NOI-1C the proposed Project would use the smallest size equipment capable of safely completing work activities, which would support the efficient use of fuel resources. Therefore, the proposed Project would not result in a
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potentially significant environmental effect due to wasteful, inefficient, or unnecessary consumption of energy resources. In addition, as the proposed Project involves the construction of a seawall for coastal bluff fortification and would not increase energy consumption over the long term, it would not conflict with nor obstruct a state or local plan adopted for the purposes of increasing the amount of renewable energy or energy efficiency.
References
California Energy Commission (CEC) 2021. 2020 Total System Electric Generation in Gigawatt Hours. June. Accessed May 12, 2021. Available at https://www.energy.ca.gov/datareports/energy-almanac/california-electricity-data/2020-total-system-electric-generation. ______2022a. California Energy Consumption Database – Electricity Consumption by County.
Accessed May 12, 2022. Available online: <http://ecdms.energy.ca.gov/elecbycounty.aspx> ______2022b “Gas Consumption by County.” Gas Consumption by County. CEC, Energy Consumption Database. Accessed May 12, 2022. Available at http://ecdms.energy.ca.gov/gasbycounty.aspx
_____2022c. California Retail Fuel Outlet Annual Reporting (CEC-A15) Results. 2022. Web.
Accessed May 12, 2022. https://www.energy.ca.gov/data-reports/energyalmanac/transportation-energy/california-retail-fuel-outlet-annual-reporting United States Energy Information Administration (U.S. EIA). 2022a. California State Energy Profile. March 17, 2022. Web. Accessed May 12, 2022. Available at:
https://www.eia.gov/state/?sid=CA
6.1.3 Greenhouse Gas Emissions
Environmental Setting
Gases that absorb and emit infrared thermal radiation (heat) in the atmosphere and affect regulation of the Earth’s temperature are known as greenhouse gases (GHGs). There are many compounds present in the Earth’s atmosphere which are GHGs, including but not limited to water vapor (H2O), carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). GHGs allow solar radiation (sunlight) to enter the atmosphere freely. When solar radiation strikes the earth’s surface, it is either absorbed by the atmosphere, land, and ocean surface, or reflected back toward space. The land and ocean surface that has absorbed solar radiation warms up and emits infrared radiation toward space. GHGs absorb some of this infrared radiation and “trap” the energy in the earth’s atmosphere. Entrapment of too much infrared radiation produces an effect commonly referred to as the “Greenhouse effect.” Human activities since the beginning of the Industrial Revolution (approximately 1750) have increased atmospheric GHG concentrations. Average global surface temperatures have risen as a result of GHG emissions. This increase in globally averaged surface
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temperatures is commonly referred to as “Global Warming,” although the term “Global Climate Change” is preferred because effects associated with increased GHG concentrations are not just limited to higher global temperatures (NOAA, 2023).
GHGs that contribute to climate regulation are a different type of pollutant than criteria or hazardous air pollutants because climate regulation is global in scale, both in terms of causes and effects. Some GHGs are emitted to the atmosphere naturally by biological and geological processes such as evaporation (water vapor), aerobic respiration (carbon dioxide), and off-gassing from low oxygen environments such as swamps or exposed permafrost (methane); however, GHG emissions from human activities such as fuel combustion (e.g., carbon dioxide) and refrigerant use (e.g., hydrofluorocarbons) significantly contribute to overall GHG concentrations in the atmosphere, climate regulation, and global climate change.
Human production of GHG has increased steadily since pre-industrial times (approximately pre1880) and atmospheric carbon dioxide concentrations have increased from a pre-industrial value of 280 parts per million (ppm) in the early 1800’s to 420 ppm in April 2022 (NOAA 2022). The effects of increased GHG concentrations in the atmosphere include climate change (increasing temperature and shifts in precipitation patterns and amounts), reduced ice and snow cover, sea level rise, and acidification of oceans. These effects in turn will impact food and water supplies, infrastructure, ecosystems, and overall public health and welfare.
The 1997 United Nations’ Kyoto Protocol international treaty set targets for reductions in emissions of four specific GHGs – carbon dioxide, methane, nitrous oxide, and sulfur hexafluoride – and two groups of gases – hydrofluorocarbons and perfluorocarbons. These GHGs are the primary GHGs emitted into the atmosphere by human activities. The six common GHGs are described below.
Carbon Dioxide (CO2). CO2 is released to the atmosphere when fossil fuels (oil, gasoline, diesel, natural gas, and coal), solid waste, and wood or wood products are burned.
Methane (CH4). CH4 is emitted during the production and transport of coal, natural gas, and oil.
Methane emissions also result from the decomposition of organic waste in municipal solid waste landfills and the raising of livestock.
Nitrous oxide (N2O). N2O is emitted during agricultural and industrial activities, as well as during combustion of solid waste and fossil fuels.
Sulfur hexafluoride (SF6). SF6 is commonly used as an electrical insulator in high voltage electrical transmission and distribution equipment such as circuit breakers, substations, and transmission switchgear. Releases of SF6 occur during maintenance and servicing as well as from leaks of electrical equipment.
Hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs). HFCs and PFCs are generated in a variety of industrial processes.
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GHG emissions from human activities contribute to overall GHG concentrations in the atmosphere and the corresponding effects of global climate change (e.g., rising temperatures, increased severe weather events such as drought and flooding). GHGs can remain in the atmosphere long after they are emitted. The potential for a GHG to absorb and trap heat in the atmosphere is considered its global warming potential (GWP). The reference gas for measuring GWP is CO2, which has a GWP of one. By comparison, CH4 has a GWP of 25, which means that one molecule of CH4 has 25 times the effect on global warming as one molecule of CO2. Multiplying the estimated emissions for non-CO2 GHGs by their GWP determines their carbon dioxide equivalent (CO2e), which enables a project’s combined global warming potential to be expressed in terms of mass CO2 emissions.
GHG emissions are often discussed in terms of Metric Tons of CO2e, or MTCO2e.
Regulatory Setting
State
California Global Warming Solutions Act (AB 32) and Related Legislation The California Air Resources Board (CARB) is the lead state agency for implementing Assembly Bill (AB) 32, the California Global Warming Solutions Act adopted by the Legislature in 2006.
AB 32 requires the CARB to prepare a Scoping Plan containing the main strategies that will be used to achieve reductions in GHG emissions in California.
Executive Order B-30-15, 2030 Carbon Target and Adaptation, issued by Governor Brown in April 2015, sets a target of reducing GHG emissions by 40 percent below 1990 levels in 2030. By directing state agencies to take measures consistent with their existing authority to reduce GHG emissions, this order establishes coherence between the 2020 and 2050 GHG reduction goals set by AB 32 and seeks to align California with the scientifically established GHG emissions levels needed to limit global warming below two degrees Celsius.
To reinforce the goals established through Executive Order B-30-15, Governor Brown went on to sign SB 32 and AB197 on September 8, 2016. SB 32 made the GHG reduction target to reduce GHG emissions by 40 percent below 1990 levels by 2030 a requirement as opposed to a goal. AB 197 gives the Legislature additional authority over CARB to ensure the most successful strategies for lowering emissions are implemented, and requires CARB to, “protect the state’s most impacted and disadvantaged communities …[and] consider the social costs of the emissions of greenhouse gases.”
CARB Scoping Plan
AB 32 requires the CARB to prepare a Scoping Plan containing the main strategies that will be used to achieve reductions in GHG emissions in California. In 2007, CARB approved a statewide 1990 emissions level and corresponding 2020 GHG emissions limit of 427 million metric tons of carbon dioxide equivalents (MTCO2e) (CARB, 2007). In 2008, CARB adopted its Climate Change Scoping Plan, which projects, absent regulation or under a “business as usual” (BAU) scenario, 2020 statewide GHG emissions levels of 596 million MTCO2e and identifies the
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numerous measures (i.e., mandatory rules and regulations and voluntary measures) that will achieve at least 174 million MTCO2e of reductions and reduce statewide GHG emissions to 1990 levels by 2020 (CARB, 2009). In 2011, CARB released a supplement to the 2008 Scoping Plan Functional Equivalent Document that included an updated 2020 BAU statewide GHG emissions level projection of 507 million MTCO2e (CARB, 2011), and in 2014 CARB adopted its First Update to the Climate Change Scoping Plan (CARB, 2014). On December 14, 2017, CARB adopted the second update to the Scoping Plan, the 2017 Climate Change Scoping Plan Update (2017 Scoping Plan Update). The primary objective of the 2017 Scoping Plan Update is to identify the measures needed to achieve the mid-term GHG reduction target for 2030 (i.e., reduce emissions by 40 percent below 1990 levels by 2030), as established under Executive Order B-30-15 and SB
32. To achieve these goals, the 2017 Scoping Plan Update includes a recommended plan-level efficiency threshold of six metric tons or less per capita by 2030 and no more than two metric tons by 2050.
In December 2022, CARB adopted the 2022 Scoping Plan, which outlines the State’s strategy for achieving carbon neutrality by 2045. The 2022 Scoping Plan identifies a technologically feasible, cost-effective, and equity-focused path for achieving the State’s climate targets for 2030 (under SB 32) and 2045 (under AB 1279). The continued implementation of existing plans, policies, and regulations adopted for the purposes of reducing GHG emissions remain critical for achieving the State’s 2030 and 2045 GHG reduction goals. For example, the 2022 Scoping Plan identifies a goal of achieving a per capita VMT reduction of at least 25 percent below 2019 levels by 2030 and 30 percent below 2019 levels by 2045, which is related to the implementation of SB 375. The 2022 Scoping Plan also puts a strong emphasis on measures that will decarbonize activities and emissions from existing and proposed land uses, and capture and store carbon in the atmosphere though man-made (e.g., machinery) and natural (e.g., sequestration) processes.
BAAQMD 2017 Clean Air Plan
As discussed in Section 3.3, Air Quality, the BAAQMD’s 2017 Clean Air Plan is a multi-pollutant plan focused on protecting public health and the climate. The 2017 Clean Air Plan lays the groundwork for a long-term effort to reduce Bay Area GHG emissions 40 percent below 1990 levels by 2030 and 80 percent below 1990 levels by 2050, consistent with GHG reduction targets adopted by the state of California.
BAAQMD 2022 CEQA Guidelines
The BAAQMD revised the 2022 CEQA Guidelines on April 25, 2023, which include climate impact thresholds of significance for land use projects (BAAQMD, 2023). The proposed Project is not considered a land use project, and so these climate impact significance thresholds are not included in this report.
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City of Pacifica Climate Action Plan
The Pacifica City County adopted the Climate Action Plan (CAP) in July 2014. The CAP aimed to reduce community-wide emissions by 35 percent below 2005 levels by 2020, and 80 percent below 1990 levels by 2050. The CAP included 15 GHG reduction measures across the Energy, Transportation, Solid Waste, and Water sectors. However, implementing measures focus on lowering operational GHG emissions, such as reducing energy consumption in buildings or improving transit, and do not apply to the Project.
Thresholds of Significance
The Project would have a significant impact on the environment if it would:
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment, or
b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.
Impacts
Global climate change is the result of GHG emissions worldwide; individual projects do not generate enough GHG emissions to influence global climate change. Thus, the analysis of GHG emissions is by nature a cumulative analysis focused on whether an individual project’s contribution to global climate change is cumulatively considerable.
Impact GHG-1: The Project would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. (Less than Significant Impact)
Impact GHG-2: The Project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing emissions of greenhouse gases. (Less than Significant Impact)
The proposed Project would generate GHG emissions from short-term construction activities.
Construction activities would generate GHG emissions from equipment fuel combustion and worker, vendor, and haul trips to and from the Project. Construction activities would last approximately six months and would cease to emit GHGs upon completion. The Project would not generate any long-term, operational GHG emissions because it does not involve active operations or energy use following bluff stabilization. The BAAQMD has not adopted a threshold of significance for construction-related GHG emissions (BAAQMD 2022). Nonetheless, construction-related emissions were quantified and amortized over the lifetime of the proposed Project (presumed to be 30 years). This normalizes construction emissions so that they can be grouped with operational emissions and compared to appropriate thresholds, plans, etc. The Project’s amortized GHG emissions are estimated to be 11.0 MTCO2e per year (see Appendix C),
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which would not have a significant impact on the environment because the proposed Project’s GHG emissions of 11 MTCO2e are less than 0.04 percent of the City’s CAP 2050 reduction target emissions level of 31,125 MTCO2e (City of Pacifica, 2014). The Project also would not conflict with any plan or policy adopted for the purposes of reducing GHG emissions, including the CARB Scoping Plan, the BAAQMD Clean Air Plan, and the Pacifica Climate Action Plan. Most of the policies and control measures contained in these plans would be implemented at the state or regional level and would not directly apply to the Project. In addition, the Project will incorporate Mitigation Measure NOI-1C (items a and f), which would limit GHG emissions from construction equipment because this mitigation measure would incorporate the smallest size equipment capable of safely completing work activities and connecting to existing electrical service (to avoid the use of stationary power generators, if feasible). Therefore, these impacts would be less than significant.
References
Bay Area Air Quality Management District. Spare the Air – Cool the Climate, Final 2017 Clean Air Plan. April 19, 2017.
____2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans. April 2022.
https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-thresholds2022/justification-report-pdf.pdf?la=en ____2023. CEQA Thresholds and Guidelines Update. Last updated April 25, 2023. Available online at: https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-actceqa/updated-ceqa-guidelines California Air Resources Board (CARB). 2007. Staff Report California 1990 Greenhouse Gas Emissions Level and 2020 Emissions Limit. Sacramento, CA. November 16, 2007. ____2008. Climate Change Scoping Plan. Sacramento, CA. December 2008. ____2009. Climate Change Scoping Plan – A Framework for Change. Endorsed by ARB December 2008. Sacramento, CA. May 11, 2009.
http://www.arb.ca.gov/cc/scopingplan/document/scopingplandocument.htm ____2011. Supplement to the AB 32 Scoping Plan Functional Equivalent Document.
Sacramento, CA. June 2011.
____2014. First Update to the Climate Change Scoping Plan. Sacramento, CA. May 2014. ____2017. 2017 Climate Change Scoping Plan. Sacramento, CA. December 2017. ____2022. California’s 2022 Scoping Plan for Achieving Carbon Neutrality. Available at:
https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022- scoping-plan-documents (accessed April 26, 2023).
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City of Pacifica 2014. Climate Action Plan. July 14, 2014. https://www.cityofpacifica.org/civicax/filebank/blobdload.aspx?blobid=7490 National Oceanic and Atmospheric Administration (NOAA) 2022. Trends in Atmospheric Carbon Dioxide Mauna Loa, Hawaii. Earth System Research Laboratory. Global Monitoring Division. May 5, 2021. Web. May 12, 2021. https://www.esrl.noaa.gov/gmd/ccgg/trends/ ____2023. Basics of the Carbon Cycle and the Greenhouse Effect. Accessed online April 28, 2023 at: https://gml.noaa.gov/outreach/carbon_toolkit/
6.1.4 Mineral Resources
Environmental Setting
Mineral resources are defined as any naturally occurring chemical elements or compounds, formed from inorganic processes and organic substances. Minable minerals are minerals having a value materially in excess of the cost of developing, mining, and processing the mineral and reclaiming the Project area. Mineral resource areas are locations that have been classified by the State Department of Conservation’s Division of Mines and Geology or designated by the State Mining and Geology Board, as well as existing surface mining operations.
The Project site is within Mineral Land Classification MRZ-3: Areas containing mineral deposits the significance of which cannot be evaluated from available data (Division of Mines and Geology 1983). The only designated locations of mineral resources within the City are the Pacifica Quarry and Mori Point which are construction aggregate resource areas of regional significance as designated by the State Mining and Geology Board (Pacifica 2022).
Regulatory Setting
State
Surface Mining and Reclamation Act
The Surface Mining and Reclamation Act of 1975 (SMARA), as codified in the California Public Resources Code (Section 2710 et seq.), provides a comprehensive surface mining and reclamation policy to minimize adverse environmental impacts and allow mined lands to be restored to a usable condition. SMARA also encourages the production, conservation, and protection of the State’s mineral resources. Section 2207 of the California Public Resources Code provides annual reporting requirements for all mines in the State, and the State Mining and Geology Board is granted authority and obligations under this section. SMARA also mandates the classification of lands with valuable mineral resources so that land use decisions that may affect mineral-bearing lands can be made with the knowledge of these resources.
SMARA requires the State Geologist to classify areas with potential for significant mineral resources. It states that: “The primary objective of the mineral land classifications is to assure that
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mineral potential and its significance is recognized and considered before land use decisions that could preclude mining are made. The availability of mineral resources is vital to our society. Yet for most types of minerals, economic deposits are rare, isolated occurrences. Access to terrain for purposes of mineral exploration and mine development has become increasingly difficult because California is also faced with growing land use competition.” The SMBG has classified land in California based on the availability of mineral resources. Four mineral resources zone (MRZ) designations established for classifying sand, gravel, and crushed rock resources are defined below:
• MRZ-1: Adequate information indicates that no significant mineral deposits are present or likely to be present.
• MRZ-2: Adequate information indicates that significant mineral deposits are present or there is a high likelihood for their presence, and development should be controlled. • MRZ-3: The significance of mineral deposits cannot be determined from the available data. • MRZ-4: There is insufficient data to assign any other MRZ designation. Under SMARA, aggregate materials are classified as reserves or resources. Reserves are defined as aggregate materials believed to be acceptable for commercial use that exist within property boundaries owned or leased by an aggregate-producing company, and for which permission allowing extraction and processing has been granted by the proper authorities.” Thresholds of Significance
The Project would have a significant impact to mineral resources if it would:
a. Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state.
b. Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan.
Impacts
Impact MIN-1: The Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state, nor would it result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. (No Impact) As noted above, the Project site is within an area designated as MRZ-3 which is the classification for areas containing mineral deposits the significance of which cannot be evaluated from available data (Division of Mines and Geology 1983). The Project is to prevent the coastal bluff from further retreat and to protect the City’s infrastructure by constructing a seawall at the toe of the bluff slope.
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The Project would not result in the loss of known minerals nor result in the loss of availability of locally important mineral resource recovery site as it is not near the Pacifica Quarry or Mori Point, which are the only two areas identified as areas of regional significance for aggregate.
References
California Department of Conservation. 1983. Mineral Land Classification Map, Aggregate Resources Only. San Mateo and San Francisco Counties. By Melvin C. Stinson, Michael W. Manson and John J. Plappert, 1982. Special Report 146 Plate 2.42. Accessed on April 13, 2022 at https://filerequest.conservation.ca.gov/?q=SR_146-2 City of Pacifica. 2022. General Plan Update and Sharp Park Specific Plan Environmental Impact Report. SCH: 2012022046. January 6.
6.1.5 Population and Housing
Thresholds of Significance
Per the CEQA Guidelines, implementation of the Project would have a significant impact related to population and housing if it would:
a. Induce substantial population unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure); or
b. Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.
Impacts
Impact POP-1: The Project would not induce unplanned population growth in an area, either directly or indirectly (No Impact).
The Project proposes to construct a seawall to protect the City’s infrastructure from further coastal bluff erosion. The Project does not provide housing or facilities that would induce any let alone substantial unplanned population growth in the area, and therefore there would be no direct or indirect impact related to unplanned population growth.
Impact POP-2: The Project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. (No Impact) No people or housing are being displaced as a result of the Project. People were displaced previously as a result of hazardous conditions due to coastal erosion. The Project prevents further erosion from occurring at the site. As stated in the response to Impact POP-1, above, the proposed Project would not induce population growth, either directly or indirectly. No impact would occur.
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6.1.6 Transportation
6.1.7 Environmental Setting
The Project is located within City of Pacifica along Esplanade Avenue. Regional access to the site is provided by State Route 1 (SR-1), just east of the site via Palmetto Avenue and West Avalon Drive and Manor Drive. As shown on Figure 3-3, equipment staging areas are proposed for the vacant blufftop areas at 310 – 330 Esplanade Avenue and adjacent to the temporary construction access at the south end of the Project. The staging areas will be fully contained on sites off of the street and thus will not impair vehicle, bicycle or pedestrian movements along the street and do not require any street closures or encroachment permits.
6.1.8 Regulatory Setting
State
California Department of Transportation (Caltrans)
Access points to and from SR-1 for construction related traffic (i.e., construction equipment trucks, haul trucks, etc.) have not been determined at this time, however, it should be noted that temporary traffic controls that encroach onto Caltrans’ ROW requires a Caltrans-issued encroachment permit, and in addition, work requiring the movement of oversized or excessive load vehicles on State roadways requires a transportation permit that is issued by Caltrans.
Local
Pacifica 2040 General Plan
Pacifica updated the General Plan in 2022. The following policies are contained in the Circulation Element:
CI-I-2 Complete Streets Design Approach. Update the City’s engineering design standards to implement Complete Streets concepts, and include Complete Streets design principles in the planning of all circulation improvement projects. These principles include, but are not limited to:
• Maximizing connections with the existing circulation network; • Minimizing ingress and egress points and consolidating entries; • Providing public transit facilities and improvements; • Providing bicycle and pedestrian facilities (bike lanes and sidewalks); • Minimizing pedestrian crossing distances by providing curb extensions; medians with safety refuges, and other treatments;
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• Improving safety by providing lighting and traffic calming devices for residential streets; • Including landscaping (trees, medians, key intersections and gateways); • Providing appropriate signage, including street signs, entry signs, and directional signs; • Providing street furniture; and
• Maintaining on-street parking.
CI-I-16: LOS for Pedestrians, Cyclists and Transit Users. Strive to maintain LOS C or better for pedestrians, cyclists, and transit users on all roadways, and impose mitigation measures as needed to achieve multi-modal service objectives.
CI-I-23: Design for Safety. Incorporate safety measures in improvement designs for intersections, roadways, pedestrians, transit, and bicycle facilities.
CI-I-25: Emergency Access. Require all developers to incorporate emergency access needs consistent with Title 10 of the Municipal Code.
Pacifica Municipal Code
The following are contained within the Pacifica Municipal Code:
Title 7. Chapter 2. Sec. 7-2.205. - Performance of work. All work shall be performed in a neat and workmanship-like manner in accordance with the standards of the City and the requirements of the Community and Economic Development Director. Such work shall be so programmed as to cause a minimum of interference with traffic and inconvenience to the public. Free and unobstructed access shall be provided to all mailboxes, fire hydrants, water gates, valves, manholes, drainage structures, and/or other public service structures and property as may be required for emergency use. Such public service structures or property shall not be removed or relocated without proper coordination with the properly constituted authorities charged with the control and maintenance of such structures and property. The working area shall be confined so as not to obstruct roadways and walks unnecessarily. Temporary roadways, driveways, and walks for vehicles and pedestrians shall be constructed where required. Upon a written application, streets, driveways, or areas may be closed for limited periods where, in the opinion of the Community and Economic Development Director, the public interests can best be served thereby. When required by the Community and Economic Development Director, the permittee shall give notice to the owners or occupants of all property where access will be impaired. The work shall be coordinated with other agencies or concerns working in the area to the satisfaction of the Community and Economic Development Director. The permittee shall inform himself or herself of the existence and location of all underground facilities and shall protect them against damages.
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Title 7. Chapter 2. Sec. 7-2.206. - Performance of work: Barricades, warning signs, and watchmen. During the performance of the work, the permittee shall provide and maintain fences, barricades, warning and directional signs, flares, red lights, watchmen, and flagmen as may be required by existing laws and regulations and as deemed necessary, in the opinion of the Community and Economic Development Director or his designated representative, to insure full and complete safety to the general public.
Thresholds of Significance
Per the CEQA guidelines, the proposed Project would have a significant impact related to transportation if it would:
a. Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities; b. Conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b); c. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or d. Result in inadequate emergency access.
Impacts
Impact TRANS-1: The Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. (No Impact)
The proposed Project does not propose any changes along the site frontage along Esplanade Avenue and therefore would not conflict with a program, plan, ordinance or policy addressing the circulation system. The Project is the construction of a seawall to prevent coastal bluff erosion and would not generate traffic over the long term or cause any changes to the circulation system during construction. Consistent with Pacifica Municipal Code Title 7, Chapter 2, Sec. 7-2.206, flaggers, barricades, fencing, and/or other traffic control measures such as warning or directional signage would be utilized during construction to ensure the safe transport of construction equipment and materials to and from the Project site.
Impact TRANS-2: The Project would not conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b). (No Impact)
The proposed Project is an infrastructure improvement and does not involve any new land uses, employees or residents at the site that have the potential to generate vehicle miles traveled (VMT).
The proposed Project would have no impacts whatsoever on vehicle miles traveled in and around the proposed Project site since there would not be any change to the operational and maintenance activity from existing conditions. The proposed seawall would require no maintenance once it is
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operational, and construction traffic (equipment and materials transport and daily worker traffic) would slightly increase traffic on local roads during the temporary construction phase of the Project. Given the temporary nature of construction-related travel, impacts related to VMT would be less than significant. Therefore, the Project will not conflict with CEQA Guidelines section 15064.3(b).
Impact TRANS-3: The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). (No Impact)
The proposed Project is intended to minimize existing coastal bluff erosion hazards at the site and would not include new roads or intersections or change the land use of the Project site or area. The seawall would be secured with tie backs and secured to footings as designed by the site-specific geotechnical report. Project construction equipment would not impact public rights-of-way by extending beyond the limits of the proposed designated staging areas. Therefore, the Project would not increase hazards due to a geometric design feature or incompatible uses.
Impact TRANS-4: The Project would not result in inadequate emergency access. (No Impact) The proposed Project is the installation of a seawall along the toe of a coastal bluff and would not include new buildings or above-ground habitable structures. Construction vehicles would use designated access routes and emergency access would be maintained during construction.
Therefore, the Project would not impact emergency access.
6.1.9 Utilities and Service Systems
Thresholds of Significance
Per the CEQA Guidelines, implementation of the Project would have a significant impact related to utilities and service systems if it would:
a. Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunication b. Have insufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years; c. Result in a determination by the wastewater treatment provider which serves or may serve the Project that it has inadequate capacity to serve the projected demand in addition to the provider’s existing commitments;
d. Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals; or
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Packet Pg. 595 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 6 CEQA Mandated Sections
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 6-19 September 2023
e. Not comply with federal, state, and local management and reduction statutes and regulations related to solid waste.
Impacts
Impact UTS-1 – The Project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects. (No Impact)
The Project would construct a seawall to prevent further coastal bluff retreat. No utility connections are required to operate the seawall therefore it will not connect to utility infrastructure such as water, sewer, stormwater, electrical, natural gas or telecommunications utilities. Existing City water service to the site will be available during the construction phase for use in mixing the shotcrete, as necessary (David Harvey, Pacifica Engineering Division). Therefore, the Project would have no impact on utilities or require relocation of existing utilities.
Impact UTS-2 – The proposed Project would not have insufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry year. (No Impact)
Impact UTS-3 – The Project would not result in a determination by the wastewater treatment provider which serves or may serve the Project that it has inadequate capacity to serve the projected demand in addition to the provider’s existing commitments. (No Impact) Impact UTS -2 and Impact UTS-3: The Project, which is primarily a short-term construction project, would not generate a significant demand for water or wastewater treatment. Portable toilet facilities will be provided for workers during construction of the Project.
Impact UTS-4 – The proposed Project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. (Less Than Significant Impact) Some construction waste would be generated by the Project over the short-term. Construction waste is expected to be minimal and would not exceed the capacity of the landfill that serves the area. Per CalRecycle, the Corinda Los Trancos (Ox Mountain) Landfill has 22,180,000 cubic yards of remaining available capacity, or approximately 36.7 percent of the facility’s maximum permitted capacity of 60,500,000 cubic yards. The Corinda Los Trancos landfill is planned for closure in 2034. The impact is considered less than significant.
Impact UTS-5 – The proposed Project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste. (No Impact) The Project would not conflict with any federal, state or local statutes and regulations related to solid waste.
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References
CalRecycle. SWIS Facility/Site Activity Details: Corinda Los Trancos Landfill (Ox Mtn) (41- AA-0002). Accessed on March 29, 2023. Available at:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223.https:
//www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223.
6.1.10 Wildfire
Environmental Setting
The Project site is mapped as being within a Local Responsibility Area with the North County Fire Authority responsible for providing firefighting capabilities. In the Hazard Risk Ranking of the San Mateo County 2021 Multijurisdictional Local Hazard Mitigation Plan, the risk of wildfire for the City of Pacifica was determined to be “Medium Risk”19.The site is not within a Very High Fire Hazard Severity Zone as designated by the California Department of Forestry and Fire Protection (Calfire).
20 The nearest area with a Very High Fire Hazard Severity Zone designation is located in a State Responsibility Area at the City’s southern border with unincorporated San Mateo County, approximately four miles south of the Project site.
California Department of Forestry and Fire Protection
The California Department of Forestry and Fire Protection (CAL FIRE) protects life and property through fire prevention engineering programs, law and code enforcement and education. CAL FIRE identifies areas within Local Responsibility Areas and recommends fire hazard severity zones; CAL FIRE also designates fire hazard severity zones for areas within State Responsibility.
Areas. Cal FIRE will review and approved the City’s wildfire section of the Environmental Safety and Public Services Element.
San Mateo County Multijurisdictional Local Hazard Mitigation Plan The San Mateo County Department of Emergency Management is responsible for alerting and notifying appropriate agencies within the county's 20 cities (including Pacifica) when disaster strikes; coordinating all agencies that respond, ensuring resources are available and mobilized in times of disaster, developing plans and procedures in response to and recovery from disasters, and developing and providing preparedness materials for residents. In 2021, the San Mateo County Department of Emergency Management published a Multijurisdictional Local Hazard Mitigation Plan, a large regional and cross-jurisdictional effort to plan for the reduction of risk from natural and other disasters.
19 San Mateo County. 2021. 2021 Multijurisdictional Local Hazard Mitigation Plan. Volume 2 – Planning Partner Annexes. Accessed April 3, 2023 at https://www.smcgov.org/media/53476/download?inline= 20 Calfire. 2022. Fire Hazard Severity Zones Maps. Accessed April 15, 2022 at https://egis.fire.ca.gov/FHSZ/
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Packet Pg. 597 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 6 CEQA Mandated Sections
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 6-21 September 2023
The Local Hazard Mitigation Plan (LHMP) assesses hazard vulnerabilities and identifies mitigation actions that jurisdictions will pursue in order to reduce the level of injury, property damage, and community disruption that might otherwise result from such events. The LHMP addresses natural and human-caused hazards, including flooding, drought, wildfire, landslides, severe weather, terrorism, cyber threats, pandemic, and the impact of climate change on hazards, as well as other hazards.
Pacifica’s LHMP is an Annex to the MJ-LHMP. The 2021 Pacifica Annex identifies coastal erosion as the top hazard in Pacifica (under the “Landslide/Mass Movements” category) and has noted at least eight significant coastal erosion events since 1997.21 Thresholds of Significance
Based on Appendix G of the State CEQA Guidelines, implementation of the Project would have a significant impact related to wildfire if it would:
For projects located in or near state responsibility areas or lands classified as Very High Fire Hazard Severity Zones, the proposed Project would have an impact related to wildfire if it would:
a. Substantially impair an adopted emergency response plan or emergency evacuation plan;
b. Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire;
c. Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; or
d. Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.
21 General Plan Update and Sharp Park Specific Plan Environmental Impact Report, Public Review Draft. January 2022.
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Impacts
Impact WILD-1: The Project would not substantially impair an adopted emergency response plan, or emergency evacuation plan, due to slope, prevailing winds and other factors exacerbate wildland fire risks, require the installation of associated infrastructure, expose people or structures to significant risks, including downslope or downstream flooding or landslides as a result of runoff, post fire slope instability, or drainage changes. (No Impact) As discussed in the Environmental Setting provided above, the Project is not located in a Very High Fire Hazard Severity zone. In addition, the Project is the construction of a seawall and restoration plantings which does not represent features that would substantially alter the wildfire risk in the area.
6.2 CUMULATIVE IMPACTS
Under Section 15065(a)(3) of the CEQA Guidelines, a lead agency shall find that a project may have a significant effect on the environment where there is substantial evidence that the Project has potential environmental effects “that are individually limited, but cumulatively considerable.” As defined in Section 15065(a)(3) of the CEQA Guidelines, cumulatively considerable means “that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” Using this definition, a project that has no impact in a given impact category cannot have a cumulatively considerable contribution because its contribution is zero.
The Project evaluated in this Focused EIR is limited to the construction of a seawall and revegetation of the blufftop above the seawall area. There are no operational aspects of the Project following construction and therefore many types of impacts that are frequently associated with development projects (e.g., housing, offices, commercial uses, etc.) would not occur. For example, as described in Section 6.1, construction of the seawall and revegetation of the bluff would have no adverse impacts on agriculture and forestry resources, mineral resources, population and housing, public services, utilities and service systems, and wildfire.
There are no other projects proposed or that would be under construction in the same general area as the proposed Project. According to the final draft of the City’s Capital Improvement Program 2022-2027 (June 2022), Therefore, short-term, construction related impacts of the Project (e.g., dust, potential soil contamination, noise and vibration, nesting bird disturbance, and water quality) would not combine with the impacts of other projects and would not be cumulatively considerable Furthermore, Best Management Practices and mitigation measures are included in the Project to reduce construction-related impacts to a less than significant level.
As described in Section 4.3 Biological Resources, the Project could affect sensitive biological resources in the short-term. These impacts, however, would not result in a cumulatively significant loss of such resources, because there are no other proposed projects or projects that would be under construction in the same general area as the proposed Project. In addition, the Project would
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implement a number of measures to reduce impacts on both common and special-status species, as described in Section 4.3. Therefore, the Project would not contribute to cumulative impacts on biological resources.
There are no planned or proposed developments in the Project area that could contribute to cumulative aesthetic, air quality, hydrology and water quality, public services or recreation impacts. The Project’s biological resources impacts are specific to the Project alignment and would not contribute to cumulative impacts elsewhere.
Based on the discussion above, the Project would not result in cumulatively considerable impacts.
6.3 GROWTH INDUCEMENT
CEQA Guidelines Section 15126.2(d) requires that the EIR discuss "...the ways in which the proposed Project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment." The Project is an infrastructure preservation project which involves the construction of a seawall at a location that has encountered significant coastal bluff erosion. The purpose of the seawall is to prevent further erosion of the coastal bluff to protect the City’s infrastructure including the road and utilities at Esplanade Avenue. The construction of the Project would not result in new jobs related to a new use at the site nor does it involve the construction of new housing or uses that requires housing to support. Therefore, the Project would not foster growth inducement either directly or indirectly.
6.4 SIGNIFICANT UNAVOIDABLE IMPACTS
CEQA Guidelines Section 15126.2(b) requires that the EIR discuss "significant environmental effects which cannot be avoided if the proposed Project is implemented." As described in the environmental analyses contained in Section 4.1 through 4.11 of this EIR, all of the potentially significant impacts would be reduced to a less than significant level with mitigation. These include biological resource impacts (Section 4.3), and noise impacts (Section 4.11). Implementation of the mitigation measures described in these sections would reduce potential impacts to less than significant levels.
6.4.1 Significant Irreversible Changes
Section 15126.2(c) of the CEQA Guidelines requires a discussion of "significant irreversible environmental changes which would be caused by the proposed Project should it be implemented." An example of such an irreversible commitment is the construction of highway improvements that would provide public access to previously inaccessible areas. A project would generally result in a significant irreversible impact if:
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• Primary and secondary impacts would commit future generations to similar uses. • The Project would involve a large commitment of nonrenewable resources. • The Project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the Project.
6.4.2 Commitment of Future Generations to Similar Uses
The proposed Project would construct a seawall to preserve the existing coastal bluff and prevent further erosion into the sea. This Project would constitute a long term commitment to minimizing coastal bluff erosion and preserving the existing infrastructure along this section of Esplanade Avenue, and retaining the existing passive open space and recreational (beach access) uses. Similar shoreline protection features (seawall) exist adjacent to the proposed Project site. Future generations would be committed to similar uses as long as the existing and proposed shoreline protection features are successful at preventing further erosion.
6.4.3 Commitment of Non-Renewable Resources
CEQA Guidelines Section 15126.2(c) requires that the EIR discuss "significant irreversible environmental changes which would be caused by the proposed Project should it be implemented." The Project proposes to protect the City’s existing infrastructure through the construction of a seawall to prevent further coastal bluff erosion. The Project would preserve existing conditions and prevent further environmental change (i.e., coastal bluff erosion). Seawalls of similar construction as the proposed seawall exist to the north and south of the site The consumption or destruction of non-renewable or slowly renewable resources would result during construction of the proposed seawall. These resources would include, but would not be limited to, petroleum products (fuels for construction equipment) concrete, sand, gravel, asphalt, masonry, metals, and water. Project implementation would also result the generation of minimal amounts of solid waste. However, construction of the proposed Project would not involve a large commitment of those resources relative to supply, nor would it consume any of those resources wastefully, inefficiently or unnecessarily. The Project has incorporated Best Management Practices, as described in Section 4.2 Air Quality which limit engine idling time. These best management practices support the efficient use of fuel resources.
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Packet Pg. 601 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 7 List of Preparers
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 7-1 September 2023
7 LIST OF PREPARERS
7.1 LEAD AGENCY
City of Pacifica
540 Crespi Drive, Pacifica, CA 94044
www.cityofpacifica.org
Christian Murdock, Planning Director
Stephanie Cervantes, AICP, Senior Planner
7.2 CONSULTANTS
MIG, Inc.
2055 Junction Avenue, San Jose, CA 95131
www.migcom.com
Mike Campbell, AICP, Director of Environmental Analysis Chris Dugan, Director of Air Quality, Greenhouse Gas, and Noise Services Tay Peterson, Director of Biological Analysis
David Gallagher, Senior Biologist
Christina Lau, Senior Environmental Analyst/Project Manager William Deeman, Air Quality, Greenhouse Gas, and Noise Services Analyst Alex Broskoff, Biologist /GIS Analyst/UAV Operator
Rose Redlich, CEQA Analyst
Cotton, Shires and Associates
330 Village Lane, Los Gatos, CA 95030
www.cottonshires.com
David Schrier, Principal Geotechnical Engineer
Andrew Mead, Principal Engineering Geologist
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Packet Pg. 603 Attachment: Attachment B - Draft Environmental Impact Report (5680 : FEIR - 310-330 Esplanade Seawall) 310-330 Esplanade Avenue Infrastructure
Preservation Project
Final Environmental Impact Report
SCH# 2022100372
Lead Agency:
City of Pacifica
Planning Department
540 Crespi Drive (temporary)
Pacifica, CA 94044
www.cityofpacifica.org
May 2024
Cotton Shires 2019
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Packet Pg. 604 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Table of Contents
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR i May 2024
Table of Contents
1 INTRODUCTION ...............................................................................................................1-1
1.1 Environmental Review Process.....................................................................................1-1
1.1.1 Notice of Preparation of an EIR.............................................................................1-1
1.1.2 Public Scoping Meeting.........................................................................................1-2
1.1.3 Public Review of the Draft EIR.............................................................................1-2
1.2 Changes to the Draft EIR ..............................................................................................1-2
1.3 Final EIR Organization .................................................................................................1-3
1.4 Notice of Determination................................................................................................1-3 2 ADDITIONAL INFORMATION........................................................................................2-5
2.1 Revisions to the Draft EIR ............................................................................................2-5
2.1.1 Seawall Impact on Sand Supply ............................................................................2-5
2.1.2 Slope Stability Analysis to Analyze Bluff Retreat ................................................2-5 3 RESPONSES TO PUBLIC DRAFT EIR COMMENTS ....................................................3-0
3.1 Comment Letters and Commenters...............................................................................3-0 Comment Letter A1: California Coastal Conservancy, October 26, 2023 ..........................3-1 Responses to Comment Letter A1 from the California Coastal Conservancy, October 26, 2023 ................................................................................................................................3-3 Comment Letter A2: California Coastal Conservancy, November 9, 2023 ........................3-5 Responses to Comment Letter A2 from the California Coastal Conservancy, November 9, 2023 ................................................................................................................................3-7 Comment Letter B: California Coastal Commission, November 2, 2023 ...........................3-9 Response to Comment Letter B from the California Coastal Commission, November 2, 2023 ..............................................................................................................................3-13 Comment Letter C: California Department of Fish and Wildlife, November 16, 2023 ....3-18
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Responses to Comment Letter C from California Department of Fish and Wildlife, November 16, 2023..............................................................................................................................3-28 Comment Letter D: California State Lands Commission, November 20, 2023 ................3-29 Responses to Comment Letter D from California State Lands Commission, November 20, 2023 ..............................................................................................................................3-33 Comment Letter E: RJR Engineering and Consulting, Inc., November 18, 2023.............3-35 Responses to Comments Letter E from RJR Engineering and Consulting, Inc., November 18, 2023 ..............................................................................................................................3-41 Comment Letter F: David Whitney, October 23, 2023 .....................................................3-43 Responses to Comments from David Whitney, October 23, 2023....................................3-44 4 ERRATA AND REVISIONS..............................................................................................4-1 5 LIST OF PREPARERS........................................................................................................5-1
5.1 Lead Agency .................................................................................................................5-1
5.2 Consultants....................................................................................................................5-1 Appendices
Appendix A: Mitigation Monitoring and Reporting Program Appendix B: New Information
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Packet Pg. 606 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 1 Introduction
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 1-1 May 2024
1 INTRODUCTION
This document is the Final Environmental Impact Report (Final EIR) for the City of Pacifica (City, or Lead Agency) 310-330 Esplanade Avenue Infrastructure Preservation Project. The EIR is prepared as an informational document for action by the City for the proposed project.
Per the California Environmental Quality Act (CEQA) Guidelines Section 15132, the Final EIR shall consist of:
• The Draft EIR or a revision of the draft.
• Comments and recommendations received on the Draft EIR either verbatim or in summary.
• A list of persons, organizations, and public agencies commenting on the Draft EIR. • The responses of the Lead Agency to significant environmental points raised in the review and consultation process.
• Any other information added by the Lead Agency.
In accordance with CEQA Guidelines Section §15132, this document together with the October 2023 Draft EIR constitutes the Final EIR for the 310-330 Esplanade Avenue Infrastructure Preservation Project.
1.1 ENVIRONMENTAL REVIEW PROCESS
Public outreach for the EIR included public noticing, issuance of a Notice of Preparation (NOP) for an Environmental Impact Report, and conducting a public scoping meeting for the EIR, as summarized below. Comments received during the public scoping meeting were taken into consideration and addressed during the preparation of the Draft EIR. Additionally, the City issued a Notice of Availability to initiate public review of the Draft EIR. Details of the public noticing is provided below.
1.1.1 Notice of Preparation of an EIR
The NOP was prepared and circulated to local, state, and federal agencies and made available to the public on October 19, 2022 (SCH# 2022100372). The NOP contained a summary of the Project and resource areas that would be covered in the EIR, and instructions on how to submit comments.
Circulation of the NOP consisted of its filing with the San Mateo County Clerk’s Office and submittal to the Governor’s Office of Planning and Research State Clearinghouse for distribution to various State Agencies for review.
Copies of the NOP were also made available at the City’s Planning Department and electronically via a web link on the City’s website. A notice of the NOP’s availability was also posted in the Pacifica Tribune. The City provided for a 30-day public review period on the NOP that ended on
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November 18, 2022. Written comments in response to the NOP were received from four agencies/organizations and seven interested individuals. The NOP and the written comments received on the NOP were included in Appendix A of the Draft EIR.
1.1.2 Public Scoping Meeting
The City held a virtual (online) public scoping meeting on November 3, 2022, during which the City staff made a presentation of the Project and received comments and fielded questions from members of the public in attendance. Oral comments heard at this scoping meeting generally consisted of concerns over access to the beach from Esplanade Avenue, that the Project should address impacts that extend all the way down to Manor Drive including the 400 block of Esplanade Avenue and the beach access ramp, potential coastal trail damage, erosion, disruption to the residents on Esplanade Avenue from Project construction, the basis for selecting the proposed Project design and the construction timeline.
1.1.3 Public Review of the Draft EIR
The Draft EIR was posted on the City’s website1 and hardcopies were made available for viewing at City Hall (541 Crespi Drive, Pacifica, CA 94044), Pacifica Sharp Park Library (104 Hilton Way, Pacifica, CA 94044) and Pacifica Sanchez Library (1111 Terra Nova Boulevard, Pacifica, CA 94044). The Draft EIR was circulated for a 45-day public review beginning October 4, 2023 and ending on November 20, 2023. The Notice of Availability was released to public agencies and the general public, printed in the newspaper, posted with the County Clerk’s office and filed at the State Clearinghouse for State Agency review on October 4, 2023.
A total of seven comment letters and emails were received by the November 20, 2023 deadline.
These included five comment letters from a State Agency (California Coastal Conservancy (two letters), California Coastal Commission, California Department of Fish and Wildlife and the State Lands Commission) and two letters from members of the public.
1.2 CHANGES TO THE DRAFT EIR
CEQA anticipates that the public review process will elicit information that can result in modification of the project design and refined impact analysis to reduce potential environmental effects of the project. As provided in CEQA Guidelines Section 15088.5, when significant new information is added to the EIR after public noticing of the Draft EIR, the EIR must be recirculated to give the public a meaningful opportunity for review. Significant new information is defined as 1) a new significant environmental impact, 2) a substantial increase in the severity of an environmental impact requiring new mitigation, or 3) a feasible project alternative or mitigation measure considerably different from those previously analyzed that would clearly reduce environmental impacts. Recirculation is not required where the new information added to the EIR 1 https://www.cityofpacifica.org/departments/planning/environmental-documents)
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merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.
This Final EIR includes the following modifications to the Draft EIR:
• Text changes to provide clarity to the analysis, make minor text corrections, or fix grammatical or typographic errors.
• Text changes and additional information based on the comments received on the Draft EIR.
These revisions do not include any added significant new information disclosing new or more severe impacts that would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
1.3 FINAL EIR ORGANIZATION
The Final EIR for the City of Pacifica is organized as follows:
Chapter 1 Introduction. This chapter explains the contents of a Final EIR and the environmental review process for the Project.
Chapter 2 Additional Information. This chapter describes and summarizes additional information related to the project.
Chapter 3 Public Comment on Draft EIR and City Responses to Comment. This chapter contains copies of the comment letters received on the Draft EIR during the public review period. The comment letters have been individually numbered. A list of those who commented is provided at the front of the chapter. Each comment letter is presented and a written response is provided to each comment raising a significant environmental issue submitted on the Draft EIR.
Chapter 4 Errata and Revisions. This chapter includes the changes to the Draft EIR needed to respond to comments and clarify or amplify the information provided in the Draft EIR. The changes correct inaccuracies and clarify the analysis in the EIR.
Appendix A Mitigation Monitoring and Reporting Program
Appendix B New Information
1.4 NOTICE OF DETERMINATION
Section 15091(a) of the CEQA Guidelines stipulates that no public agency shall approve or carry out a Project for which an EIR has been certified which identifies one or more significant
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environmental effects of the Project unless the public agency makes one or more written findings.
If the lead agency approves a Project despite it resulting in significant adverse environmental impacts that cannot be mitigated to a less than significant level, the agency must state the reasons for its action in writing. This Statement of Overriding Considerations must be included in the record of Project approval.
If the Project is approved, the City of Pacifica will file a Notice of Determination (NOD), which will be available for public inspection and posted within 24 hours of receipt at the County Clerk’s Office for 30 days, as well as the State Clearinghouse. The filing and posting of the NOD starts a 30-day statute of limitations period on court challenges to the approval under CEQA.
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Packet Pg. 610 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 2-5 May 2024
2 ADDITIONAL INFORMATION
2.1 REVISIONS TO THE DRAFT EIR
The following summarizes new information that is incorporated into the Draft EIR. The edits involve incorporating two memos prepared for the project that address comments that were made during the public comment period. These memos are summarized below and provided in full in Appendix B.
2.1.1 Seawall Impact on Sand Supply
As stated in the Draft EIR, Cotton Shires and Associates (CSA) prepared a memo (March 30, 2020) to calculate the potential impacts of the proposed sea wall on sand supply. The memo presented variables used to calculate a volume of beach quality sand that would have been supplied to the beach, if natural erosion continued (i.e., without the project). The volume of beach quality sand that would have been supplied to the beach if natural erosion continued is 2,145 cubic yards.
The memo notes that the bluff material collected for a sieve analysis was significantly finer than the beach sand material collected. Therefore, it was concluded that the bluff materials composed zero or a very small fraction of the beach sand. It goes on to state other neighboring projects used a greater percentage for this variable, however no justification was provided for the use of the higher percentage.
2.1.2 Slope Stability Analysis to Analyze Bluff Retreat CSA prepared a memo (November 15, 2023) to address a request to provide a slope stability analysis to determine a factor of safety for the infrastructure the project is intended to protect. The memo summarizes how computers analyze slope stability and the shortcomings of various methods commonly used and various problems that can arise using these methods. The memo reiterates the documented method of ongoing bluff retreat noting that wave action erodes the toe of the bluff which results in near vertical or vertical and undermined bluff faces. The lower portions of the bluff face then calve off like a glacier, followed later by the mid-bluff portion, then the upper bluff portion, and notes that these calving events are typically about 2 to 10 feet thick. The memo states this type of calving event (or failure) is not a typical landslide event, and based on CSA’s experience, does not lend itself to a traditional slope stability analysis. CSA states that a quantitative slope stability analysis could be undertaken, however notes that the analysis would not be modeling the bluff retreat hazard the proposed project is designed to address or any hazard that has been observed at the site.
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Packet Pg. 611 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-0 May 2024
3 RESPONSES TO PUBLIC DRAFT EIR COMMENTS
In accordance with CEQA Guidelines Section 15088, this document includes written responses to comments received by the City of Pacifica on the Draft Environmental Impact Report (Draft EIR).
This chapter contains copies of the letters and emails, collectively called “comment letters” received on the Draft EIR during the public review period.
3.1 COMMENT LETTERS AND COMMENTERS
The comment letters have been individually numbered and will appear on the following pages in the order presented below. Comments were received from the following agencies and individuals:
Federal and State Agencies:
A1. California Coastal Conservancy (email received October 26, 2023) A2. California Coastal Conservancy (email received November 9, 2023) B. California Coastal Commission (dated November 2, 2023) C. California Department of Fish and Wildlife (dated November 16, 2023) D. California State Lands Commission (dated November 20, 2023) Organization, Businesses, and Individuals:
E. RJR Engineering and Consulting, Inc. (dated November 18, 2023) F. David Whitney (email received October 23, 20230)
Copies of each comment letter, followed by the City written responses thereto are provided below..
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Packet Pg. 612 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) 1 Mike Campbell
From: Duff, Tim@SCC <[email protected]>
Sent: Wednesday, October 25, 2023 4:17 PM
To: Yip, Roland
Cc: Harvey, David
Subject: RE: Esplanade CCC Grants
[CAUTION: External Email]
Roland,
My comment on Table 2‐1 on pg. 2‐7 pre‐construction surveys for nesting birds to call out snowy plovers was not addressed.
My comment on 3.3.5 Construction (now 3.4.5) to “add signage at public path used for construction access and on the beach to notify the public of closures to these areas” was not addressed.
My comment to add traffic to Ch 1 Intro Section and following relevant Sections such as Section 4 Impact Analysis were not addressed.
My comment at 4.1.1 Aesthetics to “Add description of public access on bluff to the beach at 380 block” and at seawall site was not addressed.
My comment at 4.1.2 Regulatory Setting‐ Coastal Act policies to “add public access policies, i.e. Ch 3” was not addressed. Same for local access/recreation policies (not only scenic access policies).
Separate from my comments submitted to date, SCC owns a public access easement across the 380 block property that prohibits the proposed construction activity there. We need to discuss, including the need for similar bluff restoration as is proposed at the seawall bluff site, i.e. plantings, fencing, signage.
Tim
From: Duff, Tim@SCC
Sent: Wednesday, October 25, 2023 3:22 PM
To: 'Yip, Roland' <[email protected]>
Cc: 'Harvey, David' <[email protected]>
Subject: RE: Esplanade CCC Grants
Roland,
I meant the top of 2.2. The following table 2‐1 does not include my suggested need for public access / recreation mitigations for the new seawall impacts.
‐Tim
From: Duff, Tim@SCC
Sent: Wednesday, October 25, 2023 3:13 PM
A1-1
A1-2
A1-3
A1-4
A1-5
A1-6
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Packet Pg. 613 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) 2 To: Yip, Roland <[email protected]>
Cc: Harvey, David <[email protected]>
Subject: RE: Esplanade CCC Grants
Roland,
For starters, my comment at the top of Section 2.1 does not appear to be addressed: “Add mitigation measures for public access impacts, including impacts to access to and along bluffs, trails and the beach.” Please clarify why, thanks.
‐Tim
A1-7
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Packet Pg. 614 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-3 May 2024
Responses to Comment Letter A1 from the California Coastal Conservancy, October 26, 2023
Response to Comment A1-1: Snowy plover nests are not called out specifically in this measure because no impacts are expected to snowy plover. The biological resources chapter states: "There is no suitable breeding habitat for western snowy plovers at the study area, as the high tide line reaches all the way to the riprap and therefore any nest established on the beach would be washed away. However, western snowy plovers are known to occur throughout the Pacific Coast and may occasionally pass through the Project area or even use the beach for foraging. However, there is no resident population of western snowy plovers in the Project area according to databases such as the CNDDB (2019) and eBird (Cornell Lab of Ornithology, 2019).
Response to Comment A1-2: Signage notifying the public of closures of public facilities such as the beach access trail used for construction access and/or the beach in the area of the proposed seawall construction would be installed with the project, as it is standard procedure for such construction projects in public areas. The Project Description section of the EIR has been revised to include this information (see Chapter 4, Errata).
Response to Comment A1-3: Chapter 1 INTRODUCTION of the Draft EIR contains descriptions of: the purpose and scope of the EIR; the scoping and public review processes; the areas of known controversy; the public review and comment period; the availability of EIR materials; the Final EIR and Responses to Comments processes; and the Notice of Determination process. The issue of potential traffic impacts resulting from the Project is not relevant to any of these subcategories of discussion but would have been more appropriately addressed under Chapter 4. IMPACT ANALYSES. However, the issue areas addressed in Chapter 4 were limited to the most applicable to the Project, and traffic was not considered by staff to be an issue that warranted in-depth analysis or presented a potentially significant impact due to the nature of the proposed construction project and was therefore briefly addressed in Chapter 6.1 Impacts Found Less Than Significant. Chapter
6.1.6 concluded that the proposed construction staging areas would be fully contained on sites off of the street and would not impair vehicle, bicycle or pedestrian movements along the street and would not require any street closures or encroachment permits.
The impact analyses contained in Chapter 6.1.6 Transportation address the project’s impacts related to conflicts with existing programs and policies, generation of VMT, geometric design hazards, and emergency access, per the CEQA thresholds.
Response to comment A1-4: Mention of the existing public access trail at 100 Esplanade was added in Chapter 4.1.1 (3rd paragraph) because its adjacency to the future restoration/passive recreation area proposed by the project is relevant to the chapter’s discussion of views and scenic vistas. The existing beach access ramp at the south end of the 380 block would remain in its current condition following completion of the project, with no improvements proposed with the project.
Response to Comment A1-5: None of the policies contained in Article 2 (Public Access) of Chapter 3 of the California Coastal Act (Coastal Resources Planning and Management Policies) have any relation to a project’s potential impacts on scenic vistas and scenic resources, or the potential of a project to degrade the existing visual character or quality of the project area, which
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Packet Pg. 615 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-4 May 2024
is the subject of Chapter 4.1 of the Draft EIR. That is why they are not included in the analysis.
The relevant Coastal Act policies addressing scenic and visual qualities of coastal areas, Section 30251 of the Coastal Act and Policy 24 of the Local Coastal Land Use Plan, are described in Chapter 4.1.2. Public access policies are described in the Regulatory Settings discussions in other parts of the Draft EIR, such as Chapters 4.7.2 (Pacifica Zoning Ordinance), 4.8.2 (Pacifica General Plan 2040), and 4.10.2 (Coastal Act Policies).
Response to Comment A1-6: As stated in the introductory paragraph of Chapter 2.2, Table 2-1 summarizes project and cumulative impacts that are considered significant and have associated mitigation measures. There were no significant or cumulative impacts to public access or recreation requiring mitigation identified in the Draft EIR. The public access trail at 400 Esplanade would be maintained during the construction. The impact discussions in Chapter 4.10.4 stated that the project could restrict access in the area during construction, but that the construction site would be managed to maintain emergency vehicle access, and that no alteration of existing recreational facilities would be necessary. It further states that the project may restrict adjacent beach uses during the construction period, but that these impacts would be temporary during the construction period. These impacts are considered less than significant and therefore do not require mitigation.
Response to Comment A1-7: This comment is in reference to an earlier comment that was based on consultation with the California Coastal Conservancy during preparation of the administrative draft of the EIR and received in an email to Roland Yip of the Pacifica Public Works Department, dated 8/22/23, prior to the release of the Draft EIR for public review. In response to the original comment, and prior to its publishing, the Draft EIR was revised to include statements regarding public access to the bluffs, trails and beach in several different sections of the document. There were no findings of potentially significant impacts requiring mitigation, and therefore no impacts or mitigation measures were included in the summary table (Table 2-1) in Chapter 2.2. The original comment appeared in Chapter 2.2. (not “Section 2.1”).
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Packet Pg. 616 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) From: Duff, Tim@SCC <[email protected]>
Sent: Thursday, November 9, 2023 3:48 PM
To: Yip, Roland <[email protected]>
Cc: Harvey, David <[email protected]>
Subject: RE: Esplanade CCC Grants
[CAUTION: External Email]
Hi Roland,
Thank you for the email and preliminary responses to my comments. Below are my responses:
The top of 2.2. The following table 2‐1 does not include my suggested need for public access / recreation mitigations for the new seawall impacts.
As stated in the introductory paragraph of Chapter 2.2, Table 2‐1 summarizes project and cumulative impacts that are considered significant and have associated mitigation measures.
There were no significant or cumulative impacts to public access or recreation requiring mitigation identified in the DEIR. The public access trail at 400 Esplanade will be maintained during the construction. The impact discussions in Chapter 4.10.4 stated that the project could restrict access in the area during construction, but that the construction site would be managed to maintain emergency vehicle access, and that no alteration of existing recreational facilities would be necessary. It further states that the project may restrict adjacent beach uses during the construction period, but that these impacts would be temporary during the construction period. These impacts are considered less than significant and therefore do not require mitigation.
The project when completed will impact physical public access and should be mitigated, e.g. with new blufftop park improvements at both the 400 block area and the 380 block bluff where public access will also be impacted by the existing to‐be‐repaired rip rap that will continue to occupy the sandy beach and diminish beach area available to the public. The 380 block access impacts must be addressed by this EIR to avoid piecemealing as the City proposes to assert the 380 block project is exempt from CEQA review. My comment at 4.1.1 Aesthetics to “Add description of public access on bluff to the beach at 380 block” and at seawall site was not addressed.
Mention of the existing public access trail at 100 Esplanade was added in Chapter 4.1.1 (3rd paragraph) because it’s adjacency to the future restoration/passive recreation area proposed by the project is relevant to the chapter’s discussion of views and scenic vistas. The existing beach access ramp at the south end of the 380 block would remain in it’s current condition following completion of the project, with no improvements proposed with the project.
I do not understand how the 100 block addresses public access impacts at the 380 and 400 blocks. The 380 block bluff physical public access will be impacted by the existing to‐be‐repaired rip rap that will continue to occupy the sandy beach and diminish beach area available to the public. The 380 block physical access impacts must be addressed by this EIR as the City proposes to assert the 380 block project is exempt from CEQA review. The 380 block physical access impacts must be addressed by this A2-1
A2-2
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Packet Pg. 617 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) EIR to avoid piecemealing as the City proposes to assert the 380 block project is exempt from CEQA review.
My comment at 4.1.2 Regulatory Setting‐ Coastal Act policies to “add public access policies, i.e.
Ch 3” was not addressed. Same for local access/recreation policies (not only scenic access policies).
None of the policies contained in Article 2 (Public Access) of Chapter 3 of the California Coastal Act (Coastal Resources Planning and Management Policies) have any relation to a project’s potential impacts on scenic vistas and scenic resources, or the potential of a project to degrade the existing visual character or quality of the project area, which is the subject of Chapter 4.1 of the DEIR. That is why they are not included in the analysis. The relevant Coastal Act policies addressing scenic and visual qualities of coastal areas, Section 30251 of the Coastal Act and Policy 24 of the Local Coastal Land Use Plan, are described in Chapter 4.1.2. Public access policies are described in the Regulatory Settings discussions in other parts of the DEIR, such as Chapters 4.7.2 (Pacifica Zoning Ordinance), 4.8.2 (Pacifica General Plan 2040), and 4.10.2 (Coastal Act Policies).
The project’s impacts to physical access to the beach at the 380 block with the existing to‐be‐repaired rip rap that will continue to occupy the sandy beach and diminish beach area available to the public. The 380 block physical access impacts must be addressed by this EIR to avoid piecemealing as the City proposes to assert the 380 block project is exempt from CEQA review.
Thanks. I look forward to discussing our public access / Coastal Trail easement over the 380 block during the EIR review period.
‐Tim
A2-3
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Packet Pg. 618 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-7 May 2024
Responses to Comment Letter A2 from the California Coastal Conservancy, November 9, 2023
Response to Comment A2-1: Mention of the existing public access trail at 100 Esplanade was added in Chapter 4.1.1 (3rd paragraph) because its adjacency to the future restoration/passive recreation area proposed by the project is relevant to the chapter’s discussion of views and scenic vistas. The existing beach access ramp at the south end of the 380 block would remain in its current condition following completion of the project, with no improvements proposed with the project.
Therefore, the project has no impacts on public access at the 380 block because the project does not block or prevent access at this location.
The commentor asserts that public access will be impacted by the existing to-be repaired rip rap that will continue to occupy the sandy beach and diminish beach area available to the public. The project would remove existing rip rap from the beach in the area immediately adjacent to the proposed seawall construction site (310-340 Esplanade Avenue) following construction. Removal of existing rip rap from other areas of the beach outside of the seawall construction site is not included in the project, as it does not affect nor would it be impacted by the proposed seawall construction. Removal of rip rap to improve beach availability outside of the proposed seawall construction site is not within the scope of this project, and there is no nexus to require any impact analysis in the Draft EIR. A project to remove rip rap from the beach along the rest of the block, including 380 Esplanade Avenue, would be a separate project as it is not a reasonably foreseeable consequence of the proposed project.
Response to Comment A2-2: This comment was received during the public review period for the Draft EIR, however it was written in response to a previous email exchange with the Public Works Department that began prior to the publication of the Draft EIR regarding the provision of public access during the Project’s construction period (see Response to Comment A1-7 and Comment Letter A2, above).
The existing 100 block access trail provides public access to the beach below. It was discussed in Chapter 4.1 AESTHETICS of the Draft EIR because of its relevance to the analysis of views and scenic vistas contained in that chapter, but also because it provides an example of how the Project would not impact public access to the beach and trails. Similarly, public access to the beach from the trail located on the 380 block would not be impacted by the Project.
The commenter’s assertion that the 380 block bluff access will somehow be impacted by the existing rip rap on the beach is unsubstantiated. The Project includes removal of existing rip rap in the immediate vicinity of the proposed seawall construction, which spans from the northernmost point of the 100 block to approximately the southern end of the 340 Esplanade Avenue property.
The existing access trail is located approximately 1,100 feet to the south of this location.
The CEQA document prepared for the subject Project, which consists of the construction of a seawall and revegetation of areas along the blufftop that are proposed for equipment staging, is this EIR. The Project would not affect any other blufftop areas or properties from the 350
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Packet Pg. 619 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-8 May 2024
Esplanade Avenue property to the proposed staging area near the access trail, and thus a CEQA exemption is neither relevant nor proposed.
Response to Comment A2-3: As discussed in Chapter 3.4.6 of the Draft EIR, the existing beach access ramp at the south end of the 380 block of Esplanade Avenue would provide access for construction equipment during the construction phase of the project, and would remain in its current condition and provide public access following completion of the construction of the project. The project does not propose to close the ramp or preclude public access to the beach from this ramp during construction. It would therefore remain available to provide public access during the construction phase, and there would be no public access impacts.
The project would remove existing rip rap from the beach in the area immediately adjacent to the seawall construction site following construction. Removal of existing rip rap from other areas of the beach outside of the seawall construction site is not included in the project, as it does not affect nor would it be impacted by the proposed seawall construction. Removal of rip rap to improve beach availability outside of the proposed seawall construction site is not within the scope of this project and there is no nexus to require any impact analysis in the Draft EIR.
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Packet Pg. 620 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
NORTH CENTRAL COAST DISTRICT
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
WEB: WWW.COASTAL.CA.GOV
November 2, 2023
City of Pacifica
Attn: Stefanie Cervantes, Senior Planner.
540 Crespi Drive
Pacifica, CA 94044
Subject: Draft Environmental Impact Report for the proposed 310-330 Esplanade Drive Infrastructure Preservation Project
Dear Ms. Cervantes:
Thank you for sending the Draft Environmental Impact Report for the proposed 310-330 Esplanade Drive Infrastructure Preservation Project. The proposed project includes several shoreline protection structures intended to fortify the toe of the bluff including a sheet pile wall, a cap beam on top of the sheet pile wall, and a shotcrete wall secured to the bluff face with tensioned tieback rods/tendons. The wall is estimated to be 650 feet long and 40 feet high as measured from the base of the bluff. Staff requests that the following be incorporated in the Environmental Impact Report for the project, as discussed below.
Project Description
Please address the following:
1. Provide a written explanation and accompanying graphic to illustrate the infrastructure and/or any other development present, that the armoring is proposed to protect, including the anticipated remaining life, initial date of construction, and any associated coastal development permit history of such infrastructure or other development.
2. Explain the need to protect the infrastructure with armoring, including the length of time at which such infrastructure is expected or likely to be in danger, and the rationale for why the armoring is proposed to extend further south than the 310- 330 block of Esplanade Drive.
3. Describe the long-term plans for this area after the 30-year life span of the seawall has been exceeded, including long-term plans for adapting the infrastructure or development that the armoring is proposed to protect.
Aesthetic Resources
Please address the following:
1. Please ensure that the shotcrete wall design matches the aesthetics of the surrounding bluffs through color choice and mimicking natural grooves.
B1
B2
B3
B4
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Packet Pg. 621 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
NORTH CENTRAL COAST DISTRICT
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
WEB: WWW.COASTAL.CA.GOV
Biological Resources
Please address the following:
1. Please include avoidance, minimization, and mitigation (for unavoidable impacts) to address the potential for marine mammals on the beach during construction, since a juvenile sea lion was surveyed onsite.
2. Staging in ESHA is prohibited by the Coastal Act per policy 30240. The draft LCLUP maps the south staging as ESHA and there may be further evidence of ESHA produced as a result of a Coastal Development Permitting process analysis. Therefore, please explain the necessity of the south staging area and explore alternatives that would avoid impacts to ESHA.
Geology and Soils
Please address the following:
1. This section explains the history of shoreline armoring along the bluff side of these three properties, and notes that there is no indication or documentation regarding the depth of a revetment that was installed at this site in 2010. While possible, it seems unlikely that no plans exist for this revetment, and City staff should explore other avenues to research this point, including through potential Coastal Commission record reviews, to find and analyze further information about the configuration (both permitted and on the ground as built) armoring structure.
2. The soil erosion section notes that the average retreat rate for this site between 1943-2017 was 2.7 feet per year, and between 2004-2017 was 5.4 feet per year.
While this is critical information, Commission staff strongly recommends providing additional detail and analysis to this end, to include: the current rate of retreat of the bluff, a more robust analysis of the historical retreat rates for the area, estimates of future retreat rates with and without armoring, including an assessment of such rates as impacted by a range of projected sea level rise scenarios; as well as a quantitative slope stability analysis to determine the factor of safety for the infrastructure the project is intended to protect.
3. This section also explains that these sites would be uniformly graded to very gently drain towards Esplanade Avenue, the blufftop is proposed to be revegetated with native plantings, and pervious paving materials are proposed to be used, all of which will result in a low potential for runoff from the lots to the bluff face. Commission staff recommends providing additional detail regarding this proposed grading, including the resulting slope following grading, the proposed amount of cut and fill, and analysis on how that resultant slope was selected.
Public Services and Recreation
B5
B6
B7
B8
B9
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Packet Pg. 622 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
NORTH CENTRAL COAST DISTRICT
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
WEB: WWW.COASTAL.CA.GOV
Please address the following:
Clarify if the proposed project will improve public access and recreation opportunities, and connectivity and continuity of such opportunities, at this site and at the adjacent 400 Esplanade site or if improvements will be proposed under the separate 400 Esplanade project.
2. Please note that additional public access mitigation may be required depending on the sand supply impacts of both the proposed project, as well as from previous shoreline protective devices which were installed on an emergency basis, never authorized with required follow-up CDPs, and thus at this point could constitute unpermitted development on the site.
Alternatives
Please address the following:
1. While the DEIR evaluates 1) the CEQA-mandated no-project alternative; 2) grading of the bluff alternative; 3) sand replenishment alternative; and 4) rock revetment alternative, it is missing a thorough analysis of a critical adaptive planning alternative that would involve retreat of the infrastructure that the proposed shoreline protection structure is intended to protect. The section notes that a managed retreat alternative was reviewed but not included for further evaluation and identifies a number of reasons why it was not included. However, without further evaluation Commission staff is unable to concur with the conclusion of this document that the alternative does not merit further consideration, especially as the Coastal Act requires shoreline protection be the least environmentally damaging, feasible alternative. In order to actually be able to evaluate the feasibility of such an alternative, City staff should provide and evaluate the bluff erosion analysis information requested in the Geology and Soils section, above; and complete a cost analysis over the long-term of protecting the bluff as-is (including by incorporating necessary maintenance and mitigation costs) vs. the cost of relocating the infrastructure the shoreline armoring is intended to protect.
2. Although this document analyzed the CEQA-mandated no-project alternative, which evaluates the site as-is, please note that the Commission would view a noproject alternative as requiring the removal of any unpermitted armoring on the site.
3. The sand replenishment alternative notes that it is likely infeasible as sand is rapidly removed from the beach under winter storm conditions. While this may be the case for this alternative, this fact should be evaluated in more depth for the selected project as well, especially given that the proposed project would cut off B10 1.
B11
B12
B13
B14
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Packet Pg. 623 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
NORTH CENTRAL COAST DISTRICT
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
WEB: WWW.COASTAL.CA.GOV
sand supply to the beach fronting the toe of the bluff, and thus impact wave dynamics and subsequently bluff erosion.
Thank you again for the opportunity to comment on this Draft EIR, and we look forward to continued coordination on this project. If you have any questions regarding these comments, please contact me via email at [email protected].
Sincerely,
Oceane Ringuette
Coastal Planner
North Central Coast District Office
California Coastal Commission
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Packet Pg. 624 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-13 May 2024
Response to Comment Letter B from the California Coastal Commission, November 2, 2023 Response to Comment B1: The proposed armoring serves to protect critical coastal infrastructure adjacent to the bluff, encompassing essential components such as storm drains, sewer, water, electrical, and gas lines. Furthermore, the armoring is vital for safeguarding existing residences and apartments along the coastal area. This infrastructure, initially constructed in the early 1960’s, is a fundamental part of the community, facilitating daily life and supporting residential structures.
Although the City does not have any graphics from the pre-Coastal Act period directly showing the infrastructure within the street, an aerial photograph of the project area from 1965 shows existing structures located from 310 to 350 Esplanade Avenue and the existing street. In addition, the original subdivision map from 1961 shows 5-foot public utility easements along both sides of Esplanade Avenue, within which below-ground electrical, gas, water and other utility lines were installed.
The proposed armoring is a proactive measure to enhance the resilience of these vital services against coastal erosion and potential storm-related impacts. Although hard to estimate, the anticipated remaining life of the infrastructure on Esplanade Avenue is approximately 20 years if
5.4 feet per year of erosion is considered. The existing infrastructure in Esplanade Avenue (roadway, sewer, water, storm, and gas lines) are assumed, based on recorded subdivision maps, to have been constructed in approximately 1961. With proper maintenance, piping materials and roadways can last up to 100 years or longer, which means that in circumstances where there are no hazards such as coastal erosion, the existing roadway and infrastructure could remain operational for an additional 40 years or more. As far as Coastal Development Permit history along Esplanade Avenue, there have been two permits issued within the past 15 years that are known of.
One is for the development of the storm drain pump station at 380 Esplanade Avenue that that was constructed roughly ten years ago (CDP 2-11-009) and another was for the shotcrete wall at 360 Esplanade Avenue that was installed approximately 15 years ago (CDP 2-08-020).
Response to Comment B2: The imperative to protect the coastal infrastructure with armoring arises from the imminent and ongoing threat of erosion along the bluff. Without intervention, the infrastructure, including the street itself (Esplanade Avenue), would be continuously exposed to the erosive forces of the coastline. The danger is perpetual, as erosion continues to degrade the coastal environment, jeopardizing critical elements.
The length of time at which such infrastructure is expected or likely to be in danger is indefinite without intervention. Coastal erosion is an ongoing process, and the rate of degradation will persist unless preventative measures are implemented. The threat extends not only to Esplanade Avenue but also to the broader coastal infrastructure network, including the potential risk of Highway 1 far down the line. This proactive approach aligns with the principles of sustainable coastal management, recognizing the necessity to act now to preserve the integrity and functionality of essential infrastructure for the benefit of the community in the face of ongoing coastal challenges.
The rationale as to why the armoring is proposed to extend slightly further south than 330 Esplanade is to ensure seamless integration with the existing shotcrete wall that exists at 360
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Packet Pg. 625 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-14 May 2024
Esplanade (CDP 2-08-020) to create a unified and resilient coastal protection system. In order to preserve the infrastructure between 310-330 Esplanade Avenue, the Project’s geotechnical report recommended that a continuous seawall be constructed along the base of the bluff. It stated that ideally, the seawall should overlap behind the existing seawall to the north (at Land’s End) and tie-in to the existing seawall to the south (at 360-380 Esplanade Avenue). Based on CSA’s evaluation of the neighboring seawalls to the north and south, the wall to the north does not appear to be providing satisfactory long‐term support to the lower portion of the bluff, and consequently the report recommended overlapping behind the wall to the north instead of connecting to it.
Conversely, the seawall to the south at 360/380 Esplanade Avenue appears to be providing satisfactory support to the bluff. The purpose of tying in to the existing seawall to the south would be to form a continuous barrier for bluff support against wave scour. The report stated that without adequate tie-in provisions, the potential for erosional out-flanking of the proposed seawall would be significantly increased. The Project Description section of the EIR has been revised to include this information (see Chapter 4, Errata).
Response to Comment B3: Currently there is no predefined long-term plan in place beyond the 30-year lifespan of the proposed armoring. The immediate focus is on the installation of the armoring to address pressing erosion threats and protect vital infrastructure. Recognizing the dynamic nature of coastal environments, the intention is to remain adaptive and responsive to evolving conditions. Once the armoring is in place, continuous monitoring and assessment will be integral to gauge its performance and to understand how the coastal landscape evolves. Future consideration will be made based on the ongoing challenges posed by erosion, with an openness to exploring adaptive strategies, potential improvements, or alternative measures as needed. This adaptable approach ensures a proactive stance in addressing the changing dynamics of the coastal zone while prioritizing the long-term sustainability of the protected infrastructure.
Response to Comment B4: Comment noted. The construction drawings for the proposed seawall contain a finish facing schedule that includes the following note: “Finish facing shall be colored, sculpted and stained to resemble natural occurring geologic formations.” This would ensure that the seawall would match the aesthetics of the surrounding bluffs. The impact discussion under Impact AES-3 has been modified to include this information (see Errata section).
Response to Comment B5: The Draft EIR acknowledges that California sea lions and harbor seals can haul out into the study area at any time of the year to rest, but that the study area is not known to be a significant haul-out site. It additionally states that there are no known significant haul-out sites or rookery sites for either species near the study area, and that marine mammals would only be temporarily displaced by construction noise and can forage in areas surrounding the Project. Because marine mammals are not expected to be killed or injured since they could easily avoid the work site, and because the proposed Project would not result in permanent substantial changes to the availability of nearby foraging or haul-out habitat after construction is completed, this issue was not considered a significant impact requiring avoidance, minimization or mitigation measures.
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Packet Pg. 626 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-15 May 2024
Response to Comment B6: The south staging area is proposed because of its adjacency to the existing beach access trail, which would be used by construction equipment to access the project site.
The Sensitive and Critical Habitat Map (Figure 4-3) contained in the Certification Draft Local Coastal Land Use Plan (February 2020) contains the following disclaimer: “The preliminary delineation of ESHA boundaries does not include an exhaustive compilation of the habitat areas that meet the ESHA definition. Site Specific biological evaluations and field observations shall be required to identify ESHAs and other special status resources that may not have been included in the literature and database review.” The biological assessment prepared for the project site by MIG that was included in the City’s CDP application as Appendix H, (and also included as Appendix D in the Draft EIR), stated that are no mapped ESHAs within or nearby the study area (Dyett and Bhatia 2014). Given the disclaimer on the LCLUP map, the precise boundaries of the EHSA designation shown near the proposed southern staging area should not necessarily be interpreted as including the actual staging area, which consists of an approximately 7,500-square foot area extending from the edge of Esplanade Avenue to approximately 40 feet from the edge of the bluff. This area is devoid of vegetation, although the edge and face of the bluff are vegetated.
Response to Comment B7: The purpose of the Surface Conditions discussion in Chapter 4.5.1 of the Draft EIR is to provide a cursory review of the surface conditions as they currently exist on the project site. Additional research and discussion of the placement of the existing revetment is not necessary as it would not be germane to the subsequent analysis of geotechnical hazards and impacts of the project in relation to the CEQA thresholds. CEQA is focused on the project’s effects on the environment, and not the effects or impacts of existing conditions or environment on the project (See California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 Cal.4th 369.). None of the CEQA Checklist questions addressed in Chapter
4.5.4 are related to the existing revetment’s effect on the project design or potential geotechnical hazards associated with the project.
Response to Comment B8: The rates of coastal retreat cited in the EIR are consistent with the rates described in recent studies, such as the study published by Scripps Institution of Oceanography at the University of California, San Diego in 2022 (Spatial and Temporal Trends in California Coastal Cliff Retreat, Swirad & Young, Geomorphology, Volume 412, 1 September 2022), which used data of cliff erosion between 2009-2011 and 2016 at various locations along the California coast. Retreat rates in northern and central California were determined to have an average retreat rate of 0.2 to 0.7 meters (0.65 to 2.3 feet) per year. This is roughly consistent with the Draft EIR which stated that the rate between 1943-2017 was 2.7 feet per year at the project site. The need to conduct a more robust analysis of historical and future retreat rates is unclear, since the project anticipates that the unsupported portion of the bluff above the proposed seawall would continue to experience raveling and erosion/bluff retreat until ultimately reaching equilibrium at a static inclination of approximately 40 to 50 degrees, as clearly stated in the Introduction chapter of the Draft EIR (Chapter 1.1 Purpose and Scope of the EIR).
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Packet Pg. 627 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-16 May 2024
According to the project geologist, Cotton Shires & Associates (CSA), the provision of a quantitative slope stability analysis as recommended by the CCC would not be appropriate because such an analysis would not be modeling the actual bluff retreat hazard that the proposed project is designed to arrest or a hazard that has been observed at this site, as explained in the following paragraph.
The documented mechanism for the on-going bluff retreat at 310-330 Esplanade Avenue is characterized by wave action eroding the toe of the bluff, which results in near-vertical, vertical, and undermined bluff faces. The lower portion of the bluff face then calves off like a glacier, followed a while later by the mid bluff portion, and then by the upper bluff portion. Typically, these calving events are only about two to ten feet thick. This type of calving failure is not a typical landslide event, and based on CSA’s experience does not lend itself to traditional slope stability analysis due to the near-vertical failure surface the calving material mobilizes and the void at the base of the bluff caused by undermining.
Response to Comment B9: As stated under Impact HYD-3 on Page 4.7-11, the blufftop between 310 and 330 Esplanade Avenue would be recontoured to ensure that the blufftop slopes uniformly towards Esplanade Avenue to direct stormwater sheet flow towards Esplanade Avenue and away from the bluff face. Per Section 3.4.7, recontouring is anticipated to require less than 50 cubic yards of imported material. Although no significant amounts of cut and fill would be anticipated to implement the revegetation of the blufftop or create positive overland drainage flow towards Esplanade Avenue, a grading plan prepared with construction documents for the project, outside of the CEQA process, would provide more detailed information. In response to the CEQA threshold questions, the Draft EIR has concluded that impacts related to the alteration of existing drainage patterns, generation of substantial erosion or siltation on- or off-site, increases in the rate or amount of surface runoff that would result in flooding, or contribution of runoff water that would exceed the capacity of existing stormwater drainage systems, or provision of substantial additional sources of polluted runoff are less than significant.
Response to Comment B10: In the discussion under Impact REC-1 on Page 4.10-5 the Draft EIR states that the Project may restrict some adjacent beach uses during construction, as the existing access ramp to the beach from Esplanade Avenue near Manor Drive (currently closed to the public) would be used for construction vehicle and equipment access and would remain closed to the public during construction, but that the access would be improved following the project construction in conjunction with the City’s planned park and infrastructure preservation improvements for the adjacent 400 block of Esplanade Avenue. A correction to this statement has been included in the Final EIR to state that the existing access ramp would be made available to provide public access to the beach during construction (see Chapter 4, Errata).
Response to Comment B11: Comment noted. The Final EIR has been revised to include the results of a sand supply impact study for the proposed project, which concluded that the impact would be insignificant (see Response to Comment B14, and Chapter 4, Errata).
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Packet Pg. 628 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-17 May 2024
Response to Comment B12: Per Section 15126.6(c) of the CEQA Guidelines, the EIR should identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination. The reasons for rejecting the Managed Retreat Alternative discussed in the EIR include: the undermining of Esplanade Avenue being highly dependent on uncertain winter swell and rainfall conditions; significant potential for impacts to utilities and pavement (based on tension cracks observed from 5 to 15 feet from the top edge of the bluffs west of Esplanade Avenue); impacts to the stability of adjacent bluffs; and the prohibitive costs of relocation of and compensation for existing infrastructure and structures. The discussion further states that the timing for moving infrastructure such as water and wastewater lines, and planning for construction of a new pump station is lengthy, and may require acquisition of private easements, the success of which would not be guaranteed.
Further evaluation of this Alternative, including a complete cost analysis over the long term of protecting the bluff versus relocation of infrastructure is not required in order to explain the reasons underlying the City determination of infeasibility, per Section 15126.6(c). See Response to Comment B8 regarding the provision of bluff erosion analysis information.
Response to Comment B13: Comment noted.
Response to Comment B14: The EIR has been revised to modify the Principal Characteristics discussion on Page 5-14 to include impacts of the proposed project on sand supply to the beach fronting the toe of the bluff (see Chapter 4, Errata). The analysis is based on the conclusions of a memorandum prepared by Cotton, Shires & Associates, Inc. (CSA) in 2020 that calculated the volume of beach quality sand that would have been supplied to the beach if natural erosion continued.
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Packet Pg. 629 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall)
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Packet Pg. 639 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-28 May 2024
Responses to Comment Letter C from California Department of Fish and Wildlife, November 16, 2023
Response to Comment C1: Comment noted. Section 4.3.1 of the EIR (Environmental Setting) has been revised to include more detailed information regarding bank swallows and their habitat within the project area. In addition, mitigation measures as recommended have been added in Section 4.3.4 (Impacts and Mitigation Measures). (see Chapter 4, Errata) Response to Comment C2: Comment noted. As stated on Page 4.3-39 of the EIR, night lighting would be localized, temporary, and night work is not expected to occur throughout the duration of the Project, but only when necessary to address tidal conditions. Additionally, Page 4.1-9 of the Aesthetics chapter states that the City of Pacifica Design Guidelines require that exterior lighting is subdued and that large areas should use low shielded fixtures, and that tall fixtures which illuminate large areas should be avoided. It further states that any proposed construction phase lighting would be subject to compliance with the Guidelines. For these reasons, the impacts to native resident or migratory wildlife species and habitat would be less than significant.
Response to Comment C3: Comment noted. The EIR provides Mitigation Measures to address significant impacts to biological resources identified in the analysis discussions. The EIR does not identify any significant unavoidable impacts related to biological resources that would require the City to make the CEQA-mandated Findings of Overriding Considerations.
Response to Comment C4: Comment noted.
Response to Comment C5: Comment noted. The comment is not relevant to the adequacy of the Draft EIR and does not raise any significant environmental issues related to the proposed project analyzed in the Draft EIR. No response is required.
Response to Comment C6: Comment noted. Page 4.3-12 of the EIR has been revised to include the updated protection status of the American peregrine falcon and California brown pelican. (see Chapter 4, Errata).
Response to Comment C7: Comment noted. CDFW environmental document filing fees will be paid by the City of Pacifica at the time the Notice of Determination is filed at the Office of the San Mateo County Clerk-Recorder.
Response to Comment C8: Comment noted.
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Packet Pg. 640 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) STATE OF CALIFORNIA GAVIN NEWSOM, Governor
CALIFORNIA STATE LANDS COMMISSION
100 Howe Avenue, Suite 100-South
Sacramento, CA 95825-8202
Contact Phone: (916) 574-1890
November 20, 2023
File Ref: SCH # 2022100372
City of Pacifica
Attn: Stefanie Cervantes
Planning Department
540 Crespi Drive
Pacifica, CA 94044
VIA ELECTRONIC MAIL ONLY ([email protected])
Subject: Draft Environmental Impact Report for the 310-330 Esplanade Drive Infrastructure Preservation Project, San Mateo County
Dear Stefanie Cervantes:
The California State Lands Commission (Commission) staff has reviewed the subject Draft Environmental Impact Report (EIR) for the 310-330 Esplanade Drive Infrastructure Preservation Project (Project), which is being prepared by the City of Pacifica (City). The City, as the public agency proposing to carry out the Project, is the lead agency under the California Environmental Quality Act (CEQA) (Pub.
Resources Code, § 21000 et seq.). The Commission is a trustee agency for projects that could directly or indirectly affect State sovereign lands and their accompanying Public Trust resources or uses. Additionally, because the Project involves work on State sovereign land, the Commission will act as a responsible agency.
Commission Jurisdiction and Public Trust Lands
The Commission has jurisdiction and management authority over all ungranted tidelands, submerged lands, and the beds of navigable lakes and waterways. The Commission also has certain residual and review authority for tidelands and submerged lands legislatively granted in trust to local jurisdictions (Pub. Resources Code, §§ 6009, subd. (c); 6009.1; 6301; 6306). All tidelands and submerged lands, granted or ungranted, as well as navigable lakes and waterways, are subject to the protections of the common law Public Trust Doctrine.
JENNIFER LUCCHESI, Executive Officer
(916) 574-1800
TTY CA Relay Service: 711 or Phone 800.735.2922
from Voice Phone 800.735.2929
or for Spanish 800.855.3000
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Packet Pg. 641 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Stefanie Cervantes Page 2 November 20, 2023
As general background, the State of California acquired sovereign ownership of all tidelands and submerged lands and beds of navigable lakes and waterways upon its admission to the United States in 1850. The State holds these lands for the benefit of all people of the state for statewide Public Trust purposes, which include but are not limited to waterborne commerce, navigation, fisheries, water-related recreation, habitat preservation, and open space. On tidal waterways, the State's sovereign fee ownership extends landward to the mean high tide line, except for areas of fill or artificial accretion or where the boundary has been fixed by agreement or a court.
According to the Draft EIR, bluff stabilization includes a seawall and related structures that could encroach on lands managed by the State of California and therefore would require a lease. Figure 3-3 depicts the proposed Project elements and includes two lines identified as a High Tide Line (HTL, dashed blue line) and a High Water Mark (HWM, dashed magenta line). Both lines are noted as having been surveyed in either 2019 or 2020. However, on the open coast the boundary between state-owned land and private upland property is the ordinary high-water mark as delineated by the mean high tide line (MHTL). On the figure it is unclear which line, if any, depicts the MHTL. Regardless, from this figure it appears that both portions of riprap to be removed and the identified temporary access area (brown shaded area) are located within Commission jurisdiction and would therefore require Commission authorization. Please include a plat with the lease application that shows the Project elements overlaid with a recent MHTL survey. Please ensure the MHTL is clearly labeled as such, and that the survey was conducted within 6 to12 months of application submittal. For additional questions please contact Kenneth Foster (contact information is provided at the end of this letter).
Project Description
The City proposes to construct several structural elements to fortify the toe of the bluff, including a sheetpile wall that would extend below the beach to an approximate elevation of 10 feet below sea level. A cap beam would be placed on top of the sheetpile wall and a shotcrete (sprayed concrete) wall would be secured to the bluff face with tensioned tieback rods/tendons drilled into the bluff face.
The wall is estimated to be 650 feet long and would extend the seawall from the base of the bluff to an elevation of 40 feet (approximately 26 feet above the summer sand level). The wall would have tiebacks that go into the bluff to support the weight of the wall and protect the toe of the bluff from erosion. The work would also include removing loose debris from the toe of the bluff and the existing rip rap on the beach. The wall would extend approximately 20 feet below the beach to protect against undermining scour from winter storms. According to the City, the Project would protect and maintain existing infrastructure along Esplanade Avenue.
D1
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Packet Pg. 642 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Stefanie Cervantes Page 3 November 20, 2023
From the Project Description, Commission staff understands that construction below the MHTL, including portions of the sheetpile wall, riprap removal, and construction access would likely fall within the jurisdiction of the Commission.
Environmental Review
Commission staff requests that the City consider the following comments on the Draft EIR to ensure that impacts to State sovereign land are adequately analyzed for the Commission’s use of the EIR to support a future lease approval for the Project.
General Comments
1. Responsible Agencies: The Draft EIR Executive Summary states, “The City of Pacifica (City) is the CEQA Lead Agency for the Project. The Coastal Commission, U.S. Army Corps of Engineers (USACE), and Regional Water Quality Control Board (RWQCB) are responsible agencies with permitting authority for the project.” Although the Commission was added to the trustee agency list on page 3-19, the Executive Summary should also identify the Commission as a CEQA Responsible Agency.
Cultural and Tribal Resources
2. Tribal Engagement and Consideration of Tribal Cultural Resources: In the Commission’s comment letter on the Notice of Preparation, dated November 18, 2022, Commission staff provide guidance tor tribal consultation consistent with the Commission’s Tribal Policy.
Although the Draft EIR does disclose that outreach to interested Tribes has occurred, it does not identify the contacted tribes or provide content related to tribal communications. The Draft EIR’s statement that “No specific information was provided by the tribal contacts regarding the location and nature of tribal resources in the area in response to the letters, therefore, there is no confirmed potential for impacting known tribal cultural resources,” is not sufficient, as any responses or requests from the tribes during the outreach process should be part of the public record unless requested to be confidential. Commission staff recommends that the City include this information in the Final EIR to maintain a clear record of the City’s efforts to comply with AB 52.
Recreation
3. Public Beach Access: Chapter 4.10, Public Services and Recreation, should thoroughly analyze impacts to public access and recreation during and after construction of the proposed improvements, both on the bluff and on the beach, to ensure safe and continued public access to the beach. Despite the potential for danger due to construction equipment use on the beach, no D2
D3
D4
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Packet Pg. 643 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Stefanie Cervantes Page 4 November 20, 2023
mitigation measures are proposed or BMPs discussed to protect the public on the beach during the 6-month construction period. Commission staff request the Final EIR include and evaluate this potential impact and recommend mitigation that includes fencing off areas during beach construction as well as installing signage warning the public of potential Project-related dangers on the bluff or the beach.
Thank you for the opportunity to comment on the Draft EIR for the Project. As a responsible and trustee agency, the Commission will rely on the Final EIR for issuing a new lease as specified above (see Section “Commission Jurisdiction and Public Trust Lands”). Staff requests that you consider these comments before certifying the Final EIR.
Please send electronic copies of the Final EIR, Mitigation Monitoring Program, Notice of Determination, approving resolution, CEQA Findings, and, if applicable, Statement of Overriding Considerations when they become available. Please note that federal and state laws require all government entities to improve accessibility of information technology and content by complying with established accessibility requirements. (29 U.S.C. § 794d; 36 C.F.R. § 1194.1 et seq.; Gov. Code, § 7405.) California State law prohibits State agencies from publishing on their websites content that does not comply with accessibility requirements. (Gov. Code, § 115467.) Therefore, any documents submitted to Commission staff during the processing of a lease or permit, including all CEQA documentation, must meet accessibility requirements for Commission staff to place the application on the Commission agenda.
Please refer questions concerning environmental review to Cynthia Herzog, Senior Environmental Scientist, at (916) 574-1310 or [email protected]. For questions concerning Commission leasing jurisdiction, please contact Kenneth Foster, Public Lands Manager, at (916) 574-2555 or [email protected].
Sincerely,
Nicole Dobroski, Chief
Division of Environmental Science, Planning,
and Management
cc: Office of Planning and Research
C. Herzog, Commission
K. Foster, Commission
A. Kershen, Commission
D5
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Packet Pg. 644 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-33 May 2024
Responses to Comment Letter D from California State Lands Commission, November 20, 2023
Response to Comment D1: Comment noted. The lease application to the California State Lands Commission will include the Project elements with a recent (within 6-12 months of the application submittal) mean high tide line (MHTL) that is clearly labeled.
Response to Comment D2: Comment noted. California State Lands Commission has been added to the list of responsible agencies in Chapter 2.1. Please see Chapter 4, Errata.
Response to Comment D3: Comment noted. Tribal outreach occurred on April 25, 2019 via certified letters to the following tribes:
• Amah Mutsun Tribal Band of Mission San Juan Bautista – Irene Zwierlein, Chaiperson • Costanoan Rumsen Carmel Tribe - Tony Cerda, Chairperson • Indian Canyon Mutsun Band of Costanoan - Ann Marie Sayers, Chairperson • Muwekma Ohlone Indian Tribe of the SF Bay Area – Charlene Nijmeh, Chairperson • The Ohlone Indian Tribe – Andrew Galvan
The letters included the objectives of the project, proposed design elements, anticipated construction duration, noted the negative Sacred Lands File search and California Historical Resources Information System results, and requested information on Tribal Cultural Resources not included in the SLF search or if they had additional information on archaeological resources in the project vicinity.
One certified letter to Ann Marie Sayers was returned to sender, therefore a follow up email was sent on August 2, 2019. No responses were received from any Tribe as a result of this outreach.
The Tribes are on the City’s mailing list for announcements regarding this Project. This information has been included in the Final EIR. Please see Chapter 4, Errata.
Response to Comment D4: Comment noted. For safety reasons, the beach is anticipated to be inaccessible to the public between the 400 block of Esplanade Avenue and 310 Esplanade Avenue during the construction period. However, this impact would be short-term and adjacent areas of the beach would remain open to the public during construction.
The proposed Project is not expected to impact public access or recreational beach use in the long term. There is no existing public access to the beach directly from 310-330 Esplanade Avenue, and nearby public access points would not be impacted by the project. Beaches are generally narrow in the project area and thus provide limited public access, especially at high tides, when the water level sometimes reaches all the way to the toe of the bluff. The proposed project would improve safe beach access by controlling bluff failures.
Although the impacts to beach access would be temporary, limited to the duration of the construction period, the active construction areas on the beach and blufftop would present a danger to beach users during the construction period. The installation of construction fencing and signage
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Packet Pg. 645 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-34 May 2024
at these active construction areas, in conformance with the City’s standard procedures, would reduce the potential impacts to a less than significant level. The discussion under Impact PUB-1 in Section 4.10.4 has been expanded to include analysis of this issue. Please see Chapter 4, Errata.
Response to Comment D5: Comment noted. The City will provide the Final EIR, Mitigation Monitoring and Reporting Program, Notice of Determination approving resolution, CEQA findings, and if applicable, Statement of Overriding Considerations to the State Lands Commission when they become available. The City acknowledges the referenced accessibility requirements and will ensure that any documents provided to the State Lands Commission during the process of the lease or permit, including all CEQA documentation, shall meet the accessibility requirements of State Lands Commission Staff to place the application on the State Lands Commission agenda.
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Packet Pg. 646 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) 2340 Palma Drive, Suite 200 | Ventura, California 93003 | 805.485.3935 12277 Soaring Way, Suite 100, Truckee, California 96161 | (916) 260-0707 3054 Fite Circle, Suite 108, Rancho Cordova, California | (916) 260-0707 www.rjreng.com
Civil Engineering
Land Planning
Hydrology / Flood Control
Capital Improvements
Public Works Services
Stormwater Management
November 18, 2023
CITY OF PACIFICA
Planning Department
540 Crespi Drive
Pacifica, California 94004
Attention: Stefanie Cervantes, Senior Planner {[email protected]} Subject: DRAFT ENVIRONMENTAL IMPACT REPORT PRESERVATION PROJECT SCH #2022100372
Location: 310-330 ESPLANADE AVENUE
CITY OF PACIFICA, CALIFORNIA
Dear Ms. Cervantes:
RJR Engineering & Consulting, Inc. (RJR) has prepared this letter at the request of Mr. and Mrs.
Dennis Thomas, owners of 340 Esplanade Way in the City of Pacifica, California (“340”). RJR has been asked to review the Draft Environmental Impact Report (DEIR) with respect to 340 and the proposed repair scheme presented in the DEIR.
Photograph 1: GoogleEarth Image of Subject Bluff Area and Surrounding Areas 340 Esplanade
Avenue
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Packet Pg. 647 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Review of Draft EIR (SCH #2022100372)
Thomas / Esplanade Avenue, Pacifica, California
RJR Engineering & Consulting, Inc.
Page | 2
RJR has been working in this area of Pacifica, California since the late 1990’s with specific work on this bluff since 2008 to the present. We understand the City is proceeding with a seawall design that will connect to the existing sea wall north (Oceanaire)1 and south to the sea wall at 360 Esplanade Avenue (AImco). In principle, in the opinion of RJR this is a prudent approach to retard bluff retreat. However, RJR has the following comments.
RJR Comment 1 - BLUFF RETREAT: Historically bluff retreat in the area has been on the order of 2 feet annually (average). RJR’s analysis and data presented in the Cotton Shires report rendered values of 4 to 10 feet, depending on the time interval.
It is worth noting that the northern Pacifica coastline has been undergoing progressive sea cliff retreat. According to Lajoie and Mathieson (1998)2, the long-term erosion rate is approximately 2 feet per year. Bluff erosion rates are dependent on seasonal weather and tide changes and can vary depending on seasonal conditions. For instance, in 1983, 1986, 1995 and early 1998, increased rates of bluff erosion were a direct result of severe winter waves, high tides, and El Nino ocean water thermal expansion effects, coupled with a diminishing natural resupply of sand to the shoreline.
Suggestion 1: RJR suggests that the DEIR explain that the recent time period may reflect changes in coastal processes resulting the higher erosion rates. However, with the passage of time, the rates may normalize to lower rates more consistent with the historic rates.
RJR Comment 2 – ANALYSIS OF THE IMPACT OF SEAWALLS ON COASTAL SHORELINES: Seawalls are hard engineered structures with a primary function to prevent further erosion of the shoreline. They are built parallel to the shore and aim to hold or prevent sliding of the soil, while providing protection from wave action (UNFCCC, 1999)3. Although their primary function is erosion reduction, they have a secondary function as coastal flood defenses. Seawalls are subjected to significant loadings, as a result of wave impact. These loadings increase with water depth in front of the structure because this enables larger waves close to the shoreline. Seawalls are designed to dissipate or reflect incoming wave energy and as such, must be designed to remain stable under extreme wave loadings. The effects of sea level rise (“SLR”), increased wave heights and increased storminess caused by climate change should be considered in the analysis.
Smooth, vertical seawalls are the least effective at dissipating wave energy; instead, the structures reflect wave energy seawards. Reflection creates turbulence, capable of suspending 1 RJR was the Engineer of Record for the design and construction of this seawall and repair of wall defects. 2 Lajoie, K. R., and Mathieson, S. A. (1998). "1982-83 El Niño Coastal Erosion, San Mateo County, California." Open File Report 98-41, U.S. Geological Survey, Menlo Park, California. 3 UNFCCC (United Nations Framework Convention on Climate Change) (1999) Coastal Adaptation Technologies.
Bonn: UNFCCC. Access November 9, 2023.
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Packet Pg. 648 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Review of Draft EIR (SCH #2022100372)
Thomas / Esplanade Avenue, Pacifica, California
RJR Engineering & Consulting, Inc.
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sediments (Bush et al., 2004)4, thus making them more susceptible to erosion. In a worst-case scenario, reflected energy can interact with incoming waves to set up a standing wave which causes intense scouring of the shoreline (French, 2001)5.
Scour at the foot of a seawall is a particular problem with vertical seawall designs. Incoming waves impact the structure, causing water to shoot upwards. When the water falls back down, the force on the seabed causes a scour hole to develop in front of the structure. This can cause structural instability and is an important factor leading to the failure of many seawalls. A similar process occurs on inclined seawalls but in this case, scour will occur away from the foot of the structure.
Sediment availability is also affected by seawall construction6,7. The problem is caused by replacing soft, erodible shorelines with hard, non-erodible ones. While this protects the bluff, it causes problems in terms of sediment starvation; erosion in front of the seawall will continue at historic or faster rates but the sediment is not replaced through erosion (French, 2001)8. This can cause beach lowering, which reduces beach amenity value and increases wave loadings on the seawall by allowing larger waves close to the shore.
In the absence of a seawall, natural shoreline erosion would supply adjacent stretches of coastline with sediment, through longshore drift. Once a seawall is constructed however, the shoreline is protected from erosion and the supply of sediment is reduced9. This causes sediment starvation at sites located alongshore, in the direction of longshore drift and this has the capacity to induce erosion at these sites.
Suggestion 2: RJR suggests that the DEIR analyze and discuss the impacts of the seawall as related to wave refraction scour and shoreline degradation related to sediment distortion along this section of shoreline, given the current project and recent construction of the northern and southern sea walls.
4 Bush, D.M., Neal, W.J., Longo, N.J., Lindeman, K.C., Pilkey, D.F., Esteves, L.S., Congleton, J.D. and Pilkey, O.H (2004) Living with Florida’s Atlantic Beaches: Coastal Hazards from Amelia Island to Key West. USA: Duke University Press.
5 French, P.W. (2001) Coastal defences: Processes, Problems and Solutions. London: Routledge. 6 Griggs GB, Tait JF (1988) The effects of coastal protection structures on beaches along northern Monterey Bay, California; The effects of seawalls on the beach. Journal of Coastal Research 4(4): 93–111. 7 Pilkey OH, Wright HL III (1988) Seawalls versus beaches. Journal of Coastal Research (special issue) SI(4): 41–
64. 8 Ibid
9 Hegde AV (2010) Coastal erosion and mitigation methods—global state of art. Indian Journal of Geo-Marine Sciences 39(4): 521–530.
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Packet Pg. 649 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Review of Draft EIR (SCH #2022100372)
Thomas / Esplanade Avenue, Pacifica, California
RJR Engineering & Consulting, Inc.
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RJR Comment 3 – SEAWALL HEIGHT: Based on U.S. Army Corp of Engineers Coastal Engineering Manual10, the design criteria for a coastal structure are based upon several oceanographic and geologic site conditions. This includes, but not limited to, nearshore bathymetry, water level, wave height, maximum scour depth, beach slope, wave period, and soil properties. Based on the near slope shelf a slope should be established for any wave uprush analysis, still water elevations, design wave, and wave period the super-elevation of the sea surface and the following factors included in the water surface elevation:
Parameter Typ. Values
Wave set-up: 1.0 to 2.5 feet
Wind set-up and inverse barometer: 0.5 to 1.5 feet
Wave group effects: 1.0 to 2.5 feet
El Niño thermal expansion effects: 0.5 to 1.0 feet
Global warming / Sea level rise: TBD11
Scour TBD
Freeboard: 1.0 to 3.0 feet
As waves break on or near the beach, the water rushes up the beach and encounter the bluff and/or proposed structure. Wave runup is defined as the vertical height above the still water level to which a wave will rise on a structure or beach of infinite height.
Overtopping is the flow rate of water over the top of a finite height structure as a result of wave runup. In general, high waves in combination with high water levels locally result in erosion of beaches and the base of the coastal bluffs. However, the design wave condition for a shoreline structure is generally not the largest wave, because the largest waves break offshore in water depths approximately equal to the wave’s height. The largest “design wave force” will occur when a wave breaks at or directly on the shoreline structure. The largest wave that can break at/on the structure is determined by the depth of the water at the toe of the respective structure. 10 U.S. Army Engineer Waterways Experiment Station, 1996, “Shore Protection and Beach Erosion Control Study”; Institute for Water Resources, Alexandria, VA, 226p.
11 California Coastal Commission Sea Level Rise Policy Guidance, Final Adopted Science Update | November 7, 2018
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Packet Pg. 650 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Review of Draft EIR (SCH #2022100372)
Thomas / Esplanade Avenue, Pacifica, California
RJR Engineering & Consulting, Inc.
Page | 5
The DEIR presents a wall elevation of +26 feet12. Given studies on adjacent projects, the design water depth was on the order of +28 to +35 feet13, which included the previous Coastal Commission sea level rise values and estimated scour depths14.
Based on the prior discussions, based on the sea level degradation from the long-term sea wall, the scour analysis should incorporate the future conditions, not scour estimates based on unarmored shorelines.
Wave uprush events since the construction of the 100 Esplanade Avenue Sea Wall (top of sea level wall is between Elevation +32 to +35) which has been overtopped by two separate three storm events since 2011.
Suggestion 3: RJR suggests that the DEIR analyze and discuss the method, assumptions, and values utilized to determine the top elevation of the proposed sea wall. The impacts of wall overtopping should be evaluated.
RJR Comment 4 – REPAIR SEAWALL PROTECTION AND DEPTH TO BEDROCK: The DEIR suggests that the site is underlain by bedrock, which would lead parties to believe that toe protection would be readily available to protect the wall from being undermined. While observations at Mussel Rock indicates exposed Greenstone, drill holes along the beach to depths of 30 to 40 feet BEG (below existing grade, estimated to be Elevation +12 NAVD) in 2010 by Engineered Soils Repair for the 310 to 330 Esplanade Avenue did not encounter bedrock. No bedrock was encountered at depths of Elevation -15 NAVD during construction activities along the frontage of 100 Esplanade Avenue15.
Suggestion 4: RJR suggests that the DEIR analyze and discuss how the sea wall will be protected if no bedrock is encountered within a practical depth.
RJR Comment 5 – IMPACT OF SEA WALL ON 340 PROPERTY: The current bluff, as illustrated on Photograph 1 (Page 1), extends to within 25 to 30 feet of the corner of the apartment building on 340. Any alterations, modifications, or changes to the bluff can and will impact 340.
Suggestion 5: RJR suggests that the DEIR analyze and discuss the baseline and overall impact of the project on 340, especially when considering the various elements presented in this letter. 12 RJR is assuming that the values presented are North American Vertical Datum of 1988 (NAVD 88). RJR provides all elevations in this discussion based on the 88 NAVD datum. 13 Variable elevation is based on 50-, 75-, or 100-year studies. 14 Scour depths varied for 50-, 75-, or 100-year evaluations. 15 Moderate to weakly cemented sand layers were encountered at various locations within these depths.
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Packet Pg. 651 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Review of Draft EIR (SCH #2022100372)
Thomas / Esplanade Avenue, Pacifica, California
RJR Engineering & Consulting, Inc.
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Please feel free to contact the undersigned at 805-766-3950 (cell) or by email at [email protected] .
Sincerely,
RJR ENGINEERING & CONSULTING, INC.
_____________________________________________
Robert W. Anderson, R.C.E., Juris Doctorate (JD)
Principal Civil Engineer - RCE 58383 (CA)
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Distribution: Mr. & Mrs. Thomas {via Email}
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Packet Pg. 652 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-41 May 2024
Responses to Comments Letter E from RJR Engineering and Consulting, Inc., November 18, 2023
Response to Comment E1: Comment noted. Errata have been added to acknowledge the possibility that bluff erosion rates could, over time, normalize to lower rates more consistent with historic rates.
Response to Comment E2: Potential impacts of the proposed sea wall on sand supply was evaluated in the geotechnical report prepared for the project by Cotton, Shires & Associates, Inc. (CSA 2020), and summarized in Chapter 2 and presented in full in Appendix B of the Final EIR.
The volume of beach material that would have been supplied to the beach if natural erosion continued (i.e., the long-term reduction in supply of beach quality bluff material to the beach as a result of the proposed armoring) was calculated at 2,145 yards of beach quality sand. Comparisons of bluff materials and beach sand materials revealed that the bluff materials are significantly finer than the beach sand material. Therefore, it was concluded that the bluff materials compose zero to a very small fraction of the beach sand.
The geotechnical investigation noted that wave scour is a typical hazard that could impact seawalls.
Therefore, the report recommended the seawall be designed to extend the wall below elevation 2 feet. In addition, the wall was recommended to be designed to resist end-around scour by terminating the ends of the wall into well-designed and constructed existing structures, several feet into the bluff or behind superstructures. The proposed project design follows these recommendations.
Response to Comment E3: The height of the proposed seawall (40 feet NAVD88) was determined from CSA’s assessment of the risk of wave overtopping, which could adversely impact the integrity of the wall and the stability of the unsupported bluff above the wall. The assessment was based on their review of the performance of existing seawalls in Pacifica, including the existing seawall immediately to the north of the project site, as described in the geotechnical report which they prepared for the project. The report is contained in Appendix B of the Draft EIR.
Response to Comment E4: The Draft EIR states that the project is underlain by bedrock at depth, but continues on to clarify that no bedrock is exposed at the project site and that it is exposed in the foothills located approximately 2,200 feet away. The geologic report contained in Appendix B of the Draft EIR describes that borings taken at the site did not encounter any bedrock. Protection of the seawall is analyzed throughout the geotechnical report.
Response to Comment E5: Because the property at 340 Esplanade Avenue is located on the blufftop area behind (to the east of) the proposed seawall, it would also be protected by the seawall.
Therefore, the analyses of potential project impacts related to the bluff, as well as beneficial impacts of the proposed seawall contained in the Draft EIR would apply to 340 Esplanade Avenue.
Chapter 3.4 of the Draft EIR describes the proposed bluff restoration plan and bluff monitoring program that would be implemented with the project to stabilize the bluff following construction of the proposed seawall and evaluate the condition and performance of the seawall on an annual
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Packet Pg. 653 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-42 May 2024
basis. As stated in Section 3.4.4, the monitoring information would be summarized in a report prepared by a licensed engineer familiar with shoreline processes and would be submitted to the California Coastal Commission Executive Director after each winter storm season for the first three years, followed by inspections and reports submitted following either an El Nino storm event or significant earthquake.
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Packet Pg. 654 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) 1 Cervantes, Stefanie
From: David Whitney <[email protected]>
Sent: Monday, October 23, 2023 9:45 PM
To: Cervantes, Stefanie
Subject: 310-330 Esplanade Avenue Infrastructure Preservation Project EIR Draft [CAUTION: External Email]
Stephanie Cervantes
Senior Planner
Significant environmental impact at Manor Ave construction equipment worksite: Any potential coastal trail seaward from the existing curb on Esplanade Ave to suitable beachfront recreation must provide bluff-top amenities.
David Whitney
115 Eastridge Circle
Pacifica, Ca 94044
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 attachments or reply.
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Packet Pg. 655 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 3 Responses to Public Draft EIR Comments
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 3-44 May 2024
Responses to Comments from David Whitney, October 23, 2023 Response to Comment F1: Comment noted. This comment references the potential impacts of a trail that is not proposed as part of this Infrastructure Preservation Project. Therefore, the comment is not relevant to the adequacy of the Draft EIR and does not raise any significant environmental issuesrelated to the proposed project analyzed in the Draft EIR. No further response is required. Inclusion of these comments in this Final EIR will make the commentor's views available to the City of Pacifica Planning Commission, the Pacifica City Council, and other public officials who will make decisions about the proposed Project.
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Packet Pg. 656 Attachment: Attachment C - Final Environmental Impact Report (Includes MMRP) (5680 : FEIR - 310-330 Esplanade Seawall) Chapter 4 Errata and Revisions
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Final EIR 4-1 May 2024
4 ERRATA AND REVISIONS
This chapter includes the changes to the Draft EIR needed to respond to comments and clarify or amplify the information provided in the Draft EIR. The changes correct inaccuracies and clarify the analysis in the Draft EIR. Text removed from the Draft EIR is marked with strike-out. New text is indicated by underline.