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.
Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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, Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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.
Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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.
Chapter 5 Alternatives to the Proposed Project
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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.
Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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 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 Chapter 5 Alternatives to the Proposed Project
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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.
Chapter 5 Alternatives to the Proposed Project
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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.
Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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 gas- Chapter 5 Alternatives to the Proposed Project
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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.
Chapter 5 Alternatives to 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, Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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, Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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 Chapter 5 Alternatives to the Proposed Project
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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.
Chapter 5 Alternatives to the Proposed Project
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Chapter 6 CEQA Mandated Sections
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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)
Chapter 7 List of Preparers
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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 Chapter 7 List of Preparers
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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 Chapter 7 List of Preparers
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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 Chapter 6 CEQA Mandated Sections
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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 Chapter 6 CEQA Mandated Sections
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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), Chapter 6 CEQA Mandated Sections
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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 Chapter 6 CEQA Mandated Sections
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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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310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 6-16 September 2023
• 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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310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 6-17 September 2023
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 Chapter 7 List of Preparers
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 6-18 September 2023
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 Chapter 6 CEQA Mandated Sections
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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.
Chapter 7 List of Preparers
310-330 Esplanade Infrastructure Preservation Project City of Pacifica Draft EIR 6-20 September 2023
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/ Chapter 6 CEQA Mandated Sections
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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 Chapter 6 CEQA Mandated Sections
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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.
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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