CITY OF PACIFICA
COUNCIL AGENDA SUMMARY REPORT
6/26/2024
1 SUBJECT:
Consideration of a Resolution of the City Council of the City of Pacifica Certifying that the Revised Certification Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications is Intended to be carried out in a manner fully in conformity with the California Coastal Act; adopting the Revised Certification Draft LCLUP with Alternative Modifications; directing the City Manager to transmit the Revised Certification Draft LCLUP with Alternative Modifications to the California Coastal Commission for certification; and finding that approval of the Revised Certification Draft LCLUP with Alternative Modifications is exempt from the California Environmental Quality Act (CEQA).
RECOMMENDED ACTION:
Approve the Resolution of the City Council of the City of Pacifica Certifying that the Revised Certification Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications is Intended To Be Carried Out In A Manner Fully In Conformity With The California Coastal Act; Adopting the Revised Certification Draft LCLUP with Alternative Modifications; Directing the City Manager to Transmit the Revised Certification Draft LCLUP with Alternative Modifications to the California Coastal Commission For Certification; and Finding that Approval of the Revised Certification Draft LCLUP With Alternative Modifications Is Exempt From The California Environmental Quality Act (CEQA).
STAFF CONTACT:
Stefanie Cervantes, AICP, Interim Deputy Director
(650) 738-7341
[email protected]
EXECUTIVE SUMMARY:
The City has been updating its Local Coastal Land Use Plan (LCLUP) since 2009. In February 2020 the City Council approved and submitted its Certification Draft LCLUP to the California Coastal Commission (CCC) for certification. In March of 2023, the CCC submitted modifications to the City’s Certification Draft LCLUP. Most recently in 2023 and 2024, the City has undertaken a community engagement strategy to inform the community and City Council about the LCLUP Update process and steps that could be considered to respond to California Coastal Commission (CCC) staff suggested modifications. Completion of the LCLUP Update would advance Goal 4, Strategy C of the City Council’s 2023 to 2030 Strategic Plan: Update Pacifica’s Local Coastal Plan and improve communications and collaboration with the California Coastal Commission.
On May 23, 2024, the City Council held a Special Meeting to complete a detailed discussion of alternative modifications that City staff has proposed in response to the CCC staff’s suggested modifications released in March 2023. During the April and May special meetings, City Council was able to discuss the alternative modifications in all chapters and the glossary. However, at the time staff was not fully prepared to discuss the Special Resiliency Area (SRA) policies due to additional comments and suggested modifications received from the CCC. We have now received all final comments from the CCC and the June 26th meeting is intended to conclude the detailed review of the alternative modifications, specifically the SRA policies, and determine Pacifica City Council 2
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whether City Council intends to submit the City-staff recommended alternative modifications to the CCC.
Note that Attachment F Redline LCP will be appended to the Agenda Packet with its June 21st release.
INTRODUCTION:
Pacifica Needs an Updated LCLUP
The California Coastal Act requires every city along the coast to prepare a Local Coastal Program (LCP), which consists of two parts: a Local Coastal Land Use Plan (LCLUP) and an Implementation Plan (IP). The LCLUP must be consistent with the Coastal Act. The LCLUP must specify the intended uses of land within the Coastal Zone, and serves as a policy framework for future actions, such as development review and City infrastructure projects. The LCLUP must balance statewide interests for the Coastal Zone as expressed in the Coastal Act with local land use priorities. The LCLUP also guides the contents of the IP, which consists of the zoning ordinance, zoning map, and other policies and programs to implement the LCLUP.
The City’s LCLUP currently in effect was last comprehensively updated in 1980 (“1980 LCLUP”). While the LCLUP is separate from the General Plan, much of the descriptive text and policies overlap between both documents due to their similar purposes of specifying land uses, establishing goals and policies, and providing a policy framework for future actions.
There are many benefits to having an updated LCLUP. These include, but are not limited to, accurate maps, modernized policies to guide development, enhanced environmental protections, strengthened economic development and housing policies, and consistency with the City’s 2040 General Plan. Achieving consistency with the City’s General Plan, which the City Council comprehensively updated in July 2022, will become increasingly challenging over time if a corresponding LCLUP Update is not completed. Also, whenever a conflict between the 2040 General Plan and the 1980 LCLUP occurs, the 1980 LCLUP’s policies will prevail.
Staff’s assessment is that the 1980 LCLUP is not adequate to continue guiding the City’s actions in the Coastal Zone on a long-term basis. Many objectives of the 1980 LCLUP have been accomplished, such as protection of key beach and open space areas and formalization of public coastal access in many locations, while its assessments of some coastal neighborhoods are no longer reflective of the challenges and needs of those areas. Moreover, the 1980 LCLUP does not do enough to help Pacifica plan for the future. The plan is over 40 years old, and importantly, the 1980 LCLUP does not effectively identify climate change and sea level rise (SLR) as major issues that need to be addressed.
The City Council has recognized since at least 2009 that an update was needed, and started the process at that time. Yet, despite 15 years with various starts and stops in the process, the update is not yet completed. As more time passes, the need for an update continues to grow, and the problems the LCLUP seeks to address will only become more complex. The City Council has demonstrated the capacity to tackle difficult challenges in recent years, and has used lessons learned during community planning processes to inform subsequent planning and implementation activities, as exhibited in the following:
• The General Plan Update, which identified a community desire for in-fill, mixed-use development, preservation of open spaces, enhancement of parks and other community facilities, and improved planning to address hazard mitigation and evacuation from wildfires and other events, among other priorities.
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• The Sharp Park Specific Plan (SPSP), which creates a plan for the historic Sharp Park neighborhood to enhance it as a regional destination and active neighborhood center. • The Housing Element Update, which demonstrated the need to plan for more than 2,000 housing units, while undertaking other supporting actions to accelerate housing approvals and provide services for the neediest members of our community. • The Economic Opportunities Study, which identified ways for the City to strengthen its fiscal position so it can continue to provide high-quality services, infrastructure, and facilities to meet community needs.
The priorities identified in the above-referenced planning documents cannot meaningfully move forward in the Coastal Zone while limited by the 1980 LCLUP. An updated LCLUP is needed to address these emerging community priorities while also addressing issues that are all the more pressing in the Coastal Zone such as climate change and SLR adaptation. While significant City staff resources continue to be absorbed by the LCLUP Update process, work on those other community priorities cannot proceed effectively. Housing Element implementation, pursuing economic development initiatives, planning for City infrastructure and facilities, etc., can all advance much more efficiently once an updated LCLUP is in place. Completion of the LCLUP Update is also needed before staff can focus on pursuing CCC certification of the Sharp Park Specific Plan (SPSP), which combined with redevelopment of 2212 Beach Boulevard (a major economic opportunity site for the City) will provide a major boost to the Palmetto Avenue commercial corridor and enhance the City as a visitor destination. Implementation SPSP is on hold until the LCLUP and, subsequently, SPSP are certified by the CCC.
Lastly, an update to Pacifica’s LCLUP to account for SLR is inevitable. State law, as enacted in late 2023 with Senate Bill (SB) 272, now requires LCLUPs throughout California to be updated to include a plan to address SLR.
Based on this information, staff’s assessment is that completion of the LCLUP Update as expeditiously as possible and consistent with the 2040 General Plan is in the City’s best interest.
DISCUSSION:
1. Community Engagement
Community engagement has been a significant component of the LCLUP Update process, particularly the latest phase occurring in 2023 and 2024. The City Council has expanded the community engagement plan it initially approved with three meetings into a four-meeting plan, with potential for a fifth meeting. This May 23 meeting is the third iteration of “Meeting #4,” effectively resulting in a six-meeting community engagement plan, and continues the discussion of alternative modifications proposed by City staff that started on April 15. Additional information on the City’s work to update the LCLUP and the community engagement plan is available in the City Council agenda reports for the City Council meetings on October 9, 2023 (Agenda Item No. 10), November 13, 2023 (Agenda Item No. 1), December 5, 2023 (Agenda Item No. 1), March 2, 2024 (Agenda Item No. 1), April 15, 2024 (Agenda Item No. 1), April 22, 2024 (Agenda Item No. 6), and May 23, 2024 (Agenda Item No. 1). The March 2, 2024 report includes detailed case studies that describe specific scenarios that could result from application of different potential LCLUP policies in the Coastal Zone and responses to almost 150 questions submitted by the public. Additionally, the May 23, 2024 report includes responses to over 100 questions received by the public and City Council.
This community engagement process is intended to conclude the comprehensive LCLUP update process that started nearly 15 years ago. It involves concluding the LCLUP update Pacifica City Council 4
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process based on the structure and policy emphasis approved by the City Council in the 2020 LCLUP, with consideration of alternative modifications to certain policies as an alternative to the CCC staff’s suggested modifications from March 2023 (i.e., the “alternative modifications”). This process is not a reconsideration of policy emphasis or direction that was approved in the 2020 LCLUP (and continued in the Revised LCLUP) and instead is focused on specific changes to LCP policies that will ensure CCC certification.
The purpose of the LCLUP Update process and community engagement process is to bring the Council and community to a point of understanding the Revised Certification Draft LCLUP with Alternative Modifications so an informed decision can be made on whether to approve the Revised Certification Draft LCLUP with Alternative Modifications. This is a necessary step to conclude the comprehensive LCLUP update process that was started in 2009 and most recently included incorporation of conforming General Plan amendments in October 2023. Consideration of a resolution to propose alternative modifications that may be acceptable to the CCC is the best and most expedient way for the City to seek CCC certification of the LCLUP in a form that is acceptable to the CCC and the City Council.
The need for transmittal of alternative modifications by resolution arose during a City-CCC staff coordination meeting after LCLUP Meeting #3 on March 2, 2024. At the coordination meeting, CCC staff relayed that further internal discussions at the CCC concluded that transmittal by resolution was required pursuant to Public Resources Code section 30510 which states, in part, that “a proposed local coastal program may be submitted to the [CCC]” only if it is submitted “pursuant to a resolution adopted by the local government...” Staff has prepared the draft resolution included as Attachment A which will serve as the mechanism for transmittal of the alternative modifications to the CCC once they are finalized by the City Council. Adoption of the resolution would be considered at a subsequent City Council meeting.
2. Follow-up Items from April and May Meetings
Staff noted several points in City Council’s discussion at the April and May meetings that required follow-up. Items that were identified in the April meetings were discussed in the May 23 report. At the May 23 meeting, there were some additional points identified, which are discussed below. Additionally, all City Council discussed changes to the alternative modifications have been incorporated into the Summary Table (Attachment B). The redline changes on the Summary Table indicate direction provided by the City Council in the April and May meetings, as well as additional alternative modifications needed after discussions with CCC staff.
Follow-up items from the May 23 meeting are described below with staff’s recommended approach to respond to City Council.
A. Policy CR-I-25 (previously CR-I-49) Substantial Modifications to Existing Structures During the May 23 meeting, there was a detailed discussion on the CCC suggested modification and alternative modification of CR-I-25 Substantial Modification to Existing Structures (Modification No. 6.46). Staff had previously proposed to keep the CCC suggested modification language; however, an alternative modification added an exemption for properties behind the SRA, which would allow those properties to only correct existing nonconformities related to applicable coastal hazards. At the May 23 meeting, staff was directed to further refine the alternative modification to clarify that there must be a correlation between the proposed modification and the correction of existing nonconformities, including that the correction should be relate to protection of coastal resources and coastal hazards.
City staff allowed CCC to review the revised alternative modification. While they did not agree with the exact language that City staff proposed, there was agreement on the intent of the text Pacifica City Council 5
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change. As such, CCC suggested a new alternative modification that reflected in Attachment B – Summary Table. The new text lays out an exception for nonconformities related to noncoastal resource issues. Additionally, because the new alternative modification applies to all nonconformities related to non-coastal resource issues, there is no need to have specific exception language for the SSRAs. The next text is inline with the City Council discussions on May 23, that directed staff to clarify that nonconformities related development standards should be allowed to remain as currently allowed by the Pacifica Municipal Code.
B. Policy CR-I-27 (previously CR-I-51) Habitat Sea Level Rise Mitigation Buffers From March 2023, there was a minor CCC suggested modification to Policy CR-I-51 Habitat Sea Level Rise Mitigation Buffer. Staff had suggested a minor alternative modification to clarify the language; however, during the May 23 meeting, City Council directed staff to delete the alternative modification and keep the CCC suggested modification. This is reflected in the Summary Table.
3. Additional Alternative Modifications to Chapter 6
Since the last City Council meeting, staff has been coordinating with CCC staff on additional alternative modification needed to Chapter 6 to ensure consistency with the Coastal Act. Staff is incorporating these additional CCC modifications now in an attempt to reduce the likelihood that CCC staff will have additional suggested modification prior to a CCC hearing on the LCP Update. These new alternative modifications can be seen in the Summary Table attachment and include the following:
A. Reorganization of Policies
Similar to previous CCC modifications related to reorganization of policies, the new modifications are intended to make Chapter 6 easier to implement. The reorganization includes removing all the sub-area policies only and re-introducing and condensing them where appropriate. The changes do not make any edits to the sub-area descriptions.
B. Changes to existing policies
The additional modifications include changes to existing policies as follows:
• CR-I-5 Shoreline Adaptation Program: This policy has been expanded to included specific details regarding CCC’s expectation of what the scope of the Program should be and sets a 10-year timeline by which the Program needs to be certified. This program is meant to compliment the Coastal Access and Resilience Program, associated with the Special Shoreline Resiliency Areas.
• CR-I-7 Transfer of Development Rights: Minor revisions to clarify intent of the policy. • CR-I-13 LHMP Alignment: Minor revision to correct references. • CR-I-19 (previously CR-I-43) Technical Reports: Additional text to clarify safety factors. • CR-I-20 (previously CR-I-44) Siting and Design: Additional text related to setbacks. • CR-I-21 Coastal Hazards Risk Disclosure (previously CR-I-45 Assumption of Risk by Private Landowners): This policy has been expanded to include more detailed language on what the risk disclosure document will contain. Additionally, City Council directed staff to include an exception clause to this policy. CCC staff does not agree with the exception clause because it could lead to error and omissions in technical reports that would put the City and property at risk. The policy is a disclosure of risks and does not require action until and if hazards occur. Staff request Council direction on this specific topic.
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• CR-I-23 (previously CR-I-47) Bluff Face Development: Adds text to clarify that native bluff landscaping and public recreational access improvements are allowed. • CR-I-29 (previously CR-I-53) Subdivision Limitations: Minor revision. • CR-I-30 (previously CR-I-54) Soft Shoreline Protections: Minor revision to clarify policy. • CR-I-31 (previously CR-I-56) Existing Shoreline Protection Structures: Minor revision to clarify policy and correct references.
• CR-I-32 (previously CR-I-57) New Shoreline Protection Structures: Minor revision to correct references and clarification.
• The additional modifications also include new policies relating to Emergency Shoreline Protection Structures that provide specific language on when and how temporary shoreline protection structures may be approved.
The additional modifications reflect necessary details needed to demonstrate compliance with the Coastal Act. Additionally, the Council had previously stated the need to have additional details in certain policies, including CR-I-5 and CR-I-21, in order to ensure that the policy would be acceptable to the Coastal Commission and that the City understood the full implications. City staff worked with Coastal Commission staff to ensure that both of those concerns are met with the additional text changes. City staff has reviewed the new changes and believes that these policies will allow the City to create acceptable programs, approve safe and LCP compliant development, and manage and maintain public infrastructure.
C. Policies Related to Special Shoreline Resiliency Areas (SSRA) The additional modifications include changes to the policies related to the SSRAs. Firstly, the name of the policies has been changed to add “Shoreline.” A major formatting change is that instead of incorporating the SSRA policies into the existing Chapter 6 policies, the SSRA policies are now shown as standalone policies at the end of the chapter1. The additional changes also include new policies that speak directly to public infrastructure, shoreline protection structures, and timelines/sunsets of policies. Additionally, there is more detail provided as it relates to the Coastal Access and Resilience Program (previously called the Shoreline Management Plan).
The following is a summary of the SSRA policies:
• CR-I-38 public infrastructure along the shoreline in SSRA shall be allowed to rely on any existing shoreline protection structure at the time of application. • CR-I-39 allows development to rely on any existing shoreline protection structure. • CR-I-40 allows maintenance and improvements to existing shoreline protection structures.
• CR-I-41 states that SSRA policies will not go into effect until the Coastal Access and Resilience Program has been submitted to CCC and work on the Shoreline Adaptation Program has begun.
• CR-I-42 contains actions that the City must complete in order to keep SSRA policies in effect.
• CR-I-43 provides a detailed description of what the Coastal Access and Resilience Program must contain in order to maximize public access and address coastal resource impacts.
While the changes to Chapter 6 may seem extensive compared to the version of Chapter 6 published for the May 23rd City Council meeting, the intent of the Chapter 6 and the SSRA 1 This is similar to the original approach to the SSRA policies that was presented at the December 5, 2023 community roundtable meeting.
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policies is mostly unchanged. The SSRA policies will still allow development behind the designated SSRA to use protection from coastal hazards that may be provided by the existing shoreline protection structures. One CCC recommended change to the SSRA policies is that they do not automatically go into effect upon certification of the LCP but rather, when the City has begun work on two obligations (i.e. Coastal Access and Resilience Program and Shoreline Adaptation Program). While this does mean that development will not be able to take advantage of these policies for a longer period of time, staff can work with potential applicants on the timing of application submittal if needed. With the specified language related to both obligations and the close working relationship between CCC and City staff, the City can begin work in a timely fashion on both obligations. At this time, staff does not know how long it will take to submit the Coastal Access and Resilience Program and begin work on the Shoreline Adaptation Program, but within one year is a reasonable estimate.
As mentioned above, the changes and additional language is necessary to ensure the document is compliant with the Coastal Act. Both City and Coastal staff have worked closely to ensure that the additional modifications are consistent with the Coastal Act and with the goals of both agencies.
4. Additional Alternative Modification to other Chapters and Glossary As previously mentioned, staff has been closely coordinating with CCC. That coordination effort resulted in CCC staff conducting a detailed review of the entire LCP document. That review result in additional changes as described below.
A. General Plan Consistency
In October of 2023, the City Council approved amendments to the LCP document to ensure that the LCP was consistent with the 2040 General Plan (GP). Staff has reviewed the CCC staff requests to that GP language and does not agree that it should be modified or removed. If the City were to alter or remove text in the LCP that was specifically added for GP consistency, it would need to amend the GP to coincide with the certified LCP. CCC staff has also requested that certain introductory or background text be updated. While City staff understands that importance of having updated information, it is difficult to update long-term policies documents every time that information becomes outdated. Staff recommends that introductory or background text be updated when staff resources become available to conduct the necessary research and process amendments to both the LCP and GP concurrently.
Additionally, some of the requested edits to GP consistent text can be accepted. After a detailed review, staff found that some edits that were incorporated or removed in the October 2023 LCP version are unnecessary and City staff agrees that they should be removed or edited. Since GP consistency changes were never incorporated into the Summary Table, staff highlighted this text in Attachment F Redline LCP. Staff believes that these edits are minor in nature and can be processed through an administrative amendment of the GP.
B. Further Coastal Act Compliance Modifications
During the review of the entire LCP document, CCC staff noted additional modifications, outside of Chapter 6, needed to ensure that the document was compliant with the Coastal Act. Those include changes to the following policies LD-I-5 Lower Cost Visitor and Recreational Facilities; LD-I- 9 Coastal- Dependent Industry; and NH-I-3 Fault Zone.
Staff has reviewed these modifications and believes they are necessary to ensure Coastal Act compliance and certification of the LCP document. These alternative modifications have been added to the attached Summary Table with a brief explanation and staff recommends that the Pacifica City Council 8
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City Council accept the changes.
C. Additional Alternative Modifications
In addition to the above referenced changes, CCC staff also suggested additional alternative modifications to the document. In general, staff is in support of these modifications to address redundancies, typos, and formatting issues and provide further policy clarity. All of these have been added to the attached Summary Table with a brief explanation and staff recommends that the City Council accept the changes. However, staff does not support the below suggested CCC suggested alternative modifications and recommends rejection of these alternative modifications:
• LD-I-20 Undeveloped San Pedro Avenue Site: CCC staff recommends keeping their original suggested modification from March 2023 that states “some low density” instead of the staff drafted alternative modification that proposed a specific density range. Staff strongly believes that a specified density is necessary to address community concerns regarding potential future development of the site and to assure that the City’s internal land use documents, e.g. General Plan, and LUP are consistent with regard to density designations.
• ER-I-1 Creek Protection and Restoration and ER-I-24 Management of ESHA: CCC staff recommends keeping their original suggested modification from March 2023 which clarified exceptions to buffer instead of the staff drafted alternative modification that removes “no less than 50 feet in any case.” As staff has previously explained, requiring a minimum buffer with no exception is too prescriptive and does not consider the quality of habitat or design alternative. While the CCC acknowledges that language should be included in LCLUP which protects against potential taking challenges, there modification conflicts with the general exception contained in the policy which allows for reductions in buffers to avoid a takings claim. Staff believes that buffers should be determined on a case-by-case basis and as necessary to avoid takings claims. Additionally, staff does not believe that temporary disruptions to buffer zones should be determined by a time limit (e.g. less than six months). The nature of disruptions should be determined by a qualified biologist.
• In the Glossary, definition of Substantial Structural Modification: CCC staff recommends additional clarification on what qualifies as a major structural component and a shorter exclusion list. While staff appreciates the effort to clarify and streamline the definition, City Council and the community have put extensive efforts into the current alternative modification of SSM and does not support substantial changes. Instead, staff recommends a minor revision to a portion of the definition to read “however excludes, but not limited to:” to clarify that the list of example exclusions is not exhaustive. Staff believes this change meets the intent of CCC staff.
Staff will communicate further with CCC staff on the rationale behind these specific issues in hopes that CCC staff will understand and agree with the City’s alternative modifications.
5. Meeting #4: Completing Review of All Alternative Modifications Meeting #4 in the community engagement plan is designed to allow City Council to receive a presentation from staff on all of the proposed alternative modifications, including the SRA policies, and to allow City Council to ask questions on any of the alternative modifications. The City Council previously completed its review of alternative modifications except for SRA specific policies. Staff recommends the focus of this meeting #5 be on review of the SSRA policies, as described above.
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Attachment B contains the alternative modifications prepared by City staff in response to CCC staff’s suggested modifications from the CCC’s report from March 8, 2023. The table also contains a brief summary and/or explanation as to why staff is or is not proposing an alternative modification. Staff has made edits to Attachment B (shown as redlines) and Attachment F (LCP Redlined Document) since the April 15 staff report.
6. Next Steps
The key outcome of this meeting is to approve the attached Resolution which approves the Revised Certification Draft LCLUP with alternative modifications and then staff will submit the Revised Certification Draft LCLUP to CCC staff. CCC staff has indicated that they will need approximately 2-3 months to review and schedule a hearing on the City’s LCLUP once they receive the City Council resolution. The CCC may then certify the City’s LCLUP as submitted, deny the LCLUP submittal, or certify subject to City Council acceptance of additional suggested modifications.
PUBLIC COMMENTS
Staff has received six public comments since the May 23, 2024 City Council Meeting and before the release date of this report those. Those comments were provided to the Council prior to the June 10th meeting2.
California Environmental Quality Act (CEQA):
Adoption of the Revised Certification Draft LCLUP with Alternative Modifications would be exempt from CEQA pursuant to Section 15266 of the CEQA Guidelines (“Adoption of Coastal Plans and Programs”) which provides that “CEQA does not apply to activities and approvals pursuant to the California Coastal Act…by (1) Any local government, as defined by Section 30109 of the Public Resources Code, necessary for the preparation and adoption of a local coastal program…” Section 15265 further provides that “CEQA shall apply to the certification of a local coastal program… by the California Coastal Commission.” ALTERNATIVE ACTION:
No alternative action has been identified.
RELATION TO CITY COUNCIL GOALS AND WORK PLAN:
The Local Coastal Land Use Plan Update is consistent with the following item(s) in the Counciladopted Strategic Plan and Priority Work Plan for FY 2023-24:
• Goal 4: Pursue climate change adaptation and mitigation. o Strategy C: Update Pacifica’s Local Coastal Plan and improve communications and collaboration with the California Coastal Commission.
FISCAL IMPACT:
There is no direct fiscal impact from this item.
ORIGINATED BY:
Planning Department
ATTACHMENT LIST:
Attachment A - Draft Resolution for LCLUP (DOCX)
2 https://www.cityofpacifica.org/home/showpublisheddocument/18174 Pacifica City Council 10 June 26, 2024
Attachment B Summary Table with Alternative Modifications (PDF) Attachment C Rockaway Beach (PDF)
Attachment D West Sharp Park (PDF)
Attachment E Redlined LCP (PDF)