Attachment B Summary Table with Alternative Modifications — Pacifica City Council, June 26, 2024

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 2 2.1 Parks and
Open Space
Sandy beach areas; including properties that are fully on beaches or coastal dunes or bluffs;
N/A CCC suggested modification adds new text
2 2.2 Coastal
DevelopmentReview
These exemptions are generally set forth in
Section 30610 of the PRC and Sections 13252,
13252, and 13250 of the California Code of
Regulations (CCR)
These exemptions are generally set forth in Section
30610 of the PRC and Sections 13252, 13253, and
13250 of the California Code of Regulations (CCR).

N/A CCC suggested modification addresses a typo
with the code sections
2 2.3 LD‐I‐2 Designed to minimize impacts to public access, recreation, and coastal resources.

Designed to minimize impacts to public access,
recreation, and other coastal resources.

N/A CCC suggested modification adds the word
“other”
2 2.3 LD‐I‐2: Land
Divisions in
the Coastal
Zone
N/A Prohibited on properties that are within Coastal
Vulnerability Zones, unless the resulting parcels are
set aside for conservation, or unless the resulting
parcels can be developed consistent with the LCP.

N/A CCC suggested modification restates Coastal
Act prohibition on intensifying land
use/subdividing land in hazard areas.
2 2.4 LD‐I‐3:

CoastalDevelopmentPermit
Findings
N/A In advance of updating the Implementation Plan
for conformance with the policies of this 2023 Land
Use Plan, the policies of the Land Use Plan shall
provide the standard of review for any proposed
new development, including where these policies
are more protective of ESHA and other coastal
resources and maximizing public access as
consistent with the Coastal Act.

N/A CCC suggested modification resolves potential
conflicts during transition period following
LCLUP certification until General Plan and
zoning (Implementation Plan, or IP) is updated.
2 2.4A LD‐I‐5
IndividualizedDeterminations
N/A N/A Ensure decisions on coastal development permits include an individualized, property‐specific
determination of policies, conditions of approval,
and other regulations imposed to regulate
development, and ensure regulations imposed on
properties pursuant to the LCLUP are
consistent with applicable state and federal law.

Staff recommends the addition of this policy to
specify that decisions relating to coastal
development permit issuance will be reviewedindividually in a manner that is consistent with applicable state and federal laws.
2 2.4B LD‐I‐5: Lower
Cost VisitorandRecreationalFacilities
Protect lower‐cost visitor and recreationalfacilities in the Coastal Zone. These include major,free recreational attractions such as PacificaPier and Pacifica State Beach; the public golfcourse at Sharp Park; the San Francisco RV Park;California Coastal Trail and other trails, andnumerous beaches accessible at no cost.

N/A Protect, encourage, and where feasible, provide
lower‐cost visitor and recreational facilities in theCoastal Zone. These include major, free recreationalattractions such as Pacifica Pier and Pacifica StateBeach; the public golf course at Sharp Park; the SanFrancisco RV Park; California Coastal Trail and othertrails; lower cost overnight accommodations; andnumerous beaches accessible at no cost.

The edits are the minimum necessary to find the
LUP in conformance with Coastal Act Section30213.
2 2.4C LD‐I‐9:

Coastal‐DependentIndustry
Allow new coastal‐dependent industry only ifalternative locations outside the Coastal Zone areinfeasible or more environmentally damaging orbecause to do otherwise would adversely affectthe public welfare, and potential impacts tovisual resources, sensitive species and habitat,water quality are mitigated to the maximum N/A New coastal‐dependent industry that cannot
feasibly be accommodated consistent with otherpolicies of this LCP may be permitted only ifalternative locations outside the Coastal Zone areinfeasible or more environmentally damaging;permitting the development would not adverselyaffect the public welfare; and potential impacts to The edits are necessary for compliance withCoastal Act 30260.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justificationextent feasible. visual resources, sensitive species and habitat, water quality, and other coastal resources aremitigated to the maximum extent feasible. Thispolicy does not apply to a new or expanded oil andgas development, refinery, or petrochemical facility. 2 2.5 Central
PacificaCoastal Zone
Any development of the Quarry site will require
detailed evaluation of biological resources to
ensure that sensitive habitat and wetlands are
protected; the likely footprint of development
could be much smaller than the area designated.

Any development of the Quarry site will require
detailed evaluation of biological resources to
ensure that sensitive habitat and wetlands are
protected; and should be sited and designed to
minimize coastal hazard risks in accordance with
policies in Chapter 5 and 6 of the LUP. The likely
footprint of development could be much smaller
than the area designated.

N/A CCC suggested modification restates coastal
development requirements related to hazardsand refers to the relevant Chapters 5 and 6 ofthe LCLUP. 2 2.6 LD‐I‐14:

PromenadeArea andBeach
Boulevard
Property
Enhance the Promenade area as a local
community and tourist destination.

Enhance the Promenade area as a local community
and tourist destination, while also ensuring that it
adequately responds to and addresses coastal
hazard considerations consistent with the LCP.

Enhance the Promenade area as a local communityand tourist destination, while also ensuring that itadequately responds to and addresses coastalhazard considerations consistent with the LCP.Non‐permanent improvements shall not requireadditional analysis.

CCC suggested modification clarifies the policyrelated to the Beach Boulevard Promenade.City staff is generally in support of thesuggested modification; however, City staff isproposing an alternative modification to clarifythat non‐permanent improvements, such asbench and trash receptacles, do not requireadditional analysis. This will help to streamlineany such improvements in the future. 2 2.6A LD‐I‐14:

PromenadeArea andBeachBoulevardProperty
N/A N/A Delete Staff had previously proposed an alternative modification that read “Non‐permanentimprovements shall not require additionalanalysis.” Staff is proposing no longer proposingthat alternative modification due to CR‐I‐24which applies to minor development inshoreline areas. 2 2.6 LD‐I‐14:

PromenadeArea andBeach
Boulevard
Property
The preferred use is a hotel if market conditions
allow, but other appropriate uses will include a
conventional commercial/residential mixed‐useproject with cafes, restaurants, retail, and upper‐ level housing. The mix of uses for any non‐hotel
project shall emphasize uses that are of interest to
visitors and that generate revenues for the City.

Appropriate uses could include a hotel or
conventional commercial/residential mixed‐useproject with cafes, restaurants, retail, and upper‐ level housing, if such uses are deemed appropriate
considering coastal hazards and the required
protections for coastal resources. The mix of uses
for any proposal shall emphasize uses that are of
interest to visitors and that generate revenues for
the City.

N/A CCC suggested modification eliminates hotel as
preferred use, but continues to allow a hotel
on the site
2 2.7 LD‐I‐16:

RockawayQuarry Site
Enable the responsible development and
environmental conservation of the Quarry Site.

Enable the responsible development and
environmental conservation of the Quarry Site,
considering the potential coastal hazard
constraints (including but not limited to bluff
erosion, slope stability, and flooding), as well as the biological constraints (specific to sensitive species,
environmentally sensitive habitat areas, andwetlands) and coastal resource protection more broadly.

N/A CCC suggested modification restates coastal
development requirements related to hazards
and biological resources protections.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 2 2.7 LD‐I‐16:

RockawayQuarry Site
Allowable development should provide City
revenues substantial public open space, and
commercial uses and public spaces attractive to
both visitors and local residents.

Allowable development should provide community
benefits, including substantial public open space,
and commercial uses and public spaces attractive
to both visitors and local residents.

N/A CCC suggested modification revised City
revenues to community benefits.
2 2.8 LD‐I‐20:

UndevelopedSan PedroAvenue Site
Establish a Coastal Residential Mixed Use zoning
district to allow small‐scale visitor‐oriented
commercial uses as a stand‐alone project without
any residential development, or small‐scale
visitor‐oriented commercial uses with residential
development at a density range of three to five
units per gross acre. Housing may be clustered,
and uses may be mixed vertically or horizontally.

Residential uses may be constructed attached to
or detached from commercial uses, provided the
overall site contains both commercial and
residential uses.

Establish a Coastal Residential Mixed Use zoning
district to allow small‐scale visitor‐oriented
commercial uses as a stand‐alone project without
any residential development, or small‐scale visitor‐
oriented commercial uses with some low density
residential development. Housing may be
clustered, and uses may be mixed vertically or
horizontally. Residential uses may be constructed
attached to or detached from commercial uses,
provided the overall site contains both commercial
and residential uses.

Establish a Coastal Residential Mixed Use zoning
district to allow small‐scale visitor‐oriented
commercial uses as a stand‐alone project without
any residential development, or small‐scale visitor‐
oriented commercial uses with some low density
residential development at a density range of thelower third of the CRMU density range. Housingmay be clustered, and uses may be mixed vertically or horizontally. Residential uses may be constructed
attached to or detached from commercial uses,
provided the overall site contains both commercial
and residential uses.

CCC suggested modification increases the
density allowances. After clarification from CCC
staff, that was not the intent of the revision.

City staff is proposing an alternative
modification that achieves the same previouslyapproved lower density range by using different terms that are preferrable to the CCC
staff.

2.8 LD‐I‐20:

UndevelopedSan PedroAvenue Site
Development must include public coastal access
and must provide public open space.

Development must include public coastal access,
provide public open space, and consider all
biological constraints.

N/A CCC suggested modification clarifies
requirements for development of this site.
2 2.9 LD‐I‐26:

Enhanced
Visitor Node
Create a visitor‐oriented commercial and
hospitality node at Rockaway Beach and on
developable portions of the Rockaway Quarry site
which contains distinctive design, uses, and
recreational opportunities.

Taking all site constraints into account, create a
visitor‐oriented commercial and hospitality node at
Rockaway Beach and on developable portions of
the Rockaway Quarry site which contains
distinctive design, uses, and recreational
opportunities.

N/A CCC suggested modification restates coastal
development requirements related to
considering site constraints such as coastal
hazards.
2 2.10 Development
Capacity and
Projections
As noted above, the Quarry site’s development
capacity may be further reduced by site‐specific
analyses of geotechnical and biological.

As noted above, the Quarry site’s development
capacity may be further reduced by site‐specific
analyses of geotechnical and biological constraints.

N/A CCC suggested modification fixes a typo.
2 2.11 LD‐I‐27:

Public
ServicePriorities
Ensure that needs generated by development or
uses permitted over the planning period are
adequately served by existing and planned public
works facilities.

Ensure that needs generated by development or
uses permitted over the planning period are
adequately served by existing and planned public
works facilities, and plan for the maintenance,
operation, expansion and improvement to public
facilities considering threats from coastal hazards.

Support studies that evaluate the condition of
critical facilities, especially public works
infrastructure that has been identified as
vulnerable to hazards. Studies shall include
alternatives analyses for potential retrofit,
improvements, relocation, or other considerations.

N/A Ensure that existing and planned public works
facilities accommodate needs generated bydevelopment or uses permitted by the buildoutallowances of this Land Use Plan or by the GeneralPlan to serve the City’s non‐coastal zone areas. Planfor the maintenance, operation, expansion andimprovement to public facilities considering threatsfrom coastal hazards, and avoid locating new orexpanded public service facilities in the CoastalVulnerability Zone unless no feasible alternativeexists. Support studies that evaluate the conditionof critical facilities, especially public worksinfrastructure that has been identified as vulnerableto hazards. Studies shall include alternativesanalyses for potential retrofit, improvements,relocation, or other considerations.

CCC suggested modification requires analysis ofalternatives for potential retrofit or relocation but does not mandate relocation.Alternative modification incorporates reference to the LUP and General Plan buildoutallowances and to incorporate language fromLD‐I‐37 here instead and remove redundancies.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 2 2.12 LD‐I‐37:

Public
Services for
NewDevelopments
N/A Public Services for New Development.

Development shall only be approved if it can be
shown that it can be accommodated by adequate
and sustainable public services (including in terms
of water, sewer, and circulation) without any
significant impacts to coastal resources. Public
service development shall be limited to levels that
are sufficient to accommodate LCP consistent
development, including at buildout, and shall not
be allowed if it would be growth inducing past that
threshold.

Public Services for New Development. Avoidlocating new or expanded public service facilities inthe Coastal Vulnerability Zone. If no feasiblealternative exists and a new or expanded publicservice facility must be located within the CoastalVulnerability Zone, development shall be consistentwith this LCP and the Coastal Act.Development shallonly be approved if it can be shown that it can beaccommodated by adequate and sustainable publicservices (including in terms of water, sewer, andcirculation) without any significant impacts tocoastal resources.

CCC suggested modification may impactinfrastructure within the Coastal Zone thatserves areas outside the Coastal Zone. City staffalternative modification allows new orexpanded public services within the CVZ only ifno other location can be accommodated.Additionally, new or expanded public serviceswithin the CVZ must design in compliance withother LCP policies, such as designing foradaptation, and the Coastal Act.The portion proposed alternative modificationhas been incorporated into LD‐I‐27. The newmodification allow development and protectscoastal resources. 3 3.1 Coastal
Access Points
Maintain public parking as part of redevelopment
of City‐owned 2212 Beach Boulevard property.

Maintain public parking as part of redevelopment
of City‐owned 2212 Beach Boulevard property and
maintain lateral access along Beach Boulevard to
the Pier.

N/A CCC suggested modification adds requirement
for lateral access, which is a requirement under
the Coastal Act
3 3.2 Coastal
Access Points
N/A Conduct a prescriptive rights study. N/A CCC suggested modification requires additional study
3 3.2 Coastal
Access Points
N/A Conduct a prescriptive rights study. N/A CCC suggested modification requires additional study
3 3.3 PR‐I‐8:

TemporaryEvents
N/A Only temporary events meeting all the above
criteria shall require coastal development permit
review, however, the Planning Director may also
exclude from permit requirements temporary
events meeting all the above criteria when:
• The fee is for preferred seating only and more
than 75% of the provided seating capacity is
available free of charge for general public use; or,
• The event is held on sandy beach area in a
remote location with minimal demand for publicv
use, and there is no potential for adverse effect on
sensitive coastal resources; or
• The event is less than one day in duration; or
• The event has previously received a coastal
development permit and will be held in the same
location, at a similar season, and for the same
duration, with operating and environmental
conditions essentially the same as those associated
with the previously‐approved event.

The Planning Director (or the Coastal Commission’s
Executive Director if the Planning Director’s
determination is challenged) may determine that a
Only temporary events meeting all the above
criteria shall require coastal development permit
review, however, the Planning Director may also
exclude from permit requirements temporary
events meeting all the above criteria when:
• The fee is for preferred seating only and more
than 75% of the provided seating capacity is
available free of charge for general public use; or,
• The event is held on sandy beach area in a remote
location with minimal demand for publicv use, and
there is no potential for adverse effect on sensitive
coastal resources; or
• The event is only one day in duration; or
• The event has previously received a coastal
development permit and will be held in the same
location, at a similar season, and for the same
duration, with operating and environmental
conditions essentially the same as those associated
with the previously‐approved event.

The Planning Director (or the Coastal Commission’s
Executive Director if the Planning Director’s
determination is challenged) may determine that a
CCC suggested modification allows for
streamlined approval of temporary events
under certain circumstances. Generally, City
staff supports the approach. However, City
staff is proposing an alternative modification to
address typos and punctuation and clarify the
duration of events allowed under this criteria.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification temporary event, even an event that might
otherwise not require a coastal development
permit per this section above, shall require a
coastal development permit if he/she determines
that unique or changing circumstances exist
relative to the particular temporary event that
have the potential for significant adverse impacts
on coastal resources. Such circumstances may
include, but shall not be limited to, the following:
• The event, either individually or together with
other temporary events scheduled before or after
the particular event, precludes the general public
from use of a public recreational area for a
significant period of time; or
• The event and its associated activities or access
requirements will either directly or indirectly
impact environmentally sensitive habitat areas,
rare or endangered species, significant scenic
resources (including as mapped on the LCP Land
Use Plan maps or as determined during project
review), or other coastal resources; or
• The event is scheduled between Memorial Day
weekend and Labor Day and would restrict public
use of roadways or parking areas or otherwise
significantly impact public use or access to coastal
waters; or• The event has historically required a coastal development permit to address and monitor
associated impacts to coastal resources.Temporary
events located solely within the Coastal
Commission’s original coastal development permit
jurisdiction area require review and determination
of coastal development permit requirement or
temporary event exemption from the Coastal
Commission
temporary event, even an event that might
otherwise not require a coastal development permit
per this section above, shall require a coastal
development permit if it is determined that unique
or changing circumstances exist relative to the
particular temporary event that have the potential
for significant adverse impacts on coastal resources.

Such circumstances may include, but shall not be
limited to, the following:• The event, either individually or together withother temporary events scheduled before or after the particular event, precludes the general public
from use of a public recreational area for a
significant period of time; or• The event and its associated activities or access requirements will either directly or indirectly impact
environmentally sensitive habitat areas, rare or
endangered species, significant scenic resources
(including as mapped on the LCP Land Use Plan
maps or as determined during project review), or
other coastal resources; or
• The event is scheduled between Memorial Day
weekend and Labor Day and would restrict publicuse of roadways or parking areas or otherwise significantly impact public use or access to coastal
waters; or• The event has historically required a coastal development permit to address and monitor
associated impacts to coastal resources. Temporary
events located solely within the Coastal
Commission’s original coastal development permit
jurisdiction area require review and determination
of coastal development permit requirement or
temporary event exemption from the Coastal
Commission.
3 3.4 PR‐I‐12:

CoastalAccess PointSouth of SanFrancisco RVPark
Lateral access along the bluffs should be provided
from this coastal access point to City‐ and Coastal
Commission‐required public access at San
Francisco RV Park to the north, and to properties
to the south upon future redevelopment.

Lateral access along the bluffs as well as vertical
trail improvements should be provided from this
coastal access point to City‐ and Coastal
Commission‐required public access at San
Francisco RV Park to the north, and to properties to
the south upon future redevelopment.

N/A Delete CCC suggested modification adds language to
include vertical trail improvements. With GPconsistency changes a portion of the CCCsuggested modification remain that shouldhave been deleted as well. 3 3.5 PR‐I‐24:

Sharp Park
Support the continued operation of golf at Sharp
Park Golf Course consistent with redeveloping
source protection, natural hazard, and coastal
vulnerability policies, and support development of
additional recreational uses in upland portions of
Support the continued operation of golf at Sharp
Park Golf Course consistent with redeveloping
source protection, natural hazard, and coastal
vulnerability policies, existing CDP terms and
conditions, and support development of additional
Support the continued operation of golf at SharpPark Golf Course consistent with redeveloping resource protection, natural hazard, and coastalvulnerability policies, existing CDP terms andconditions, and support development of additional City staff alternative modification would delete
the word “existing,” which clarifies that a CDP
must be obtained and can be modified throughthe appropriate approval process over time.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justificationthe Park located outside the Coastal Zone east of Highway 1.
recreational uses in upland portions of the Park
located outside the Coastal Zone east of Highway

1. recreational uses in upland portions of the Park
located outside the Coastal Zone east of Highway 1.
3 3.6 PR‐G‐11:

Trail SystemExpansion
Expand the trail system in Pacifica to create a
connected trail network with communitywide
links to open space and recreation facilities, as
shown on Figure 3‐3.

Expand the trail system in Pacifica to create a
connected trail network with communitywide links
to open space and recreation facilities, as shown
on Figure 3‐3, and to enhance and augment
California Coastal Trail connections and
connectivity.

N/A CCC suggested modification adds the California
Coastal Trail to the policy.
3 3.6A PR‐I‐45:

Pedestrian‐OrientedStreetImprovement
Implement Bicycle and Pedestrian Master Planrecommendations to improve pedestrianorientated safety and comfort.

N/A To the extent they are consistent with all LCP
policies, implement Bicycle and Pedestrian MasterPlan recommendations to improve pedestrian‐orientated safety and comfort.

Edits to ensure that implementing therecommendations of this outside (non‐LCP)document would occur in a Coastal Actconsistent way. 3 3.7 PR‐I‐57:

RoadwayRetrofits
Roadway retrofits will require additional analysis. Roadway retrofits will require additional analysis, such as coastal hazard concerns in areas within the
Coastal Zone.

PR‐I‐57: Bicycle Roadway Retrofits
Additional analysis will be required to identify
roadway retrofits to create complete streets. such
as coastal hazard concerns in areas within theCoastal Zone. Retrofits will be consistent with thisLCP.

CCC suggested modification adds language that
roadway retrofits need to analyze coastalhazards. The City alternative modification clarifies that the policy only applies to roadway
retrofits that do not increase capacity and are
intended to create complete streets.
3 3.8 PR‐I‐60:

RoadwayAbandonment/Vacationand PublicAccess
Do not abandon, vacate, or render unusable any
City‐owned right‐of‐way, unless necessary for
reasons of public safety or environmental
conservation. Whenever public roadways are
proposed to be abandoned, assess the value of
maintaining public pedestrian and/or bicycle
access, especially where coastal access can be
maintained or improved. Abandonment/vacation
of any public right‐of‐way that may negatively
affect coastal resources or public access to the sea
will require a coastal development permit. Any
public right‐of‐way that cannot be maintained in a
condition suitable for public use shall be offered
to another public agency or private association
that agrees to maintain the right‐of‐way for public
use.

Do not abandon, vacate, or render unusable any
City‐owned roadways and/or rights‐of‐way, unless
necessary for reasons of public safety or
environmental conservation. Whenever public
roadways and/or rights‐of‐way are proposed to be
abandoned, assess the value of maintaining public
pedestrian and/or bicycle access, especially where
coastal access can be maintained or improved.

Abandonment/vacation of any public roadways
and/or rights‐of‐way requires a coastal
development permit, which shall only be approved
if coastal resources can be protected in as good or
better conditions as exist at the time of permit
evaluation, and subject to terms and conditions to
ensure the public’s interests are maintained
moving forward.

Abandonment/vacation of any public roadways
and/or rights‐of‐way may require a coastal
development permit, which shall only be approved
if coastal resources can be protected in as good or
better conditions as exist at the time of permit
evaluation, and subject to terms and conditions to
ensure the public’s interests are maintained moving
forward.

CCC suggested modification adds City‐owned
roadways, in addition to public rights‐of‐way.

City staff’s alternative modification indicates a
CDP may be required (as opposed to requiring
it in all instances). It is possible certain
vacations may be exempt from CDPrequirements.
4 4.1 Surface
Water
Some of the watersheds drain directly into the
ocean, while other feed one of five.

Some of the watersheds drain directly into the
ocean, while other feed one of five creeks.

The City’s General Plan consistency changes
eliminated this sentence and the suggested
modification is no longer applicable.
4 4.2 Wetlands N/A Importantly, wetlands in the coastal zone only need meet one parameter (i.e., hydrology, hydric
soils, or hydrophytic species) to be considered a
wetland, as differentiated from three parameter
delineations which require all three to be present
(e.g., ACOE delineations).

Importantly, wetlands in the coastal zone only need
to meet one parameter (i.e., hydrology, hydric soils,
or hydrophytic species) to be considered a wetland,
as differentiated from three parameter delineations
which require all three to be present (e.g., U.S. Army
Corps of Engineers delineations).

CCC suggested modification clarifies the
language; however, City staff is proposing an
alternative modification to address typos and
expand an acronym.
4 4.3 ER‐I‐1: Creek
Protectionand
Restoration.

Requiring a minimum of 100 feet setbacks from
the top of creek banks, or from the outer edge of
riparian vegetation, where it exists, for
development proposed adjacent to creeks, in
Requiring a minimum of 100 feet setbacks from the
top of creek banks, or from the outer edge of
riparian vegetation, where it exists, whichever is
further, for development proposed adjacent to
Requiring a minimum of 100 feet setbacks from thetop of creek banks, or from the outer edge ofriparian vegetation, where it exists, whichever isfurther, for development proposed adjacent to CCC suggested modification amends the text toclarify exceptions; however, the statement “noless than 50 feet in any case” is too prescriptiveand does not consider the quality of habitat or Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justificationkeeping with City regulations and Best Management Practices. Exceptions to such buffer
requirements should be supported by a biological
report demonstrating that the adjusted buffer, incombination with incorporated siting, design or other mitigation measures, shall prevent impacts
that significantly degrade the creek. Buffer
adjustments should also be limited to where the
entire subject legal lot is within the buffer or
where it is demonstrated that development
outside the buffer would have a greater impact on
the creek.
creeks, in keeping with City regulations and Best
Management Practices. The 100‐foot buffer may
be reduced by the minimum necessary (1) to avoid
a taking (for private development), or (2) to
provide required public services (for public
development), provided that the buffer is as close
to 100 feet as possible, and no less than 50 feet in
any case, and provided that creek resource impacts
are avoided as much as possible, and unavoidable
impacts commensurately mitigated, all as
conclusively demonstrated by a qualified biologist
to the satisfaction of the City, USFWS, and CDFW.
creeks, in keeping with City regulations and BestManagement Practices. The 100‐foot buffer may bereduced by the minimum necessary (1) to avoid ataking (for private development), or (2) to providerequired public services (for public development),provided that any unavoidable impacts arecommensurately mitigated, that the buffer is asclose to 100 feet as possible, and no less than 50feet in any case, and provided that creek resourceimpacts are avoided as much as possible, andunavoidable impacts commensurately mitigated, allas conclusively demonstrated by a qualified biologistto the satisfaction of the City, USFWS, and CDFW. design alternatives. City staff proposes toeliminate the statement and the buffer will bedecided on a case‐by‐case basis as informed bya qualified biologist. Additional text to clarifymitigation may be needed. 4 4.3 ER‐I‐1: Creek
Protectionand
Restoration.

Permitted uses within buffer zones are limited touses dependent on the resources within these areasand their buffer zones (i.e., habitat managementand restoration, scientific research and educationalactivities, and low‐intensity public access andrecreation), except where reduced buffer is requiredto avoid a taking or essential for the provision ofpublic services. Temporary disruption, asdetermined by a qualified biologist in considerationof on‐site specific biological resources, for theconstruction, alteration, repair, and maintenance ofexisting or newly permitted facilities or structures isallowed if there are no feasible alternatives, thedisruption area is restored to its pre‐ disruptionstate or better within one year from the initial pointof impact and there is no significant grounddisturbance.

CCC suggested modification added language toPolicy ER‐I‐2 that specified allowed uses withina designated buffer area. City staff is generallyin support of the suggested modification;however, City staff is proposing an alternativemodification to clarify that takings avoidance isa relevant factor for consideration, as isprovision of public services. City staff is alsoclarifying that temporary disruptions may bepermissible if reviewed and recommended by aqualified biologist.The last portion of the first sentence isredundant and should be removed. 4 4.3A ER‐I‐1: Creek
ProtectionandRestoration.

Permitted uses within buffer zones are limited touses dependent on the resources within theseareas and their buffer zones (i.e. habitatmanagement and restoration, scientific researchand educational activities, and low‐intensity publicaccess and recreation), except where reducedbuffer is required to avoid a taking or essential forthe provision of public services.

N/A Permitted uses within buffer zones are limited to
uses dependent on the resources within these areasand their buffer zones (i.e. habitat management andrestoration, scientific research and educationalactivities, and low‐intensity public access andrecreation), The text was deleted as the previous bulletallows buffers to be reduced to avoid a takings.The policy does not need to and should not alsoallow for buildings in the reduced buffer area toavoid a takings‐‐ the reduced buffer wouldalready accommodate that. Permitted useswithin the buffer (whether reduced or not) canstill only be limited to resource dependent uses.Please delete. 4 4.4 Plant
Communitiesand WildlifeHabitats
The EIR for the General Plan and Local Coastal
Land Use Plan Update includes a more detailed
description of each of these communities and
habitats. The listed species and habitats here are
not intended to preclude the possibility that other
species or habitat occur within Pacifica. Species
identified with various plant communities or
habitats are not necessarily present in the
Planning Area. Some of these communities are
recognized as “special status communities,” or
provide critical habitat for special status species.

The map is illustrative and for information
purposes only; site‐specific biological studies are
required as part of proposed development review
to determine the presence and extent of plant
communities and habitat. The mappedcommunities and habitats are not intended to preclude the possibility that other communities or
habitat occur within Pacifica, nor to definitively
conclude that the plant communities or habitats
identified are present as indicated, rather the map
is a tool to help identify areas where further
evaluation for biological issue may be relevant.

The map is illustrative and for information purposes
only; site‐specific biological studies are required as
part of proposed development review to determine
the presence and extent of plant communities and
habitat. The mapped communities and habitats are
not intended to preclude the possibility that othercommunities or habitat occur within Pacifica, nor todefinitively conclude that the plant communities orhabitats identified are present as indicated, ratherThe map is a tool to help identify areaswhere further evaluation for biological issues maybe relevant.

CCC suggested modification clarifies the
language; however, City staff is proposing an
alternative modification to address typos.

Additionally, some of the City’s General Plan
consistency changes eliminated portions of this
text.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.5 Annual
Grasslands
Annual Grasslands Grasslands N/A The City’s General Plan consistency changes eliminated the term “annual” from the header
and the suggested modification is no longer
applicable.
4 4.6 Northern
Coastal Scrub
Northern coastal scrub habitat is found on
undeveloped slopes, often in a mosaic with annual
grasslands. Northern maritime chaparral, a
special‐status community, is included in this
category. Northern coastal scrub is dominated by
either coyote brush or California sagebrush,
depending on slope aspect.

Northern coastal scrub habitat is found on
undeveloped slopes, often in a mosaic with
grasslands. Northern maritime chaparral, a special‐
status community, is included in this category.

Northern coastal scrub dominated by either coyote
brush or California sagebrush, primarily depending
on slope aspect.

N/A CCC suggested modification removes the term
“annual” and generalizes language.
4 4.7 Seasonal
Wetlandsand Ponds
Seasonal Wetlands and Ponds Wetlands and Ponds N/A CCC suggested modification generalizes language
4 4.7 Seasonal
Wetlandsand Ponds
Seasonal Wetlands occur in smaller drainages and
localized depressions, forming ponds or flowing
water, and are underlain by saturated soils during
the winter and spring. Seasonal wetlands also
occur along the banks and sediments that
accumulate in creeks. Wetlands in Pacifica are
found along riparian areas, drainages, along the
coast, and as fresh and brackish water marshes
(such as on the Sharp Park Golf Course).

Vegetation and wildlife found in wetlands varies
with water characteristics, inundation patterns,
surrounding habitat, and level of disturbance.

Wetlands occur in smaller drainages and localized
depressions, forming ponds or flowing water.

Wetlands also occur along in creeks, riparian areas,
drainages, along the coast, and as fresh and
brackish water marshes (such as on the Sharp Park
Golf Course). Vegetation and wildlife found in
wetlands varies with water characteristics,
inundation patterns, surrounding habitat, and level
of disturbance.

Wetlands occur in smaller drainages and localized
depressions, forming ponds or flowing water.

Wetlands also occur along in creeks, riparian areas,
drainages, along the coast, and as fresh and brackish
water marshes (such as on the Sharp Park Golf
Course). Vegetation and wildlife found in wetlands
varies with water characteristics, inundation
patterns, surrounding habitat, and level of
disturbance.

CCC suggested modification clarifies the
language; however, City staff is proposing an
alternative modification to address typos.
4 4.7 Special‐
StatusSpecies
SPECIAL‐STATUS SPECIES IN SEASONAL WETLANDS

AND PONDS
The California red‐legged frog, San Francisco
garter snake, Leech’s skyline diving beetle, San
Francisco forktail
damselfly, Tomales isopod, western pond turtle,
and bristly sedge are special‐status species that
may be found in wetlands around Pacifica. The
wetlands in Sharp Park are also known to support
saltmarsh common yellowthroat. Seasonal
wetlands and ponds at Mori Point and Sharp Park
Golf Course support the California red‐legged frog
as well as the San Francisco garter snake.

SPECIAL‐STATUS SPECIES IN WETLANDS AND
PONDSThe California red‐legged frog, San Francisco garter snake, Leech’s skyline diving beetle, San Francisco
forktail damselfly, Tomales isopod, western pond
turtle, and bristly sedge are special‐status species
that may be found in wetlands in and around
Pacifica. The wetlands in Sharp Park are also known
to support saltmarsh common yellowthroat.

Seasonal wetlands and ponds at Mori Point and
Sharp Park Golf Course also known to support the
California red‐legged frog as well as the San
Francisco garter snake.

N/A Generalizes language
Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.8 N/A N/A Dunes
Dune habitat includes areas with sandy substrates
proximate to the marine environment and may
range from bare to vegetated with species typical
of foredune and dune scrub communities, including
non‐natives such as ice plant and invasive grasses.

Dune form topography may or may not be evident,
depending on the condition of the dune and past
land use or invasions, but may be readily restored.

While most dunes occur near sea level, there are
several examples of perched dune systems atop
bluffs in Pacifica, where aeolian forces have
created the substrate and processes appropriate to
support dune vegetation. All areas that meet this
definition of Dunes are categorically consideredESHA.

N/A CCC suggested modification adds a new habitat
category.
4 4.9 Potential
Environmentally SensitiveHabitat Areas(ESHAs)
Figure 4‐3 identifies potential ESHAs in the
Planning Area. Potential ESHAs include all
designated critical habitat for Endangered orThreatened Species; special status communities10; and areas designated as “other potential
Environmentally Sensitive Habitat Areas”.

Figure 4‐3 identifies potential ESHAs in the
Planning Area in three general categories: wetland,
stream/riparian, and other terrestrial ESHAs. These
potential ESHAs include all current designated
critical habitat for Endangered or Threatened
Species; known special status communities; and
areas designated as “other potential
Environmentally Sensitive Habitat Areas”. Figure 4‐
3 is meant to serve as a flag for further studies to
be undertaken when development is proposed.However, the map is illustrative and for information purposes only; site‐specific biological
studies are required as part of proposed
development review to determine the presence
and extent of ESHA and its required buffer zone.

And other information than Figure 4‐3 may dictate
the need for such studies as well (e.g., site
evaluation, other studies nearby, etc.), even if the
area is not mapped as potential ESHA on Figure 4‐

3. Figure 4‐3 identifies potential ESHAs in the Planning Area in three general categories: wetland,
stream/riparian, and other terrestrial ESHAs. These
potential ESHAs include all current designated
critical habitat for Endangered or Threatened
Species; known special status communities; and
areas designated as “other potential
Environmentally Sensitive Habitat Areas”. Figure 4‐3
is meant to serve as a flag for further studies to be
undertaken when development is proposed.

However, the map is illustrative and for information
purposes only; site‐specific biological studies are
required as part of proposed development review to
determine the presence and extent of ESHA and itsrequired buffer zone. And oOther information than Figure 4‐3 may dictate the need for such studies as
well (e.g., site evaluation, other studies nearby,
etc.), even if the area is not mapped as potential
ESHA on Figure 4‐3.

CCC suggested modification clarifies the
language; however, City staff is proposing an
alternative modification to address typos.
4 4.9A Other
PotentialESHA
Any proposed development on land designated onthe Sensitive and Critical Habitat map (Figure 4‐3)as having potential to include an EnvironmentallySensitive Habitat Area requires a site‐specificevaluation by qualified biologists.

N/A Grasslands/Prairie vegetation communities shown
on Figure 4‐2 are also mapped on Figure 4‐3 asPotential ESHA. Any proposed development on landdesignated on the Potential EnvironmentallySensitive Habitat Areas map (Figure 4‐3) as havingpotential to include an Environmentally SensitiveHabitat Area requires a site‐specific evaluation byqualified biologists Edits for consistency with the name and contentof Figure 4‐3.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.10 ER‐G‐6:

CoastalEnvironmentand SpecialSpeciesStatusCommunities
Conserve and protect beaches, sand dunes,
coastal bluffs, and special status communities,
particularly the Coastal bluff scrub on the
northern bluffs.

Conserve and protect beaches, sand dunes, coastal
bluffs, and special status communities, particularly
the Coastal bluff scrub on the northern bluffs.

Prohibit development in coastal dunes to preserve
dune formations, vegetation, and wildlife habitats.

Prevent overuse in dune areas by mechanisms such
as restricting parking and directing pedestrian
traffic through signage and sand fencing to areas
capable of sustaining such use. Prohibit motor
vehicles in dune areas except for emergency
purposes, and prohibit motor vehicles in non‐dunebeach areas except for emergency and essential maintenance purposes and where previously
coastal permitted.

N/A CCC suggested modification adds new and
clarifying language.
4 4.11 ER‐G‐7:

Creeks andRiparianAreas as
Habitat
Protect year‐round creeks andtheir riparian habitats.

Protect year‐round and intermittent creeks and
their riparian habitats.

N/A CCC suggested modification adds clarifying
language.
4 4.12 ER‐I‐21:

Protection of
BiologicalResourceswith New
Development
2) Pre‐construction plant and wildlife surveys:

Project applicants shall engage a qualified
biologist to conduct presence/absence biological
surveys for sensitive plant and wildlife species
prior to construction adjacent to or within
identified special status communities and other
sensitive areas identified in Figure 4‐3. If special
status species are identified, the qualified
biologist shall consult with the California
Department of Fish and Wildlife (CDFW) and
establish no‐disturbance buffers around the
special status specie to avoid disturbance and
direct impacts to these resources duringconstruction. If no special status species are detected during surveys, then construction‐
related activities may proceed. Nesting birds, in
particular, are protected by two means; they
receive protection under the Migratory Bird
Treaty Act, and nesting raptors (in the order
Falconiformes or Strigiformes) are protected
under the State Fish and Game Code, §3503.5.
2) Pre‐construction plant and wildlife surveys:

Project applicants shall engage a qualified biologist
to conduct presence/absence biological surveys for
sensitive plant and wildlife species prior to
construction adjacent to or within areas identified
as potential ESHAs on Figure 4‐3, or as otherwise
indicated and needed. If special status species are
identified, the qualified biologist shall consult with
the California Department of Fish and Wildlife
(CDFW) and establish no‐disturbance buffersaround the special status specie to avoid disturbance and direct impacts to these resources
during construction. If no special status species are
detected during surveys, then construction‐related
activities may proceed. Nesting birds, in particular,
are protected by two means; they receive
protection under the Migratory Bird Treaty Act,
and nesting raptors (in the order Falconiformes or
Strigiformes) are protected under the State Fish
and Game Code, §3503.5.

N/A CCC suggested modification adds clarifying
language.
4 4.12 ER‐I‐21:

Protection of
BiologicalResourceswith New
Development
3) Require biological resource assessments be
conducted prior to approval for any development
within 300 feet of creeks, wetlands, or other
sensitive habitat areas shown on Figure 4‐3 of the
General Plan.
3) Require biological resource assessments be
conducted prior to approval for any development
within 300 feet of creeks, wetlands, or other
sensitive habitat areas. Such assessment shall
identify means to avoid impacts to any such
resources (including through siting, design, and LCP
required buffers), and means of enhancing
resources and providing offsetting and
commensurate mitigation for unavoidable impacts
that are LCP allowable.
3) Require biological resource assessments be
conducted prior to approval for any development
within 300 feet of creeks, wetlands, or other
sensitive habitat areas, such as but not limited to
areas in Figure 4‐3. Such assessment shall identifymeans to avoid impacts to any such resources (including through siting, design, and LCP required
buffers), and means of enhancing resources and
providing offsetting and commensurate mitigation
for unavoidable impacts that are LCP allowable.

CCC suggested modification clarifies the
requirements; however, City staff is proposingan alternative modification to include the reference to Figure 4‐3 of the LCLUP.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.12 ER‐I‐21:

Protection of
BiologicalResourceswith New
Development
4) Require on‐site monitoring of biological
resources by a qualified biologist throughout the
duration of construction activity.
4) Require on‐site monitoring of biological
resources by a qualified biologist throughout the
duration of construction activity and afterwards,
should approval conditions warrant.

N/A CCC suggested modification adds clarifying
language.
4 4.13 ER‐I‐23:

Verificationof ESHA
N/A Historical evidence of ESHA N/A CCC suggested modification adds new sub‐ policy under Verification of ESHA.
4 4.14 ER‐I‐24:

Managementof ESHA
No new development shall be allowed within
primary habitat areas with the
exception of resource‐dependent uses
that can be demonstrated to have no significant
adverse impact.

No new development shall be allowed within ESHA
with the exception of resource‐dependent uses
(such as habitat management and restoration,
scientific research and educational activities, and
low‐intensity public access and recreation) that can
be demonstrated to have no significant disruption
of habitat values.

N/A CCC suggested modification adds clarifying
language.
4 4.14 ER‐I‐24:

Managementof ESHA
• Buffer areas shall be established around all
sensitive resources, providing a minimum of 100
feet, and varying as needed to account for
feeding, breeding, nesting, and other habitat
requirements. Exceptions to such buffer
requirements should be supported by a biological
report demonstrating that the adjusted buffer, in
combination with incorporated siting, design or
other mitigation measures, will prevent impactsthat significantly degrade the ESHA and will be compatible with the continuance of the ESHA.

Buffer adjustments should also be limited to
where the entire subject legal lot is within the
buffer or where it is demonstrated that
development outside the buffer would have agreater impact on the ESHA. • Buffer areas shall be established around all ESHA,
providing a minimum of 100 feet, and may be
expanded as needed to account for feeding,
breeding, nesting, and other habitat requirements.

The 100‐foot buffer may be reduced by the
minimum necessary (1) to avoid a taking (for
private development), or (2) to provide required
public services (for public development), provided
that the buffer is as close to 100 feet as possible,
and no less than 50 feet in any case, and provided
that ESHA resource impacts are avoided as much as
possible, and unavoidable impactscommensurately mitigated, all as conclusively demonstrated by a qualified biologist to the
satisfaction of the City, USFWS, and CDFW.
• Buffer areas shall be established around all ESHA,providing a minimum of 100 feet, and may beexpanded as needed to account for feeding,breeding, nesting, and other habitat requirements.The 100‐foot buffer may be reduced by theminimum necessary (1) to avoid a taking (for privatedevelopment), or (2) to provide required publicservices (for public development), provided that anyunavoidable impacts are commensurately mitigated,that the buffer is as close to 100 feet as possible,and no less than 50 feet in any case, and providedthat ESHA resource impacts are avoided as much aspossible, and unavoidable impacts commensuratelymitigated, all as conclusively demonstrated by aqualified biologist to the satisfaction of the City,USFWS, and CDFW.

CCC suggested modification amends the text toclarify exceptions; however, the statement “noless than 50 feet in any case” is too prescriptiveand does not consider the quality of habitat ordesign alternatives. City staff proposes toeliminate the statement and the buffer will bedecided on a case‐by‐case basis as informed bya qualified biologist.Additional text to clarify that mitigation may benecessary. 4 4.14 ER‐I‐24:

Managementof ESHA
• Alteration of landforms, removal of vegetation,
impervious surfaces, noise, light, and glare shall
be minimized.
• Alteration of landforms, removal of vegetation,
impervious surfaces, noise, light, and glare shall be
minimized as much as possible.

N/A CCC suggested modification amends text to
clarify exceptions.
4 4.15 ER‐I‐28:

ConstructionduringNestingSeason
If site work or construction occurs during the
nesting season (February 1 through August 31),
then pre‐construction breeding bird surveys shall
be performed by a qualified wildlife biologist prior
to any site disturbance to ensure that no nests will
be disturbed or destroyed during Project
implementation. If an active nest is found
sufficiently close to work areas to be disturbed by
construction activities, then the biologist shall
create a no‐disturbance buffer of 250 feet around
passerine nests and a 500 foot buffer around
raptor nests. Work‐free buffer zones shall be
maintained until after the breeding season or until
after the qualified biologist determines the young
If site work or construction occurs during the
nesting season (February 1 through August 31),
then pre‐construction breeding bird surveys shall
be performed by a qualified wildlife biologist prior
to any site disturbance to ensure that no nests will
be disturbed or destroyed during Project
implementation. If an active nest is found
sufficiently close to work areas to be disturbed by
construction activities, then the biologist shall
create a no‐disturbance buffer of 250 feet around
passerine nests and a 500 foot buffer around
raptor nests. Work‐free buffer zones shall be
maintained until after the breeding season or until
after the qualified biologist determines the young
N/A CCC suggested modification deletes text
related to nesting during construction.

Nests initiated during active construction would
be presumed to be unaffected by the activity, and
a buffer zone around such nests is not necessary.

However, nests shall be flagged and construction
activity shall avoid killing and/or injuring nesting
birds.
have fledged (usually late June through mid‐July).
4 4.16 ER‐I‐30:

Protection of
the California
Red‐Legged
Frog and SanFranciscoGarter Snake
To minimize disturbance, require all grading
activity within 100 feet of aquatic habitat shall be
conducted during the dry season (May 1 through
October 15) to protect California red‐legged frog
and San Francisco garter snake. A qualified
biologist shall conduct presence/absence surveys
for California red‐legged frog and San Francisco
garter snake prior to construction in or adjacent
to riparian areas, grasslands near ponds/wetlands,
or other sensitive habitat. Any individuals
identified shall be treated in consultation with
USFWS. Construction shall follow accepted
procedures for exclusion and avoidance of
California red‐legged frog and
San Francisco garter snake and their habitat.

Additionally, the biologist shall supervise the
installation of exclusion fencing along the
boundaries of the work area, shall conduct
environmental awareness training for
construction workers, and shall be present during
initial vegetation clearing and ground‐disturbing
activities.

Allowed construction activity with the potential to
impact California red‐legged frogs and SanFrancisco garter snake shall be conducted during the dry season (May 1 through October 15) to
protect California red‐legged frog and San
Francisco garter snake. In such cases a qualified
biologist shall conduct presence/absence surveys
for California red‐legged frog and San Francisco
garter snake prior to construction in or adjacent to
riparian areas, grasslands near ponds/wetlands, or
other sensitive habitat. Any individuals identified
shall be treated in consultation with USFWS.Construction shall follow accepted procedures for exclusion and avoidance of California red‐legged
frog and
San Francisco garter snake and their habitat.

Additionally, the biologist shall supervise the
installation of exclusion fencing along the
boundaries of the work area, shall conduct
environmental awareness training for construction
workers, and shall be present during initialvegetation clearing and ground‐disturbing activities.

N/A CCC suggested modification adds clarifying
language.
4 4.17 ER‐I‐39: Bowl
Site
Establish appropriate zoning for the “Bowl” site
along the east side of Palmetto Avenue in
Fairmont West for Planned Development to
ensure site planning that clusters development,
avoiding potential flooding or geotechnical
hazards and protecting open space resources.

Establish appropriate zoning for the “Bowl” site
along the east side of Palmetto Avenue in Fairmont
West for Planned Development to ensure site
planning that clusters development, avoiding
potential flooding or geotechnical hazards and
protecting open space resources, and taking all
other coastal resources site constraints into
consideration.

N/A CCC suggested modification adds clarifying
language.
4 4.17
A
Viewsheds Several specific viewsheds from Highway 1 and Sharp Park Road are shown on Figure 4‐4.

N/A Several specific coastal view corridors from Highway 1 and Sharp Park Road are shown on Figure 4‐4.

Edited to match the terminology used in Figure4‐4.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 5 5.1 Natural
Hazards
Ensuring the safety of community members,
through protection from hazards, is an essential
service of public agencies and a critical priority for
maintaining community health. The purpose ofthe Natural Hazards chapter is to establish goals and policies to mitigate the potential impactsfrom natural and man‐made hazards that pose a threat to public health, and safety.

Ensuring the safety of community members,
through protection from hazards, is an essential
service of public agencies and a critical priority for
maintaining community health. The purpose of the
Natural Hazards chapter is to establish goals and
policies to mitigate the potential impacts from
natural and man‐made hazards that pose a threat
to public health, safety, and coastal resources.

N/A CCC suggested modification adds clarifying
language.
5 5.2 Coastal Bluffs A bluff is a high bank or bold headland with a broad, precipitous, sometimes rounded cliff face
overlooking a plain or body of water.

Deleted N/A CCC suggested modification deletes text in an introductory paragraph.
5 5.3 NH‐G‐1:

Reduce Risk
Minimize risks of property damage and personal
injury posed by geologic and seismic hazards.

Protect coastal resources, and minimize risks of
property damage and personal injury posed by
geologic, seismic and coastal hazards.

N/A CCC suggested modification adds clarifying
language.
5 5.3A NH‐I‐3: Fault
Zone
New development shall be sited and designed tominimize risks from seismic events. Building forhuman occupancy shall avoid surface traces ofactive faults, consistent with the Alquist‐PrioloEarthquake Fault Zone Act and other relevantstate laws. (See the Liquefaction and Fault Zonesmap, Figure 5‐1).

N/A New development shall be sited and designed to
minimize risks from seismic events. Continue toreview projects located in identified fault zonessubject to the Alquist‐Priolo Earthquake Fault ZoneAct. (See the Liquefaction and Fault Zones map,Figure 5‐1).

City Council approved GP consistency changes.This alternative modification is necessary tocomply with Coastal Act Section 30253. 5 5.4 NH‐I‐9:

ErosionPrevention
Require erosion prevention of hillside areas by
revegetation or other acceptable methods.

Deleted NH‐I‐9: Hillside Erosion Prevention.

Encourage erosion prevention of hillside areas tomaintain slope stability by revegetation. Other slopestability methods may be acceptable, consistentwith this LCP.

CCC suggested modification deleted the entirepolicy related to hillside erosion prevention.City staff alternative modification clarifies thatthe policy is intended for hillside erosion, andnot bluff erosion. 5 5.5 NH‐I‐10:

Geotechnical
Studies
• Within 50 feet of a bluff. • Within 300 feet of a bluff edge in Coastal Vulnerability Zones.

N/A CCC suggested modification amends policy to
include Coastal Vulnerability Zones.
5 5.5 NH‐I‐10:

Geotechnical
Studies
Geotechnical studies shall identify any geologic
hazards affecting the proposed project site, any
necessary mitigation measures, and a statement
of the site’s suitability for the proposed
development and whether or not it will be safe
from geologic hazard for its expected life.

Geotechnical studies shall identify any geologic
hazards affecting the proposed project site, any
necessary mitigation measures, and a statement of
the site’s suitability for the proposed development
and whether or not it will be safe from geologic
hazard for its anticipated life.

N/A CCC suggested modification amends the text to
be consistent with new definitions.
5 5.6 NH‐I‐17:

Developmentin CoastalZone
• Not accelerate the need for a shoreline
structure or increase the likelihood of a future
seawall beyond the existing development’s
expected life;
N/A N/A CCC suggested modification deletes text
related to new development.
5 5.6 NH‐I‐17:

Developmentin CoastalZone
Small improvement projects are exempt, including
improvements that would increase height, bulk or
floor area by less than ten percent.

N/A N/A CCC suggested modification deletes text
related to small improvements to align with
the Substantial Structural Modificationdefinition.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 5 5.7 Flood Zones Flood hazards mapped by FEMA to support the development of Flood Insurance Rate Maps
(FIRMs) generally identify areas of greater flood
risk (100 and 500 year events) in the lower
reaches of the main stream channels, and the risk
of coastal flooding along the shoreline. Flood
zones based on the FIRMs are shown in Figure 5‐3.

Flood hazards mapped by FEMA to support the
development of Flood Insurance Rate Maps
(FIRMs) generally identify areas of greater flood
risk (100 and 500 year events) in the lower reaches
of the main stream channels, and the risk of coastal
flooding along the shoreline, although they do not
account for climate change or sea level rise, and
thus should be reviewed in conjunction with
Appendix B (“Coastal Zone Vulnerability Maps”).

Flood zones based on the FIRMs are shown in
Figure 5‐3.

N/A CCC suggested modification adds clarifying
language.
5 5.8 NH‐G‐2:

Developmentin Hazardous
Areas
Protect development in 100‐year floodplains and
tsunami hazard zones with flood damage
prevention programs.

Site and design development in 100‐year
floodplains and tsunami hazard zones to minimize
hazard risk without the need for armoring (e.g.
flood damage prevention programs).

N/A CCC suggested modification adds clarifying
language.
5 5.9 NH‐I‐24:

Flood HazardReduction
Flood Hazard Reduction. Continue to comply with
the Flood Damage Prevention Ordinance in the
Municipal Code.

Deleted N/A City staff is not proposing an alternative
modification; however, once the City’s Flood
Prevention Ordinance is certified by CCC an LCP
amendment can be processed to include the
policy in the LCLUP.
5 5.10 NH‐I‐ 26:

Flood Control
Maintenance
Regularly maintain flood control structures,
including, but not limited to drainage channels,
pipes, culverts, and stream beds.

Regularly maintain flood control structures,
including, but not limited to drainage channels,
pipes, and culverts.

Regularly maintain flood control structures,including, but not limited to drainage channels,pipes, and culverts.Routine maintenance of streambeds shall conformto the Coastal Act, including but not limited toSection 30236.

CCC suggested modification removedstreambeds from the policy. Significant areasof Pacifica are serviced by creeks as criticalstormwater infrastructure that require regularmaintenance. City staff alternativemodification clarifies that all routinemaintenance in streambeds will conform to theCoastal Act. 5 5.11 NH‐I‐27:

Flood Control
Structures
Require flood control devices that alter streams to
incorporate best mitigation measures whenever
feasible, and only permit them where no other
method for protecting existing structures in the
flood plain is feasible, where such
protection is necessary for public safety, or to
protect existing development.

Require flood control devices that alter rivers and
streams to incorporate the best mitigation
measures feasible, and only permit them where no
other method for protecting existing structures in
the flood plain is feasible, where such protection is
both necessary for public safety, including for
water supply, and to protect existing development,
or where the primary function is the improvementof fish and wildlife habitat.

N/A CCC suggested modification amends policy text
to include rivers, water supply, and mention of
fish and wildlife habitat.
5 5.12 NH‐I‐31:

CriticalFacilitiesLocation
Site critical public facilities including hospital and
healthcare facilities, emergency shelters, police
and fire stations, and emergency communications
facilities outside of the tsunami evacuation zone,
and 100‐year flood plains.

Site critical public facilities including hospital and
healthcare facilities, emergency shelters, police
and fire stations, and emergency communications
facilities outside of the tsunami evacuation zone,
100‐year flood plains, and other portions of the
Coastal Vulnerability Zone over the anticipated life
of the development.

N/A CCC suggested modification amends policy text
to include Coastal Vulnerability Zones.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification

5.13 NH‐I‐35:

DevelopmentReview
Review development proposals to ensure that
they incorporate appropriate fire‐mitigation
measures, including adequate provisions for
evacuation, access by emergency responders, and
vegetation clearances that don’t impact ESHAs or
wetlands.

Review development proposals to ensure that they
incorporate appropriate fire‐mitigation measures,
including adequate provisions for evacuation,
access by emergency responders, and vegetation
clearances that don’t impact ESHAs or wetlands or
their associated buffers, unless undertaken
consistent with the City’s ESHA and wetlands
policies.

N/A CCC suggested modification amends policy text
to expand considerations of ESHA buffers
5 5.14 NH‐I‐39:

Vegetation
Management
Promote and support the North County Fire
Authority’s Vegetation Management Program to
reduce urban/wildland interface fire hazards.

Promote and support the North County Fire
Authority’s Vegetation Management Program to
reduce urban/wildland interface fire hazards, if
consistent with the LCP.

All vegetation management efforts should include
coordination with applicable City Departments andState and Federal agencies.

CCC suggested modification amends policy to
require LCP consistency; however, City staff is
proposing an alternative modification toaddress a grammatical error. 6 6.1 Coastal
Resilience
The purpose of this chapter is to provide policies
which protect existing development from the
hazard of sea level rise and which guide the design
of new development to respond to sea level rise
during the economic life of the project. Topics
covered in this element include sea level rise
projections, transfer of development rights (TDR),
repair and replacement of existing shoreline
protection structures (e.g., sea walls), and
establishment of appropriate site design measures
for new development. Protection of property
rights is an important theme in this chapter.

The purpose of this chapter is to provide policies
which protect existing development from the
hazard of sea level rise and which guide the design
of new development to respond to sea level rise
during the anticipated life of the project. Topics
covered in this element include sea level rise
projections, transfer of development rights (TDR),
repair and replacement of existing shoreline
protection structures (e.g., sea walls), and
establishment of appropriate site design measures
for new development.

The purpose of this chapter is to provide policieswhich protect existing development from the hazardof sea level rise and which guide the design of newdevelopment to respond to sea level rise during theanticipated life of the project. Topics covered in thiselement include sea level rise projections, transferof development rights (TDR), repair andreplacement of existing shoreline protectionstructures (e.g., sea walls), and establishment ofappropriate site design measures for newdevelopment. Balancing appropriate protection ofproperty and coastal resources along the dynamiccoastline is an important theme in this chapter.

CCC suggested modification deletesintroductory text. City staff is proposing analternative modification to add languagerelated to balancing City priorities. 6 6.2 A Coastal Act
Policies
N/A N/A Additionally, for all purposes within this LCLUP, no activity undertaken pursuant to Section 30610(g) of
the Coastal Act shall be construed to be a
Substantial Structural Modification as defined in this
LCLUP.

Staff had previously recommended an
alternative modification that would reinsert
reference to Section 30610(g) of the Coastal
Act into the exclusions of the SSM definition.

Upon further discussion with CCC staff, City
staff agrees with the removal of language
referencing subdivision (g) of Section 30610 of
Public Resources Code from the exclusion
language of the SSM definition. This codeprovision within the Coastal Act is applicable to properties within the City and would not
equate to a SSM and thus does not need to be
included as an exclusion in the SSM definition.

CCC staff prefers, and City staff agrees, that
this provision and definition not be interpreted
together.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.2 Coastal Act
Policies
Therefore, the policies focus on protection and
armoring of the shoreline and reassessment of the
adaptation plan in the future. The policies do not
include managed retreat as an adaptation strategy
unless and until a future Local Coastal Land Use
Plan amendment and public input process
culminates in supporting the strategy.

Therefore, the policies focus on protecting beaches
and the natural shoreline while also allowing for
protection and armoring of the shoreline for
specific limited circumstances as provided for
within the Coastal Act and reassessment of the
adaptationplan in the future.

N/A CCC suggested modification clarifies language
to be consistent with the Coastal Act.
6 6.3 Vulnerability
Assessment ‐
PacificInstituteStudy
However, because the Coastal Vulnerability Zone
Maps show significant erosion for areas that are
protected by existing shoreline protectionstructures, the Maps highlight the importance of the existing structures and the vital need for them
to be maintained to protect those vulnerable
areas.

Deleted However, because the Coastal Vulnerability Zone Maps show significant erosion for areas that areprotected by existing shoreline protectionstructures, the Maps highlight the protectionprovided by the structures.

CCC suggested modification deletes
introductory text. City staff is proposing analternative modification to add languagerelated to the existing shoreline protections inthe City. 6 6.4 Adaptation
Plan
The cost‐benefit analysis section of the
Adaptation Plan was not adopted or approved by
the City of Pacifica. The purpose of the cost
benefit analysis was to provide information
regarding various sea level rise scenarios and
adaptation options and was not intended to
prescribe specific adaptation policies. The cost‐
benefit analysis shall not be used for any future
purpose by the City of Pacifica or its planning
processes, including implementation of the Local
Coastal Program, public infrastructure investment,
permitting or other regulatory purposes.

Deleted The cost‐benefit analysis section of the Adaptation Plan was not adopted or approved by the City ofPacifica. The purpose of the cost benefit analysiswas to provide information regarding various sealevel rise scenarios and adaptation options and wasnot intended to prescribe specific adaptationpolicies. The cost‐benefit analysis was perceived torequire additional work to adequately analyze thevalue of public recreational amenities.

CCC suggested modification deletesintroductory text. City staff is proposing analternative modification to add languagerelated to the cost‐benefit analysis. 6 6.4 Adaptation
Plan
The findings of the Adaptation Plan are just one of
the considerations that were used to develop the
Coastal Resilience policies below and, as
discussed, the Coastal Resilience policies focus on
protection and armoring of the shoreline and
reassessment of the Adaptation Plan in the future.

The findings of the Adaptation Plan are just one of
the considerations that were used to develop the
Coastal Resilience policies below and, as discussed,
the Coastal Resilience policies focus on protection
and armoring of the shoreline for specific limited
circumstances as provided for within the Coastal
Act and reassessment of the Adaptation Plan in the
future.

N/A CCC suggested modification adds clarifying
language.
6 6.4 Adaptation
Plan
Therefore, changes to the cost‐benefit analysis in
a manner to discourage managed retreat as
suggested by some public commenters detailed
below would be unnecessary since the Coastal
Resilience policies do not include managed retreat
as an adaptation strategy. As noted earlier in this
section, the cost‐benefit analysis prepared for the
Adaptation Plan shall not be used for any future
purpose by the City of Pacifica or its planning
processes.

Deleted Therefore, changes to the cost‐benefit analysis are not necessary to inform the Coastal Resiliencypolicies.

CCC suggested modification deletesintroductory text. City staff is proposing analternative modification to add languagerelated to the cost‐benefit analysis. 6 6.4 Adaptation
Plan
The Adaptation Plan was prepared to inform City
decision making about a variety of sea level rise
adaptation policies, but does not include or
dictate the ultimate policies selected by the City.

Although managed retreat alternatives are
analyzed in the Adaptation Plan in accordance
Deleted The Adaptation Plan was prepared to inform City decision making about a variety of sea level riseadaptation policies, but does not include or dictatethe ultimate policies selected by the City. Althoughmanaged retreat alternatives are analyzed in theAdaptation Plan in accordance with the City’s grant CCC suggested modification deletesintroductory text. City staff is proposing analternative modification to add languagerelated to the Adaptation Plan and potentialfuture changes.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justificationwith the City’s grant agreement with the CCC, these analyses do not, in themselves, equate to a
managed retreat policy. To the contrary, the City
has rejected managed retreat as a sea level rise
adaptation policy in this LCP and managed retreat
could only become the policy of the City
subsequent to a future amendment to the LCP.
agreement with the CCC, these analyses do not, inthemselves, equate to a managed retreat policy.The City uses other sea level rise adaptation policiesin this LCP and any future changes to these policieswill require an amendment to this LCP. 6 6.5A CR‐I‐1:

VulnerabilityIdentificationand Mapping
The City’s Coastal Vulnerability zones shall bemapped based on the best available science aboutprojected sea level rise, erosion, flooding, andother coastal hazards. Mapping shall be updatedas necessary to guide implementation of the LCP’sCoastal Resilience policies.

N/A Delete An additional modification removes the entirety of this policy and replaces it with the policybelow.
6 6.5 CR‐I‐1:

Vulnerability
Identificationand Mapping
Notwithstanding the Coastal Vulnerability Zone
Maps, site‐specific hazard mapping and
assessment may be required as part of the
individual development review process for
properties within the City’s Coastal Vulnerability
zones.

Notwithstanding the Coastal Vulnerability Zone
Maps, site‐specific hazard mapping and assessment
may be required as part of the individual
development review process for properties within
the City’s Coastal zone.

N/A Delete CCC suggested modification amends policy to
include Coastal Vulnerability Zones.An additional modification removes the entirety of this policy and replaces it with thepolicy below. 6 6.5B CR‐I‐1:

CoastalVulnerabilityZones
N/A N/A Those areas of the City that are predicted to be vulnerable to coastal hazards have been mapped asCoastal Vulnerability Zones in Appendix B, wheresuch mapping is based on the best available scienceabout projected sea level rise, erosion, flooding, andother coastal hazards at the time of LUP adoption. Itis likely that such areas will change over time, andAppendix B shall be regularly updated to guideimplementation of the LCP’s coastal resiliencyprovisions. In any case, however, if best availablescience at the time an application is reviewed showsthat proposed development located outside of suchmapped area is also vulnerable to coastal hazards,then such application shall be reviewed as thoughsuch development was located in the CoastalVulnerability Zones. 6 6.6 CR‐I‐2: Sea
Level RiseAdaptationPlanDevelopmentin CoastalVulnerabilityZones Adaptation alternatives evaluated in the
Adaptation Plan that are not specifically expressed
in these Coastal Resilience policies shall not be
implemented without an amendment to the LCP,
public notice, and opportunity for public input.

Deleted N/A CCC suggested modification deletes text
6 6.6A CR‐I‐2
Developmentin CoastalVulnerabilityZones
The City shall implement its Sea Level RiseAdaptation Plan as expressed in the general andsub‐area Coastal Resilience policies. Adaptationalternatives evaluated in the Adaptation Plan thatare not specifically expressed in these CoastalResilience policies shall not be implementedwithout an amendment to the LCP, public notice, N/A Deleted An additional modification removes this entire text.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justificationand opportunity for public input. The City shallmonitor implementation and, consistent withCoastal Resilience Policy CR‐I‐4, update the SeaLevel Rise Adaptation Plan to strengthen publicsafety, preserve existing neighborhoods, assurelocal economic vitality, respond to climate change,promote environmental justice, implement theCoastal Act, and protect the public trust. 6 6.6B CR‐I‐2
Developmentin CoastalVulnerabilityZones
Development in Coastal Vulnerability Zones maybe approved consistent with the sub‐area policiesin Section 6.6 if the following findings can bemade:

N/A Development located in Coastal Vulnerability Zones
may only be approved if such development,measured over its full anticipated life, is sited,designed, and conditioned:

Alternative modification to demonstratecompliance with Coastal Act. 6 6.6C CR‐I‐2
Developmentin CoastalVulnerabilityZones
a. The proposed development is sited anddesigned to avoid, and where unavoidable, tominimize coastal hazards and impacts to coastalresources to the maximum extent feasible,consistent with the Adaptation Plan; N/A a. To avoid, and where unavoidable, to minimize
risks from coastal hazards to the maximum feasible;
Alternative modification to demonstratecompliance with Coastal Act. 6 6.6 CR‐I‐2: Sea
Level RiseAdaptationPlanDevelopment inCoastalVulnerabilityZones b. All project impacts on coastal resources are
mitigated to the maximum extent feasible through
the City’s Shoreline Mitigation Program (Coastal
Resilience Policy CR‐I‐5) or consistent with Coastal
Resilience Policy CR‐I‐59.
b. All project impacts on coastal resources are
avoided, and where unavoidable, minimized and
mitigated to the maximum extent consistent with
Coastal Resilience Policy CR‐I‐59.

N/A b. To avoid, and where unavoidable, to
minimize and commensurately mitigate to themaximum extent feasible; CCC suggested modification amends policy to
prioritize avoidance of coastal resource
impacts
6 6.6 CR‐I‐2: Sea
Level RiseAdaptationPlanDevelopmentin CoastalVulnerabilityZones c. The project will not pose unacceptable risks to
life or property or otherwise create a nuisance;
and
c. The project will not pose unacceptable risks to
life or property for the anticipated life of the
development or otherwise create a nuisance;
N/Ac. To avoid creating a nuisance; Clarification to align with proposed added definition of "“anticipated life"”
6 6.6 CR‐I‐2: Sea
Level RiseAdaptationPlanDevelopmentin CoastalVulnerabilityZones d. The project will not encroach on public trust
lands.
d. The project will not encroach on public trust
lands for the anticipated life of the development;
and
N/A d. To avoid encroachment onto public trust
lands; and
Clarification to align with proposed addeddefinition of "“anticipated life"” 6 6.6 CR‐I‐2: Sea
Level RiseAdaptationPlanDevelopmentin CoastalVulnerabilityZones N/A e. The project is designed to assure stability and
structural integrity absent the need for shoreline
protective devices.
e. The project is designed to To assure stability and
structural integrity absent the need for withoutreliance on shoreline protective protection devicesfor the anticipated life of the development.

CCC suggested modification is an addition of a
Coastal Act provision. City staff alternative
modification clarifies that the policy relates to
the anticipated life of the developmentconsistent with other policies in the LCP.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.7 CR‐I‐3:

MonitoringShorelineChange
The monitoring program shall include yearly
(minimum) shoreline and bluff edge surveys and
also establish thresholds for reassessing the City’s
Adaptation Plan.

The monitoring program shall include biannual
(minimum following winter and summer) shoreline
and bluff edge surveys and also establish
thresholds for reassessing the City’s Adaptation
Plan.

The monitoring program shall include biannual(minimum following winter and summer) shorelineand bluff edge surveys and also establish thresholdsfor reassessing the City’s Adaptation Plan.The City, in coordination with Coastal Commissionstaff, shall create an alternating schedule to performhalf of the required surveys each year.

CCC suggested modification would require theCity to conduct additional monitoring. The newrequirement may be too burdensome on Cityresources. City staff proposes an alternativemodification that would allow the City toalternate the areas that are surveyed andtiming in order to realistically meet therequirements of this policy. The schedulewould be created in coordination with CCCstaff in order to provide the most valuable andefficient data. 6 6.7A CR‐I‐4
AssessingCoastalResiliencyProvisionsImplementation
The City shall reassess its Sea Level RiseAdaptation Plan as expressed in the general andsub‐area Coastal Resilience policies every fiveyears or sooner as required by the shorelinemonitoring program (Coastal Resilience Policy CR‐I‐3). The reassessment shall consider thefollowing:
 Efficacy of Adaptation Plan and
implemented measures.
 Updated sea level rise projections and
risks.
 Potential need to revise adaptation
measures or implement new measures,including review of emerging engineering,science, and technologies.  Funding needs and potential funding
sources.

The draft findings of the City’s reassessment shallbe disseminated to the public for review andcomment prior to being finalized.

N/A The City shall assess implementation of the LCP’s
coastal resiliency provisions at least every five years,where such assessment shall at the minimumconsider the following:
 The efficacy of such provisions at protecting
and enhancing the City’s beach andshoreline area resources, criticalinfrastructure, and other built and naturalenvironment features.  Updated seal level rise projections and risks. The potential need to revise coastal resiliency measures and/or to implementnew measures, including review ofemerging engineering, science, andtechnologies.  Funding needs and potential funding
sources.
 The results of the City’s shoreline
monitoring program (CR‐I‐3), shorelineadaption program (CR‐I‐5), adaptationfunding efforts (CR‐I‐6), consideration of anLCP transfer of development rights program(CR‐I‐7), critical transportationinfrastructure efforts (CR‐I‐8), hazard proneinfrastructure efforts (CR‐I‐9), businessoutreach efforts (CR‐I‐10), high water markefforts (CR‐I‐11), flood ordinance and LHMPconsistency efforts (CR‐I‐11 and CR‐I‐12),sediment management and beachnourishment programs (CR‐I‐14 and CR‐I‐15), additional flood protection efforts (CR‐I‐16), groundwater monitoring efforts (CR‐I‐17), and Caltrans coordination efforts (CR‐I‐18).

The City shall use such assessment efforts to formthe basis for LCP updates and changes to betteraddress coastal hazards in a way that can protectand enhance bluff, shoreline, offshore, and sandybeach recreational areas for public use and Alternative modification to demonstratecompliance with Coastal Act.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification enjoyment while ensuring all development(including private structures and publicinfrastructure) are safe from coastal hazards asmuch as possible both now and in the future. 6 6.8 CR‐I‐5:

ShorelineAdaptation
MitigationProgram
Within three years of certification of the LCP Land
Use Plan update, the City shall adopt a Shoreline
Mitigation Program to address the coastal
resource impacts of existing and future shoreline
protection projects in the City.

Within three years of certification of the LCP Land
Use Plan update, the City shall adopt a Shoreline
Mitigation Program to address the coastal resource
impacts of existing and future shoreline protection
projects in the City, and it shall be submitted to the
Coastal Commission for certification as an LCP
amendment.

N/A Within 10 years of the certification of this LUP
the City shall develop a Shoreline AdaptationProgram for the City’s shoreline and obtain CoastalCommission certification of the LCP amendmentinformed by the Plan. The Program is encouraged tobe made up of sub‐area plans for smaller sections ofthe coastline that share similar attributes, shall buildon past adaptation work, and identify adaptationapproaches that will be implemented to addressvulnerabilities and protect coastal resourcesthroughout the City.The Program shall be consistent with and help tosupport and implement the Coastal Access andResilience Program developed per CR‐I‐44 and at aminimum address the following topics:
a) Existing and Future Conditions.

Leveraging any existing relevant data orstudies, describe the relevant shorelinearea in terms of its resources andconstraints. Identify baseline conditionsin terms of existing public and privatedevelopment; shoreline, sandy beach,and offshore public access andrecreational areas; and environmentalresources. Include an assessment ofbeach widths throughout tidal andseasonal ranges. Additionally, analyzehow conditions are expected to changeas coastal hazards (including short‐ andlong‐term erosion and flooding) areexacerbated by sea level rise. Describehow the presence or absence ofdevelopment and shoreline protectionstructures has impacted and isprojected to impact conditions overtime, particularly how suchdevelopment would or would not allowfor natural migration of beaches overtime and impact public use andavailability of the sandybeach/shoreline. Identify areas wherebeaches would likely be able to persist ifable to migrate as sea levels rise versus CCC suggested modification requires LCPamendment to incorporate shorelinemitigation program. Alternative modification todemonstrate compliance with Coastal Act. Thispolicy has been expanded to included specificdetails regarding CCC’s expectation of what thescope of the Program should be and sets a 10‐year timeline by which the Program needs tobe certified. This program is meant tocompliment the Coastal Access and ResilienceProgram, associated with the Special ShorelineResiliency Areas.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification those areas where thegeology/conditions are such that thecontinued presence of beaches in suchareas is unlikely. b) b) Goals and Actions. Describe the
overall vision for Pacifica’s coastline(and each sub‐area) over the short,medium, and long‐term horizon. Thisvision shall relate to the opportunitiesand constraints identified above andshall include specific goals and actionsfor protection of public access andcoastal resources and minimization ofcoastal hazard risks. The Program shallprovide requirements for adaptingexisting and future development,including public and private structures,community infrastructure, coastalaccessways, and other shoreline areadevelopment to meet specific goals inline with the overall vision of the City’sshoreline (and each sub‐area), includingas such objectives may differ by sub‐areas. Strategies to consider shallinclude but are not limited to sedimentmanagement, beach nourishment,green infrastructure, shorelinearmoring, elevation of development,structural modifications, and removal ofdevelopment as part of a Transfer ofDevelopment Rights Program (Policy CR‐I‐7) or other voluntary process forproperty owners. Additionally, theProgram shall identify the timeline overwhich different options may be applied,including how different strategies wouldbe phased over time, and shall explicitlydefine triggers for when differentadaptation options would need to beimplemented. The Program shall alsodescribe the policy options (e.g., landuse and zoning requirements,development approval conditions, deedrestrictions, design guidelines, etc.),specific projects, and fundingmechanisms necessary to ensureadaptation actions are carried out. c) Special Shoreline Resilience Areas.

Considering the existing and futureshoreline conditions and the City’s goalsand actions described in parts (a) and Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification (b) above, evaluate phased adaptationapproaches for the Special ShorelineResilience Areas. Consider the extent towhich armoring shoreline protectionstructures may continue to be thepreferred adaptation approach orwhether alternatives may betterachieve City goals and result inpreferred coastal resource outcomes.Furthermore, analyze the ability of thearmoring shoreline protectionstructures to withstand coastal hazardconditions over time as sea levels rise,the feasibility and costs of anticipatedmaintenance activities, any anticipatedaugmentations or replacement that maybe necessary over time as sea levelsrise, and any threshold hazardconditions beyond which the armoringshoreline protection may not be able tofunction and the associated adaptationmeasures that would be necessitatedfor the development that relies on theshoreline protection. d) Sandy Beach Areas. The City shall
identify all sandy beach areas thatprovide for associated recreationalopportunities, including but not limitedto Sharp Park south of the Pacifica pier,southern Rockaway Beach, and PacificaState Beach. For areas where publicbeach access has already been or islikely to be limited and eventually lostdue to the presence of developmentthat prevents natural beachformation/migration, the Program shallfocus on strategies that will result in theremoval of development to allow fornatural beach migration processes. TheProgram for these sandy beach areas(broken down by each sub‐area as wellas overall) shall also include thefollowing:i. Minimum Sandy Beach Widths. Ananalysis of the minimum width of sandybeach necessary to maintain optimumpublic recreational access and habitatfunction. This analysis shall includeconsiderations of daily tidal range,seasonal erosion, and short‐ term,storm‐ driven erosion when determining Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification optimum beach widths. Additionally,the analysis shall assess the types ofadaptation strategies, including but notlimited to sediment management,beach nourishment, and removal ofdevelopment (subject to voluntarymechanism available to propertyowners, as described above), along withappropriate triggers for when differentadaptation strategies should beimplemented to ensure that minimumsandy beach widths are maintained overtime as sea levels rise.ii. Sandy Beach Monitoring. TheProgram shall include monitoringprotocols for the width of the beach aswell as recreational access, sandy beachuse, and habitat values throughout theyear and over time. Such monitoringprotocols shall identify and tracklocations, times, and durationsthroughout the year when the sandybeach is too narrow to be adequate forpublic recreation and/or lateral access.Such monitoring will ensure that theminimum beach width establishedthrough the analysis above is adequatefor maintaining public access andcoastal resource values and will providethe necessary information for whenadaptation triggers are met, asdescribed below.iii. Sandy Beach Adaptation. TheProgram shall identify the suite ofactions and programs that will beimplemented over time to maintainsandy beach utility. The Program shallalso include explicit triggers forsediment management, beachnourishment, voluntary developmentremoval, and/or alternative strategiesthat are designed to ensure that theidentified minimum sandy beach widthis maintained. The Program shallidentify “maintenance” triggers forwhen beach nourishment or relatedstrategies to protect sandy beach areasshould occur as well as “adaptation”triggers for when new adaptation Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification strategies will have to be implementedin order to preserve beach recreationalaccess as sea levels rise and erosionworsens.iv. Mitigation. The Program shallinclude provisions designed to offsetloss of sandy beach area, includingapplication of complementaryprovisions for offsetting such lossesthrough enhancements in otherbeach/shoreline areas in the City ifapplicable.e. Alternative Access. Where geologicconditions or land use patterns andshoreline armoring approaches will limitthe ability of sandy beaches to persist(even without the presence ofdevelopment and shoreline protectionstructures), the Program shall identifyoptions to allow for alternative types ofshoreline access. Such options mayinclude, but are not limited to, verticalaccess to rocky shorelines or to theocean, lateral access along blufftops oras part of shared vertical seawalls,viewing platforms, and parks. TheProgram shall identify preferredlocations for such features and tools forensuring such features are constructedand maintained (e.g. conditions ofapproval, shoreline protection structuredesign requirements, acquisition ofeasements or other areas, voluntaryremoval of development, etc.).Additionally, the Program shall identifyand describe how such features shouldbe adapted and modified over time assea levels rise to ensure access ismaintained over time.f) Funding Opportunities.Identification of potential fundingopportunities to support short‐,medium‐, and long‐term adaptationoptions. This shall include funding forimplementation of specific adaptationprojects (e.g. sediment management,beach nourishment, greeninfrastructure, habitat restoration, Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification development removal, etc.);construction of public access features;purchase of deed restrictions,easements, or similar interests; andstructural buyouts and relatedopportunities for acquisition andremoval of structures encroachingwithin the established sandy beachareas. Potential funding opportunitiesmay include in‐lieu fees (including thosegenerated from mitigation for shorelineprotection structures per Policy CR‐I‐59), grants, state/federal funds, andGHADs/CSAs. Opportunities to integrateadaptation strategies with otherplanning processes (e.g., Local HazardMitigation Plans, Capital ImprovementPlans, Climate Action Plans, etc.),including in order to leverage fundingoptions, shall also be explored.g) GHADs/CSAs. Identification ofmeasures necessary to support creationof Geologic Hazard Abatement Districts,City Service Areas, or other similarentities involving one or more sectionsof the coastline, as a preferredmechanism for implementation ofShoreline Adaptation Program (andrelated LCP amendment) requirements. 6 6.8 CR‐I‐5:

ShorelineMitigationProgram
Until the adoption of a Shoreline MitigationProgram, coastal resource impacts shall bemitigated in accordance with CR‐I‐59.

Until the adoption of a Shoreline MitigationProgram by the City and subsequent certificationby the Coastal Commission, coastal resourceimpacts shall be mitigated in accordance with CR‐I‐59.

N/A Deleted CCC suggested modification requires LCP
amendment to incorporate shorelinemitigation program
6 6.8A CR‐I‐7
Transfer ofDevelopmentRightsProgram
Use the City’s transfer of development rights(TDR) ordinance to relocate development rightsfrom Coastal Vulnerability zones (sending sites) toreceiving sites outside of Coastal Vulnerabilityzones. Identify areas where densities and heightsmay be increased using TDR credits, including tofacilitate affordable housing.

N/A The City shall explore the ways in which the City’s transfer of development rights (TDR) ordinancecould be applied within the LCP to relocatedevelopment rights from Coastal Vulnerability Zones(sending sites) to receiving sites outside of CoastalVulnerability Zones, including to identify areaswhere densities and heights may be increased usingTDR credits, including to facilitate affordablehousing.

Clarification of policy text.
6 6.9 CR‐I‐8:

Critical
TransportationInfrastructure
The City will pursue opportunities to preserve ,
protect, or relocate critical local transportation
infrastructure, or provide alternative access, to
mitigate against isolation and economic loss, and
to ensure public safety.

The City will pursue opportunities to preserve ,
protect, or relocate critical local transportation
infrastructure, or provide alternative access, to
mitigate against isolation and economic loss, and
to ensure public safety, while avoiding (and where
unavoidable minimizing and mitigating) impacts to
coastal resources, including public access and
The City will pursue opportunities to preserve,
protect, or relocate critical local transportation
infrastructure, or provide alternative access, to
mitigate against isolation and economic loss, and to
ensure public safety, while avoiding (and where
unavoidable minimizing and mitigating) impacts to
coastal resources, including public access and
City staff alternative modification would delete
the word “prior,” which clarifies that a permit
must be obtained and can be modified through
the appropriate approval process over time.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification recreation, to the maximum extent feasible, and
being consistent with prior permit conditions
and/or legal obligations pursuant to the California
Coastal Act.
recreation, to the maximum extent feasible, and
being consistent with prior permit conditions and/or
legal obligations pursuant to the California Coastal
Act.
6 6.10 CR‐I‐9:

Hazard ProneInfrastructure
The City will preserve, protect, or relocate hazard
prone infrastructure to maintain critical services.

The City will preserve, protect, or relocate hazard
prone infrastructure to maintain critical services
and protect coastal resources, including if required
by prior permit conditions and/or legal obligations
pursuant to the California Coastal Act.

The City will preserve, protect, or relocate hazardprone infrastructure to maintain critical services and protect coastal resources, including if required by
prior permit conditions and/or legal obligations
pursuant to the California Coastal Act.

City staff alternative modification would delete
the word “prior,” which clarifies that a permit
must be obtained and can be modified through
the appropriate approval process over time.
6 6.10
A
CR‐I‐13:LHMPAlignment
The City will coordinate its departments andprograms to align the Local Hazard Mitigation Plan(LHMP) with the LCP to ensure proactive,coordinated and streamlined adaptation effortsand response to future coastal hazards. The Cityshall leverage FEMA funding opportunities forhazard mitigation and other related fundingmechanisms to implement the Sea Level RiseAdaptation Plan as expressed in the general andsub‐area Coastal Resilience policies.

N/A The City will coordinate its departments and
programs to align the Local Hazard Mitigation Plan(LHMP) with the LCP to ensure proactive,coordinated and streamlined adaptation efforts andresponse to future coastal hazards. The City shallleverage FEMA funding opportunities for hazardmitigation and other related funding mechanisms toimplement the LCP’s coastal resiliency provisions.

Correction of references.
6 6.11 CR‐I‐15:

ShorelineProtectionStructures
N/A Shoreline Protection Structures. Shoreline
protection structures shall be avoided except thatexisting shoreline protection structures may bemaintained or new shoreline protection structuresconstructed to protect existing structures in dangerfrom erosion if found to be the leastenvironmentally‐damaging alternative, impacts tobeach, public access and recreation, and othercoastal resources are fully mitigated consistentwith CR‐I‐5 and CR‐I‐59, and compliant with anyprior permit conditions and/or legal obligationspursuant to the California Coastal Act . Allowshoreline protection structures for the public roadand sewer line existing structures if necessary andconsistent with Policies CR‐I‐56 and CR‐I‐57, otherLCP policies, and the Coastal Act. Newdevelopment on blufftops shall comply will all LCPsetback policies, including CR‐I‐44.

N/A Deleted CCC suggested modification reorganizes the
document.An additional modification deletes this thatwas a CCC suggested modification. 6 6.12 CR‐I‐1516:

BeachNourishment
N/A Beach Nourishment. Evaluate the feasibility of
using beach nourishment, in conjunction with sand
retention structures (see artificial headlands
concept in the Adaptation Plan) as described in CR‐
I‐55, to reduce shoreline protection structure
maintenance requirements and maintain beaches
of at least 100 feet in width on average. If feasible
and approved through a coastal development
permit, secure funding and implement as soon as
possible. Repeat as necessary. Mitigate all adverse
impacts and monitor effectiveness over time.

In coordination with the California Coastal
Commission and other permitting agencies (e.g.,State Lands Commission, U.S. Army Corps ofEngineers), the City shall evaluate a beachnourishment program in conjunction with sandretention structures (see artificial headlands concept in the Adaptation Plan) as described in CR‐I‐
55, to reduce shoreline protection structurerequirements and maintain beaches of at least 100feet in width on average, consistent with other LCPpolicies and the Coastal Act. The beach nourishment CCC suggested modification was an attempt to
organize the document by taking several
policies in the subarea sections related to
Beach Nourishment and putting them in
Section 6.5 Coastal Resiliency Policies to apply
to the entire Coastal Zone. However, City staff
proposes an alternative modification that ismore inclusive of all the language that is included in the 2020 Revised Certification Draft
related to Beach Nourishment by deleting CR‐I‐
55 and incorporating the language into CR‐1‐
Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification program will need to be evaluated to be the leastenvironmentally damaging feasible alternative andwill include measures to protect water quality andto avoid (and where unavoidable to minimize andmitigate) potential adverse coastal resourceimpacts, including biological resource impacts, fromdeposition of material, including measures such assand compatibility specifications, restrictions onvolume of deposition, timing or seasonalrestrictions, and identification of environmentallypreferred locations for deposits.

16.5 6 6.12
A
CR‐I‐16:AdditionalFloodProtectionMeasures.

N/A N/A Additional Flood Protection Measures. The City shall evaluate the need for additional flood protectionmeasures, which may include:
 Clarendon Road and/or West Fairway Park
stormwater basin, pump station, and/orinterior Sharp Park Golf Course levee to helpprotect homes and businesses;  A San Pedro Creek floodwall along
commercial property to help manageflooding;
 Floodproofing at the Anza (stormwater)
and/or Linda Mar (sewer and stormwater)pump stations to help protect againstcoastal storm flooding vulnerabilities; and  Elevate and floodproof development
structures if consistent with any permitconditions and/or legal obligations pursuantto the California Coastal Act as necessary tomitigate flood damage, consistent withheight limitations.

Reorganization of document and combinedpolicy text.
6 6.12
B
CR‐I‐17GroundwaterMonitoring
N/A N/A The City shall begin groundwater monitoring to help determine needs for dewatering wells in the lowestportions of the coastal neighborhoods.

An additional modification that reorganizes thedocument and also broadens the applicability ofthis policy. 6 6.12
C
CR‐I‐18CaltransCoordination
N/A N/A The City shall coordinate with Caltrans to evaluate options for protecting Highway 1, if necessary.

An additional modification that reorganizes thedocument.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.13
A
SubareaDescriptions
The following policies and programs implementthe near‐term sea level rise adaptation prioritiesfor each sub‐area in Pacifica, and identify mid‐ andlong‐term adaptation measures, subject tofeasibility and monitoring concerns. Thesepriorities were developed based on existingconditions and existing/near term vulnerabilitiesfor each sub‐area, as well as the City’s adoptedgoals for sea level rise adaptation.

The following section discusses implementation the
near‐term sea level rise adaptation priorities foreach sub‐area in Pacifica, and identifies mid‐ andlong‐term adaptation measures, subject tofeasibility and monitoring concerns. These prioritieswere developed based on existing conditions andexisting/near term vulnerabilities for each sub‐area,as well as the City’s adopted goals for sea level riseadaptation.

Typo correction needed due to reorganization ofchapter. 6 6.13 Sub‐area
Policies andPrograms
Where applicable, the titles of the policies in this
subsection detail when the policy should be
implemented. For example, CR‐I‐15 Shoreline
Protection Structures (0‐1 foot SLR or 260‐footoffset from bluff toe to infrastructure) should be implemented when 0 to 1 foot of sea level rise or
a 260‐foot bluff offset is experienced. The bluff
offset is measured distance between the edge of
the bluffs and the asset (e.g., infrastructure,
development). These triggers do not account for
regulatory permitting, approvals, or financing;
therefore planning should be done in advance of
the triggers.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.13 Sub‐area
Policies andPrograms
Generally, for all lands within the 2050 Pacific
Institute erosion hazard zone11, utilities, roadways
and other public infrastructure should be
floodproofed unless other adaptation alternatives
are implemented and performing well.

Generally, for land within the Coastal Vulnerability
zones, utilities, roadways and other public
infrastructure should be floodproofed unless other
adaptation alternatives are implemented and
performing well, and only if consistent with LCP
and Coastal Act policies.

N/A Generally, for land within the CoastalVulnerability Zones, utilities, roadways and otherpublic infrastructure should be floodproofed unlessother adaptation alternatives are implemented andperforming well, and only if consistent with LCP andCoastal Act policies.

CCC suggested modification amends text to use
Coastal Vulnerability Zones. Alternative
Modification to address a typo
6 6.13 Sub‐area
Policies andPrograms
In addition, the City should, when appropriate,
evaluate and pursue floodproofing infrastructure
that may be currently exposed to coastal erosion
and flooding to reduce the consequences of
under‐performance of protection measures (CR‐I‐
61).

In addition, the City should, when appropriate,
evaluate and pursue floodproofing infrastructure
that may be currently exposed to coastal erosion
and flooding to reduce the consequences of under‐
performance of protection measures, only if such
floodproofing infrastructure is the least
environmentally damaging feasible alternative and
consistent with LCP and Coastal Act policies (CR‐I‐
61).

In addition, the City should, when appropriate,
evaluate and pursue floodproofing infrastructure
that may be currently exposed to coastal erosion
and flooding to reduce the consequences of under‐
performance of protection measures, only if suchfloodproofing infrastructure is designed to eliminate or mitigate adverse impacts on local shoreline sandsupply, consistent with LCP and Coastal Act policies(CR‐I‐1661).

CCC suggested modification amends text to
related to floodproofing infrastructure. City
staff is proposing an alternative modification toclarify requirements for sand supply. 6 6.13 Sub‐area
Policies andPrograms
The City’s overall approach for new development
is to minimize or avoid current and projected
future coastal hazards through siting and design.

At the same time, managed retreat is not included
in any of the near‐term policies. Managed retreat
would be reconsidered if feasibility and
monitoring warranted, as detailed in Coastal
Resilience Policies CR‐I‐3 and CR‐I‐4.

The City’s overall approach to address coastal
hazards is through siting and design of new
development to be out of harm’s way and to limit
shoreline armoring as much as possible, including
to help preserve and protect the City’s shoreline
and beaches.

N/A CCC suggested modification deletes
introductory language specific to managedretreat. Since the text is not policy language,staff is not proposing an alternativemodification. 6 6.14 Special
ResiliencyAreas
N/A N/A The Special Resiliency Areas (SRA) include the
existing shoreline protection structures in theRockaway Beach and West Sharp Park sub‐areas.These areas have existingshoreline protection In order to address many of the CCC suggestedmodification’s impacts on Pacifica’s existingdeveloped neighborhoods, City staff isproposing an alternative modification that Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification structures protect a mix of unified coastal access,including coastal access points and trails; publicinfrastructure, including sidewalks, roads, water,and sewer; electrical utilities; and public parking,both on‐ and off‐street. development patterns withsignificant amounts of Pre‐Coastal Act development,a mix of public streets and infrastructure, land useprioritized by the Coastal Act, and significant unifiedpublic coastal access, all protected by broad existingshoreline protection, The unique circumstance inthat warrant a unique policy approach. The purposeof modifying policies applicable to this area is toallow ongoing economic use and vitality of property,provision of public services, operation of visitor‐serving uses, and protection of robust coastal accessfor all persons including persons with disabilitieswithin a Special Resiliency Area (SRA). The two SRAlocations are identified in Figure 6‐2 and
6‐3.
would create two Special Resiliency Areas(SRAs), which would allow those areas greaterflexibility in permitting requirements anddesign.The Special Shoreline Resilience Area policiesare incorporated at the end of the chapter. 6 6.15 CR‐I‐17
ShorelineManagementPlan
N/A N/A The City will establish a funding source for visitor amenity improvements implementation. Fundingsources may include, but not be limited to, grants,fees, assessments, taxes, and any other lawfulpublic or private funding sources. The City willcreate a funding and implementation plan withspecific projects to improvese visitor amenities inthe Special Resiliency Areas or elsewhere in Pacifica.Creation of this plan will include communityoutreach and input. The plan will be updated every5 years and will identify specific short‐, medium‐,and long‐term projects to mitigate coastal resourceimpacts from ongoing reliance on shorelineprotection within Special Resiliency Areas. Ingeneral, the implementation plan will fund a varietyof projects identifying and carrying out shorelineprotection removal opportunities, implementingnature‐based solutions to adapt existing shorelineprotection devices, maintenance or alteration ofexisting shoreline protection devices to expandpublic coastal access including but not limited totrails and beach access, acquiring and conservingundeveloped coastal properties, and enhancingvisitor amenities. Specific amenity improvementsand shoreline protection device removal may occuranywhere within the City of Pacifica. provided untilsuch time as the CCC certifies the plan In order to address many of the CCC suggestedmodification’s impacts on Pacifica’s existingdeveloped neighborhoods, City staff isproposing an alternative modification thatwould create two SRAs, which would allowthose areas greater flexibility in permittingrequirements and design.The Shoreline Management Plan is intended toprovide other types of coastal enhancementsand benefits, such as increased coastal access,while allowing the existing shoreline protectionstructures in Rockaway Beach and West SharpPark to be used in technical analysis of hazardsfor development in those areas.The Special Shoreline Resilience Area policiesare incorporated at the end of the chapter.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.16 CR‐I‐15:

ShorelineProtection
Structures (0‐
1foot SLR or
260 footoffset from
bluff toe to
infrastructure)
Shoreline Protection Structures (0‐1 foot SLR or
260‐foot offset from bluff toe to infrastructure).

Shoreline protection structures shall be avoided
except that the existing shoreline protection
structures may be maintained or new shoreline
protection structures constructed to protect
existing structures in danger from erosion if found
to be the least environmentally‐damaging
alternative, impacts are fully mitigated consistent
with CR‐I‐5, and compliant with any prior permit
conditions and/or legal obligations pursuant to
the California Coastal Act . Allow shoreline
protection structures for the public road and
sewer line existing structures if necessary and
consistent with Policies CR‐I‐56 and CR‐I‐57, other
LCP policies, and the Coastal Act. New
development on blufftops shall comply will all LCP
setback policies, including CR‐I‐44.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.17 CR‐I‐16:

BeachNourishment(2 feet SLR or
260‐footoffset from
bluff toe to
infrastructure).

Beach Nourishment (2 feet SLR or 260‐foot offset
from bluff toe to infrastructure). Evaluate the
feasibility of using beach nourishment, in
conjunction with sand retention structures (see
artificial headlands concept in the Adaptation
Plan) as described in CR‐I‐55, to reduce shoreline
protection structure maintenance requirements
and maintain beaches of at least 100 feet in width
on average. If feasible and approved through a
coastal development permit, secure funding and
implement as soon as possible. Repeat as
necessary. Mitigate all adverse impacts and
monitor effectiveness over time.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.17
A
CR‐I‐17Transfer ofDevelopmentRights(ongoing).

Provide an option to private landowners tovoluntarily transfer development potential assupported by CR‐I‐7.

N/A Deleted An additional modification deletes this policy to reorganize and condense the chapter.
6 6.18 CR‐I‐18:

ShorelineProtection
Structures (0‐
1 foot SLR or
220‐foot
offset from
bluff toe to
infrastructure ordevelopment)
Shoreline Protection Structures (0‐1 foot SLR or
220‐foot offset from bluff toe to infrastructure or
development). Maintain existing or construct new
shoreline protection structures to protect existing
public infrastructure structures, including
between Bill Drake Way and Manor Drive. Allow
private property owners to maintain existing or
construct new shoreline protection structures if
allowed pursuant to Policies CR‐I‐56 and CR‐I‐57,
and if consistent with prior permit conditions
and/or legal obligations pursuant to the California
Coastal Act, and require mitigation of beach,
public access and recreation and other coastal
resource impacts, consistent with CR‐I‐5 or CR‐I‐
Deleted N/A CCC suggested modification reorganizes the
document.

BeachNourishment(0‐1 foot SLRor 220‐foot
offset from
bluff toe to
infrastructure or
development)
Beach Nourishment (0‐1 foot SLR or 220‐foot
offset from bluff toe to infrastructure or
development). Evaluate the feasibility of using
beach nourishment, in conjunction with sand
retention structures (artificial headlands concept)
as described in CR‐I‐55, to reduce shoreline
protection structure maintenance requirements
and maintain beaches of at least 100 feet in width
on average. If feasible and approved through a
coastal development permit, secure funding and
implement as soon as possible. Mitigate all
adverse impacts and monitor effectiveness over
time.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.20 CR‐I‐20:

ShorelineProtection
Structures (0‐
1 feet SLR or
70‐footoffset from
bluff toe to
development
orinfrastructure).

Shoreline Protection Structures (0‐1 feet SLR or
70‐foot offset from bluff toe to development or
infrastructure). Private landowners may maintain,
expand, or construct new shoreline protection
structures to protect existing structures in danger
from erosion, consistent with CR‐I‐2 and any prior
permit conditions and/or legal obligations
pursuant to the California Coastal Act.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.21 CR‐I‐21:

BeachNourishment(0‐2 feet SLR
or 70‐footoffset from
bluff toe to
development
orinfrastructure).

Beach Nourishment (0‐2 feet SLR or 70‐foot offset
from bluff toe to development or infrastructure).

Evaluate the feasibility of using beach
nourishment, in conjunction with sand retention
structures (artificial headlands concept), to reduce
shoreline protection structure maintenance
requirements and maintain beaches of at least100 feet in width on average. If feasible and approved through a coastal development permit,
secure funding and implement as soon as
possible. Repeat as necessary. Mitigate all adverse
impacts and monitor effectiveness over time.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.22 CR‐I‐22:

FloodProtection (1feet SLR)
Flood Protection (1 feet SLR). Enable property
owners to modify development structures (e.g.,
elevate a residence) to manage impacts of wave
run‐up and overtopping of bluff face.

Flood Protection. Enable property owners to modify
development structures to manage impacts of waverun‐up and overtopping of bluff face provided suchmodifications are consistent with the LCP and anyprior permit conditions and/or legal obligationspursuant to the California Coastal Act. Deleted City staff alternative modification would delete
the word “prior,” which clarifies that a permit
must be obtained and can be modified through
the appropriate approval process over time.

An additional modification removes this policy
to reorganizes the document and condense thepolicies.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.23 CR‐I‐23:

Sharp ParkGolf Course
Sharp Park Golf Course. Strongly support the City
and County of San Francisco’s maintenance of the
Sharp Park Golf Course berm and armoring,
consistent with the Coastal Development Permit
issued by the California Coastal Commission,
including adaptation planning for the course, andprotecting public access.

The City of Pacifica shall strongly support the City
and County of San Francisco’s ongoing
maintenance of the berm even if Coastal
Commission termination of authorization is
trigged by the conditions of approval, or require
construction of flood protection improvements by
the City and County of San Francisco.

Deleted Sharp Park Golf Course. Strongly support City and County of San Francisco’s ability to provide publicaccess along the coast, protect EnvironmentallySensitive Habitat Areas, and provide floodprotection. Deleted CCC suggested modification deleted the entirepolicy related to the Sharp Park Golf Course.City staff is proposing an alternativemodification that would keep a policy relatedto the Sharp Park Golf Course but would focuson public access and resource enhancements.An additional modification removes this policyto reorganize the chapter. The policy isreinserted below. 6 6.24 CR‐I‐24:

ShorelineProtection
Structures (0
feet SLR)
Shoreline Protection Structures (0 feet SLR).

Maintain existing or construct shoreline
protection structures to protect existing public
infrastructure structures if consistent with Policies
CR‐I‐56 and CR‐I‐57. Extend the Beach Boulevard
seawall to the Sharp Park Golf Course berm if
consistent with Policies CR‐I‐56 and CR‐I‐57.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.25 CR‐I‐25:

StructureElevation (0‐
2 feet SLR)
Structure Elevation (0‐2 feet SLR). Maintain
existing or construct shoreline protection
structures if consistent with Policies CR‐I‐56 and
CR‐I‐57 to limit wave overtopping unless beach
nourishment strategies are effective in reducing
wave run‐up on the backshore. Elevate
development structures if consistent with Policy
CR‐I‐61 as necessary to mitigate flood damage,
consistent with height limitations. Elevations of
wave run‐up and associated development
thresholds shall be determined via a site‐specific
study.

Structure Elevation. Maintain existing or constructshoreline protection structures if consistent withPolicies CR‐I‐56 and CR‐I‐57, and with any priorpermit conditions and/or legal obligations pursuantto the California Coastal Act to limit waveovertopping unless beach nourishment strategiesare effective in reducing wave run‐up on thebackshore. Elevate development structures ifconsistent with Policy CR‐I‐61, and with any priorpermit conditions and/or legal obligations pursuantto the California Coastal Act as necessary to mitigateflood damage, consistent with height limitations,determined via a site‐specific study. Deleted City staff alternative modification would deletethe word “prior,” which clarifies that a permitmust be obtained and can be modified throughthe appropriate approval process over time.An additional modification removes this policyto reorganize the chapter and condense thepolicies. 6 6.26 CR‐I‐26:

BeachNourishment(0‐1 feet SLR)
Beach Nourishment (0‐1 feet SLR). Pursue beach
nourishment and sand retention structures to
reduce shoreline protection structure
maintenance requirements and provide beach
resources. Encourage the City and County of San
Francisco to nourish the beach fronting the Sharp
Park Golf Course berm to maintain beach widths.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.27 CR‐I‐27:

FloodProtection (0
foot SLR)
(0 foot SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.27
A
CR‐I‐27 FloodProtection
Evaluate and construct appropriate floodprotection measures, which may include aClarendon Road stormwater basin, pump station, N/A Deleted Reorganization of chapter.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justificationand/or interior Sharp Park Golf Course levee, toprotect homes and businesses from existing fluvialstorm flood hazard zone. 6 6.28 CR‐I‐28:

FloodProtection (3
feet SLR).
(3 feet SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.28 CR‐I‐28 Flood
Protection
Evaluate the future need to construct a WestFairway Park stormwater basin, pump station, andinterior Sharp Park Golf Course levee to protectwestern homes from future coastal/fluvial floodhazard zone.

N/A Deleted Reorganization of chapter.
6 6.29 CR‐I‐29:

ShorelineProtection
StructureShorelineProtectionStructures (0
feet SLR).

Shoreline Protection Structure Shoreline
Protection Structures (0 feet SLR). Maintain
existing or construct new shoreline protection
structures along the north cove for public safety
and hazard reduction if consistent with Policies
CR‐I‐56 and CR‐I‐57.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.30 CR‐I‐30:

ShorelineProtection
(2‐3 feet SLR,or whenbackshoretoe is 100feet fromHighway 1). (2‐3 feet SLR, or when backshore toe is 100 feet
from Highway 1)
Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.30
A
CR‐I‐30:ShorelineProtection
Coordinate with Caltrans to evaluate the need fora revetment or other appropriate shorelineprotection for the Highway 1 embankment.

N/A Deleted Reorganization of chapter.
6 6.31 CR‐I‐31:

Public Access
(0 feet SLR).
(0 feet SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.31
A
CR‐I‐31:Public Access
Plan and provide for enhanced public access,consistent with the City’s Shoreline MitigationProgram (CR‐I‐5).

N/A Deleted Reorganization of chapter.
6 6.32 CR‐I‐32:

BeachNourishment/Public
Access (0
feet SLR).

Beach Nourishment/Public Access (0 feet SLR).

Plan and implement beach nourishment for
Rockaway Beach. Monitor and measure
performance and any reduction of shoreline
protection structure maintenance needs. Establish
mechanisms through the City’s Shoreline
Mitigation Program (CR‐I‐5) to receive and use
beach impact mitigation funds from other sub‐
areas of the City.

Deleted N/A CCC suggested modification reorganizes the
document.

Implement new development shoreline setbacksconsistent with CR‐I‐44.

N/A Deleted Reorganization of chapter.
6 6.32
B
CR‐I‐34Transfer ofDevelopmentRights(ongoing).

Provide an option to the private landowners ofthe Rockaway Headlands to voluntarily transferdevelopment potential as supported by CR‐I‐7.

N/A Deleted Reorganization of chapter.
6 6.33 CR‐I‐35:

ShorelineProtection (2
ft SLR or 100
foot offsetfromshoreline toinfrastructure).

Shoreline Protection (2 ft SLR or 100 foot offset
from shoreline to infrastructure). Evaluate beach
conditions and consider future shoreline
protection to protect existing parking structures
and the existing Linda Mar stormwater and
wastewater pump station structures as necessary.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.34 CR‐I‐37:

BeachNourishment(2 ft SLR or
100 footoffset from
shoreline toinfrastructure).

Beach Nourishment (2 ft SLR or 100 foot offset
from shoreline to infrastructure). Evaluate beach
conditions and implement beach nourishment as
necessary to maintain a 100‐foot buffer seaward
of the sewer force main and/or Highway 1. Repeat
nourishments as needed.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.34
A
CR‐I‐36Highway OneProtections
Coordinate with Caltrans to evaluate options forprotecting Highway 1, if necessary.

N/A Deleted Reorganization of chapter.
6 6.35 CR‐I‐38:

FloodProtection (0
feet SLR).
(0 feet SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.35
A
CR‐I‐38:FloodProtection
Analyze need for floodwall along commercialproperty to manage flooding from San PedroCreek under existing conditions with sea level riseallowance. Future flood studies that includeclimate‐driven changes in precipitation shouldinform any floodwall design. Floodproof Anzapump station (stormwater) to mitigate existingcoastal storm flooding vulnerabilities to wave run‐up.

N/A Deleted Reorganization of chapter.
6 6.36 CR‐I‐39:

FloodProtection (2feet SLR or100‐foot
offset from
(2 feet SLR or 100‐foot offset from shoreline to
infrastructure)
Deleted N/A CCC suggested modification generalize policy and reorganized the document.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification shoreline toinfrastructure).
6 6.36
A
CR‐I‐39:FloodProtection
Floodproof the Linda Mar pump stations (sewerand stormwater) to mitigate future coastal stormflooding vulnerabilities to wave run‐up asnecessary.

N/A Deleted Reorganization of chapter.
6 6.37 CR‐I‐40:

GroundwaterManagement(0‐2 feet
SLR).
(0‐2 feet SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.37
A
CR‐I‐40:GroundwaterManagement
Begin groundwater monitoring to determineneeds for dewatering wells in the lowest portionsof the West Linda Mar neighborhood.

N/A Deleted Reorganization of chapter.
6 6.38 CR‐I‐41:

ShorelineProtection
StructureUpgrades.

Shoreline Protection Structure Upgrades. Allow
maintenance of existing or new shoreline
protection structures to reduce hazards and
resource impacts if consistent with Policies CR‐I‐
56 and CR‐I‐57. Mitigate impacts consistent with
the City’s Shoreline Mitigation Program (CR‐I‐5),
or CR‐I‐59, as necessary.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.38 CR‐I‐42:

FloodProtection
(0‐1 feetSLR).
(0‐1 feet SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.38
A
CR‐I‐42:FloodProtection
Allow private property owners to raise homes andother development structures above wave run‐uphazards if consistent with Policy CR‐I‐61,consistent with height limitations.

N/A Deleted Reorganization of chapter.
6 6.40 CR‐I‐1943:

TechnicalReports.

Development proposed on the shoreline shall
include coastal engineering, geomorphology and
other relevant technical reports unless on‐site
hazards already identified in a recent Coastal
Vulnerability Zone Map or assessment approved
within the last five years are adequate for
evaluating and ensuring compliance with the LCP,
including through use of permit conditions to
address any uncertainty.

Development proposed in Coastal Vulnerability
Zones shall include coastal engineering,
geomorphology and other relevant technical
reports unless on‐site hazards already identified in
a recent Coastal Vulnerability Zone Map or
assessment approved within the last five years are
adequate for evaluating and ensuring compliance
with the LCP, including through use of permit
conditions to address any uncertainty.

N/A CCC suggested modification amends the text to
make the policy applicable to Coastal
Vulnerability Zones, instead of shorelineproperties.
6 6.41 CR‐I‐1943:

TechnicalReports.
• consider the impacts from the med‐high
projection (CalNRA & OPC 2018) of sea‐level rise
for the anticipated duration of the proposed
development;
• consider the impacts from the med‐high
projection (CalNRA & OPC 2018; or similar
precautionary projections as reflected in future
updated statewide guidance) of sea‐level rise for
the anticipated life of the proposed development;
N/A consider the impact from the intermediate‐high
projections (CalNRA & OPC 2024; or similarprecautionary projections as reflected in futureupdated statewide guidance) of sea‐level rise forthe anticipated life of the proposed development CCC suggested modification amends the text to
reflect that best available science may change
over time.
6 6.42 CR‐I‐1943:

TechnicalReports.
• demonstrate that the development will avoid (or
if unavoidable, minimize) impacts from coastal
hazards to the maximum extent feasible; and
• demonstrate that the development will avoid (or
if unavoidable, minimize) impacts from coastal
hazards for the anticipated life of the proposed
development without reliance on any existing or
future shoreline protection devices;
demonstrate that the development will avoid (or ifunavoidable, minimize) impacts from coastalhazards for the anticipated life of the proposeddevelopment without reliance on any existing orfuture shoreline protection devices, except that CCC suggested modification reflects languagefrom the Sea Level Rise adopted policyguidance. City staff is generally in support ofthe modification; however, staff is proposingan alternative modification to address the Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification development behind Special Shoreline ResiliencyAreas will be allowed to consider protectionprovided by existing shoreline protection structureswhen analyzing hazards; may consider CR‐I‐38, CR‐I‐39 and CR‐I‐41.

Special Shoreline Resiliency Areas. Thealternative modification will give the SRA theability to use the existing shoreline protectionsstructures when analyzing coastal hazardsimpacts. 6 6.43 CR‐I‐1943:

TechnicalReports.

N/A • demonstrate that the factor of safety for blufftop development will be greater than or equal to 1.5
for static conditions and greater than or equal to

1.1 for seismic conditions; and
N/Afor blufftop and/or shoreline development, be
set back a sufficient distance from the blufftop edgeor highest predicted water line, accounting for waverunup, highest astronomical tide, storm surge, andother relevant factors (and at least 25 feet, or addetermined by site‐specific conditions) to avoidcoastal hazard risks to the maximum degreepossible while ensuring stability and structuralintegrity in light of potential erosion and othercoastal hazards, where such minimum requiredsetback shall be the distance necessary for allstructural development (including any decks, fences,patios, arbors, and other ancillary development, andgenerally not including native landscaping, minorgrading for landscaping/restoration purposes, andother similar non‐structural development) to stayinland of a line that identifies the future predictedlocation of the blufftop edge or highest predictedwater line, accounting for wave runup, highestastronomical tide, storm surge, and other relevantfactors, accounting for expected erosion and a bluffstability factor of safety of at least 1.5 for staticconditions and at least 1.1 for seismic conditions(where K=0.15) or sea level rise and other climatechange impacts as applicable; and CCC suggested modification adds clarifying
language related to safety requirements.
6 6.44 CR‐I‐2044:

Siting andDesign.

New development on vacant shoreline property
shall be sited and designed to be safe from
erosion, bluff failure, wave run‐up, flooding and
other coastal hazards for at least 100 years
without shoreline protection, considering
projected sea level rise and other climate change
effects to be determined from best available
science and current guidance at the time of
approval of the proposed development. Permit
approvals shall prohibit shoreline protection
structures for the authorized development,
require the property owner to record an
acknowledgement that the development does not
qualify as an existing structure entitled to
construction of a shoreline protection structure
under Coastal Act Section 30235 and a waiver of
any rights to such protection structures and where
necessary require a removal and restoration plan,
including bonding for large projects, to avoid
future shoreline protection structures or project
failure.

New development in Coastal Vulnerability Zones
shall be sited and designed to be safe from erosion,
bluff failure, wave run‐up, flooding and other
coastal hazards for at least 100 years without
shoreline protection, considering projected sea
level rise and other climate change effects to be
determined from best available science and current
guidance at the time of approval of the proposed
development, as demonstrated by site‐specific
analyses and/or technical reports. Permit approvals
shall prohibit shoreline protection structures for
the authorized development, require the property
owner to record an acknowledgement that the
development does not qualify as an existing
structure entitled to construction of a shoreline
protection structure under Coastal Act Section
30235, and any other laws, that waive any rights to
such protection structures that might exist, and
that, where necessary, requires a removal andrestoration plan, including bonding for large projects, to avoid future shoreline protection
New Ddevelopment in Coastal Vulnerability Zonesshall be sited, and designed, and setback from theblufftop and/or shoreline to be safe from erosion,bluff failure, wave run‐up, flooding and othercoastal hazards for at least 100 years the anticipatedlife of the development or in accordance with CR‐I‐19, without shoreline protection, consideringprojected sea level rise and other climate changeeffects to be determined from best available scienceand current guidance at the time of approval of theproposed development, as demonstrated by site‐specific analyses and/or technical reports. Coastaldevelopment pPermit approvals shall prohibitshoreline protection structures for the authorizeddevelopment, require the property owner to recordan acknowledgement that the development doesnot qualify as an existing structure entitled toconstruction of a shoreline protection structureunder Coastal Act Section 30235, and any otherlaws, that waive any rights to such protectionstructures that might exist, and that, where CCC suggested modification amends the policyto be applicable to the Coastal VulnerabilityZone and reflects current CCC conditions ofapproval. City staff is generally in support ofthe modification; however, staff is proposingan alternative modification to address theSpecial Resiliency Areas. The alternativemodification will give the SRA the ability to usethe existing shoreline protections structureswhen siting and designing development.Additionally, staff is proposing an alternativemodification to change the year time period to“anticipated life.” A CCC suggestedmodification added a definition for anticipatedlife, staff is proposing this alternativemodification to be consistent throughout thedocument.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification structures or project failure. necessary, requires a removal and restoration plan, including bonding for large projects, to avoid futureshoreline protection structures or project failure.However, behind Special Shoreline Resiliency Areasdevelopment may consider CR‐I‐38, CR‐I‐39, and CR‐I‐44. , new development shall be allowed to be sitedand designed in reliance on and in consideration ofprotection provided by existing shoreline protectionstructures. 6 6.45 CR‐I‐2145:

Assumptionof Risk byPrivateLandowners.CoastalHazards RiskDisclosure Permit approvals of development on the shoreline
shall require the applicant to record a deed
restriction requiring the owner to assume liability
and indemnify and hold the City harmless and
make other acknowledgments relating to the risks
of development on the property.

Permit approvals of development in Coastal
Vulnerability Zones and Tsunami Evacuation Zones
shall require the applicant to: record a deed
restriction requiring the owner to assume liability
and indemnify and hold the City, its officers,agents, and employees harmless, including any injury and/or damage from coastal hazards in
connection with the permitted development;
unconditionally waive any claim of damage from
coastal hazards against the City; waive rights to
future shoreline armoring; acknowledge the
development may need to be removed and the site
restored in response to future hazard conditions;
and to assume all responsibility for any adverse
effects to property caused by the permitted project
and/or need for removal or relocation of
development.

Permit Coastal Development Permit approvals ofdevelopment in Coastal Vulnerability Zones or andTsunami Inundation Zones shall require theproperty owners of all affected properties to recorddeed restrictions against all such properties prior toissuance of coastal development permits for thedevelopment wherein the property ownersacknowledge and agree, on behalf of themselvesand all successors and assigns that theyapplicant to:record a deed restriction requiring the owner toassume liability and indemnify and hold the City, itsofficers, agents, and employees harmless, includingany injury and/or damage from coastal hazards inconnection with the permitted development;unconditionally waive any claim of damage fromcoastal hazards against the City; waive rights tofuture shoreline armoring; acknowledge thedevelopment may need to be removed and the siterestored in response to future hazard conditions;and to assume all responsibility for any adverseeffects to property caused by the permitted projectand/or need for removal or relocation ofdevelopment.  acknowledge the site is subject to coastal
hazards, including but not limited toepisodic and long‐ term shoreline retreatand coastal erosion, high seas, ocean waves,storms, tsunami, tidal scour, coastalflooding, landslides, bluff and geologicinstability, and the interaction of same, andall as impacted by sea level rise;  assume and accept the risks to themselves
and their properties of injury and damagefrom such coastal hazards in connectionwith the permitted development;  unconditionally waive any claim of damage
or liability against the City and its officers,agents, and employees, for injury and/ordamage in connection with the permitteddevelopment; CCC suggested modification amends the policyto be applicable to the Coastal VulnerabilityZone and Tsunami Evacuation Zone andreflects current CCC conditions of approval.City staff is generally in support of themodification; however, City staff proposes tochange “Evacuation” to “Inundation” zone. Theuse of Tsunami Evacuation Zones for thispurpose is overly broad and not closely enoughrelated to actual tsunami hazard conditions.City staff’s alternative modification will ensurea requirement more closely aligned with actualhazard conditions.Additional modifications include specificlanguage to be included in deed restrictions.Additionally, City Council directed staff toinclude an exception clause to this policy. CCCstaff does not agree with the exception clausebecause it could lead to error and omissions intechnical reports that would put the City andproperty at risk. The policy is a disclosure ofrisks and does not require action until and ifhazards occur. Staff request Council directionon this specific topic.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification  indemnify and hold harmless the City and its
officers, agents, and employees withrespect to the City’s approval of thedevelopment against any and all liability,claims, demands, damages, costs, expenses,and amounts paid in settlement arising fromany injury and/or damage in connectionwith the permitted development, includingin terms of the approval or issuance of thecoastal permit, the interpretation and/orenforcement of coastal permit terms andconditions, or any other matter related tothe coastal permit;  acknowledge public funds may not be
available in the future to repair, maintain,and/or continue to provide infrastructureand related services to the property (e.g.,roads and utilities), and that the occupancyof structures may be prohibited if suchservices are no longer available to serve thedevelopment, including where sewagedisposal and/or water systems are renderedinoperable;  waive any rights that might exist under
applicable law for shoreline protectionstructures for the duration the permitteddevelopment is present on the property;  acknowledge the development may need to
be removed and the site restored inresponse to future hazard conditions and/orcertain defined triggers identified in theLCLUP and implementing Programs and/oras identified by the terms and conditions ofthe CDP including when deemed unsafe, ifland comes to be impressed with a publictrust interest, when within 10 feet of theblufftop edge, when within 10 feet of themean high tide line, when no longer servedby necessary utilities/infrastructure, , whencoastal hazards would necessitateconstruction of a shoreline protectionstructure to ensure safe occupancy of thedevelopment, and/or as part of shorelineprotection structure repair/maintenance ifthe development is not permitted to obtainshoreline protection; and  acknowledge any adverse effects to
property caused by the approveddevelopment shall be fully the responsibilityof the property owner, including any cost Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification associated with abatement and/or futurerelocation/removal of structures due tocoastal hazards; and acknowledge approvalof coastal development permits shall notconstitute a waiver of any public rights thatmay exist on the affected properties(including but not limited to the public’sright of access onto or across the property),and such property owner shall not use anysuch approval as evidence of a waiver of anypublic rights that may exist on the affectedproperties now or in the future.

Except that an applicant shall not be required torecord a deed restriction as described in this policyif a site‐specific geotechnical hazard analysisprepared by a qualified professional licensed by theState of California determines that the project sitewould not be subject to the hazard(s) identified inthe CoastalVulnerability Zones and Tsunami Inundation Zonefor the Anticipated Life of the project. 6 6.45
A
CR‐I‐23 BluffFaceDevelopment
Shoreline protection structures, grading, andlandform alteration on bluff faces are prohibited,except for the following:
 Public access structures where no feasible
alternative means of public access exists;and
N/A Development on bluff faces is prohibited, except for the following:
 Native bluff landscaping; public recreational
access improvements (e.g. stairways, paths,overlooks, ramps, etc.) and critical publicinfrastructure (e.g. public roads, publicutility infrastructure, etc.) where no feasiblealternative means of providing suchimprovements/infrastructure exists; and Clarifies policy.
6 6.46 CR‐I‐2549:

SubstantialModifications to Existing
Structures.

Substantial Modifications to Existing Structures.

When a proposed physical improvement to an
existing structure would constitute a Substantial
Exterior Structural Modification (SESM), as
defined, the portion of the project constituting a
SESM shall be undertaken consistent with the LCP
and, if applicable, the Coastal Act, including but
not limited to Policies CR‐I‐43 and CR‐I‐44. Any
portion of the existing structure that remains and
which is determined to be legally nonconforming
with an LCP standard, including bluff setbacks or
other hazard criteria, shall not be modified to
increase the degree of nonconformity.

Substantial Structural Modifications. Whenproposed modifications to an existing structureconstitute a Substantial Structural Modification(SSM), as defined, such proposed development shallcorrect any existing legal nonconformities and shallbe undertaken consistent with the LCP and theCoastal Act, including but not limited to Policies CR‐I‐1943 and CR‐I‐2044. Except that in SpecialResiliency Areas, development shall only berequired to correct existing nonconformities relatedto applicable coastal hazards on the site.Nonconformities related to non‐coastal resourceissues may be maintained at the discretion of thedecision making body so long as they do not lead tosignificant impacts to coastal resource CCC suggested modification requires projectsthat meet the SSM definition to correct anyexisting legal nonconformities, in order to theentire site to be compliant with the LCP andCoastal Act. Staff is generally in support;however, staff is proposing an alternativemodification to address the Special ResiliencyAreas. The alternative modification will givethe SRA the ability to correct only existingnonconformities associated with coastalhazards present on the site, rather than abroader range of potential LCLUP or zoningnonconformities. 6 6.47 CR‐I‐2751:

Habitat Sea
Level RiseMigrationBuffers.

A sea level rise buffer area shall be added to
require new development habitat buffers if
necessary to allow for the migration of wetlands
and other coastal habitats caused by sea level rise
over the anticipated duration (i.e., economic life)
An additional sea level rise buffer area shall be
added to required habitat buffers if necessary to
allow for the migration of wetlands and other
coastal habitats caused by sea level rise over the
anticipated life of the development. Habitats
A sea level rise buffer area shall be added torequired habitat buffers if necessary to allow for themigration of wetlands and other coastal habitatscaused by sea level rise over the anticipated life ofthe development. The overall buffer area shall CCC suggested modification would require anadditional seal level rise buffer. Staff isgenerally in support of the modification;however, staff is proposing an alternativemodification to clarify that a buffer area should Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justificationof the development. Habitats include all wetlands, riparian, intertidal/shoreline and terrestrial
environmentally sensitive habitat areas (ESHAs) as
defined by the Coastal Act. The sea level rise
projection considered shall be determined for the
type of development from CalNRA and OPC (2018)
guidance or the latest update.
include all wetlands, riparian, intertidal/shoreline
and terrestrial environmentally sensitive habitatareas (ESHAs) as defined by the Coastal Act. The sea level rise projection considered shall be
determined based on the type of development and
current State guidance.
include both the sea level rise and habitat buffer.Habitats include all wetlands, riparian,intertidal/shoreline and terrestrial environmentallysensitive habitat areas (ESHAs) as defined by theCoastal Act. The sea level rise projection consideredshall be determined based on the type ofdevelopment and current State guidance. N/A include all the buffer requirements.During the May 23 discussion, City Councildirected staff to keep the CCC suggestedmodification and remove the alternativemodification. 6 6.47
A
CR‐I‐29SubdivisionLimitations
Update the Zoning Ordinance to prohibit thedivision of shoreline property that createshazardous or unbuildable parcels due to erosion,bluff failure, wave run‐up, flooding and othercoastal hazards for at least 100 years withoutshoreline protection, considering projected sealevel rise and other climate change effects to bedetermined from best available science andcurrent guidance at the time of approval of theproposed development. Only allow new lots to becreated if they can be developed without everrequiring shoreline protection for thedevelopment.

N/A Prohibit the division of shoreline property that
creates hazardous or unbuildable parcels due toerosion, bluff failure, wave run‐up, flooding andother coastal hazards for at least 100 years withoutshoreline protection, considering projected sea levelrise and other climate change effects to bedetermined from best available science and currentguidance at the time of approval of the proposeddevelopment. Only allow new lots to be created ifthey can be developed without ever requiringshoreline protection for the development.

Alternative modification from “Update theZoning Ordinance” to “Prohibit” 6 6.47
B
CR‐I‐30 SoftShorelineProtections
Encourage the use of soft or natural shorelineprotection methods, such as dune restoration andbeach/sand nourishment as alternatives to hardshoreline protection structures, such asrevetments or sea walls. Soft shoreline protectiondevices shall be fully evaluated for coastalresource impacts, and, shall only be approved iffound consistent with the LCP and Coastal Actpolicies related to shoreline protection. Considercombining beach replenishment with groinconstruction to maintain beaches and protectdevelopment. (see subarea policies).

N/A Encourage the use of soft or natural shoreline
protection methods, such as dune restoration andbeach/sand nourishment as alternatives to hardshoreline protection structures, such as revetmentsor sea walls. Soft shoreline protection devices shallbe fully evaluated for coastal resource impacts.Consider combining beach replenishment with groinconstruction to maintain beaches and protectdevelopment.

Clarification to policy.
6 6.48 CR‐I‐55:

BeachNourishment
In coordination with the California Coastal
Commission and other permitting agencies (e.g.,
State Lands Commission, U.S. Army Corps of
Engineers), the City shall evaluate a beach
nourishment program in conjunction with sand
retention structures to assist in maintaining beach
width and elevations, consistent with sub‐area
policies. The beach nourishment program will
include measures to protect water quality and to
avoid (and where unavoidable to minimize andmitigate) potential adverse coastal resource impacts, including biological resource impacts,
from deposition of material, including measures
such as sand compatibility specifications,restrictions on volume of deposition, timing or seasonal restrictions, and identification of
environmentally preferred locations for deposits.

Delete and incorporated into CR‐I‐1 CCC suggested modification clarified that beach nourishment needs to be in compliancewith the Coastal Act. City staff proposes analternative modification that would delete CR‐I‐55 and incorporate the language into CR‐I‐16.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.49 CR‐I‐3156:

ExistingShorelineProtectionStructures
Except as may be otherwise provided in the LCP
sub‐area policies, legally permitted shoreline
protection structures may be repaired and
maintained, as supported by Section 30235 of the
Coastal Act, subject to all coastal development
permit requirements (including those associated
with the construction of the structure and/or prior
repair and maintenance episodes) until the
development they are protecting is removed or no
longer requires shoreline protection structures, at
which time the shoreline protection structure
shall be reevaluated for consistency with the LCP
and removed if no longer necessary. Activities
considered “repair and maintenance” shall not
result in any enlargement or extension of the
shoreline protection structure, or any seaward
encroachment or impairment of public trust
resources, and shall provide mitigation for any
new coastal resource impacts not previously or
otherwise mitigated, including through the City’s
Shoreline Mitigation Program (CR‐I‐5) and/or
Policy CR‐I‐59.

Except as may be otherwise provided in the LCP
sub‐area policies, legally permitted shoreline
protection structures may be repaired and
maintained, as supported by Section 30235 of the
Coastal Act, subject to all coastal development
permit requirements (including those associated
with the construction of the structure and/or prior
repair and maintenance episodes) until the
development they are protecting is removed or
redeveloped pursuant to the definition of a
Substantial Structural Modification (SSM) or no
longer requires shoreline protection structures, at
which time the shoreline protection structure shall
be reevaluated for consistency with the LCP,
removed if no longer necessary and/or allowed,
and the area restored. Activities considered “repair
and maintenance” shall not result in any
enlargement or modification to the shoreline
protection structure, or any replacement of
materials in excess of 50%, or any seaward
encroachment or impairment of public trust
resources, and shall provide mitigation for any new
coastal resource impacts not previously or
otherwise mitigated, including through the City’s
Shoreline Mitigation Program (CR‐I‐5) and/or Policy
CR‐I‐59.

N/ALegally permitted shoreline protection
structures may be repaired and maintained, assupported by Section 30235 of the Coastal Act,subject to all coastal development permitrequirements (including those associated with theconstruction of the structure and/or prior repair andmaintenance episodes) until the development theyare protecting is removed or redeveloped pursuantto the definition of a Substantial StructuralModification (SSM) or no longer requires shorelineprotection structures, at which time the shorelineprotection structure shall be reevaluated forconsistency with the LCP, removed if no longernecessary and/or if found to be inconsistent withthe LCP by the reevaluation, and the area restored.Activities considered “repair and maintenance” shallnot result in any enlargement or extension ofmodification to the shoreline protection structure,or any replacement of materials in excess of 50%, orany seaward encroachment or impairment of publictrust resources, shall provide mitigation for any newcoastal resource impacts not previously orotherwise mitigated, including through the City’sShoreline Adaptation Program (CR‐I‐5), CoastalAccess and Resilience Program (CR‐I‐44) and/orPolicy CR‐I‐34, shall minimize impacts, and must befound to be the least environmentally damagingfeasible alternative.

CCC suggested modification revises the policy
to align with other provisions in the LCP,
Coastal Act, and CCC policy. Staff is not
proposing alternative modification. Minor
revision to clarify policy and correct references.
6 6.50 CR‐I‐3156:

ExistingShorelineProtectionStructures
Other modifications to existing shoreline
protection structures which fall within the
limitations of an exclusion contained in the
definition of Substantial Exterior Structural
Modification shall be considered to be an existing
shoreline protection structure. This policy shall
not be applied to justify the removal of a shoreline
protection structure which protects any structure
authorized to be constructed pursuant to an
exclusion contained in the definition of
Substantial Exterior Structural Modification.

Deleted Modifications to existing shoreline protection
structures which fall within the limitations of anexclusion contained in the definition of SubstantialStructural Modification shall be considered to beallowed without the above‐mentionedconsiderations.

CCC suggested modification deletes textrelated to modifications to existing structures.City staff is proposing an alternativemodification to clarify that maintenance andmodification of existing shoreline protectionstructures is allowed. 6 6.51 CR‐I‐3257:

NewShorelineProtectionStructures
Shoreline protection structures, including
revetments, breakwaters, groins, seawalls, cliff
retaining walls, deep piers and caissons, and other
such construction that alters natural shoreline
processes shall be permitted consistent Section
30235 of the Coastal Act and with the LCP’s sub‐
area policies only when required to serve coastal‐
dependent uses or protect existing structures or
public beaches in danger from erosion, when
designed to eliminate or mitigate adverse impacts
on local shoreline sand supply.

Shoreline protection structures, including
revetments, breakwaters, groins, seawalls, cliff
retaining walls, deep piers and caissons, and other
such construction that alters natural shoreline
processes shall only be permitted if consistent
Section 30235 of the Coastal Act and with the LCP’s
sub‐area policies, and only when required to serve
coastal‐dependent uses or protect existing
structures or public beaches in danger from
erosion, when there is no less environmentally
damaging feasible alternative and when designed
to avoid, and where unavoidable, minimize to the
Shoreline protection structures, includingrevetments, breakwaters, groins, seawalls, cliffretaining walls, deep piers and caissons, and othersuch construction that alters natural shorelineprocesses shall only be permitted if consistentSection 30235 of the Coastal Act and with the LCP’ssub‐area policies, and only when required to servecoastal‐dependent uses or protect existingstructures (including existing public roads and sewerlines if necessary) or public beaches in danger fromcoastal hazards erosion, when there is no lessenvironmentally damaging feasible alternative and CCC suggested modification amends the policyto address alternative evaluation andminimizing coastal resource impacts. City staffis generally in support; however, City staff isproposing an alternative modification thatwould replace the word “erosion” with “coastalhazards” in order to be more inclusive of thevariety of coastal hazards affecting thecoastline and in recognition of the deleted sub‐area policies. Minor revision to correctreferences and clarification.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification maximum extent feasible adverse impacts on local
shoreline sand supply and other coastal resources,
where unavoidable coastal resource impacts are
required to be commensurately mitigated.
when designed to avoid, and where unavoidable,minimize to the maximum extent feasible adverseimpacts on local shoreline sand supply and othercoastal resources, where unavoidable coastalresource impacts are required to becommensurately mitigated 6 6.52 CR‐I‐3358:

Authorization Limits of
ShorelineProtectionStructures
Shoreline protection structures shall only be
authorized until the time when the existing
structure protected by such shoreline protection
structure: 1) is/are no longer present, or 2) no
longer require(s) armoring. This policy shall not be
applied to justify the removal of a shoreline
protection structure which protects any structure
authorized to be constructed pursuant to an
exclusion contained in the definition of
Substantial Exterior Structural Modification.

Shoreline protection structures shall only be
authorized until the time when the structure
protected by such shoreline protection structure:
1) is/are no longer present, 2) no longer require(s)
armoring, or 3) is redeveloped pursuant to the
definition of a Substantial Structural Modification
(SSM).

N/A CCC suggested modification amends the policy
related to time limits on shoreline protectionstructures. Staff is generally in support of themodification, if alternative modifications toother policies related to the Special ResiliencyAreas (SRAs) remain. 6 6.53 CR‐I‐34:

MitigatingImpacts ofNewShorelineProtectionStructures.

This policy may be met through compliance withthe City’s Shoreline Mitigation Program (CR‐I‐5).

N/A This policy may be met through compliance with the
City’s Shoreline Adaptation Program (CR‐I‐5) orCoastal Access and Resilience Program (CR‐I‐44).

Correction to references
6 6.54 CR‐I‐36:

EmergencyShorelineProtectionStructures
N/A N/A In cases of emergency, an emergency shoreline
protection structure may only be approved on atemporary basis, and only under the condition thatthe structure is required to be removed unless aregular CDP is approved for retention of thestructure. In such cases, a complete CDP applicationshall be required to be submitted within 60 daysfollowing construction of the temporary emergencyshoreline protective structure, unless an alternatedeadline is authorized by the Planning Director forgood cause, including continued good faith effortstoward submittal of such application. Any suchtemporary emergency shoreline protectivestructure shall be sited and designed to be theminimum necessary to abate the identifiedemergency, and to be as consistent as possible withall LCP shoreline protective structure standards,including in terms of avoiding coastal resourceimpacts to the maximum possible extent. Mitigationfor impacts will be required through the regular CDPprocess, including mitigation commensurate withthe duration of impacts caused by the emergencytemporary structure. The City shall notify theExecutive Director upon receipt of a request for anemergency shoreline protective structure within theCity’s CDP jurisdiction.

New policy.

Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.55 CR‐I‐37:

Sharp ParkGolf Course
N/A N/A Strongly support the City and County of San
Francisco’s ability to provide public access along thecoast, protect Environmentally Sensitive HabitatArea, and provide flood protection.

Reorganization of chapter
6 6.56 CR‐I‐38:

PublicInfrastructure Along theShoreline inSpecialResiliencyAreas N/A N/A Public infrastructure (e.g., public roads, sidewalks, parking areas, accessways, water and sewerinfrastructure) on the immediate oceanfront of theSpecial Shoreline Resilience Areas mapped inFigures 6‐2 and
6‐3 shall be consistent with all LCP
provisions except that, to establish the safety andstability of the proposed development, suchdevelopment may rely on a shoreline protectionstructure that is existing at the time of theapplication and/or that is proposed in the samepermit application as the infrastructure itself.

SSRA policy
6 6.57 CR‐I‐39:

DevelopmentDirectlyInland ofPublicInfrastructure in SpecialResiliencyArea N/A N/A Notwithstanding Policy CR‐I‐2, development located directly inland of the public infrastructure on theimmediate oceanfront of the Special ShorelineResilience Areas mapped in Figures 6‐2 and
6‐3 may
rely on a shoreline protection structure in that areathat is existing at the time of the permit applicationto help demonstrate that its setbacks meet therequirements of Policies CR‐I‐43 and CR‐I‐44. Inaddition to meeting the requirements of Policy CR‐I‐45, such development shall be conditioned torequire the applicant to acknowledge that thedevelopment’s long‐term safety may be based inpart on shoreline protection structures locatedseaward of the development, which may or may notbe effective, and/or be maintained, and/or bepresent in the future. 6 6.58 CR‐I‐40
Armoring inSpecialResiliencyAreas
N/A N/A In the Special Shoreline Resilience Areas mapped in Figures
6‐2 and
6‐3, repair and maintenance,
enhancement, realignment, andredevelopment/replacement of a shorelineprotection structure that is existing at the time ofthe permit application, including minor extensionsin order to fill gaps or otherwise ensure the overallshoreline protection structure is effective may beapproved when required to protect publicinfrastructure (e.g., public roads, sidewalks, parkingareas, accessways, water and sewer infrastructure)on the immediate oceanfront of the SpecialShoreline Resilience Areas mapped in Figures 6‐2
and
6‐3. Such shoreline protection structure must
comply with all relevant LCP policies except that itmay be approved regardless of whether suchshoreline protection structure is required to protecta coastal dependent use, a public beach in danger oferosion, or a structure that qualifies as an "existingstructure" within the meaning of Coastal Act Section Chapter Modific
ationNumber
Policy Numberand/or SubjectAddressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 30235. Any such shoreline protection structureshall incorporate public access elements into itsdesign, be the least environmentally damagingfeasible design, and improve coastal resourceconditions relative to conditions that exist at thetime of permit approval (examples of improvedconditions could include restoring intertidal habitat,enhancing public access, having a smaller footprintthan a shoreline protection structure that alreadylawfully exists, enhancing scenic and visual qualitiesof the area). 6 6.58 CR‐I‐41
EffectiveDate ofPolicies etc.

N/A N/A Policies CR‐I‐38, CR‐I‐39, and CR‐I‐40 shall only be of force and effect when and if, as determined bythe Coastal Commission’s Executive Director:
 In accordance with Policy CR‐I‐43,the initial Coastal Access and ResilienceProgram is developed and submitted forCommission review, and In accordance with Policy CR‐I‐5,the development of the ShorelineAdaptation Program has been initiated,including, at a minimum, that the Cityhas developed a public engagementplan, workplan, timeline, and identifiedfunding for completion of the technicalstudies and planning work. 6 6.59 CR‐I‐42
Suspensionof Policies
N/A N/A Policies CR‐I‐38, CR‐I‐39, and CR‐I‐40 shall be suspended, and shall have no further force andeffect during the period of suspension, uponthe occurrence of any of the followingconditions, as determined by the CoastalCommission’s Executive Director:
 In accordance with Policy CR‐I‐43, if:
o the Coastal Access and
Resilience Program is notcertified by the Commissionwithin 15 months of acceptanceof the LCP amendment for filingas identified in Policy CR‐I‐41,or o any of the CDP
applications that arerequired every 5 years toimplement projects arenot submitted incomplete form, or o any of the projects required in the
Coastal Access and Resilience
Chapter Modific
ationNumber
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 In accordance with Policy CR‐I‐5, if:
o The City has not completed the
technical studies to accomplishpart (a) of the ShorelineAdaptation Program within 6 years of effective certification ofthe Land Use Plan Amendmentthat created the requirement forthe Shoreline AdaptationProgram (i.e., created Policy CR‐I‐5), or o The City has not prepared a
Draft Shoreline AdaptationProgram within
8 years of
effective certification of theLUPA that created therequirement for the ShorelineAdaptation Program (i.e.,created Policy CR‐I‐5), or o The Coastal Commission has
not certified a Final ShorelineAdaptation Program within 10years of effective certificationof the LUPA that created therequirement for the ShorelineAdaptation Program (i.e.,created Policy CR‐I‐5).

In the event that the Coastal Commission’s
Executive Director determines that the City has notmet one or more of the above conditions, theExecutive Director shall provide a preliminarywritten determination to the City explaining thatone or more conditions set forth above have notbeen met and that suspension of Policies CR‐I‐38,CR‐I‐39 and CR‐I‐40 shall occur after fifteen workingdays, unless the City submits written objections tothe preliminary determination and the ExecutiveDirector concurs with the objections. The City maysubmit to the Executive Director a written notice ofobjection within seven working days of the date ofthe preliminary determination. The ExecutiveDirector will promptly review and either concur ordisagree, in writing, with any objection submitted bythe City prior to the fifteenth working day from thedate of the preliminary determination. The period ofsuspension will end, and Policies CR‐I‐38, CR‐I‐38and CR‐I‐40 will once again become effective, at the Chapter Modific
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Date ofPolicies CR‐I‐38, CR‐I‐39,CR‐I‐40.

N/A N/A Additionally, as of January 1, 2045, no new
development may rely on Policies CR‐I‐38, CR‐I‐39,or CR‐I‐40 , unless the Commission has certified anLCP amendment extending that deadline. As ofJanuary 1, 2045 (or such later date as specified in anLCP amendment), development approved based onPolicies CR‐I‐38 and CR‐I‐39 that relied on ashoreline protection structure to demonstratesafety, stability, and adequate setbacks (including inrelation to the requirements of Policies CR‐I‐19 andCR‐I‐20) shall become legal nonconforming and,moving forward, a Substantial StructuralModification to such development shall, inaccordance with Policy CR‐I‐25, be required to beconsistent with all LCP provisions, including but notlimited to Policies CR‐I‐2, CR‐I‐19, and CR‐I‐20related to setbacks and safety without relying onshoreline protection to establish safety, and PolicyCR‐I‐32 regarding approvable shoreline protection. 6 6.61 CR‐I‐44:

CoastalAccess andResilienceProgram.

N/A N/A The City shall develop a Coastal Access and
Resilience Program to ensure continued andincreased access to the coast, including as sea levelsrise. The Program shall include, but is not limited to,methods to maximize public access to and alongthe coast despite sea level rise and address thecoastal resource impacts associated with shorelineprotection structures along the City’s shoreline,including as required per Policy CR‐I‐34, and impactsassociated with the perpetuation of shorelineprotection structures within Special ShorelineResilience Areas allowed by Policies CR‐I‐38, CR‐I‐39,and CR‐I‐40. The priority for such access benefitsand mitigation shall be efforts/projects designed tomaintain and enhance sandy beaches and publicaccess to and along the City’s shoreline in a mannerthat is most protective of coastal resources andgeneral public access utility. The Program shallinclude, at a minimum, all of the following:
 A prioritized list of public access projects
within the City’s Coastal Zone that can helpmaximize access to the coast and serve asrequired mitigation. Projects shall beorganized in terms of expectedimplementation dates within 5‐yearincrements and shall be developed with fullcommunity input. Some opportunities mayinclude enhancement of public recreational Chapter Modific
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 Enhanced public pathway system seaward
of private development in the RockawayBeach area.
 Coordinated vertical accessways,
landscaping, benches, picnic tables, bicycleracks, garbage and recycling receptacles,doggie mitt stations, and enhanced signagein the Sharp Park area.  The following projects listed in the
program: Rockaway to Pacifica State BeachTrail Rehabilitation, Rockaway BeachParking Structure, Rockaway Parking Area,Beach Boulevard Promenade ParkImprovements, Sharp Park PriorityDevelopment Area (PDA) Access PedestrianImprovement project  A timeline and benchmarks for
implementation of identified projects,including measures by which progress andsuccess can be measured over time, as wellas necessary monitoring and tracking. At aminimum, projects shall be designed to beimplemented in at most 5 year increments.  Identification and development of a funding
mechanism (or mechanisms) sufficient tocover all identified projects. Suchmechanisms may include, but are notlimited to:
 Development of a protocol for requiring
mitigation for development within SpecialShoreline Resilience Areas that is allowed torely on existing shoreline protectionstructures pursuant to CR‐I‐38 and CR‐I‐39,thus resulting in continued impacts fromthat armoring.  Formation of a GHAD, CSA, or similar. State or Federal grant funding Other funding mechanisms identified for Chapter Modific
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An initial program shall be developed and should besubmitted as an amendment to the LCP by 3 yearsfrom the date of LUP Update certification]. By 5years from the date of Coastal Commission approvalof the initial Coastal Access and Resilience Program(and every subsequent 5 years) the City shall submita complete CDP application to the CoastalCommission, or where applicable the City itself shallapprove projects via City CDPs, to implementprojects identified in the Program. The Programshall be monitored, evaluated, updated, andresubmitted as an amendment to the LCP at leastevery 10 years thereafter. 6 6.61 6.9 Costal
Flooding andOther HazardStandardPolicies
CR‐I‐61 Flood Risk Reduction. The City should,when appropriate, evaluate and pursue,floodproofing of infrastructure and otherdevelopment in danger from projected floodingby 2050. Allow and facilitate (if feasible) privateowners to floodproof development structures,consistent with other LCP policies.

N/A Deleted Reorganization of chapter.

Glossary

7.1A Acronyms N/A N/A CSA: City Service Area Clarification Glossary

7.1B Acronyms N/A N/A SCS: Sustainable Communities Strategy Clarification Glossary

7.1 Anticipated
Life
N/A The period over which a development is expected
to be usable, with normal repairs and
maintenance, for the purpose for which it was
designed, typically a minimum of 75‐100 years for
residential and commercial development and a
minimum of 100‐150 years for critical
infrastructure.

N/A CCC suggested modification adds new text
from CCC's adopted guidance for residentialdevelopment and critical infrastructure.

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7.2 Beach The expanse of sand, gravel, cobble or other loose material that extends landward from the low
water line to the place where there is
distinguishable change in physiographic form, or
to the line of permanent vegetation. The seaward
limit of a beach (unless specified otherwise) is the
mean low water line.

The expanse of sand, gravel, cobble or other loose
material that extends landward from the mean low
water line to the place where there is
distinguishable change in physiographic form, or to
the line of permanent vegetation. The seaward
limit of a beach (unless specified otherwise) is the
mean low water line. The inland extent of the
beach shall be determined as follows:
1) From a distinct linear feature (e.g., a seawall,
road, or bluff, etc.);
2) From the inland edge of the further inland beach
berm as determined from historical surveys, aerial
photographs, and other records or geological
evidence; or
3) Where a beach berm does not exist, from the
further point separating the dynamic portion of the
beach from the inland area as distinguished by
vegetation, debris or other geological or historical
evidence.

N/A CCC suggested modification amends the text to
be consistent with Coastal Act.

Glossary

7.3 Bluff A high bank or bold headland with a broad,
precipitous, sometimes rounded cliff face
overlooking a plain or body of water.

Deleted N/A CCC suggested modification deletes text to
eliminate redundancy.

Glossary

7.4 Coastal
Hazards
N/A Include but are not limited to episodic and long‐
term shoreline retreat and coastal erosion, high
seas, ocean waves, storms, tsunami, tidal scour,
wave overtopping, coastal flooding, and their
interaction, all of which may be exacerbated by sea
level rise.

N/A CCC suggested modification adds clarifying
language.

Glossary

7.5 Development On land, in or under water, the placement or erection of any solid material or structure; dis‐
charge or disposal of any dredged material or of
any gaseous, liquid, solid, or thermal waste;
grading, removing, dredging, mining, or extraction
of any materials; change in the density or intensity
of use of land, including, but not limited to,
subdivision pursuant to the Subdivision Map Act
(commencing with Section 66410 of the
Government Code), and any other division of land,
including lot splits, except where the land division
is brought about in connection with the purchase
of such land by a public agency for public
recreational use; change in the intensity of use of
water, or of access thereto; construction,
reconstruction, demolition, or alteration of the
size of any structure, including any facility of any
private, public, or municipal utility; and the
removal or harvesting of major vegetation other
On land, in or under water, the placement or
erection of any solid material or structure; dis‐
charge or disposal of any dredged material or of
any gaseous, liquid, solid, or thermal waste;
grading, removing, dredging, mining, or extraction
of any materials; change in the density or intensity
of use of land, including, but not limited to,
subdivision pursuant to the Subdivision Map Act
(commencing with Section 66410 of the
Government Code), and any other division of land,
including lot splits, except where the land division
is brought about in connection with the purchase
of such land by a public agency for public
recreational use; change in the intensity of use of
water, or of access thereto; construction,
reconstruction, demolition, or alteration of the size
of any structure, including any facility of any
private, public, or municipal utility; and the
removal or harvesting of major vegetation other
N/A CCC suggested modification adds new text to
clarify terms used in document and be
consistent with the Coastal Act.

Chapter Modific
ationNumber
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City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justificationthan for agricultural purposes, kelp harvesting, and timber operations which are in accordance
with a timber harvesting plan submitted pursuant
to the provisions of the Z'berg‐Nejedly Forest
Practice Act of 1973 (commencing with Section
4511).As used in this section, "structure" includes, but is not limited to, any building, road, pipe, flume,
conduit, siphon, aqueduct, telephone line, and
electrical power transmission and distributionline.
than for agricultural purposes, kelp harvesting, and
timber operations which are in accordance with a
timber harvesting plan submitted pursuant to the
provisions of the Z'berg‐Nejedly Forest Practice Act
of 1973 (commencing with Section 4511).

As used in this section, "structure" includes, but is
not limited to, any building, road, pipe, flume,
conduit, siphon, aqueduct, telephone line, and
electrical power transmission and distribution line.

In this LCP, ‘development’ is synonymous with
‘new development.’
Glossary

7.6 Environment
al Justice
The fair treatment of people of all races, cultures,
and incomes with respect to the development,
adoption, implementation, and enforcement of
environmental laws, regulations, and policies
The fair treatment and meaningful involvement of
people of all races, cultures, and incomes with
respect to the development, adoption,
implementation, and enforcement of
environmental laws, regulations, and policies
The fair treatment and meaningful involvement of
people of all races, cultures, and incomes withrespect to the development, adoption,implementation, and enforcement of environmentallaws, regulations, and policies N/A The City’s General Plan consistency changeseliminated this sentence and the suggested modification is no longer applicable. However,
the proposed CCC Suggested Modification isconsistent with the Coastal Act and thus shouldremain.

Glossary

7.7 Existing
Structure
A structure that has any of the following
characteristics:i) lawfully constructed prior to the certification date of the LCLUP; orii) permitted for construction prior to the certification date of the LCLUP, and all permits
remained in full force and effect prior to the date
of construction; or
iii) authorized to be constructed pursuant to an
exclusion contained in the definition of
Substantial Exterior Structural Modification.”
Deleted N/A CCC suggested modification deletes text to be consistent with CCC guidance.

Glossary

7.7A Mean‐High
Tide Line
N/A N/A The intersection of the tidal plane of the mean high water with the shore. Determined by surveyprepared by a licensed professional land surveyorbased on field data collected within 12 months. Thesurvey must be conducted in consultation with andapproved by the California State Lands Commission.

City Council directed staff to add a definitionfor Mean High Tide Line. While the Coastal Actmakes several mentions of “mean high tide,”the Coastal Act does not contain a definition.Staff is recommending an alternativemodification to add a new definition similar toPolicy CR‐I‐46.

Glossary

7.8 New
Development
Development, as defined in Section 30106 of the
California Coastal Act, where no existing
development occurs. New Development does not
include the remodeling or improvement of an
existing structure, as defined, and also does not
include any structure authorized to be
constructed pursuant to an exclusion contained in
the definition of Substantial Exterior Structural
Modification.”
Deleted N/A CCC suggested modification deletes text to be consistent with CCC guidance.

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7.9 Shoreline Intersection of the ocean or sea with land; the line delineating the shoreline on National Ocean
Service nautical charts and surveys approximates
the mean low water line from the time the chart
was pre‐ pared.

Seaward of the base of coastal bluffs and/or at or
near the sandy beach/ocean elevation, including as
depicted in Appendix B (“Coastal Zone Vulnerability
Maps”) and denoted as “wave run‐up,” “storm
flood area,” and “flood prone area.”
N/A CCC suggested modification adds clarifying
language to be consistent with CCC guidance
Glossary

7.10 Substantial
ExteriorStructuralModification(SESM)
Substantial Exterior Structural Modification
(SESM): Any physical improvement which modifies
an existing structure, as defined, to achieve any of
the following:i) a seaward encroachment of the structure; or ii) removal or replacement of 50 percent or more
of the linear length of the exterior walls, whether
or not the floor area or building footprint is
expanded; or
iii) an addition that includes new floor area at or
below the first story equal to 50 percent or more
of the structure’s total existing floor area; or
iv) an increase of the existing building footprint
equal to 50 percent or more;
but excluding any of the following:
i) removal, replacement, or maintenance of
nonstructural components of exterior walls such
as siding, shingles, and roofing materials and
windows;ii) development on any site which is protected
from coastal erosion by an existing, permitted
shore‐ line protection structure;
iii) replacement of any structure pursuant to the
provisions of subdivision (g) of Section 30610 of
the Public Resources Code;
iv) the demolition and reconstruction of a single‐
family residence; provided, that the reconstructed
residence shall not exceed either the floor area,
height or bulk of the former structure by more
than 10 percent, and that the reconstructed
residence shall be sited in the same location on
the affected property as the former structure; or
v) the reconstruction, repair, or maintenance of
any shoreline protection structure; provided,
Substantial Structural Modifications (SSM): Any
physical improvement which modifies an existing
structure in any of the following ways:
i) alteration, removal or replacement of 50 percent
or more of the linear length of the exterior walls, or
other major structural components (including but
not limited to floor, roof, and foundation
structures), whether or not the floor area or
building footprint is expanded; or
ii) an addition that includes new floor area equal to
50 percent or more of the structure’s total existing
floor area; oriii) an increase of the existing building footprint equal to 50 percent or more;
but excluding removal, replacement, or
maintenance of nonstructural exterior components
such as decorative siding, shingles, and windows.

Incremental changes that cumulatively amount to
replacement of 50 percent of more over time shall
also be considered a SSM.

Substantial Structural Modifications (SSM): Anyphysical improvement which modifies an existingstructure in any of the following ways:i) alteration, removal or replacement of 50 percentor more of the linear length of the exterior walls, orother major structural components (including butnot limited to floor, roof, and foundationstructures), whether or not the floor area orbuilding footprint is expanded; orii) an addition that includes new floor area equal to50 percent or more of the structure’s total existingfloor area; oriii) an increase of the existing building footprintequal to 50 percent or more;howeverbut excluding, but not limited to removal,replacement, or maintenance of nonstructuralexterior components, such as: decorative i) plywood roof sheathing;ii) underlayment;iii) siding;iv) shingles;v) other roof materials; andvi) windows and doors (including garage doors);
vii) exterior
waterproofing/weatherproofingmaterials;
viii) appliance installations and
replacements, such as water heaters,generators, and solar panels, that donot involve structural modifications; ix) remedial actions to address termite
infestation and dry rot; and
x) other modifications required to comply
with State and/or Federal laws andregulations, such as disabledaccessibility improvements and seismicretrofits/upgrades.

Incremental structural changes that cumulatively
CCC suggested modification deletes text to beconsistent with CCC guidance. Staff is generallyin support of the modification; however, staff isproposing an alternative modification to clarifythat nonstructural elements and waterproofingmaterials are not part of the SSM definition.Upon further discussion with CCC staff, Citystaff agrees with the removal of languagereferencing subdivision (g) of Section 30610 ofPublic Resources Code from the exclusionlanguage of the SSM definition. This codeprovision within the Coastal Act is applicable toproperties within the City and would notequate to a SSM and thus does not need to beincluded as an exclusion in the SSM definition.CCC staff prefers, and City staff agrees, thatthis provision and definition not be interpretedtogether. Staff is proposing an alternativemodification, new Modification No. 6.2A, thatprovides the clarification on the applicability ofSection 30610(g) of the Coastal Act.Additionally, staff has incorporated directionprovided from Council at the March 2ndmeeting to include general non‐structuralproperty upgrades, remedial actions, and othermodification required by State and/or Federallaws in the SSM exclusions.

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seaward of the location of the former structure,
and that such modifications do not increase the
height or length of the former shoreline
protection structure by more than 10 percent.

Changes to exterior walls, floor area, height,
length, or building footprint shall be measured
cumulatively from those existing at the site on the
date of certification of the LCLUP. The cost of
improvements shall not be used as a basis in
application of this definition or any policy relying
thereupon unless expressly stated in the policy.
amount to replacement of 50 percent or more overtime shall also be considered a SSM.

Glossary

7.11 Tsunami
InundationZone
N/A N/A An area of likely tsunami inundation under a
tsunami scenario. The applicable tsunami scenarioshould balance a reasonable probability of eventoccurrence with a reasonable potential of thetsunami event causing substantial loss of life and/ordamage to property. Such a tsunami scenario couldinclude, but is not necessarily limited to, 475‐yearAverage Return Period (ARP) event described in thepublication Probabilistic Tsunami Hazard Maps forthe State of California (Phase 2), CaliforniaDepartment of Conservation (2023).

Staff recommends an alternative modificationto add a new definition to clarify and provideguidance on the Tsunami Inundation Zone.

Pacifica City CouncilJune 26, 2024

Pacifica City Council
June 26, 2024