Attachment B Summary Table With Alternative Modifications — Pacifica City Council, August 12, 2024

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
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
Development
Review
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: Coastal
Development
Permit
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
Individualized
Determinatio
ns
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 reviewed
individually in a manner that is
consistent with applicable state and
federal laws.
2 2.4B LD-I-5: Lower
Cost Visitor
and
Recreational
Facilities
Protect lower-cost visitor and recreational
facilities in the Coastal Zone. These include major, free recreational attractions such as Pacifica
Pier and Pacifica State Beach; the public golf course at Sharp Park; the San Francisco RV Park;
California Coastal Trail and other trails, and numerous beaches accessible at no cost.

N/A Protect, encourage, and where feasible, provide lower-cost visitor and recreational facilities in the Coastal Zone. These include major, free recreational attractions such as Pacifica Pier and Pacifica State Beach; the public golf course at Sharp Park; the San Francisco RV Park; California Coastal Trail and other trails; lower cost overnight
accommodations; and numerous beaches accessible at no
cost.

The edits are the minimum necessary to
find the LUP in conformance with
Coastal Act Section 30213.
2 2.4C LD-I-9:

CoastalDependent
Industry
Allow new coastal-dependent industry only if alternative locations outside the Coastal Zone are infeasible or more environmentally damaging or
because to do otherwise would adversely affect the
public welfare, and potential impacts to
visual 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 other policies of this LCP may be permitted only if alternative locations outside the Coastal Zone are infeasible or more environmentally
damaging; permitting the development would not
adversely affect the public welfare; and potential impacts to visual resources, sensitive species and habitat, water The edits are necessary for compliance
with Coastal Act 30260.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification extent feasible. quality, and other coastal resources are mitigated to the maximum extent feasible. This policy does not apply to a new or expanded oil and gas development, refinery, or
petrochemical facility.
2 2.5 Central
Pacifica
Coastal 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 hazards and refers to the
relevant Chapters 5 and 6 of the
LCLUP.
2 2.6 LD-I-14:

Promenade
Area and
Beach
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 community
and tourist destination, while also ensuring that it
adequately responds to and addresses coastal
hazard considerations consistent with the LCP.

Non-permanent improvements shall not require
additional analysis.

CCC suggested modification clarifies
the policy related to the Beach
Boulevard Promenade. City staff is
generally in support of the suggested
modification; however, City staff is
proposing an alternative modification
to clarify that non-permanent
improvements, such as bench and
trash receptacles, do not require
additional analysis. This will help to
streamline any such improvements in
the future.
2 2.6A LD-I-14:

Promenade
Area and
Beach
Boulevard
Property
N/A N/A Delete Staff had previously proposed an
alternative modification that read “Nonpermanent improvements shall not require additional analysis.” Staff is
proposing no longer proposing that
alternative modification due to CR-I-24
which applies to minor development in
shoreline areas.
2 2.6 LD-I-14:

Promenade
Area and
Beach
Boulevard
Property
The preferred use is a hotel if market conditions allow, but other appropriate uses will include a conventional
commercial/residential mixed-use project 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-use
project with cafes, restaurants, retail, and upperlevel 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:

Rockaway
Quarry 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,
and wetlands) and coastal resource protection
N/A CCC suggested modification restates
coastal development requirements
related to hazards and biological
resources protections.

Rockaway
Quarry 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:

Undeveloped
San Pedro
Avenue 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 visitororiented commercial uses with some low density residential development at a density range of the
lower third of the CRMU density range. 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.

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
previously approved lower density
range by using different terms that
are preferrable to the CCC staff.

2.8 LD-I-20:

Undeveloped
San Pedro
Avenue 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
Service
Priorities
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 by
development or uses permitted by the buildout
allowances of this Land Use Plan or by the General
Plan to serve the City’s non-coastal zone areas. Plan
for the maintenance, operation, expansion and
improvement to public facilities considering threats
from coastal hazards, and avoid locating new or
expanded public service facilities in the Coastal
Vulnerability Zone unless no feasible alternative
exists. 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.

CCC suggested modification requires
analysis of alternatives for potential
retrofit or relocation but does not
mandate relocation.

Alternative modification incorporates
reference to the LUP and General
Plan buildout allowances and to
incorporate language from LD-I-37
here instead and remove
redundancies.

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. Avoid locating
new or expanded public service facilities in the
Coastal Vulnerability Zone. If no feasible alternative
exists and a new or expanded public service facility
must be located within the Coastal Vulnerability
Zone, development shall be consistent with this LCP
and the Coastal Act.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.

CCC suggested modification may
impact infrastructure within the
Coastal Zone that serves areas
outside the Coastal Zone. City staff
alternative modification allows new
or expanded public services within
the CVZ only if no other location can
be accommodated. Additionally, new
or expanded public services within
the CVZ must design in compliance
with other LCP policies, such as
designing for adaptation, and the
Coastal Act.

The portion proposed alternative
modification has been incorporated
into LD-I-27. The new modification
allow development and protects
coastal resources.
3 3.1 Coastal Access
Points
Maintain public parking as part of redevelopment of Cityowned 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 3.1A Coastal Access
Point 13A
N/A N/A Sharp Park, Berm – ADA access on berm Updated to reflect existing conditions. 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 GP1 PR-I-7:

Adjustment of
Lateral
Shoreline
Easements
This edit was added in October 2023 as part of the GP
consistency changes. It added the following to the policy:

Alternatively, the Planning Director may determine that lateral access is not necessary.

CCC Suggested Modification from June 2024
recommended deletion of the sentence.

N/A Staff agrees with the CCC suggested
modification from June 2024. The
added language does not clarify how
the Planning Director can make such
determinations. The text is also
confusing because the sentence above
already give the City the ability to
determine when lateral public access is
not necessary.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 3 3.3 PR-I-8:

Temporary
Events
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 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
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
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.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 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
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.
3 3.4 PR-I-12:

Coastal Access
Point South of
San Francisco
RV Park
Lateral access along the bluffs should be provided from this coastal access point to City- and Coastal Commissionrequired 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 GP consistency
changes a portion of the CCC
suggested modification remain that
should have 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 the Park located outside the Coastal Zone east of Highway 1.

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 recreational uses in upland portions of
the Park located outside the Coastal Zone east of
Highway 1.

Support the continued operation of golf at Sharp
Park Golf Course consistent with redeveloping
resource protection, natural hazard, and coastal
vulnerability policies, existing CDP terms and
conditions, and support development of additional
recreational uses in upland portions of the Park
located outside the Coastal Zone east of Highway 1.

City staff alternative modification
would delete the word “existing,”
which clarifies that a CDP must be
obtained and can be modified
through the appropriate approval
process over time.
3 3.6 PR-G-11: Trail
System
Expansion
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:

PedestrianOriented
Street
Improvement
Implement Bicycle and Pedestrian Master Plan
recommendations to improve pedestrian orientated
safety and comfort.

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

Edits to ensure that implementing the
recommendations of this outside (nonLCP) document would occur in a Coastal Act consistent way.
3 3.7 PR-I-57:

Roadway
Retrofits
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 the Coastal
Zone. Retrofits will be consistent with this LCP.

CCC suggested modification adds
language that roadway retrofits need
to analyze coastal hazards. 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.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 3 3.8 PR-I-60:

Roadway
Abandonment
/Vacation and
Public Access
Do not abandon, vacate, or render unusable any Cityowned 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 CDP
requirements.
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
Protection
and
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 keeping with City regulations and Best Management Practices. 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, 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.

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
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.

Requiring a minimum of 100 feet setbacks buffers
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
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 incidental public services (for public
development), provided that any unavoidable
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 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 and applicable resource
agencies.

CCC suggested modification amends
the text to clarify exceptions;
however, the statement “no less than
50 feet in any case” is too prescriptive
and does not consider the quality of
habitat or design alternatives. City
staff proposes to eliminate the
statement and the buffer will be
decided on a case-by-case basis as
informed by a qualified biologist.

Additional text to clarify mitigation
may be needed.
4 4.3 ER-I-1: Creek
Protection
and
Restoration.

N/A Permitted uses within buffer zones are limited to
uses dependent on the resources within these
areas and their buffer zones (i.e. habitat
management and restoration, scientific research
and educational activities, and low-intensity
public access and recreation). Temporary
Permitted uses within buffer zones are limited to
uses dependent on the resources within these areas
and their buffer zones (i.e., habitat management
and restoration, scientific research and educational
activities, and low-intensity public access and
recreation), except where reduced buffer is required
CCC suggested modification added
language to Policy ER-I-2 that
specified allowed uses within a
designated buffer area. City staff is
generally in support of the suggested
modification; however, City staff is
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification disruption (e.g. less than six months) for the
construction, alteration, repair, and maintenance
of existing or newly permitted facilities or
structures is allowed if there are no feasible
alternatives, the disruption area is restored to its
pre- disruption state or better within one year
from the initial point of impact and there is no
significant ground disturbance.
to avoid a taking or essential for the provision of
public services. Temporary disruption, (e.g. less than
six months) as determined by a qualified biologist in
consideration of on-site specific biological resources, for the construction, alteration, repair, and
maintenance of existing or newly permitted facilities
or structures is allowed if there are no feasible
alternatives, the disruption area is restored to its
pre- disruption state or better within one year from
the initial point of impact and there is no significant ground disturbance.
proposing an alternative modification
to clarify that takings avoidance is a
relevant factor for consideration, as is
provision of public services. City staff
is also clarifying that temporary
disruptions may be permissible if
reviewed and recommended by a
qualified biologist.

The last portion of the first sentence
is redundant and should be removed.
4 4.3A ER-I-1: Creek
Protection
and
Restoration.

Permitted uses within buffer zones are limited to uses
dependent on the resources within these areas and their buffer zones (i.e. habitat management and restoration,
scientific research and educational activities, and lowintensity public access and recreation), except where reduced buffer is required to avoid a taking or essential for
the provision of public services.

Permitted uses within the buffer
(whether reduced or not) can still only
be limited to resource dependent uses.

Please delete.
4 4.4 Plant
Communities
and Wildlife
Habitats
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 mapped
communities 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 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 issues may
be 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.
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
Wetlands and
Ponds
Seasonal Wetlands and Ponds Wetlands and Ponds N/A CCC suggested modification generalizes language
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.7 Seasonal
Wetlands and
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-Status
Species

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 redlegged frog as well as the San Francisco garter snake.

SPECIAL-STATUS SPECIES IN 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 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
4 GP2 Special-Status
Special in
Beach/Intertid
al Habitat
This edit was added in October 2023 as part of the GP
consistency changes. It added the following to the
paragraph: Pacifica State Beach in the 1970s hosted
nesting Western Snowy Plovers, a Federally listed
threatened species. Since 2003 volunteers have regularly surveyed and monitored the plovers and have seen only
wintering plovers in declining numbers. ESHA is required on the north half of the beach where plovers roost and
feed.

CCC Suggested Modification from June 2024
recommended deletion of the last sentence and
the following clarifying sentence: The northern
half of the beach where plovers roost and feed
qualifies as ESHA.

N/A Staff agrees with the CCC suggested
modification from June 2024 as the
sentence is confusing. The proposed
modification clarifies that this area
contains ESHA.
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 considered ESHA.

N/A CCC suggested modification adds a
new habitat category.

Potential ESHAs include all designated critical habitat for Endangered or Threatened 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.

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 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
Potential
ESHA
Any proposed development on land designated on the
Sensitive and Critical Habitat map (Figure 4-3) as having potential to include an Environmentally Sensitive Habitat Area requires a site-specific evaluation by qualified
biologists.

N/A Grasslands/Prairie vegetation communities shown on
Figure 4-2 are also mapped on Figure 4-3 as Potential ESHA.

Any proposed development on land designated on the
Potential Environmentally Sensitive Habitat Areas map
(Figure 4-3) as having potential to include an
Environmentally Sensitive Habitat Area requires a sitespecific evaluation by qualified biologists Edits for consistency with the name and
content of Figure 4-3.
4 4.10 ER-G-6:

Coastal
Environment
and Special
Species Status
Communities
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-dune beach 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 and
Riparian Areas
as Habitat
Protect year-round creeks and
their riparian habitats.

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

N/A CCC suggested modification adds
clarifying language.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.12 ER-I-21:

Protection of
Biological
Resources
with 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 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.
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 nodisturbance buffers around 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
Biological
Resources
with 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 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.

CCC suggested modification clarifies
the requirements; however, City staff
is proposing an alternative
modification to include the reference
to Figure 4-3 of the LCLUP.
4 4.12 ER-I-21:

Protection of
Biological
Resources
with 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:

Verification of
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:

Management
of 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.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.14 ER-I-24:

Management
of 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 impacts that 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 a greater 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 impacts
commensurately 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 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 incidental
public services (for public development), provided
that any unavoidable 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
provided that ESHA 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 and applicable resource
agencies, USFWS, and CDFW.

Additional text to clarify that
mitigation may be necessary.
4 4.14 ER-I-24:

Management
of 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:

Construction
during
Nesting
Season
If site work or construction occurs during the nesting
season (February 1 through August 31), then preconstruction 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 have fledged (usually late June through midJuly).

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.

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 have fledged (usually late June through
mid-July).

N/A CCC suggested modification deletes
text related to nesting during
construction.
4 4.16 ER-I-30:

Protection of
the California
Red-Legged
Frog and San
Francisco
Garter 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
Allowed construction activity with the potential
to impact California red-legged frogs and San
Francisco 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
N/A CCC suggested modification adds
clarifying language.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 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.
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.
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
Figure 4-4.
4 GP3 ER-I-53:

Underground
Utilities
This edit was added in October 2023 as part of the GP
consistency changes. It added the following to the policy:

This policy applies Citywide.

CCC Suggested Modification from June 2024
recommended deletion of the sentence.

N/A Staff agrees with the CCC suggested
modification from June 2024. The
sentence is deleted to clarify that the
policy applicable only within the coastal
zone.
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 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, 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 GP4 Soil Erosion This edit was added in October 2023 as part of the GP consistency changes. It added the following to the policy:

Within the Coastal Zone, the City requires new
CCC Suggested Modification from June 2024
recommended deletion of the sentence.

N/A Staff agrees with the CCC suggested
modification from June 2024. The
paragraph is deleted because it is
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification development to be set back from coastal bluffs enough
to accommodate a 100-year event, whether caused by
seismic, geotechnical, or storm conditions (unless this limitation makes a property undevelopable). Areas
determined by the study to be unsuitable for
development shall be set aside for permanent
environmental protection as part of any development.
inconsistent with policies within
Chapter 6.
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 to
minimize risks from seismic events. Building for human
occupancy shall avoid surface traces of active faults,
consistent with the Alquist-Priolo Earthquake Fault Zone Act and other relevant state laws. (See the Liquefaction and Fault Zones map, Figure 5-1).

N/A New development shall be sited and designed to minimize risks from seismic events. Continue to review projects
located in identified fault zones subject to the AlquistPriolo Earthquake Fault Zone Act. (See the Liquefaction and Fault Zones map, Figure 5-1).

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

Erosion
Prevention
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 to
maintain slope stability by revegetation. Other slope
stability methods may be acceptable, consistent
with this LCP.

CCC suggested modification deleted
the entire policy related to hillside
erosion prevention. City staff
alternative modification clarifies that
the policy is intended for hillside
erosion, and not 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:

Development
in Coastal
Zone
• 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:

Development
in Coastal
Zone
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
Modification definition.
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
N/A CCC suggested modification adds
clarifying language.

Development
in 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
Hazard
Reduction
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.

Routine maintenance of streambeds shall conform
to the Coastal Act, including but not limited to
Section 30236.

CCC suggested modification removed
streambeds from the policy.

Significant areas of Pacifica are
serviced by creeks as critical
stormwater infrastructure that
require regular maintenance. City
staff alternative modification clarifies
that all routine maintenance in
streambeds will conform to the
Coastal 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 improvement of 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:

Critical
Facilities
Location
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
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification

5.13 NH-I-35:

Development
Review
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 and
State and Federal agencies.

CCC suggested modification amends
policy to require LCP consistency;
however, City staff is proposing an
alternative modification to address 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 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. Balancing appropriate protection of
property and coastal resources along the dynamic
coastline is an important theme in this chapter.

CCC suggested modification deletes
introductory text. City staff is
proposing an alternative modification
to add language related 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.

Chapter Modific
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and/or Subject
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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 adaptation
plan in the future.

N/A CCC suggested modification clarifies
language to be consistent with the
Coastal Act.
6 6.3 Vulnerability
Assessment -
Pacific
Institute
Study
However, because the Coastal Vulnerability Zone Maps
show significant erosion for areas that are protected by existing shoreline protection structures, 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 are
protected by existing shoreline protection
structures, the Maps highlight the protection
provided by the structures.

CCC suggested modification deletes
introductory text. City staff is
proposing an alternative modification
to add language related to the
existing shoreline protections in the
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 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 was perceived to
require additional work to adequately analyze the
value of public recreational amenities.

CCC suggested modification deletes
introductory text. City staff is
proposing an alternative modification
to add language related to the costbenefit 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 Resiliency
policies.

CCC suggested modification deletes
introductory text. City staff is
proposing an alternative modification
to add language related to the costbenefit 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 with 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 Deleted 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 with the City’s grant
agreement with the CCC, these analyses do not, in
themselves, equate to a managed retreat policy. The
City uses other sea level rise adaptation policies in
CCC suggested modification deletes
introductory text. City staff is
proposing an alternative modification
to add language related to the
Adaptation Plan and potential future
changes.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification policy in this LCP and managed retreat could only
become the policy of the City subsequent to a future
amendment to the LCP.
this LCP and any future changes to these policies will
require an amendment to this LCP.
6 6.5A CR-I-1:

Vulnerability
Identification
and Mapping
The City’s Coastal Vulnerability zones shall be mapped
based on the best available science about projected sea level rise, erosion, flooding, and other coastal hazards.

Mapping shall be updated as necessary to guide
implementation of the LCP’s Coastal Resilience policies.

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

Vulnerability
Identification
and 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.

Delete CCC suggested modification amends
policy to include Coastal Vulnerability
Zones.

An additional modification removes
the entirety of this policy and
replaces it with the policy below.
6 6.5B CR-I-1: Coastal
Vulnerability
Zones
N/A N/A Those areas of the City that are predicted to be vulnerable to coastal hazards have been mapped as
Coastal Vulnerability Zones in Appendix B, where
such mapping is based on the best available science
about projected sea level rise, erosion, flooding, and
other coastal hazards at the time of LUP adoption. It
is likely that such areas will change over time, and
Appendix B shall be regularly updated to guide
implementation of the LCP’s coastal resiliency
provisions. In any case, however, if best available
science at the time an application is reviewed shows
that proposed development located outside of such
mapped area is also vulnerable to coastal hazards,
then such application shall be reviewed as though
such development was located in the Coastal
Vulnerability Zones.
6 6.6 CR-I-2:

Development
in Coastal
Vulnerability
Zones
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
Development
in Coastal
Vulnerability
Zones
The City shall implement its Sea Level Rise Adaptation
Plan as expressed in the general and sub-area Coastal
Resilience policies. 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. The City shall monitor implementation and, consistent with Coastal
Resilience Policy CR-I-4, update the Sea Level Rise
Adaptation Plan to strengthen public safety, preserve
existing neighborhoods, assure local economic vitality, respond to climate change, promote environmental
justice, implement the Coastal Act, and protect the public N/A Deleted An additional modification removes
this entire text.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification trust.
6 6.6B CR-I-2
Development
in Coastal
Vulnerability
Zones
Development in Coastal Vulnerability Zones may be
approved consistent with the sub-area policies in Section

6.6 if the following findings can be made:

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
demonstrate compliance with Coastal
Act.
6 6.6C CR-I-2
Development
in Coastal
Vulnerability
Zones
a. The proposed development is sited and designed to
avoid, and where unavoidable, to minimize coastal
hazards and impacts to coastal resources 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
demonstrate compliance with Coastal
Act.
6 6.6 CR-I-2:

Development
in Coastal
Vulnerability
Zones
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-I59. 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.
b. To avoid, and where unavoidable, to minimize
and commensurately mitigate to the maximum
extent feasible;
CCC suggested modification amends
policy to prioritize avoidance of
coastal resource impacts
6 6.6 CR-I-2:

Development
in Coastal
Vulnerability
Zones
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;
c. To avoid creating a nuisance; Clarification to align with proposed added definition of “anticipated life”
6 6.6 CR-I-2:

Development
in Coastal
Vulnerability
Zones
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
d. To avoid encroachment onto public trust lands;
and
Clarification to align with proposed
added definition of “anticipated life”
6 6.6 CR-I-2:

Development
in Coastal
Vulnerability
Zones
N/A e. The project is designed to assure stability and
structural integrity absent the need for shoreline
protective devices.
e. To assure stability and structural integrity
without reliance on shoreline protection devices,
except as provided in CR-I-38, CR-I-39, CR-I-40.

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 development
consistent with other policies in the
LCP.
6 6.7 CR-I-3:

Monitoring
Shoreline
Change
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) shoreline
and bluff edge surveys and also establish thresholds
for reassessing the City’s Shoreline Adaptation
ProgramPlan.

The City, in coordination with Coastal Commission
staff, shall create an alternating schedule to perform
half of the required surveys each year.do half of the
applicable area each year.

CCC suggested modification would
require the City to conduct additional
monitoring. The new requirement
may be too burdensome on City
resources. City staff proposes an
alternative modification that would
allow the City to alternate the areas
that are surveyed and timing in order
to realistically meet the requirements
of this policy. The schedule would be
created in coordination with CCC staff
in order to provide the most valuable
and efficient data.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.7A CR-I-4
Assessing
Coastal
Resiliency
Provisions
Implementati
on
The City shall reassess its Sea Level Rise Adaptation Plan as expressed in the general and sub-area Coastal
Resilience policies every five years or sooner as required by the shoreline monitoring program (Coastal Resilience Policy CR-I-3). The reassessment shall consider the
following:
• 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 shall be
disseminated to the public for review and comment 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 minimum
consider the following:
• The efficacy of such provisions at protecting
and enhancing the City’s beach and
shoreline area resources, critical
infrastructure, and other built and natural
environment features.
• Updated seal level rise projections and risks.
• The potential need to revise coastal
resiliency measures and/or to implement
new measures, including review of emerging
engineering, science, and technologies.
• Funding needs and potential funding
sources.
• The results of the City’s shoreline
monitoring program (CR-I-3), shoreline
adaption program (CR-I-5), adaptation
funding efforts (CR-I-6), consideration of an
LCP transfer of development rights program
(CR-I-7), critical transportation infrastructure
efforts (CR-I-8), hazard prone infrastructure
efforts (CR-I-9), business outreach efforts
(CR-I-10), high water mark efforts (CR-I-11),
flood ordinance and LHMP consistency
efforts (CR-I-11 and CR-I-12), sediment
management and beach nourishment
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 form
the basis for LCP updates and changes to better
address coastal hazards in a way that can protect
and enhance bluff, shoreline, offshore, and sandy
beach recreational areas for public use and
enjoyment while ensuring all development
(including private structures and public
infrastructure) are safe from coastal hazards as
much as possible both now and in the future.

Alternative modification to
demonstrate compliance with Coastal
Act.
6 6.8 CR-I-5:

Shoreline
Adaptation
Program
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.

Within 10 years of the certification of this LUP the
City shall develop a Shoreline Adaptation Program
for the City’s shoreline and obtain Coastal
Commission certification of the an LCP amendment
informed by the Plan.Program. The Program is
encouraged to be made up of sub-area plans for
smaller sections of the coastline that share similar
attributes, shall build on past adaptation planning
work, and identify adaptation approaches that will
. Alternative modification to
demonstrate compliance with Coastal
Act. This policy has been expanded to
included specific details regarding
CCC’s expectation of what the scope
of the Program should be and sets a
10-year timeline by which the
Program needs to be certified. This
program is meant to compliment the
Chapter Modific
ation
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and/or Subject
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City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification be implemented to address vulnerabilities and
protect coastal resources throughout the City.

The Program shall be consistent with and help to
support and implement the Coastal Access and
Resilience Program developed per CR-I454 and at a
minimum address the following topics:
a) Existing and Future Conditions.

Leveraging any existing relevant data or
studies, describe the relevant shoreline
area in terms of its resources and
constraints. Identify baseline conditions
in terms of existing public and private
development; shoreline, sandy beach,
and offshore public access and
recreational areas; and environmental
resources. Include an assessment of
beach widths throughout tidal and
seasonal ranges. Additionally, analyze
how conditions are expected to change
as coastal hazards (including short- and
long-term erosion and flooding) are
exacerbated by sea level rise. Describe
how the presence or absence of
development and shoreline protection
structures has impacted and is projected
to impact conditions over time,
particularly how such development
would or would not allow for natural
migration of beaches over time and
impact public use and availability of the
sandy beach/shoreline. Identify areas
where beaches would likely be able to
persist if able to migrate as sea levels
rise versus those areas where the
geology/conditions are such that the
continued presence of beaches in such
areas 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. This
vision shall relate to the opportunities
and constraints identified above and
shall include specific goals and actions
for protection of public access and
coastal resources and minimization of
coastal hazard risks. The Program shall
provide requirements for adapting
existing and future development,
Coastal Access and Resilience
Program, associated with the Special
Shoreline Resiliency Areas.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification including public and private structures,
community infrastructure, coastal
accessways, and other shoreline area
development to meet specific goals in
line with the overall vision of the City’s
shoreline (and each sub-area), including
as such objectives may differ by sub-
areas. Strategies to consider shall
include but are not limited to sediment
management, beach nourishment, green
infrastructure, shoreline
armoringprotection structures, elevation
of development, structural
modifications, and removal of
development as part of a Transfer of
Development Rights Program (Policy CR- I-7) or other voluntary process for property owners. Additionally, the
Program shall identify the timeline over
which different options may be applied,
including how different strategies would
be phased over time, and shall explicitly
define triggers for when different
adaptation options would need to be
implemented. The Program shall also
describe the policy options (e.g., land
use and zoning requirements,
development approval conditions, deed
restrictions, design guidelines, etc.),
specific projects, and funding
mechanisms necessary to ensure
adaptation actions are carried out.
c) Special Shoreline Resilience Areas.

Considering the existing and future
shoreline conditions and the City’s goals
and actions described in parts (a) and (b)
above, evaluate phased adaptation
approaches for the Special Shoreline
Resilience Areas. Consider the extent to
which armoring shoreline protection
structures may continue to be the
preferred adaptation approach or
whether alternatives may better achieve
City goals and result in preferred coastal
resource outcomes. Furthermore,
analyze the ability of the armoring
shoreline protection structures to
withstand coastal hazard conditions
over time as sea levels rise, the
feasibility and costs of anticipated
maintenance activities, any anticipated
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification augmentations or replacement that may
be necessary over time as sea levels rise,
and any threshold hazard conditions
beyond which the armoring shoreline
protection structures may not be able to
function and the associated adaptation
measures that would be necessitated for
the development that relies on the
shoreline protection structures.
d) Sandy Beach Areas. The City shall
identify all sandy beach areas that
provide for associated recreational
opportunities, including but not limited
to Sharp Park south of the Pacifica pier,
southern Rockaway Beach, and Pacifica
State Beach. For areas where public
beach access has already been or is
likely to be limited and eventually lost
due to the presence of development
that prevents natural beach
formation/migration, the Program shall
focus on strategies that will result in the
removal of development to allow for
natural beach migration processes. The
Program for these sandy beach areas
(broken down by each sub-area as well
as overall) shall also include the
following:
i. Minimum Sandy Beach Widths. An
analysis of the minimum width of sandy
beach necessary to maintain optimum
public recreational access and habitat
function. This analysis shall include
considerations of daily tidal range,
seasonal erosion, and short- term,
storm- driven erosion when determining
optimum beach widths. Additionally, the
analysis shall assess the types of
adaptation strategies, including but not
limited to sediment management, beach
nourishment, and removal of
development (subject to voluntary
mechanisms available to property
owners, as described above), along with
appropriate triggers for when different
adaptation strategies should be
implemented to ensure that minimum
sandy beach widths are maintained over
time as sea levels rise.
ii. Sandy Beach Monitoring. The
Chapter Modific
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Number
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and/or Subject
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City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Program shall include monitoring
protocols for the width of the beach as
well as recreational access, sandy beach
use, and habitat values throughout the
year and over time. Such monitoring
protocols shall identify and track
locations, times, and durations
throughout the year when the sandy
beach is too narrow to be adequate for
public recreation and/or lateral access.

Such monitoring will ensure that the
minimum beach width established
through the analysis above is adequate
for maintaining public access and coastal
resource values and will provide the
necessary information for when
adaptation triggers are met, as
described below.
iii. Sandy Beach Adaptation. The
Program shall identify the suite of
actions and programs that will be
implemented over time to maintain
sandy beach utility. The Program shall
also include explicit triggers for
sediment management, beach
nourishment, voluntary development
removal, and/or alternative strategies
that are designed to ensure that the
identified minimum sandy beach width
is maintained. The Program shall identify
“maintenance” triggers for when beach
nourishment or related strategies to
protect sandy beach areas should occur
as well as “adaptation” triggers for when
new adaptation strategies will have to
be implemented in order to preserve
beach recreational access as sea levels
rise and erosion worsens.
iv. Mitigation. The Program shall
include provisions designed to offset
loss of sandy beach area, including
application of complementary provisions
for offsetting such losses through
enhancements in other beach/shoreline
areas in the City if applicable.
e. Alternative Access. Where geologic
conditions or land use patterns and
shoreline armoring approaches will limit
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification the ability of sandy beaches to persist
(even without the presence of
development and shoreline protection
structures), the Program shall identify
options to allow for alternative types of
shoreline access. Such options may
include, but are not limited to, vertical
access to rocky shorelines or to the
ocean, lateral access along blufftops or
as part of shared vertical seawalls,
viewing platforms, and parks. The
Program shall identify preferred
locations for such features and tools for
ensuring such features are constructed
and maintained (e.g. conditions of
approval, shoreline protection structure
design requirements, acquisition of
easements or other areas, voluntary
removal of development, etc.).

Additionally, the Program shall identify
and describe how such features should
be adapted and modified over time as
sea levels rise to ensure access is
maintained over time.
f) Funding Opportunities.

Identification of potential funding
opportunities to support short-,
medium-, and long-term adaptation
options. This shall include funding for
implementation of specific adaptation
projects (e.g. sediment management,
beach nourishment, green
infrastructure, habitat restoration,
development removal, etc.);
construction of public access features;
purchase of deed restrictions,
easements, or similar interests; and
structural buyouts and related
opportunities for acquisition and
removal of structures encroaching
within the established sandy beach
areas. Potential funding opportunities
may include in-lieu fees (including those
generated from mitigation for shoreline
protection structures per Policy CR-I5934), grants, state/federal funds, and GHADs/CSAs. Opportunities to integrate
adaptation strategies with other
planning processes (e.g., Local Hazard
Mitigation Plans, Capital Improvement
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Plans, Climate Action Plans, etc.),
including in order to leverage funding
options, shall also be explored.
g) GHADs/CSAs. Identification of
measures necessary to support creation
of Geologic Hazard Abatement Districts,
City Service Areas, or other similar
entities involving one or more sections
of the coastline, as a preferred
mechanism for implementation of
Shoreline Adaptation Program (and
related LCP amendment) requirements.
6 6.8 CR-I-5:

Shoreline
Mitigation
Program
Until the adoption of a Shoreline Mitigation Program,
coastal resource impacts shall be mitigated in accordance with CR-I-59.

Until the adoption of a Shoreline Mitigation
Program by the City and subsequent certification
by the Coastal Commission, coastal resource
impacts shall be mitigated in accordance with CRI-59.

Deleted CCC suggested modification requires
LCP amendment to incorporate
shoreline mitigation program
6 6.8A CR-I-7
Transfer of
Development
Rights
Program
Use the City’s transfer of development rights (TDR)
ordinance to relocate development rights from Coastal
Vulnerability zones (sending sites) to receiving sites
outside of Coastal Vulnerability zones. Identify areas
where densities and heights may be increased using TDR
credits, including to facilitate affordable housing.

N/A The City shall explore the ways in which the City’s transfer of development rights (TDR) ordinance
could be applied within the LCP to relocate
development rights from Coastal Vulnerability Zones
(sending sites) to receiving sites outside of Coastal
Vulnerability Zones, including to identify areas
where densities and heights may be increased using
TDR credits, including to facilitate affordable
housing.

Clarification of policy text.
6 6.9 CR-I-8: Critical
Transportatio
n
Infrastructure
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 recreation, to the maximum extent
feasible, and being consistent with prior permit
conditions and/or legal obligations pursuant to
the California Coastal Act.

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
recreation, to the maximum extent feasible, and
being consistent with 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 CR-I-9: Hazard
Prone
Infrastructure
The City will preserve, protect, or relocate hazard prone infrastructure to maintain critical services.

Preservation/protection in situ with shoreline armoring shall be required to meet the requirements of Policies.

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.

Preservation/protection in situ with shoreline
armoring shall be required to meet the
requirements of Policies.

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.

Preservation/protection in situ with shoreline
armoring shall be required to meet the
requirements of Policies CR-I-31 and CR-I-32.

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
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.10
A
CR-I-13: LHMP
Alignment
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 and response to future coastal
hazards. The City shall leverage FEMA funding
opportunities for hazard mitigation and other related
funding mechanisms to implement the Sea Level Rise
Adaptation Plan as expressed in the general and sub-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 and
response to future coastal hazards. The City shall
leverage FEMA funding opportunities for hazard
mitigation and other related funding mechanisms to
implement the LCP’s coastal resiliency provisions.

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

Shoreline
Protection
Structures
N/A Shoreline Protection Structures. Shoreline
protection structures shall be avoided except
that 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 to beach, public access and recreation,
and other coastal resources are fully mitigated
consistent with CR-I-5 and CR-I-59, 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
An additional modification deletes
this that was a CCC suggested
modification.
6 6.12 CR-I-15: Beach
Nourishment
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 of
Engineers), the City shall evaluate a beach
nourishment program, 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, consistent with other LCP
policies and the Coastal Act. The beach nourishment
program will need to be evaluated to be the least
environmentally damaging feasible alternative and
will include measures to protect water quality and to
avoid (and where unavoidable to minimize and
mitigate) 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.

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 is more
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-
15 Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.12
A
CR-I-16:

Additional
Flood
Protection
Measures.

N/A N/A Additional Flood Protection Measures. The City shall evaluate the need for additional flood protection
measures, which may include:
• Clarendon Road and/or West Fairway Park
stormwater basin, pump station, and/or
interior Sharp Park Golf Course levee to help
protect homes and businesses;
• A San Pedro Creek floodwall along
commercial property to help manage
flooding;
• Floodproofing at the Anza (stormwater)
and/or Linda Mar (sewer and stormwater)
pump stations to help protect against
coastal storm flooding vulnerabilities; and
• Elevate and floodproof development
structures if consistent with any permit
conditions and/or legal obligations pursuant
to the California Coastal Act as necessary to
mitigate flood damage, consistent with
height limitations.

Reorganization of document and
combined policy text.
6 6.12
B
CR-I-17
Groundwater
Monitoring
N/A N/A The City shall begin groundwater monitoring to help determine needs for dewatering wells in the lowest
portions of the coastal neighborhoods.

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

An additional modification that
reorganizes the document.
6 6.13
A
Subarea
Descriptions
The following policies and programs implement the nearterm sea level rise adaptation priorities for each sub-area in Pacifica, and identify mid- and long-term adaptation measures, subject to feasibility and monitoring concerns.

These priorities were developed based on existing
conditions and existing/near term vulnerabilities for each sub-area, as well as the City’s adopted goals for sea level rise adaptation.

The following section discusses implementation the
near-term sea level rise adaptation priorities for
each sub-area in Pacifica, and identifies mid- and
long-term adaptation measures, subject to feasibility
and monitoring concerns. These priorities were
developed based on existing conditions and
existing/near term vulnerabilities for each sub-area,
as well as the City’s adopted goals for sea level rise
adaptation.

Typo correction needed due to
reorganization of chapter.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.13 Sub-area
Policies and
Programs
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-foot offset 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 and
Programs
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.

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.

CCC suggested modification amends
text to use Coastal Vulnerability
Zones. Alternative Modification to
address a typo
6 6.13 Sub-area
Policies and
Programs
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 underperformance of protection measures, only if such floodproofing infrastructure is designed to eliminate
or mitigate adverse impacts on local shoreline sand
supply, consistent with LCP and Coastal Act policies
(CR-I-16).

CCC suggested modification amends
text to related to floodproofing
infrastructure. City staff is proposing
an alternative modification to clarify
requirements for sand supply.
6 6.13 Sub-area
Policies and
Programs
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
managed retreat. Since the text is not
policy language, staff is not proposing
an alternative modification.
6 6.14 N/A N/A The Special Resiliency Areas (SRA) include the existing shoreline protection structures in the
Rockaway Beach and West Sharp Park sub-areas.

These areas have existing development patterns
with significant amounts of Pre-Coastal Act
development, a mix of public streets and
infrastructure, land use prioritized by the Coastal
Act, and significant unified public coastal access, all protected by broad existing shoreline protection,
that warrant a unique policy approach. The purpose
of modifying policies applicable to this area is to
allow ongoing economic use and vitality of property,
provision of public services, operation of visitorserving uses, and protection of robust coastal access for all persons including persons with disabilities
The Special Shoreline Resilience Area
policies are incorporated at the end
of the chapter.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification within a Special Resiliency Area (SRA). The two SRA
locations are identified in Figure 6-2 and 6-3.
6 6.15 CR-I-17
Shoreline
Management
Plan
N/A N/A The City will establish a funding source for visitor amenity improvements implementation. Funding
sources may include, but not be limited to, grants,
fees, assessments, taxes, and any other lawful public
or private funding sources. The City will create a
funding and implementation plan with specific
projects to improvese visitor amenities in the Special
Resiliency Areas or elsewhere in Pacifica. Creation of
this plan will include community outreach and input.

The plan will be updated every 5 years and will
identify specific short-, medium-, and long-term
projects to mitigate coastal resource impacts from
ongoing reliance on shoreline protection within
Special Resiliency Areas. In general, the
implementation plan will fund a variety of projects
identifying and carrying out shoreline protection
removal opportunities, implementing nature-based
solutions to adapt existing shoreline protection
devices, maintenance or alteration of existing
shoreline protection devices to expand public
coastal access including but not limited to trails and
beach access, acquiring and conserving undeveloped
coastal properties, and enhancing visitor amenities.

Specific amenity improvements and shoreline
protection device removal may occur anywhere
within the City of Pacifica. provided until such time
as the CCC certifies the plan
In order to address many of the CCC
suggested modification’s impacts on
Pacifica’s existing developed
neighborhoods, City staff is proposing
an alternative modification that
would create two SRAs, which would
allow those areas greater flexibility in
permitting requirements and design.

The Shoreline Management Plan is
intended to provide other types of
coastal enhancements and benefits,
such as increased coastal access,
while allowing the existing shoreline
protection structures in Rockaway
Beach and West Sharp Park to be
used in technical analysis of hazards
for development in those areas.

The Special Shoreline Resilience Area
policies are incorporated at the end
of the chapter.
6 6.16 CR-I-15:

Shoreline
Protection
Structures (0-
1foot SLR or
260 foot
offset 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 environmentallydamaging 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-I56 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.

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-17
Transfer of
Development
Rights
(ongoing).

Provide an option to private landowners to voluntarily
transfer development potential as supported 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:

Shoreline
Protection
Structures (0-
1 foot SLR or
220-foot
offset from
bluff toe to
infrastructure
or
development)
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-I5 or CR-I-59, as necessary.

Deleted N/A CCC suggested modification
reorganizes the document.
6 6.19 CR-I-19: Beach
Nourishment
(0-1 foot SLR
or 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:

Shoreline
Protection
Structures (0-
1 feet SLR or
70-foot offset
from bluff toe
to
development
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.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification or
infrastructure)
.
6 6.21 CR-I-21: Beach
Nourishment
(0-2 feet SLR
or 70-foot
offset from
bluff toe to
development
or
infrastructure)
.

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
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 6.22 CR-I-22: Flood
Protection (1
feet 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 wave run-up and overtopping of bluff
face provided such modifications are consistent
with the LCP and any prior permit conditions
and/or legal obligations pursuant 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 the policies.
6 6.23 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, and protecting 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 Deleted CCC suggested modification deleted
the entire policy related to the Sharp
Park Golf Course. City staff is
proposing an alternative modification
that would keep a policy related to
the Sharp Park Golf Course but would
focus on public access and resource
enhancements.

An additional modification removes
this policy to reorganize the chapter.

The policy is reinserted below.
6 6.24 CR-I-24:

Shoreline
Protection
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.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.25 CR-I-25:

Structure
Elevation (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
construct shoreline protection structures if
consistent with Policies CR-I-56 and CR-I-57, and
with any prior permit conditions and/or legal
obligations pursuant to the California Coastal Act
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, and with any prior permit conditions
and/or legal obligations pursuant to the
California Coastal Act as necessary to mitigate
flood damage, consistent with height limitations,
determined via a site-specific study.

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 reorganize the chapter
and condense the policies.
6 6.26 CR-I-26: Beach
Nourishment
(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: Flood
Protection (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 Flood
Protection
Evaluate and construct appropriate flood protection
measures, which may include a Clarendon Road
stormwater basin, pump station, and/or interior Sharp
Park Golf Course levee, to protect homes and businesses from existing fluvial storm flood hazard zone.

N/A Deleted Reorganization of chapter.
6 6.28 CR-I-28: Flood
Protection (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 West Fairway
Park stormwater basin, pump station, and interior Sharp Park Golf Course levee to protect western homes from
future coastal/fluvial flood hazard zone.

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

Shoreline
Protection
Structure
Shoreline
Protection
Structures (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:

Shoreline
Protection (2-
3 feet SLR, or
when
backshore toe
(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.

Shoreline
Protection
Coordinate with Caltrans to evaluate the need for a
revetment or other appropriate shoreline protection 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 Mitigation Program (CR-I-5).

N/A Deleted Reorganization of chapter.
6 6.32 CR-I-32: Beach
Nourishment/
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.
6 6.32
A
CR-I-33
Development
Setbacks
(ongoing).

Implement new development shoreline setbacks
consistent with CR-I-44.

N/A Deleted Reorganization of chapter.
6 6.32
B
CR-I-34
Transfer of
Development
Rights
(ongoing).

Provide an option to the private landowners of the
Rockaway Headlands to voluntarily transfer development
potential as supported by CR-I-7.

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

Shoreline
Protection (2
ft SLR or 100
foot offset
from
shoreline to
infrastructure)
.

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: Beach
Nourishment
(2 ft SLR or
100 foot
offset from
shoreline to
infrastructure)
.

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.

N/A Deleted Reorganization of chapter.
6 6.35 CR-I-38: Flood
Protection (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: Flood
Protection
Analyze need for floodwall along commercial property to manage flooding from San Pedro Creek under existing
conditions with sea level rise allowance. Future flood
studies that include climate-driven changes in
precipitation should inform any floodwall design.

Floodproof Anza pump station (stormwater) to mitigate
existing coastal storm flooding vulnerabilities to wave run-up.

N/A Deleted Reorganization of chapter.
6 6.36 CR-I-39: Flood
Protection (2
feet SLR or
100-foot
offset from
shoreline to
infrastructure)
.
(2 feet SLR or 100-foot offset from shoreline to
infrastructure)
Deleted N/A CCC suggested modification
generalize policy and reorganized the
document.
6 6.36
A
CR-I-39: Flood
Protection
Floodproof the Linda Mar pump stations (sewer and
stormwater) to mitigate future coastal storm flooding
vulnerabilities to wave run-up as necessary.

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

Groundwater
Management
(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:

Groundwater
Management
Begin groundwater monitoring to determine needs for
dewatering wells in the lowest portions of the West Linda Mar neighborhood.

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

Shoreline
Protection
Structure
Upgrades.

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

N/A Deleted Reorganization of chapter.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.40 CR-I-19:

Technical
Reports.

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 shoreline properties.
6 6.41 CR-I-1943:

Technical
Reports.
• 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 similar
precautionary projections as reflected in future
updated statewide guidance) of sea-level rise for the
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:

Technical
Reports.
• 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 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, except that
development behind Special Shoreline Resiliency
Areas will be allowed to consider protection
provided by existing shoreline protection structures
when analyzing hazards; may consider CR-I-38, CR-I39 and CR-I-41.

CCC suggested modification reflects
language from the Sea Level Rise
adopted policy guidance. City staff is
generally in support of the
modification; however, staff is
proposing an alternative modification
to address the Special Shoreline
Resiliency Areas. The alternative
modification will give the SRA the
ability to use the existing shoreline
protections structures when
analyzing coastal hazards impacts.
6 6.43 CR-I-1943:

Technical
Reports.

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 edge
or highest predicted water line, accounting for wave
runup, highest astronomical tide, storm surge, and
other relevant factors (not less than 25 feet, or asd
determined by site-specific conditions) to avoid
coastal hazard risks to the maximum degree possible
while ensuring stability and structural integrity in
light of potential erosion and other coastal hazards,
where such minimum required setback shall be the
distance necessary for all structural development
(including any decks, fences, patios, arbors, and
other ancillary development, and generally not
including native landscaping, minor grading for
landscaping/restoration purposes, and other similar
non-structural development) to stay inland of a line
that identifies the future predicted location of the
blufftop edge or highest predicted water line,
accounting for wave runup, highest astronomical
tide, storm surge, and other relevant factors,
accounting for expected erosion and a bluff stability
factor of safety of at least 1.5 for static conditions
and at least 1.1 for seismic conditions (where
K=0.15) or sea level rise and other climate change
CCC suggested modification adds
clarifying language related to safety
requirements.

Siting and
Design.

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
and restoration plan, including bonding for large
projects, to avoid future shoreline protection
structures or project failure.

New Ddevelopment in Coastal Vulnerability Zones
shall be sited, and designed, and setback from the
blufftop and/or shoreline to be safe from erosion,
bluff failure, wave run-up, flooding and other coastal
hazards for at least 100 years the anticipated life of
the development or in accordance with CR-I-19,
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. Coastal
development pPermit 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 and restoration plan,
including bonding for large projects, to avoid future
shoreline protection structures or project failure.

However, behind Special Shoreline Resiliency Areas
development may consider CR-I-38, CR-I-39, and CRI-44. , new development shall be allowed to be sited and designed in reliance on and in consideration of
protection provided by existing shoreline protection
structures.

CCC suggested modification amends
the policy to be applicable to the
Coastal Vulnerability Zone and
reflects current CCC conditions of
approval. City staff is generally in
support of the modification;
however, staff is proposing an
alternative modification to address
the Special Resiliency Areas. The
alternative modification will give the
SRA the ability to use the existing
shoreline protections structures
when siting and designing
development.

Additionally, staff is proposing an
alternative modification to change
the year time period to “anticipated
life.” A CCC suggested modification
added a definition for anticipated life,
staff is proposing this alternative
modification to be consistent
throughout the document.
6 6.45 CR-I-2145:

Assumption of
Risk by Private
Landowners.

Coastal
Hazards Risk
Disclosure
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 of
development in Coastal Vulnerability Zones or and
Tsunami Inundation Zones (Figure 6-2) shall require
the property owners of all affected properties to
record deed restrictions against all such properties
prior to issuance of coastal development permits for
the development wherein the property owners
acknowledge and agree, on behalf of themselves
and all successors and assigns that theyapplicant 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
CCC suggested modification amends
the policy to be applicable to the
Coastal Vulnerability Zone and
Tsunami Evacuation Zone and reflects
current CCC conditions of approval.

City staff is generally in support of the
modification; however, City staff
proposes to change “Evacuation” to
“Inundation” zone. The use of
Tsunami Evacuation Zones for this
purpose is overly broad and not
closely enough related to actual
tsunami hazard conditions. City
staff’s alternative modification will
ensure a requirement more closely
aligned with actual hazard conditions.

Additional modifications include
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 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. • acknowledge the site is subject to coastal hazards, including but not limited to
episodic and long- term shoreline retreat
and coastal erosion, high seas, ocean waves,
storms, tsunami, tidal scour, coastal
flooding, landslides, bluff and geologic
instability, and the interaction of same, and
all as impacted by sea level rise;
• assume and accept the risks to themselves
and their properties of injury and damage
from such coastal hazards in connection
with the permitted development;
• unconditionally waive any claim of damage
or liability against the City and its officers,
agents, and employees, for injury and/or
damage in connection with the permitted
development;
• indemnify and hold harmless the City and its
officers, agents, and employees with respect
to the City’s approval of the development
against any and all liability, claims, demands,
damages, costs, expenses, and amounts paid
in settlement arising from any injury and/or
damage in connection with the permitted
development, including in terms of the
approval or issuance of the coastal permit,
the interpretation and/or enforcement of
coastal permit terms and conditions, or any
other matter related to the coastal permit;
• acknowledge public funds may not be
available in the future to repair, maintain,
and/or continue to provide infrastructure
and related services to the property (e.g.,
roads and utilities), and that the occupancy
of structures may be prohibited if such
services are no longer available to serve the
development, including where sewage
disposal and/or water systems are rendered
inoperable;
• waive any rights that might exist under
applicable law for shoreline protection
structures for the duration the permitted
development is present on the property;
• acknowledge the development may need to
specific language to be included in
deed restrictions. Additionally, City
Council directed staff to include an
exception clause to this policy. CCC
staff does not agree with the
exception clause because it could
lead to error and omissions in
technical reports that would put the
City and property at risk. The policy is
a disclosure of risks and does not
require action until and if hazards
occur. Staff request Council direction
on this specific topic.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification be removed and the site restored in
response to future hazard conditions and/or
certain defined triggers identified in the
LCLUP and implementing Programs and/or
as identified by the terms and conditions of
the CDP including when deemed unsafe, if
land comes to be impressed with a public
trust interest, when within 10 feet of the
blufftop edge, when within 10 feet of the
mean high tide line, when no longer served
by necessary utilities/infrastructure, , when
coastal hazards would necessitate
construction of a shoreline protection
structure to ensure safe occupancy of the
development, and/or as part of shoreline
protection structure repair/maintenance if
the development is not permitted to obtain
shoreline protection; and
• acknowledge any adverse effects to
property caused by the approved
development shall be fully the responsibility
of the property owner, including any cost
associated with abatement and/or future
relocation/removal of structures due to
coastal hazards; and acknowledge approval
of coastal development permits shall not
constitute a waiver of any public rights that
may exist on the affected properties
(including but not limited to the public’s
right of access onto or across the property),
and such property owner shall not use any
such approval as evidence of a waiver of any
public rights that may exist on the affected
properties now or in the future.

Except that an applicant shall not be required to
record a deed restriction as described in this policy if a site-specific geotechnical hazard analysis prepared
by a qualified professional licensed by the State of
California determines that the project site would not
be subject to the hazard(s) identified in the Coastal
Vulnerability Zones and Tsunami Inundation Zone
for the Anticipated Life of the project.
6 6.45
A
CR-I-23 Bluff
Face
Development
Shoreline protection structures, grading, and landform
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 public infrastructure (e.g.
public roads, public utility infrastructure, etc.)
where no feasible alternative means of providing
such improvements/infrastructure exists; and
Clarifies policy.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.46 CR-I-2549:

Substantial
Modifications
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-I44. 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. When
proposed modifications to an existing structure
constitute a Substantial Structural Modification
(SSM), as defined, such proposed development
shall correct any existing legal nonconformities
and shall be undertaken consistent with the LCP
and the Coastal Act, including but not limited to
Policies CR-I-43 and CR-I-44.

Substantial Structural Modifications. When
proposed modifications to a an existing structure
constitute a Substantial Structural Modification
(SSM), as defined, such proposed development shall
correct any existing legal nonconformities and shall
be undertaken consistent with the LCP and the
Coastal Act, including but not limited to Policies CRI-1943 and CR-I-2044. Except that in Special Resiliency Areas, development shall only be required
to correct existing nonconformities related to
applicable coastal hazards on the site.

Nonconformities related to non-coastal resource
issues may be maintained at the discretion of the
decision- making body so long as they do not lead to
significant impacts to coastal resources.

CCC suggested modification requires
projects that meet the SSM definition
to correct any existing legal
nonconformities, in order to the
entire site to be compliant with the
LCP and Coastal Act. Staff is generally
in support; however, staff is
proposing an alternative modification
to address the Special Resiliency
Areas. The alternative modification
will give the SRA the ability to correct
only existing nonconformities
associated with coastal hazards
present on the site, rather than a
broader range of potential LCLUP or
zoning nonconformities.
6 6.47 CR-I-2751:

Habitat Sea
Level Rise
Migration
Buffers.

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) of 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.

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
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 based on the type of development
and current State guidance.

A 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. The overall buffer area shall
include both the sea level rise and habitat buffer.

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 based on the type of
development and current State guidance. N/A
CCC suggested modification would
require an additional seal level rise
buffer. Staff is generally in support of
the modification; however, staff is
proposing an alternative modification
to clarify that a buffer area should
include all the buffer requirements.

During the May 23 discussion, City
Council directed staff to keep the CCC
suggested modification and remove
the alternative modification.
6 6.47
A
CR-I-29
Subdivision
Limitations
Update the Zoning Ordinance to prohibit the division of shoreline property that creates hazardous or unbuildable parcels due to 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. Only allow new lots to be created if they
can be developed without ever requiring shoreline
protection for the development.

N/A Prohibit the division of shoreline property that creates hazardous or unbuildable parcels due to 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. Only allow new lots to be created if they can be developed without ever requiring shoreline protection for the development.

Alternative modification from “Update
the Zoning Ordinance” to “Prohibit”
6 6.47
B
CR-I-30 Soft
Shoreline
Protections
Encourage the use of soft or natural shoreline protection methods, such as dune restoration and beach/sand
nourishment as alternatives to hard shoreline protection structures, such as revetments or sea walls. Soft
shoreline protection devices shall be fully evaluated for coastal resource impacts, and, shall only be approved if found consistent with the LCP and Coastal Act policies
related to shoreline protection. Consider combining
beach replenishment with groin construction to maintain beaches and protect development. (see subarea policies).

N/A Encourage the use of soft or natural shoreline protection methods, such as dune restoration and beach/sand
nourishment as alternatives to hard shoreline protection structures, such as revetments or sea walls. Soft shoreline protection devices shall be fully evaluated for coastal resource impacts. Consider combining beach
replenishment with groin construction to maintain beaches and protect development.

Clarification to policy.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.48 CR-I-55: Beach
Nourishment
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 and mitigate) 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.

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 subarea policies and the Coastal Act. The beach nourishment program will need to be evaluated
to be the least environmentally damaging
feasible alternative and will include measures to
protect water quality and to avoid (and where
unavoidable to minimize and mitigate) 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 compliance with the Coastal Act.

City staff proposes an alternative
modification that would delete CR-I55 and incorporate the language into CR-I-16.
6 6.49 CR-I-3156:

Existing
Shoreline
Protection
Structures
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, 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 if found to be inconsistent with
the LCP by the reevaluation, and the area restored.

Activities considered “repair and maintenance” shall
not result in any enlargement or extension of
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, shall provide mitigation for any new
coastal resource impacts not previously or otherwise
mitigated, including through the City’s Shoreline
Adaptation Program (CR-I-5), Coastal Access and
Resilience Program (CR-I-44) and/or Policy CR-I-34,
shall minimize impacts, and must be found to be the
least environmentally damaging feasible 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.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.50 CR-I-3156:

Existing
Shoreline
Protection
Structures
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 an
exclusion contained in the definition of Substantial
Structural Modification shall be considered to be
allowed without the above-mentioned
considerations.

CCC suggested modification deletes
text related to modifications to
existing structures. City staff is
proposing an alternative modification
to clarify that maintenance and
modification of existing shoreline
protection structures is allowed.
6 6.51 CR-I-3257:

New Shoreline
Protection
Structures
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 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.

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 (including existing public roads and sewer
lines if necessary) or public beaches in danger from
coastal hazards erosion, when there is no less
environmentally damaging feasible alternative and
when designed to avoid, and where unavoidable,
minimize to the 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.

CCC suggested modification amends
the policy to address alternative
evaluation and minimizing coastal
resource impacts. City staff is
generally in support; however, City
staff is proposing an alternative
modification that would replace the
word “erosion” with “coastal
hazards” in order to be more inclusive
of the variety of coastal hazards
affecting the coastline and in
recognition of the deleted sub-area
policies. Minor revision to correct
references and clarification.
6 6.52 CR-I-3358:

Authorization
Limits of
Shoreline
Protection
Structures
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 protection structures. Staff
is generally in support of the
modification, if alternative
modifications to other policies
related to the Special Resiliency Areas
(SRAs) remain.
6 6.53 CR-I-34:

Mitigating
Impacts of
New Shoreline
Protection
Structures.

This policy may be met through compliance with the
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) or Coastal Access and Resilience Program (CR-I-44).

Correction to references
6 6.54 CR-I-36:

Emergency
Shoreline
Protection
Structures
N/A N/A In cases of emergency, an emergency shoreline protection structure may only be approved on a temporary basis, and only under the condition that the structure is required to be removed unless a regular CDP is approved for retention of the structure. In such cases, a complete CDP application shall be required to be submitted within 60 days following construction of the temporary emergency shoreline
protective structure, unless an alternate deadline is
New policy.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification authorized by the Planning Director for good cause,
including continued good faith efforts toward submittal of such application. Any such temporary emergency shoreline protective structure shall be sited and designed to be the minimum necessary to abate the identified emergency, and to be as consistent as possible with all LCP shoreline
protective structure standards, including in terms of
avoiding coastal resource impacts to the maximum possible extent. Mitigation for impacts will be required through the regular CDP process, including mitigation commensurate
with the duration of impacts caused by the emergency
temporary structure. The City shall notify the Executive Director upon receipt of a request for an emergency
shoreline protective structure within the City’s CDP
jurisdiction.
6 6.55 CR-I-37: Sharp
Park Golf
Course
N/A N/A Strongly support the City and County of San Francisco’s ability to provide public access along the coast, protect Environmentally Sensitive Habitat Area, and provide flood protection.

Reorganization of chapter
6 6.56 CR-I-38: Public
Infrastructure
Along the
Shoreline in
Special
Resiliency
Areas
N/A N/A Public infrastructure (e.g., public roads, sidewalks, parking areas, accessways, water and sewer infrastructure) on the immediate oceanfront of the Special Shoreline Resilience Areas mapped in Figures 6-3 and 6-4 shall be consistent with all LCP provisions except that, to establish the safety and stability of the proposed development, such
development may rely on a shoreline protection structure that is existing at the time of the application and/or that is proposed in the same permit application as the
infrastructure itself.

SSRA policy
6 6.57 CR-I-39:

Development
Directly Inland
of Public
Infrastructure
in Special
Resiliency
Area
N/A N/A Notwithstanding Policy CR-I-2, development located directly inland of the public infrastructure on the
immediate oceanfront of the Special Shoreline Resilience Areas mapped in Figures 6-3 and 6-4 may rely on a
shoreline protection structure in that area that is existing at the time of the permit application to help demonstrate that its setbacks meet the requirements of Policies CR-I-4319 and CR-I-4420. In addition to meeting the requirements of Policy CR-I-4521, such development shall be conditioned to require the applicant to acknowledge that the
development’s long-term safety may be based in part on
shoreline protection structures located seaward of the
development, which may or may not be effective, and/or
be maintained, and/or be present in the future.
6 6.58 CR-I-40
Armoring in
Special
Resiliency
Areas
N/A N/A In the Special Shoreline Resilience Areas mapped in Figures 6-3 and 6-4, repair and maintenance, enhancement,
realignment, and redevelopment/replacement of a
shoreline protection structure that is existing at the time of the permit application, including minor extensions in order to fill gaps or otherwise ensure the overall shoreline
protection structure is effective may be approved when
required to protect public infrastructure (e.g., public roads, Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification sidewalks, parking areas, accessways, water and sewer
infrastructure) on the immediate oceanfront of the Special Shoreline Resilience Areas mapped in Figures 6-3 and 6-4.

Such shoreline protection structure must comply with all relevant LCP policies except that it may be approved
regardless of whether such shoreline protection structure is required to protect a coastal dependent use, a public beach in danger of erosion, or a structure that qualifies as an "existing structure" within the meaning of Coastal Act
Section 30235. Any such shoreline protection structure
shall incorporate public access elements into its design, be the least environmentally damaging feasible design, and improve coastal resource conditions relative to conditions that exist at the time of permit approval (examples of
improved conditions could include restoring intertidal
habitat, enhancing public access, having a smaller footprint than a shoreline protection structure that already lawfully exists, enhancing scenic and visual qualities of the area). 6 6.58 CR-I-41
Effective Date
of Policies 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 by the
Coastal Commission’s Executive Director:
• In accordance with Policy CR-I-434, the
initial Coastal Access and Resilience Program is
developed and submitted for Commission
review, and
• In accordance with Policy CR-I-5, the
development of the Shoreline Adaptation
Program has been initiated, including, at a
minimum, that the City has developed a public
engagement plan, workplan, timeline, and
identified funding for completion of the
technical studies and planning work.
6 6.59 CR-I-42
Suspension of
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 and effect
during the period of suspension, upon the occurrence
of any of the following conditions, as determined by
the Coastal Commission’s Executive Director:
• In accordance with Policy CR-I-43, if:
o the Coastal Access and Resilience
Program is not certified by the
Commission within 15 months of
acceptance of the LCP amendment for
filing as identified in Policy CR-I-41, or
o any of the CDP applications that
are required every 5 years to
implement projects are not
submitted in complete form, or
o any of the projects required in the Coastal
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Access and Resilience Program are not
developed/implemented.
• In accordance with Policy CR-I-5, if:
o The City has not completed the
technical studies to accomplish part (a)
of the Shoreline Adaptation Program
within 6 years of effective certification
of the Land Use Plan Amendment that
created the requirement for the
Shoreline Adaptation Program (i.e.,
created Policy CR-I-5), or
o The City has not prepared a Draft
Shoreline Adaptation Program within 8
years of effective certification of the
LUPA that created the requirement for
the Shoreline Adaptation Program (i.e.,
created Policy CR-I-5), or
o The Coastal Commission has not
certified a Final Shoreline Adaptation
Program within 10 years of effective
certification of the LUPA that created
the requirement for the Shoreline
Adaptation Program (i.e., created
Policy CR-I-5).

In the event that the Coastal Commission’s Executive
Director determines that the City has not met one or more of the above conditions, the Executive Director shall
provide a preliminary written determination to the City explaining that one or more conditions set forth above
have not been met and that suspension of Policies CR-I-38, CR-I-39 and CR-I-40 shall occur after fifteen working days, unless the City submits written objections to the
preliminary determination and the Executive Director
concurs with the objections. The City may submit to the Executive Director a written notice of objection within seven working days of the date of the preliminary
determination. The Executive Director will promptly review and either concur or disagree, in writing, with any objection submitted by the City prior to the fifteenth working day from the date of the preliminary determination. The period of suspension will end, and Policies CR-I-38, CR-I-38 and CRI-40 will once again become effective, at the beginning of the fifth working day after the Executive Director provides a written determination to the City that all necessary
conditions have been satisfied.
6 6.60 CR-I-43: End
Date of
Policies CR-I38, CR-I-39,
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 an LCP amendment extending
that deadline. As of January 1, 2045 (or such later date as Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification CR-I-40. specified in an LCP amendment), development approved based on Policies CR-I-38 and CR-I-39 that relied on a
shoreline protection structure to demonstrate safety,
stability, and adequate setbacks (including in relation to the requirements of Policies CR-I-19 and CR-I-20) shall become legal nonconforming and, moving forward, a Substantial
Structural Modification to such development shall, in
accordance with Policy CR-I-25, be required to be
consistent with all LCP provisions, including but not limited to Policies CR-I-2, CR-I-19, and CR-I-20 related to setbacks and safety without relying on shoreline protection to
establish safety, and Policy CR-I-32 regarding approvable shoreline protection.
6 6.61 CR-I-44:

Coastal Access
and Resilience
Program.

N/A N/A The City shall develop a Coastal Access and Resilience Program to ensure continued and increased access to the coast, including as sea levels rise. The Program shall
include, but is not limited to, methods to maximize public access to and along the coast despite sea level rise and address the coastal resource impacts associated with
shoreline protection structures along the City’s shoreline, including as required per Policy CR-I-34, and impacts
associated with the perpetuation of shoreline protection structures within Special Shoreline Resilience Areas allowed by Policies CR-I-38, CR-I-39, and CR-I-40. The priority for such access benefits and mitigation shall be efforts/projects designed to maintain and enhance sandy beaches and
public access to and along the City’s shoreline in a manner that is most protective of coastal resources and general public access utility. The Program shall include, at a
minimum, all of the following:
• A prioritized list of public access projects within the City’s Coastal Zone that can help maximize access
to the coast and serve as required mitigation.

Projects shall be organized in terms of expected
implementation dates within 5-year increments
and shall be developed with full community input.

Some opportunities may include enhancement of
public recreational access facilities (e.g., pathways,
overlooks), removal of existing armoring, naturebased adaptation, beach nourishment, and acquisition/conservation of properties subject to
coastal hazards. Potential projects include but are
not limited to:
• Enhanced public pathway system seaward of
private development in the Rockaway Beach area.
• Coordinated vertical accessways, landscaping,
benches, picnic tables, bicycle racks, garbage and
recycling receptacles, doggie mitt stations, and
enhanced signage in the Sharp Park area.
• The following projects listed in the program:

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Rockaway to Pacifica State Beach Trail
Rehabilitation, Rockaway Beach Parking Structure,
Rockaway Parking Area, Beach Boulevard
Promenade Park Improvements, Sharp Park Priority
Development Area (PDA) Access Pedestrian
Improvement project
• A timeline and benchmarks for implementation of
identified projects, including measures by which
progress and success can be measured over time,
as well as necessary monitoring and tracking. At a
minimum, projects shall be designed to be
implemented in at most 5 year increments.
• Identification and development of a funding
mechanism (or mechanisms) sufficient to cover all
identified projects. Such mechanisms may include,
but are not limited to:
• Development of a protocol for requiring mitigation
for development within Special Shoreline Resilience
Areas that is allowed to rely on existing shoreline
protection structures pursuant to CR-I-38 and CR-I39, thus resulting in continued impacts from that armoring.
• Formation of a GHAD, CSA, or similar.
• State or Federal grant funding
• Other funding mechanisms identified for
adaptation planning and projects as discussed in
Policy CR-I-5.

An initial program shall be developed and should be
submitted as an amendment to the LCP by 3 years from the date of LUP Update certification]. By 5 years from the date of Coastal Commission approval of the initial Coastal Access and Resilience Program (and every subsequent 5 years) the City shall submit a complete CDP application to the Coastal Commission, or where applicable the City itself shall
approve projects via City CDPs, to implement projects
identified in the Program. The Program shall be monitored, evaluated, updated, and resubmitted as an amendment to
the LCP at least every 10 years thereafter.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.61 6.9 Costal
Flooding and
Other Hazard
Standard
Policies
CR-I-61 Flood Risk Reduction. The City should, when
appropriate, evaluate and pursue, floodproofing of
infrastructure and other development in danger from
projected flooding by 2050. Allow and facilitate (if
feasible) private owners to floodproof development
structures, consistent with other LCP policies.

N/A Deleted Reorganization of chapter.

G
l
o
s
s
a
r
y

7.1A Acronyms N/A N/A CSA: City Service Area Clarification G
l
o
s
s
a
r
y

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
residential development and critical
infrastructure.

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

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification further point separating the dynamic portion of
the beach from the inland area as distinguished
by vegetation, debris or other geological or
historical evidence.

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 longterm 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 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'bergNejedly Forest Practice Act of 1973 (commencing with Section 4511).

On land, in or under water, the placement or
erection of any solid material or structure; discharge 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 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.’
N/A CCC suggested modification adds new
text to clarify terms used in
document and be consistent with the
Coastal Act.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Glossary 7.6 Environmenta
l 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 with
respect to the development, adoption,
implementation, and enforcement of environmental
laws, regulations, and policies N/A
The City’s General Plan consistency
changes eliminated this sentence and
the suggested modification is no
longer applicable. However, the
proposed CCC Suggested
Modification is consistent with the
Coastal Act and thus should remain.

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; or
ii) 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 survey
prepared by a licensed professional land surveyor
based on field data collected within 12 months. The
survey must be conducted in consultation with and
approved by the California State Lands Commission.

City Council directed staff to add a
definition for Mean High Tide Line.

While the Coastal Act makes several
mentions of “mean high tide,” the
Coastal Act does not contain a
definition. Staff is recommending an
alternative modification to add a new
definition similar to Policy CR-I-46.

Glossary GP5 Mitigation This edit was added in October 2023 as part of the GP consistency changes. It replaced the definition with the following: As defined in Section 15370 of the State
Guidelines for Implementation of the California
Environmental Quality Act, mitigation includes:

1. Avoiding the impact altogether by not taking a certain action or parts of an action.

2. Minimizing impacts by limiting the degree or
magnitude of the action and its implementation.

3. Rectifying the impact by repairing, rehabilitating, or restoring the impacted environment.

4. Reducing or eliminating the impact over time by
preservation and maintenance operations during the life of the action.

5. Compensating for the impact by replacing or providing substitute resources or environments.

CCC Suggested Modification from June 2024
recommended deletion of the definition.

N/A Staff agrees with the CCC suggested
modification from June 2024. The
definition is deleted because it relies on
the California Environmental Quality Act
definition, which may not be applicable
to all projects within the coastal zone.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Glossary GP6 Mitigation
Measure
This edit was added in October 2023 as part of the GP
consistency changes. It added the following: Action taken to avoid, minimize, or eliminate environmental impacts.

Mitigation includes: avoiding the im-pact altogether by not taking a certain action or parts of an action;
minimizing impacts by limiting the degree or magnitude
of the action and its implementation; rectifying the
impact by repairing, rehabilitating, or restoring the
affected environment; reducing or eliminating the impact over time by preservation and maintenance during the
life of the action; and compensating for the impact by
repairing or providing substitute resources or
environments.

CCC Suggested Modification from June 2024
recommended deletion of the definition.

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.

Glossary 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 runup,” “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
Exterior
Structural
Modification
(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;
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; or
iii) 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,
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; or
iii) an increase of the existing building footprint
equal to 50 percent or more;
howeverbut excluding, but not limited to removal,
replacement, or maintenance of nonstructural
exterior components, such as: decorative
i) plywood roof sheathing;
CCC suggested modification deletes
text to be consistent with CCC
guidance. Staff is generally in support
of the modification; however, staff is
proposing an alternative modification
to clarify that nonstructural elements
and waterproofing materials are not
part 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 code provision 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,
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 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, however, that the reconstructed, repaired, or maintained shoreline
protection structure is not 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. and windows.

Incremental changes that cumulatively amount
to replacement of 50 percent of more over time
shall also be considered a SSM.
ii) underlayment;
iii) siding;
iv) shingles;
v) other roof materials; and
vi) windows and doors (including garage
doors);
vii) exterior waterproofing/weatherproofing
materials;
viii) appliance installations and
replacements, such as water heaters,
generators, and solar panels, that do not
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 and
regulations, such as disabled
accessibility improvements and seismic
retrofits/upgrades.

Incremental structural changes that cumulatively
amount to replacement of 50 percent or more over
time shall also be considered a SSM.
that this provision and definition not
be interpreted together. Staff is
proposing an alternative
modification, new Modification No.

6.2A, that provides the clarification
on the applicability of Section
30610(g) of the Coastal Act.

Additionally, staff has incorporated
direction provided from Council at
the March 2
nd meeting to include
general non-structural property
upgrades, remedial actions, and other
modification required by State and/or
Federal laws in the SSM exclusions.

Glos
sary

7. 1
1 Tsun
ami
Inun
datio
n
Zone
N/A N/A An area of likely tsunami inundation under a
tsunami scenario. The applicable tsunami
scenario should balance a reasonable probability
of event occurrence with a reasonable potential
of the tsunami event causing substantial loss of
life and/or damage to property. Such a tsunami
scenario could include, but is not necessarily
limited to, 475-year Average Return Period (ARP)
event described in the publication Probabilistic
Tsunami Hazard Maps for the State of California
(Phase 2), California Department of Conservation
(2023).

Staff recommends an alternative modification to add a new definition to clarify and provide guidance on the Tsunami Inundation Zone.

Pacifica City CouncilAugust 12, 2024

Pacifica City Council
August 12, 2024