Coastal Development Permit (CDP): A permit for any development within the coastal zone that is required pursuant to subdivision (a) of Section 30600 of the California Coastal Act.
Coastal-Dependent Development or Use: Any development or use which requires a site on, or adjacent to, the sea in order to function.
Coastal Hazards: Include but are not limited to episodic and long-term shoreline retreat and coastal erosion, high seas, ocean waves, storms, tsunami, tidal scour, wave overtopping, coastal flooding, and their interaction, all of which may be exacerbated by sea level rise.
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Packet Pg. 243 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) PACIFICA LOCAL COASTAL LAND USE PLAN – REVISED CERTIFICATION DRAFT, SEPTEMBER 2024 G-4
Coastal-Related Development: Any use that is dependent on a coastal-dependent development or use.
Coastal Views Corridors/View Sheds: An area that is identified as significant for providing visual access to the coast.
Coastal Vulnerability Zone: The areas shown on the City’s maps prepared for the Pacifica SLR Vulnerability Assessment (1/12/2018), incorporated herein, and as may be amended from time-to-time based on updated best available science about projected sea-level rise, erosion, flooding, and other coastal hazards, excluding tsunami inundation and evacuation zones.
Critical Habitat Areas: Areas containing features essential for the conservation of species listed under the FESA, and which may require special management and protection outside that which is already provided by FESA. Critical Habitat Areas are designated by the USFWS.
Cumulative Effects: The incremental effects of an individual project shall be reviewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.
Design Life. The design life of a structure is the period of time during which it can still safely meet the demand of its users.
Development: 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.’ Dune: Ridges or mounds of loose, wind-blown material usually sand. A dune structure often has a back and foredune area. Stable dunes are often colonized by vegetation.
Easement: A right given by the owner of land to another party for specific limited use of the land. An easement may be acquired by a government through dedication when the purchase of an entire interest in the property may be too expensive or unnecessary; usually needed for utilities or shared parking.
Economic Life (also called “design life” and “expected life”): Period over which a development is expected to be usable, with normal repairs and maintenance, for the purpose for which it was designed.
1.b
Packet Pg. 244 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4)
GLOSSARY
G-5
Energy Facility: Any public or private processing, producing, generating, storing, transmitting, or recovering facility for electricity, natural gas, petroleum, coal, or other source of energy.
Erosion: The process by which material is removed from the earth’s surface (including weathering, dissolution, abrasion, and transportation), most commonly by wind or water.
Environmental Justice: 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.
Environmentally Sensitive Habitat Area (ESHA): Any area in which plant or animal life or their habitat are either rare or especially valuable because of their special nature or role in an ecosystem and which could be easily disturbed or degraded by human activities and development (California Public Resources Code Section 30107.5).
Estuary: A coastal water body, usually semi-enclosed by land, having open, partially obstructed, or intermittent exchange with the open ocean, and in which ocean water is at least occasionally diluted by freshwater from the land.
Fault Rupture: The displacement of the earth’s surface due to the movement along a fault associated with an earthquake.
Feasible: Capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.
Fluvial: Produced by the action of a stream.
Fill: Earth or any other substance or material, including pilings placed for the purposes of erecting structures thereon, placed in a submerged area.
Fuel Modification: A fire control strategy that thins vegetative cover within a buffer area surrounding development in order to interrupt continuous paths of fuel and provide defensible space to allow for firefighting operations in case of wildland fire.
Groundwater: Subsurface water occupying the zone of saturation usually found in porous rock strata and soils.
Habitat: The natural environment of a plant or animal.
Headland: A high, steep-faced projection extending into the sea, usually marking an area of fairly stable and rigid landform.
Hillside Preservation District (HPD): A district that overlays Pacifica’s base zoning and covers most of the city’s ridges and open spaces. The HPD is intended to ensure that development of highly sensitive slopes does not endanger the public or harm the environmental or scenic values of the site, and to encourage highquality site planning and design that enhances the beauty of the landscape. The District creates more stringent lot coverage limits, based on the average natural slope of the site, and requires submission of development plans, grading plans, and other documentation.
1.b
Packet Pg. 245 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) PACIFICA LOCAL COASTAL LAND USE PLAN – REVISED CERTIFICATION DRAFT, SEPTEMBER 2024 G-6
Hydric Soil: A type of soil with characteristics resulting from prolonged saturation and chemically reducing conditions such as occurs under anaerobic conditions.
Hydrology: The dynamic processes of the water within an environment including the sources, timing, amount, and direction of water movement.
Hydrophytic Vegetation: Plants that have adapted to living in aquatic environments. These plants are also called hydrophytes. In wetlands, hydrophytic species occur where at least the root zone of the plant is seasonally or continually found in saturated or submerged soil.
Landslide: Also known as slope failure, a landslide involves the downslope displacement and movement of material, and can be triggered by either static (gravity) or dynamic (seismic) forces.
Land Divisions: Land divisions include subdivisions (through parcel map, tract map, grant deed, or any other method), lot line adjustments, redivisions, mergers, and certificates of compliance.
Littoral Cell: A region that encompasses most features affecting sediment transport. The boundaries of the cell are usually delineated by river drainage areas, promontory headlands, or submarine canyons on the periphery, the continental shelf-continental slope boundary on the seaward side and by inland ridges and river inlets on the landward side. Sediment within these cells generally travel seaward by river drainage, southward (downcoast) by longshore currents, and are eventually lost to the continental slope area or submarine canyon.
Liquefaction: The transformation of soil from a solid to a liquefied state, in which saturated soil temporary loses strength due to the buildup of excess pore water pressure, especially during earthquake-induced cyclic loading.
Low Impact Development (LID): Site planning and development features that reduce impermeable surface areas and increase infiltration, such as use of permeable paving, vegetated swales, and water retention facilities.
Marine System: Open ocean overlying the continental shelf and coastline exposed to waves and currents of the open ocean shoreward to (1) extreme high water of spring tides; (2) seaward limit of wetland emergent vegetation, trees, or shrubs; or (3) the seaward limit of the Estuarine System, other than vegetation. Salinities exceed 30parts per thousand.
Mean-High Tide: 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.
Monitoring: The systematic collection of physical, biological, or economic data or a combination of these data in order to make decisions regarding project operation or to evaluate project performance. Monitoring is typically required for beach nourishment projects and habitat restoration projects.
Net Developable Area. The total area of land available for development, not necessarily the total area of a property itself. It does not include open space, drainage land, regional roads and land used for other public facilities.
1.b
Packet Pg. 246 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4)
GLOSSARY
G-7
Non-conforming Use: A use of a structure or land that was lawfully established and maintained, but which does not conform with the use regulations or required conditions for the district in which it is located by reason of adoption or amendment of this code or by reason of annexation of territory to the City.
Non-conforming Structure: An existing structure that is legally nonconforming with an LCP standard.
Permit: Any license, certificate, approval, or other entitlement for use granted or denied by any public agency.
Prescriptive Rights: Prescriptive rights refer to public rights that are acquired over private lands through continuous use over the length of a “prescriptive period” of at least five years. This right of access is considered an “implied dedication” of a public easement, and can occur with or without the explicit consent of the property owner.
Public Trust Lands: All lands subject to the Common Law Public Trust for commerce, navigation, fisheries, recreation, and other public purposes. Public Trust lands include tidelands, submerged lands, the beds of navigable lakes and rivers, and historic tidelands and submerged lands that are presently filled or reclaimed, and which were subject to the Public Trust at any time.
Public works: The following developments are considered public works:
1. All production, storage, transmission, and recovery facilities for water, sewerage, telephone, and other similar utilities owned or operated by any public agency or by any utility subject to the jurisdiction of the Public Utilities Commission, except for energy facilities.
2. All public transportation facilities, including streets, roads, highways, public parking lots and structures, ports, harbors, airports, railroads, and mass transit facilities and stations, bridges, trolley wires, and other related facilities.
3. All publicly financed recreational facilities, all projects of the State Coastal Conservancy, and any development by a special district.
4. All community college facilities.
Qualified Biologist: A person who has earned a minimum of a Bachelor of Science degree in biology or a related field from an accredited college or university and has demonstrated field experience evaluating land use impacts on marine or wildlife species and their habitats. Biologists who conduct wetland delineations shall have completed the U.S. Army Corps of Engineers' "Reg IV" wetland delineation training, or the equivalent, and shall have the demonstrated ability to independently conduct wetland delineations.
Riparian: Consists of trees, shrubs, or herbs that occur along watercourses or water bodies. The vegetation is adapted to flooding and soil saturation during at least a portion of its growing season.
Riprap: A protective layer or facing of rock, concrete blocks or quarry stone, placed to prevent erosion, scour, or sloughing of an embankment or bluff.
Sea: The Pacific Ocean and all harbors, bays, channels, estuaries, salt marshes, sloughs, and other areas subject to tidal action through any connection with the Pacific Ocean, excluding non-estuarine rivers, streams,
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Packet Pg. 247 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) PACIFICA LOCAL COASTAL LAND USE PLAN – REVISED CERTIFICATION DRAFT, SEPTEMBER 2024 G-8
tributaries, creeks, and flood control and drainage channels. “Sea” does not include the area of jurisdiction of the San Francisco Bay Conservation and Development Commission, established pursuant to Title 7.2 (commencing with Section 66600) of the Government Code, including any river, stream, tributary, creek, or flood control or drainage channel flowing directly or indirectly into such area.
Sea Cliff: A vertical or very steep cliff or slope produced by wave action, situated at the seaward edge of the coast or the landward side of the wave-cut platform, and marking the inner limit of beach erosion.
Seawall: A structure separating land and water areas, primarily designed to prevent erosion and other damage due to wave action. It is usually a vertical wood or concrete wall as opposed to a sloped revetment.
Sediment: Grains of soil, sand, or rock that have been transported from one location and deposited at another.
Sensitive Coastal Resource Areas: Those identifiable and geographically bounded land and water areas within the coastal zone of vital interest and sensitivity. "Sensitive coastal resource areas" include the following: (a) Special marine and land habitat areas, wetlands, lagoons, and estuaries as mapped and designated in Part 4 of the coastal plan;(b) Areas possessing significant recreational value; (c) Highly scenic areas; (d) Archaeological sites referenced in the California Coastline and Recreation Plan or as designated by the State Historic Preservation Officer; (e) Special communities or neighborhoods which are significant visitor destination areas; (f) Areas that provide existing coastal housing or recreational opportunities for low- and moderate income persons; and(g) Areas where divisions of land could substantially impair or restrict coastal access.
Seiche: A standing wave in an enclosed body of water that may be caused by tidal action or a seismic event.
Shore: Narrow strip of land in immediate contact with the sea, including the zone between high and low water. A shore of unconsolidated material is usually called a beach.
Shore Protection: Structures or sand placed at or on the shore to reduce or eliminate upland damage from wave action or flooding during storms.
Shoreline: Seaward of the base of coastal bluffs and/or at or near the sandy beach/ocean elevation, including as depicted in Appendix B (“Coastal Zone Vulnerability Maps”) and denoted as “wave run-up,” “storm flood area,” and “flood prone area.”
Shoreline Armoring: Protective structures such as vertical seawalls, revetments, riprap, revetments, and bulkheads built parallel to the shoreline for the purposes of protecting a structure or other upland property.
Special Status Species: Any species which is listed, or proposed for listing, as threatened or endangered by the U.S. Fish and Wildlife Service, National Marine Fisheries Service, or California Department of Fish and Wildlife under the provisions of the Federal and State Endangered Species Acts. It also includes any species designated by the U.S. Fish and Wildlife Service and California Department of Fish and Wildlife as a “candidate” or “species of concern” or species identified on California Native Plant Society’s Lists 1A, 1B, or 2, implying potential danger of extinction.
1.b
Packet Pg. 248 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4)
GLOSSARY
G-9
Storm Surge: A rise above normal water level on the open coast due to the action of wind stress on the water surface. Storm surge resulting from a hurricane also includes the rise in level due to atmospheric pressure reduction as well as that due to wind stress.
Stream: A topographic feature that at least periodically conveys water through a bed or channel having banks. This includes watercourses having a surface or subsurface flow that supports or has supported riparian vegetation. A creek is a subset of a stream that tends to have low water flow.
Structure: Anything construed or erected which requires a fixed location on the ground, or is attached to a building or other structure having a fixed location on the ground.
Submerged Lands: Submerged lands shall be defined as lands which lie below the line of mean low tide.
Subsidence: The sinking of a portion of the ground surface that may occur from immediate settlement, shrinkage of expansive soil, liquefaction, earthquakes, or excess extraction of groundwater.
Substantial Structural Modification (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 or surface area of the exterior walls or other major structural components (including but not limited to floor framing, roof framing, and foundation structures), considered individually (i.e., percentages are calculated by the individual structural component being altered, and not additive between different structural components), 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; however excluding, but not limited to alteration, removal, or replacement, of nonstructural components, such as:
i) underlayment;
ii) siding;
iii) shingles;
iv) other nonstructural roofing materials;
v) windows and doors (including garage doors) that do not alter width or location; vi) exterior waterproofing/weatherproofing materials
vii) appliance installations and replacements, such as water heaters, generators, and solar panels, that do not involve structural modifications;
1.b
Packet Pg. 249 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) PACIFICA LOCAL COASTAL LAND USE PLAN – REVISED CERTIFICATION DRAFT, SEPTEMBER 2024 G-10
viii) nonstructural remedial actions to address termite infestation and dry rot; and ix) other nonstructural modifications required to comply with State and/or Federal laws and regulations, such as disabled accessibility improvements and seismic retrofits/upgrades.
Incremental changes to floor area and individual major structural components that amount to alteration, removal, or replacement of 50 percent or more over time shall also be considered a SSM.
Temporary Event: An activity or use that constitutes development as defined in Section 30106 of the California Coastal Act, but which is or will be of limited duration and involves the placement of non-permanent structures; and/or involves the use of sandy beach, parkland, filled tidelands, water, streets, or parking areas which are otherwise open and available for general public use.
Tidelands: Lands which are located between the lines of mean high tide and mean low tide.
Total Maximum Daily Load (TMDL): The maximum amount of a pollutant that can be discharged into a water body from all sources (point and non-point) and still maintain water quality standards. Under Clean Water Act section 303(d), TMDLs must be developed for all water bodies that do not meet water quality standards after application of technology-based controls. TMDL also refers to the written, quantitative analysis and plan for attaining and maintaining water quality standards in all seasons for a specific water body and pollutant.
Transfer of Development Rights (TDR): A mechanism to relocate potential residential development from areas where environmental or land use impacts could be severe to other areas more appropriate for development, in order to preserve significant open space resources. Owners of environmentally sensitive sites may transfer residential development rights to other sites where higher-density development can be supported, or from one part of a site to another.
Tsunami: A wave generated by abrupt movement of the seabed, which can result from an earthquake or a significant landslide.
Tsunami Inundation Zone: 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).
Watershed: The total area above a given point on a watercourse which contributes water to the flow of the watercourse; the entire region drained by a watercourse.
Wave Run-up: The distance or extent that water from a breaking wave will extend up a beach or structure.
Wetland: The Coastal Act defines wetland as land which may be covered periodically or permanently with shallow water and includes saltwater marshes, freshwater marshes, open or closed brackish water marshes, mudflats, and fens. The California Code of Regulations further defines wetland as land where the water table is at, near, or above the land surface long enough to promote the formation of hydric soils or to support the
1.b
Packet Pg. 250 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4)
GLOSSARY
G-11
growth of hydrophytes, and shall also include those types of wetlands where vegetation is lacking and soil is poorly developed or absent as a result of frequent and drastic fluctuations of surface water levels, wave action, water flow, turbidity or high concentrations of salts or other substances in the substrate.
Wildlife Movement Corridor: Wildlife movement corridors link areas of suitable habitat that are otherwise separated by barriers such as rugged terrain, changes in vegetation, or areas of human disturbance or development, allowing wildlife to access additional areas with food, water, and other resources.
1.b
Packet Pg. 251 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) Pac i c
O cea n
Dev i l’s S l ide
Tunne l
Figure 1-1
Paci ca and the Paci ca
Coastal Zone
Coastal Zone
Planning Area
City Limits
0 1/4 1/2 1
MILES
2 Source: City of Pacifica, 2019; County of
San Mateo, 2019; Dyett & Bhatia, 2019.
Paci ca
Pier
Sharp Par k
Golf Cours e
Mori Poin t
(GGNRA )
Pe d ro Poi n t
Headland s
(G G NRA )
Sharp
Park
Beach
Rockaway
Beach
Paci ca
State
Beach
Northern
Coastal
Blu
s
(GGNRA)
Water
Recycling
Plant
OLD COAST HWY
P A OTTEMLA VE
FRANCISCO BLVD
BRADFORD WAY
FAIRWAY DR
DVLB HCAEB
GRAND AVE
ESPLANADE AVE
SEASIDE DR
CLARENDON RD
1 92
35 1
1 280
Paci ca
380
101
101
280
101
280
80 101
Brisbane
Burlingame
Colma
Daly
City
Half
Moon
Bay
Hillsborough
Paci ca Millbrae
San
Bruno
South San Francisco
Montara
Emery
S A N F R A N C I S C O
S A N
M A T E O
San
Francisco
Bay
Paci c
Ocean
Paci ca Planning Area
County Lines
Urbanized Area
Freeways
Highways
Major Arterials
BART
Caltrain
1.b
Packet Pg. 252 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) Pac i c
O cea n
P A OTTE MLA VE
SHOREVIEW AVE
SALADA AVE
SANTA ROSA AVE
MONTECITO AVE
CLARENDON RD
P A OTTE MLA VE
CARMEL AVE
PALOMA AVE
PACIFIC AVE
SAN JOSE AVE
SANTA MARIA AVE
GRAND AVE
SAN PEDRO AVE
DANMANN
HALLING WAY
SHELTER COVE
STANLEY AVE
KENT RD
OLYMPIAN WAY
STERLING AVE
LIVINGSTON AVE
ROCKAWAY BEACH
DONDEE ST
OLD COUNTY RD
SAN MARLO WAY
2 1
1 2
3 4
6 5
7 Dev i l’s S l ide
Tunne l
Figure 2-2:
Existing Land Use
in the Coastal Zone
Single-family Resdiential
Multi-family Residential
Mobile Homes
Commerical
Auto Services
Hotels, Motels
O ce
Mixed Use
Utilities
Industrial
Schools
Church
Other Public or Community Uses
Other Open Space
Parks & Accessible
Open Space
Beach
Agriculture
Vacant/Undeveloped
Coastal Zone
Planning Area
City Limits
0 1/4 1/2 1
MILES
2 Source: City of Paci
ca, 2019; County of San Mateo,
2019; Dyett & Bhatia, 2019.
Visitor Accommodations
1 San Francisco RV Resort
2 America’s Best Value Inn
Paci
ca
3 Best Western Lighthouse Hotel
4 Sea Breeze Motel
5 Paci
ca Motor Inn
6 Holiday Inn Express
& Suites Paci
ca
7 Paci
ca Beach Hotel
Paci ca
Pier
Sharp Par k
Golf Cours e
Mori Poin t
(GGNRA )
Pe d ro Poi n t
Headland s
(G G NRA )
Sharp
Park
Beach
Rockaway
Beach
Paci ca
State
Beach
Northern
Coastal
Blu
s
(GGNRA)
Water
Recycling
Plant
Paci ca Pier
Rockaway
Beach
Paci ca
State
Beach
OLD COAST HWY
P A OTTE MLA VE
BRADFORD WAY
FAIRWAY DR
BEACH BLVD
GRAND AVE
ESPLANADE AVE
SEASIDE DR
ESPLANADE AVE
DVLB HCAEB
DVLB OCSI CNARF
MANOR DR
AVALON DR
MONTEREY RD
FRANCISCO BLVD
1.b
Packet Pg. 253 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4)
GAT EWAY DR
FIRECREST AVE
INVERNESS DR
MONTEREY RD
PALMETTO AVE
MANOR DR
SKYLINE BLVD
GLENCOURT
MONTEREY RD
VEA OTTEMLAP
EDGEMAR DR
MILLER AVE
AVALON DR
OCEANA BLVD
PALOMA AVE
TALBOT AVE
BRADFORD WAY
SHARP PARK RD
MOANA WAY
LUNDY WAY
FAIRWAY DR RIDGEWAY DR
BEACH BLVD
REINA DEL MAR AVE
ROCKA WAY BEACH AVE
TERRANOVA BLVD
EVERGLADES DR
ODDSTAD BLVD
CRESPI DR
LERIDA WAY
CRESPI DR
SEVILLE DR
MANZANITA D
A
R
LICANTE
LIN
DR
DA MAR BLVD
ROSITA RD
ROSITA RD
ADOBE RD
PERALTA RD
DE SOLO
LINDA MAR BLVD
FASSLER AVE
PARK LINCOLN GRAND AVE
WESTBOROUGH
KING DR
SKYLINE BLVD
MILAGRA DR
HICKEY BLVD
ESPLANADE AVE
MANOR DR
ROBERTS RD
SHARP PA RK RD
SEASIDE DR
CLARENDON RD
P a c c
O c e a n
D e vi l ’ s S l i d e T u n n e l
Figure 2-3:
Land Use Diagram
0 1/4 1/2 1
MILES
2 Source: City of Paci ca, 2019; San Mateo
County, 2019; Dyett & Bhatia, 2019.
Planning Area
City Limits
Low Intensity VisitorServing Commercial
Public and Semi-Public
Beach/Commuter Parking
Utilities
Park
Conservation
Urban Reserve (Unincorporated)
Transportation Corridor
Coastal Zone
ESPLANADE AVE VEA OTTEMLAP
DVLB HCAEB
MANOR DR
AVALON DR
MONTEREY RD
PALMETTO AVE
SHOREVIEW AVE
SALADA AVE
LINDA
SANTA ROSA AVE
MONTECITO AVE
CLARENDON RD
VEA OTTEMLAP
CARMEL AVE
PALOMA AVE
PACIFIC AVE
FRANCISCO BLVD
SAN JOSE AVE
SANTA MARIA AVE
GRAND AVE
DANMANN
HALLING WAY
SHELTER COVE
STANLEY AVE
KENT RD
OLYMPIAN WAY
STERLING AVE
LIVINGSTON AVE
* Sites 0.5 acres or more may be developed at up
to 30 dwelling units per gross acre.
developed up to 1.5 times the maximum with the
Density Bonus program.
SAN PEDRO AVE
Note: Senior or a
ordable housing may be
Open Space/Agriculture/Residential
(up to 0.2 units/acre)
Very Low Density Residential
(0.2 -2.0 units/acre)
Low Density Residential
(3 -9 units/acre)
Medium Density Residential
(10 -15 units/acre)
High Density Residential
(16 -21 units/acre)*
Coastal Residential Mixed Use
Mixed Use Neighborhood
(16 -26 units/acre)*
Mixed Use Center
(30 to 50 units/acre)
Retail Commercial
Office Commercial
Service Commercial
Visitor-Serving Commercial
1.b
Packet Pg. 254 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) West Edgemar,
Paci c Manor
Fairmont
West
West
Sharp
Park
Sharp Park GC,
West Fairway Park,
and Mori Point
Pedro Point
and
Shelter Cove
Rockaway Beach,
Quarry, and
Headlands
Paci ca
State
Beach
F
Northern
Coastal
Blu s
Bowl Site
Paci
c
Manor
Industrial
Northern
Palmetto
Promenade and Beach
Boulevard Property
Palmetto Ave
Eureka Square and
Mixed Use Center
Sharp Park
Golf Course
Rockaway
Quarry Site
Rockaway
Beach
Rockaway
Headlands
Undeveloped
San Pedro
Avenue Site
Pedro Point
Shopping Center
Shamrock
Ranch
Pac i c
O cea n
Dev i l’s S l ide
Tunne l
0 1/4 1/2 1
MILES
2 Source: City of Pacifica, 2019; San Mateo
County, 2019; Dyett & Bhatia, 2019.
Figure 2-4:
Sub-Areas &
Speci c Sites
Subarea
Speci c Sites
Coastal Zone
City Limits
Planning Area
OLD COAST HWY
P A OTTEMLA VE
BRADFORD WAY
FAIRWAY DR
DVLB HCAEB
GRAND AVE
ESPLANADE AVE
SEASIDE DR
Figure 2-7
Figure 2-5
Figure 2-6
Key to Area Maps
1.b
Packet Pg. 255 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) Northern
Coastal
(GGNRA)
Bowl
Manor
Shopping
Center
Industrial
Northern
Palmetto
Beach
Boulevard
Property
Palmetto
Ave
Eureka Square
and Mixed
Use Center
Fish
Undercrossing
Fairmont
West Park
Ingrid B.
Lacy
Middle
School
City
Hall
Promenade
Sharp
Park
Golf
Course
Overcrossing
Overcrossing
San
Francisco
RV Park
Pier Talbot Rd Trail
Coastal Trail
West Edgemar,
West
Sharp
Park
Fairmont
West
Lands End
Apts.
12 10
11 9
4 5
2 1
7 VEA OTTEMLAP
BEACH BLVD
PALMETTO AVE
ESPLANADE AVE
FRANCISCO BLVD
7 8
Note: ordable housing may be
developed up to 1.5 times the maximum with the
Density Bonus program.
0 1/4 1/2
MILES
1 Open Space/Agriculture/Residential
(up to 0.2 units/acre)
Low Density Residential
(3 -9 units/acre)
Medium Density Residential
(10 -15 units/acre)
High Density Residential
(16 -21 units/acre)*
Mixed Use Neighborhood
(16 -26 units/acre)*
Mixed Use Center
(30 to 50 units/acre)
Retail Commercial
Service Commercial
Low Intensity VisitorServing Commercial
Public and Semi-Public
Park
Conservation
Transportation Corridor
Coastal Access Points
(Beach)
Coastal Access Points
top/View)
Park Opportunity Site
View Corridor
Existing Trail
Proposed Trail
On-street trail
Subareas
Coastal Zone
City Limits
Planning Area
Coastal Access Points are
keyed to Table 3-1
Figure 2-5:
* Sites 0.5 acres or more may be developed at up
to 30 dwelling units per gross acre.
3 6
8 1.b
Packet Pg. 256 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) Sharp Park
Golf Course,
West Fairway Park
& Mori Point
Rockaway Beach,
Quarry, &
Headlands
State
Beach
Rockaway
Quarry Site
Rockaway
Beach Rockaway
Headlands
Water Recycling
Plant
Flats
Pad
Proposed
Overcrossing
Undercrossing
Coastal Trail
Coastal Trail
BRADFORD WAY
FAIRWAY DR
SEASIDE DR
Mor i Po i n t
( G GNR A )
Sh a r p Pa r k
& Golf Cour s e
Sharp
Park
Beach
12 14
13 17
18 19
20 21
22 23
24 7
8 0 1/4 1/2
MILES
1 Open Space/Agriculture/Residential
(up to 0.2 units/acre)
Low Density Residential
(3 -9 units/acre)
Medium Density Residential
(10 -15 units/acre)
High Density Residential
(16 -21 units/acre)*
Mixed Use Neighborhood
(16 -26 units/acre)*
Mixed Use Center
(30 to 50 units/acre)
Retail Commercial
Service Commercial
Low Intensity VisitorServing Commercial
Public and Semi-Public
Park
Conservation
Transportation Corridor
Coastal Access Points
(Beach)
Coastal Access Points
top/View)
Park Opportunity Site
View Corridor
Existing Trail Proposed
Trail
On-street trail
Existing Trailhead
Subareas
Speci c Sites
Coastal Zone
City Limits
Planning Area
Coastal Access Points are
keyed to Table 3-1
Figure 2-6:
Note: ordable housing may be
developed up to 1.5 times the maximum with the
Density Bonus program.
* Sites 0.5 acres or more may be developed at up
to 30 dwelling units per gross acre.
15 16
1.b
Packet Pg. 257 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) State Beach
Pedro
Point
& Shelter
Cove
Pedro Point Trail
Coastal Trail
Undeveloped
San Pedro Ave Site
Pedro Point
Shopping
Center
Shamrock
Ranch
GRAND AVE
SAN PEDRO AVE
Devil’s Slide Trail
DEVIL’S SLIDE TUNNEL
Pedro Point
Headlands
(GGNRA)
State Beach
25 21
22 23
24 26
27 Open Space/Agriculture/ Residential
(up to 0.2 units/acre)
Very Low Density Residential
(0.2 -2.0 units/acre)
Low Density Residential
(3 -9 units/acre)
Mixed Use Neighborhood
(16 -26 units/acre)*
Retail Commercial
Low Intensity VisitorServing Commercial
Beach/Commuter Parking
Utilities
Park
Conservation
Urban Reserve
Transportation Corridor
0 1/4 1/2
MILES
1 Existing Trail
Proposed Trail
On-street trail
Existing Trailhead
Proposed Trailhead
Coastal Access Points
(Beach)
Coastal Access Points
View Corridor
20 Subareas
Coastal Zone
City Limits
Planning Area
Coastal Access Points are
keyed to Table 3-1
Figure 2-7:
outh
* Sites 0.5 acres or more may be developed at up
to 30 dwelling units per gross acre.
Note: ordable housing may be
developed up to 1.5 times the maximum with the
Density Bonus program.
Coastal Residential Mixed Use
Visitor-Serving Commercial
16 1.b
Packet Pg. 258 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4)
GAT EWAY DR
FIRECREST AVE
INVERNESS DR
MONTEREY RD MANOR DR
SKYLINE BLVD
GLENCOURT
MONTEREY RD
EDGEMAR DR
MILLER AVE
AVALON DR
OCEANA BLVD
PALOMA AVE
TALBOT AVE
BRADFORD WAY
SHARP PARK R
D
MOANA WAY
LUNDY WAY RIDGEWAY DR
BEACH BLVD
REINA DEL MAR AVE
ROCKA WAY BEACH AVE
TERRANOVA BLVD
EVERGLADES DR
ODDSTAD BLVD
CRESPI DR
LERIDA WAY
CRESPI DR
SEVILLE DR
MANZANITA D
A
R
LICANTE
LIN
DR
DA MAR BLVD
ROSITA RD
ROSI
ADOBE RD
TA RD
PERALTA RD
DE SOLO
LINDA MAR BLVD
FASSLER AVE
PARK LINCOLN
WESTBOROUGH
KING DR
SKYLINE BLVD
MILAGRA DR
HICKEY BLVD
MANOR DR
ROBERTS RD
SHARP PA RK RD
CLARENDON RD
Pa c
O c e a n
De v i l ’ s S l i de T u nn e l
Pier
Sh a r p Pa r k
G o l f C o u r s e
Mo r i P o in t
( G G N R A )
Pedro Point
Headlands
(GGNRA)
Sharp
Park
Beach
Rockaway
Beach
State Beach
Northern
Coastal
(GGNRA)
23 24 26
27 22
21 20
19 18
17 13
14 7
2 1
1 3
Figure 3-1:
Coastal Access
0 1/4 1/2 1
MILES
2 Coastal Access Points
Coastal Access Points
(Beach)
Regional Open Space
Neighborhood &
District Parks
Golf Course
Beach
Conservation
Partial Conservation
with Development
School
Coastal Zone
City Limits
Planning Area
Source: City of Paci ca, 2019; San Mateo
County, 2019; Dyett & Bhatia, 2019.
on GGNRA land
Pursue small public park and trail
Improve public access and
Maintain public parking as part
of redevelopment of City-owned
Beach Boulevard property
Ensure public access
Provide public trail to overlook
point as part of development
or land conservation
Provide additional signage and amenities
at Crespi Drive parking lot in relation to
proposed extension of Baquiano Trail
Improve new segment of Coastal Trail
along former railroad berm
Trail and access improvements expected under
land steward management; new trails should
provide coastal views from Pedro Peak
PALMETTO AVE
ALMETTO A P VE FAIRWAY DR
GRAND AVE
ESPLANADE AVE
SEASIDE DR
4 9
8 7
12 11
10 14 15
16 Ensure public access to beach
in 400-block of Esplanade Avenue
if feasible
and restore blu conditions
Play elds
13A
3 6
5 25
1.b
Packet Pg. 259 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) P
acc
Ocean
D e vi l ’ s S l i d e T u n n e l
Figure 3-2:
Parks and Open Space
System
0 1/4 1/21
MILES
2 Park Opportunity Site
RegionalOpenSpace
District, Neighborhood,
& Pocket Parks
Special Facilities
Schoolelds
Priorities for Conservation
Golf Course
Beach
OtherProtected OpenSpace
PartialConservation
with Development
Urban Reserve
Visitor Serving Commercial
LowIntensity Visitor-
Serving Commercial
Visitor Parking Lot
Coastal Zone
City Limits
Planning Area
County, 2019; Dyett & Bhatia, 2019.
P
PALMETTO AVE
VE A OTTE MLAP
FAIR
WAY DR
GRAND AVE
SEASIDE
DR
Pier
Sharp Park
Go lfC ourse
MoriPoint (GG N R A )
Pedro Point
Headlands
(GGNRA)
Sharp Park
Beach
Rockaway
Beach
State Beach
Northern Coastal
Ingrid B. Lacy
Middle School
Rockaway
Quarry
Site
Fairmont
West Park
Sharp Park Beach Promenade
FRANCISCO BLVD
SAN PEDRO AVE
BEACH BLVD
P
P
P
P
P
P
P
Source: City of Paci ca, 2019: San Mateo
1.b
Packet Pg. 260 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) 400
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MilagraRidge Trail
PiertoRidge Trail
SharpPark Trail
Mori RidgeTrail
BaquianoTrail Trail
San Pedro Valley Trail
PedroPo ni t Trail
Coastal Trail
Coastal Trail
De v il’s Slide T rail
HarryDean Trail
Pac i c
O cea n
Dev i l’s S l ide
Tunne l
Figure 3-3:
Trail System
0 1/4 1/2 1
MILES
2 Existing Trails
Existing On-Street
Trail Routes
Proposed Trails or
Trail Improvements
Proposed On-Street
Trail Routes
Coastal Trail
Existing Trailheads
Trailheads to be
Improved
Visitor Parking Lot
Existing SR 1 Crossing
Proposed SR 1 Crossing
Regional Open Space
Neighborhood, District
and Pocket Parks
Golf Course
Beach
Other Protected Open Space
Partial Conservation
with Development
School Play elds
100
Contour
Coastal Zone
City Limits
Planning Area
Source: City of Paci ca, 2008; San Mateo
County, 2009; Dyett & Bhatia, 2013.
OLD COAST HWY
P A OTTE MLA EV
BRADFORD WAY
FAIRWAY DR
BEACH
GRAND AVE
ESPLANADE AVE
SEASIDE DR
SAN JOSE AVE Paci ca
Pier
Sha rp Pa r k G ol f C ou r s e
Mor i Poi n t (G GN R A )
Pedro Point
Headlands
(GGNRA)
Sharp
Park
Beach
Rockaway
Beach
Paci ca
State Beach
Northern
Coastal
Blu
s
(GGNRA)
BLVD
Fa r allon View
1.b
Packet Pg. 261 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) Manor Dri
v
e
O
v
e
r
c
rossing
(planned)
Manor Dri
v
e
O
v
e
r
c
rossing
(planned)
Paci c
O cean
Dev i l’s S l ide Tunne l
Figure 3-4:
BicycleNetwork
0 1/4 1/21
MILES
2 Existing Class I
Proposed Class I
Existing ClassII
Proposed Class II
Existing Class III
Proposed Class III
Class III to be upgraded
to Class II
Class I to be upgraded
Bicycle Lockers
Bicycle Parking
Changing Room w/Water
Changing Room w/oWater
Pedestrian/Bicycle Overpass
Pedestrian/Bicycle Underpass
Existing Link
PotentialLinkto UnpavedTrail
Coastal Zone
Parks/Open Space
City Limits
Planning Area
Source: City of Paci ca, 2019; DKS, 2009;
SanMateoCounty, 2009;Dyett&Bhatia, 2019.
Paci ca
Pier
Sharp Park
Golf Course
Mori Point
(GGNRA)
Ped ro Point
Headlands
(GG NRA)
Sharp
Park
Beach
Rockaway
Beach
Paci ca
State
Beach
Northern
Coastal
Blu
s
(GGNRA)
Water
Recycling
Plant
OLD COASTHWY
P A OTTE MLA EV
FRANCISCO
BRADFORD
FAIR
WAY DR SEASIDE DR
BEACH BLVD
SAN PEDRO
GRAND AVE
ESPLANADE AVE
1.b
Packet Pg. 262 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) Pac
i c
Ocean
GATEWAY
DR
PALMETTO AVE
MONTEREY RD
EVA OTTE MLAP
OCEANA BLVD
PA
L
O
MA
AVE
TA
L
B
OT
AVE
DVLB OCSI CNARF
CLARENDON RD BRADFORD WAY SHARPPA RK
R
D
M
O
A
N
A
WAY
LUNDY WAY
FAIR
WAY DR RIDG
E
WAY DR
SEASIDE DR
BEACH BLVD ROCKAWAY BEACH
AVE
FASSLER AVE
SAN PEDRO AVE GRAND AVE
MILAG
RA
D
R
ESPLANADE AVE
MANOR
DR
ROBERTS RD
Manor Dri
ve
O
v
e
r
c
rossing
(planned imp
r
o
vements)
R
E
I
N
A
D
E
L
MA
R
AVE
CRESPI
DR
LINDA MAR
BLVD
Dev i l’s S l ide Tunne l
Figure 3-5:
RoadwayNetwork
and Planned
Improvements
0 1/4 1/21
MILES
2 Freeway
MultiLane Highway
TwoLane Highway
Arterial
Collector
Local Street
Unimproved RightofWay
Planned Improvement
PotentialFuture Street
Pedestrian Priority Zone
Coastal Zone
City Limits
Planning Area
Source: City of Paci ca, 2019; DKS, 2019;
San Mateo County,2019;Dyett& Bhatia,
2019.
Paci ca
Pier
Sharp Park
Golf Course
Mori Point
(GGNRA)
Ped ro Point
Headlands
(GG NRA)
Sharp
Park
Beach
Rockaway
Beach
Paci ca
State
Beach
Northern
Coastal
Blu
s
(GGNRA)
Water
Recycling
Plant
1.b
Packet Pg. 263 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) Manor Dri
v
e
O
v
e
r
c
rossing
(planned)
112
110
14 16
16 16
14 294
110
112
19 16
140
140
112
16 14
14 110
294
118 112
P
P
16 110
49 49
19 49
19 19
Manor Dri
v
e
O
v
e
r
c
rossing
(planned)
Pac
O cean
D e vi l’ s S l i d e T u nne l
Figure 3-6:
Transit Routes
and Facilities
0 1/4 1/21
MILES
2 SamTrans to BART
SamTrans to Caltrain
Local Service
Park and Ride Lot
Coastal Zone
City Limits
Planning Area
Source: City of Paci ca, 2019; DKS, 2019; San
Mateo County, 2019; Dyett& Bhatia,2019.
118
GATEWAY
DR
OLD COASTHWY
MONTEREY RD
E AV TO TE LM PA
OCSI CNARF
BRADFORD SHARPPARK
R
D
FAIR
WAY DR SEASIDE DR
BEACH BLVD
LINDA MAR BLVD
FASSLER
AVE
SAN PEDROGRAND AVE
ESPLANADE AVE
Sharp Park Golf Cour s e
Mori Point
(GGNRA)
Ped ro Point
Headlands
(GG NRA)
Sharp
Park
Beach
Rockaway
Beach
State
Beach
Northern
Coastal
(GGNRA) CRESPI DR
SamTrans OnDemand
Service Area
1.b
Packet Pg. 264 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) NORTH
GLOBE
BIG
INCH
MILAGR A
CREEK
UNNAMED
SANCHEZ
CREEK
CALER A
CREEK
QUARRY
SAN PEDRO
CREEK
Milagra Creek
S anchez Cr eek
Cal e r a Creek
Roc kaway Creek
San P edro Cree k
Pac i c
O cea n
D e vil’s
Sl i d e T u n n e l
Figure 4-1:
Hydrology
0 1/4 1/2 1
MILES
2 Creeks
Water Treatment Facility
Stream Restoration Projects
Coastal Zone Protected Open Space
Coastal Zone
City Limits
Planning Area
Source: FEMA, 2017; ESA, 2009;
City of Pacifica, 2019; San Mateo
County, 2019; Dyett & Bhatia, 2019.
Watersheds
Sharp Par k Golf Cours e
Paci ca
Pier
Mori Poin t
(GGNRA )
Pedro Poin t
Headland s
(GGNRA )
Sharp
Park
Beach
Rockaway
Beach
Paci ca
State
Beach
Northern
Coastal
Blu
s
(GGNRA)
Water
Treatment
Facility
Laguna
Salada
Horse
Stable
Pond
OLD COAST HWY
AP ML ET OT VA E
BRADFORD WAY
FAIRWAY DR
BEACH BLVD
GRAND AVE
ESPLANADE AVE
SEASIDE DR FRANCISCO BLVD
1.b
Packet Pg. 265 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) 0 1/4 1/2
1 MILES
2 Pac i c
O c e a n
Dev i l’s S l ide Tunne l
Figure 4-2: Vegetation
Grassland
Coastal Bluff Scrub
Eucalyptus
Northern Coastal Scrub
Monterey Cypress
Riparian Mixed Hardwood
Beach/Intertidal
Urban
Creeks
Coastal Zone
City Limits
Planning Area
Source: California Dept of Fish & Game,
1988, 2003; California Dept of Forestry,
2009; USDA Forest Service, 2017;
FEMA, 2017; ESA, 2009; City of
Pacifica, 2019; San Mateo County, 2019;
Dyett & Bhatia, 2019.
Paci ca
Pier
Sharp Park
Golf Course
Mori Point
(GGNRA)
Ped ro Point
Headlan d s
(GG NRA)
Sharp
Park
Beach
Rockaway
Beach
Paci ca
State
Beach
Northern
Coastal Blu
s
(GGNRA)
Water
Recycling
Plant
N o r ther
n C oastal Scru b
Norther
n Coastal Scru b
Ann u a l Grassl a n d
A nn ua
l Grass la n d
Riparian Mixed
Hardwood
Beach/Intertidal
Eucalyptus
Monterey
Cyprus
Coastal
Blu Scrub
Beach/
Intertidal
Beach/Intertidal
Urban
Urban
Urban
Ann u a l
Grassl a n d
Riparian Mixed
Hardwood
Norther
n Coastal Scru b
Beach/Intertidal
Coastal
Blu Scrub
P A OTTEMLA EV
DVLB OCSICNARF
CLARENDON RD
FAIRWAY DR
SAN PEDRO
ESPLANADE AVE
1.b
Packet Pg. 266 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) Pa
c
O ce a n D e vil’ s S l i d e T u nne l
Figure 4-3:
Potential
Environmentally
Sensitive Habitat
Areas
0 1/4 1/21
MILES
2 Coastal Zone
City Limits
Planning Area
SOURCE: U.S. Fish & Wildlife Service 2019;
National Marine Fisheries Service, 2019;
National Park Service, 2009; USDA Forest
Service, 2017; California Natural Diversity
Database, 2019; California Native Plant
Society, 2019; California Dept of Fish &
Game, 2019
; FEMA, 2017; ESA, 2008;
City of Pacifica, 2019; San Mateo County,
2019; Dyett & Bhatia, 2019.
Critical Habitat
Steelhead
California Red-Legged Frog
Pier
Sharp Pa r k
Golf Cour s e
Mori Poi n t
(GGNR A )
Ped ro Poi n t
Headlan d s
(GG NR A )
Sharp
Park
Beach
Rockaway
Beach
State
Beach
Northern
Coastal
(GGNRA)
OLD COAST HWY
E AVTOTELMPA
BRADFORD WAY
FAIRWAY DR
BEACH BLVD
GRAND AVE
ESPLANADE AVE
SEASIDE
DR
San Pedro Creek
Potential ESHA
Note: The preliminary delineation of ESHA boundaries does not include an exhaustive compilation of the habitat areas that meet the ESHA definition. Site-specific biological evaluations and field observations shall be required to identify ESHAs and other special status resources that may not have been included in the literature and database review.
1.b
Packet Pg. 267 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) 400
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200
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Mori Point
Rockaway
Headlands
Pedro Point
Headlands
Pacific
Ocean
D evil’s Slid e T u n n el
Figure 4-4:
Visual Resources
0 1/2 1 1/4
MILES
2 Source: US Geological Survey, 2009; City of
Pacifica, 2008; San Mateo County, 2009;
Dyett & Bhatia, 2013.
Gateways
Prominent Landforms
Coastal View Corridors
Scenic Routes
Prominent Ridges
Coastal Zone
City Limits
Planning Area
Pacifica
Pier
Sharp Park
Golf Course
Mori Point
(GGNRA)
Pedro Point
Headlands
(GGNRA)
Sharp
Park
Beach
Pacifica
State
Beach
Northern
Coastal Bluffs
(GGNRA)
Rockaway
State Beach
PALMETTO AVE
PALMETTO AVE
FAIRWAY DR
BEACH BLVD
GRAND AVE
ESPLANADE AVE
SEASIDE DR
Manor Dr
Palmetto Ave
Paloma Ave
Salada Ave
Clarendon Rd
Coast Highway
Coast Highway
Coast Highway
Coast Highway
Shelter Cove/Shoreside Dr
Rockaway Beach
1.b
Packet Pg. 268 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) 400
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Source: Association of Bay Area Governments,
2003; US Geological Survey, 2019; ESA. 2009; City of Paci ca, 2019; San Mateo County, 2019; Dyett & Bhatia, 2019. 100
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1.b
Packet Pg. 269 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) 400
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2019.
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Packet Pg. 270 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) 8-16
Milagra Ridge
(GGNRA)
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1.b
Packet Pg. 271 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) Milagra Ridge
(GGNRA)
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Headlands
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Public Safety Facilities
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Figure 5-4:
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Packet Pg. 272 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4) :HVW/LQGD0DU
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Packet Pg. 274 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4)
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Packet Pg. 275 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP
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Packet Pg. 276 Attachment: Attachment B - Revised Certification Draft Local Coastal Land Use Plan (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
1 August 6, 2024
Stefanie Cervantes, Acting Deputy Director
City of Pacifica Planning Department
540 Crespi Drive
Pacifica, CA 94044
Sent via email
Subject: City of Pacifica Draft Local Coastal Program Land Use Plan Update – Commission Staff Comments for August 12, 2024 City Council Meeting
Dear Ms. Cervantes,
Thank you for the opportunity to provide additional comments on the City’s comprehensive update to their Land Use Plan (LUP) in advance of the City Council’s adoption hearing. Commission staff requests that this comment letter is shared with your Councilmembers and is made part of the record for the August 12 City Council meeting.
First and foremost, Commission staff is greatly appreciative of all the City’s coordination efforts with us on this comprehensive LUP update to date. Following significant coordination over the last few months, Commission staff provided the City with detailed comments on the full LUP on June 19, 2024. These comments are generally supportive of the City’s draft sea level rise and coastal hazards policies, including the Special Shoreline Resiliency Area policies. As the City notes in their June 26, 2024 staff report, planning for climate change and sea level rise hazards through this LUP update is a critical and necessary step towards protecting the City’s natural and built assets for continued enjoyment by residents and visitors alike. We are glad to see City staff’s acceptance of all Commission staff’s comments on Chapter 6: Coastal Resilience from our June 19 correspondence, as described in the City’s June 26 staff report. With an aside about Policy CR-I-21 Coastal Hazard Risk Disclosure (see #5 below), we believe Chapter 6 is now reflective of what Commission staff can recommend the Commission approve as submitted.
There are four other topics that Commission staff continue to have concerns about: 1) a larger category of what the City has described as “General Plan consistency edits,” 2) Policy LD-I-20 regarding the Undeveloped San Pedro Avenue Site, 3) Policies ER-I-1 and ER-I-24 regarding creek and ESHA buffers, and 4) the definition of “Substantial Structural Modification (SSM).” We would like to reiterate that we believe the best path forward to certification is if our two staffs are largely in agreement on the LUP. In that vein, we understand that the City is striving to approve the LUP update in a form that the Coastal Commission is most likely to approve as submitted, without any modifications. In that spirit, Commission staff is providing additional context on our recommendations associated with 1) General Plan consistency edits, and is providing revised recommendations associated with 2) Undeveloped San Pedro Site, 3) creek and ESHA buffer policies, and 4) the definition of SSM that we believe address both
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Packet Pg. 277 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
2 Commission and City staff concerns and represents a compromise that we could find acceptable to recommend for Commission approval. The Coastal Hazard Risk Disclosure Policy is discussed as a fifth item below.
1. General Plan Consistency Edits
Commission staff appreciates the City’s efforts to align its LUP with its General Plan but notes that Coastal Act consistency, rather than General Plan consistency, is the standard of review for the LUP.
Commission staff stand by our June 19 recommendations for this reason, but we are amenable to receiving further explanation from the City beyond the General Plan consistency concern and discussing these items further. City staff expressed acceptance of some of our June 19 requested edits to the General Plan consistency language and noted that these edits could be processed through an administrative amendment to the General Plan. City and Commission staff also discussed and resolved some of these issues on our July 31 phone call. Commission staff would like to further articulate the Coastal Act reasoning for the remaining requested edits and hopes that these General Plan edits could also be processed administratively, or that the City could find the LUP language in substantial conformance with the General Plan.
Chapter 2: Land Use and Development
A. On page 2-12, Commission staff requested deletion of the allowable residential density in the Urban Reserve land use designation. Following our July 31 phone call, Commission staff now understand that this language is intended to be the density standard that would apply if/when this land is annexed into the city. If the City would like to retain this sentence, please revise it to clarify that this is a future standard that would apply after annexation and land use designation change, and until then, is only for informational purposes at this time (e.g., change “shall” to “will” with additional context).
i. Coastal Act Reasoning: As written, it could be read that this is a current density standard applicable to lands that the City does not have permitting authority over. It is a standard of review issue to have language in an LCP that sets a development standard for land that the City does not have authority over.
Chapter 3: Public Access and Recreation
B. For Policy PR-I-50 on page 3-36, please explain why the City wants to delete high density residential and mixed use from the types of new development projects that would require bicycle parking facilities.
i. Coastal Act Reasoning: Reducing the types of new development projects that would require bicycle parking facilities is not consistent with Coastal Act policies that require new development to maximize public access and recreation opportunities (Section 30210), provide for non-automobile circulation (Section 30252), and reduce vehicle miles traveled (Section 30253). If the City’s reasoning is solely for General Plan
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Packet Pg. 278 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
3 consistency, Commission staff continue to request that the original policy language be retained.
C. For Policy PR-I-69 on page 3-49, please explain why the City wants to delete “enhances access to the coast.”
i. Coastal Act Reasoning: Enhancing access to the coast is a foundational pillar of the Coastal Act (Section 30210). This policy would not necessarily require transit service to enhance access to the coast as a development standard; rather, as originally written, the policy would only encourage the City to continue coordination efforts with transit agencies with a goal of enhancing access to the coast via transit services. Commission staff continue to request that the original policy language be retained.
D. For Policy PR-I-72 on page 3-49, please explain why the City wants to replace “in all appropriate locations where existing or projected future rider demand will support it” with “on all or part of the Linda Mar Boulevard Park-and-Ride lot.”
i. Coastal Act Reasoning: Commission staff views the City’s revision as a significant narrowing of the scope of this policy, which is contrary to the Coastal Act mandates to maximize public access (Section 30210), facilitate the provision or extension of transit services (Section 30252), and reduce vehicle miles traveled (Section 30253). If the City’s reasoning is solely for General Plan consistency, Commission staff continue to request that the original policy language be retained.
E. For Policy PR-I-74 on page 3-49, please explain why the City revised the original policy language and why the City did not agree with Commission staff’s suggested edits for readability. i. Coastal Act Reasoning: Commission staff’s edits were not intended to change the meaning or application of this policy, only to re-word it for clarification and userfriendliness. As previously written, it was unclear what the required conditions of approval for new development would be. Clarifying these requirements is important for effective implementation of the Coastal Act. If the City’s reasoning is solely for General Plan consistency, Commission staff continue to request that the is revised per Commission staff’s 6/19 recommendation. Commission staff also note that the policy title should be revised to “Transportation Demand Management Measures.” F. For policy PR-G-27 on page 3-52, please clarify why “distribute parking areas throughout the Coastal Zone to mitigate against the impacts of overcrowding or overuse by the public of any single area” was deleted.
i. Coastal Act Reasoning: This language comes directly from Coastal Act Section 30212.5 and is necessary to find the LUP in compliance with the Coastal Act. Commission staff continue to request that the original policy language be retained, or it could be retained but be preceded by the following phrase, which is found in Section 30212.5: “Wherever appropriate and feasible, distribute parking areas . . .”
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Packet Pg. 279 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
4 Chapter 4: Environmental and Scenic Resources
G. For Policy ER-I-8 on page 4-12, please explain the City’s objection to including the term “suitable” or “suitability” with respect to the quality of sediment that can be placed on the shoreline.
i. Coastal Act Reasoning: It is important to ensure that sediment placed on the shoreline from dredging or other activities is found to be “beach quality” for marine resource protections, water quality, and recreational purposes. This is necessitated by Coastal Act Sections 30230, 30231, 30233(b), and 30240, which generally require protection of marine resources, coastal water quality, and sensitive habitat areas. If the City’s reasoning is solely for General Plan consistency, Commission staff continue to request retention of the original policy language or the alternative “Allow suitable”.
H. For Policy ER-I-21 on page 4-27, please explain the City’s reasoning for the revisions to subsection 1 of the policy.
i. Coastal Act Reasoning: Commission staff believes that the City’s revisions are in conflict with Policy ER-G-5 and thus create an internal inconsistency that would implicate development review. The City’s revisions also significantly weaken the policy in conflict with what is required by Coastal Act Section 30240. If the City’s reasoning is solely for General Plan consistency, Commission staff continue to request retention of the original policy language.
I. For Policies ER-G-16, ER-G-17, ER-I-44, and ER-I-53, please explain why the City objects to Commission staff’s recommendations to better match the terminology used in the policies with the terminology used on Figure 4-4.
i. Coastal Act Reasoning: It is important for user friendliness and effective implementation of the Coastal Act to match the terms of the resources that are required to be protected with the terms of where those resources are mapped in Figure 4-4.
Using different terms in different parts of an LCP can lead to confusion and questions about whether the different terms mean the same thing. If the City would prefer to update/revise Figure 4-4 so that the City’s policy language better aligns with the figure’s terminology in that way, that is fine.
Chapter 5: Natural Hazards
J. On page 5-8, the City seems to accept Commission staff’s request to delete the first paragraph starting with “Within the Coastal Zone…” but not the second paragraph starting with “Similarly, a site stability survey is required…” Following our July 31 phone call, Commission staff understand that City staff intended to delete both paragraphs as requested. i. Coastal Act Reasoning: As explained and applicable to both the first and second paragraphs, this new language creates internal inconsistencies with Chapter 6 and thus could implicate development review. Commission staff continue to request that both paragraphs be deleted.
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Packet Pg. 280 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
5 Glossary
K. Please explain the City’s reasoning for replacing the definitions of “easement” and “special status species” with entirely new definitions.
i. Coastal Act Reasoning: Commission staff had reviewed the LUP update in the context of the original definitions and agreed with the language of the original definitions. The new definitions do not seem necessary and are not adequately robust. The new definition of Special Status Species is particularly concerning as it would not include any listed or candidate animal species under California’s Endangered Species Act. Coastal Act Section 30240 protects areas in which plant or animal life are either rare or especially valuable, and this would certainly include species identified under the state Endangered Species Act, and not just the federal Endangered Species Act. Notably, there are numerous species listed under the state act but not the federal act,1 which demonstrates the need for the LCP to protect habitat of state-listed or state-candidate species. Further, the new definition of “special status species” creates an inconsistency with the description of this same term in Chapter 4 (see page 4-23). Commission staff continue to request retention of the original definition of “special status species.” The change in definition of “easement” does not raise as significant of a concern; however, it would be helpful to know the City’s rationale for the change. If the City’s reasoning is solely for General Plan consistency, Commission staff continue to request retention of the original definition. Alternatively, the City could remove this definition entirely and hold this discussion for the IP.
2. Policy LD-I-20 Undeveloped San Pedro Site
For Policy LD-I-20 Undeveloped San Pedro Avenue Site on page 2-31 in Chapter 2, Commission staff recommends the following alternative language to address both the City’s concerns about including a specified density and Commission staff’s concerns about the sensitivity of the site. Please note that our primary concern is about appropriately planning for this site to avoid and protect coastal resources. If the City is intending to allow for a certain amount of total units on this site, then the policy could instead be revised to address the desired density per net acre (the gross acreage minus area that is undevelopable due to coastal resource constraints).
a. 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 standalone 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, reduced as necessary to account for coastal resource protections 1 See https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=109405&inline
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Packet Pg. 281 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
6 as required by the LCP. 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. Development must include public coastal access, and must provide public open space, and consider all biological constraints.
3. Creek and ESHA Buffer Policies
Regarding Policies ER-I-1 and ER-I-24, Commission staff acknowledges the City’s desire to retain flexibility in the application of creek and ESHA buffer reductions, particularly to account for takings situations. This is why Commission staff suggested revised language in its June 19th correspondence that separated the policy language allowing for buffer reductions in a takings situation (such that this reduction no longer is tied to the 50-foot minimum) from the language allowing for buffer reductions to accommodation public services for public development (such that this reduction can be no less than 50 feet). The City’s June 26th staff report does not appear to recognize this change, as it states that “[City] Staff believes that buffers should be determined on a case-by-case basis and as necessary to avoid takings claims.” Commission staff agree and note that the June 19th revisions are consistent with this position as it applies to takings situations. Commission staff still request the 50-foot minimum to apply to buffer reduction allowances for public services to reduce ambiguity and maintain sufficient creek and ESHA protections in these situations. The Coastal Act explicitly provides this flexibility for takings situations but otherwise has a very high standard for protection of sensitive habitat areas, and the Commission’s practice has been to establish a minimum buffer to help ensure these protections.
Commission staff also recognize that the City would like to maintain flexibility with determining “temporary disruptions.” We note that the “(e.g. less than six months)” provides an example rather than a strict rule. While Commission staff still prefer to keep this example language in the policy, the City’s additional language about a qualified biologist determination is also acceptable.
In reviewing this policy language again for this correspondence, Commission staff noted several other issues. The primary concern is that Chapter 4 is lacking a policy that addresses wetland buffer requirements. Such a policy is necessary for compliance with the Coastal Act. The other concerns are: 1) within Policies ER-I-1 and ER-I-24, the term “public services” is not defined and thus could potentially be applied in a broader manner than intended; 2) the language calls for review of a qualified biologist’s determination by the City, USFWS, and CDFW—there may be situations where USFWS or CDFW do not have reason to review, and situations where other unlisted resource agencies should provide this same review; 3) consistency with terminology of buffers vs. setbacks; and 4) a sentence fragment in Policy ERI-24 that should be deleted. For all these reasons, Commission staff recommend the following alternative language:
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Packet Pg. 282 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
7 Policy ER-I-1: Creek Protection and Restoration. Maintain, protect, and restore Pacifica’s creeks, including San Pedro, Rockaway, Calera, Sanchez, and Milagra creeks, as environmental and aesthetic resources. Actions will include, but are not limited to:
• Continuing restoration efforts along San Pedro Creek to improve conditions for steelhead by removing obstacles to fish passage, placing rock weirs to facilitate fish passage, and by monitoring the effectiveness of these projects; • Partnering with local organizations, such as the San Pedro Creek Watershed Coalition, Go Native, the Pacifica Land Trust, and others, on restoration efforts; • Exploring opportunities to collaborate with other agencies and organizations on stream restoration and riparian habitat restoration along Sanchez and Calera creeks; • Enforcing restrictions on the planting of invasive species near creek areas; • Identifying and working with property owners to take advantage of unique opportunities where human active use (e.g., through trail development) would enhance creek appreciation without disrupting ecological function;
• 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 to avoid a taking (for private development), provided that any unavoidable impacts are commensurately mitigated. The 100-foot buffer may also be reduced to provide required incidental public services (for public development), provided that the buffer is as close to 100 feet as possible, is 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.
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.
• 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 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.
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Packet Pg. 283 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
8 Policy ER-I-24: Management of ESHA and Wetlands. If the area qualifies as an ESHA or a wetland under the California Coastal Act, the following regulations apply:
• No new development shall be allowed within primary habitat areas ESHA with the exception of resource-dependent uses (such as i.e. habitat management and restoration, scientific research and educational activities, and low-intensity public access and recreation) that can be demonstrated to have no significant adverse impact disruption of habitat values.
• No new development shall be allowed within wetlands except as described in Policy ER-I-5.
• Buffer areas shall be established around all sensitive resources ESHA and wetlands, providing a minimum of 100 feet, and varying 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 to avoid a taking (for private development), provided that any unavoidable impacts are commensurately mitigated. The 100-foot buffer may also be reduced to provide required incidental public services (for public development), provided that the buffer is as close to 100 feet as possible, is no less than 50 feet in any case, and provided that ESHA or wetland 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. areas on the parcel. 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. • Development shall be sited and designed to prevent impacts that would degrade adjacent habitat areas, taking into account drainage, vegetation, topography, and other considerations.
• Alteration of landforms, removal of vegetation, impervious surfaces, noise, light, and glare shall be minimized as much as possible.
4. Definition of Substantial Structural Modification
For the Glossary definition of Substantial Structural Modification, Commission staff appreciates that the City is interested in continuing to reflect the language that came out of the local public process for this LUP update. However, the City’s minor change to this definition, as noted in its June 26 staff report, does not entirely address Commission staff’s concerns. In an effort to respect the City’s position and
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Packet Pg. 284 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
9 address remaining Commission staff concerns about overly broad exceptions to the definition, we recommend the following alternative language. The alternative language is intended to 1) help clarify where and how the definition of SSM does apply, both individually and incrementally; 2) remove or modify proposed exceptions that could be considered structural; and 3) improve language consistency (e.g., carrying the references to “alteration, removal and replacement” throughout the policy). For the first intent, Commission staff notes that the newly suggested language “considered individually…” will help provide property owners with the assurance that changes to major structural components are counted individually, rather than additively. For example, a project that alters 20% of the roof framing, 20% of the floor framing, and 20% of the foundation would not be considered a 60% alteration that thus triggers redevelopment because these changes are not additive between different structural components. The clarifications about incremental changes at the end of the definition are solely intended to better align with the language used in subsections i) and ii) at the beginning, i.e. “floor area and individual major structural components.”
Substantial Exterior Structural Modification (SESM): Any physical improvement which modifies an existing structure, as defined, to achieve in any of the following ways:
i) a seaward encroachment of the structure; or
ii) alteration, removal or replacement of 50 percent or more of the linear length or surface area of the exterior walls or other major structural components (including but not limited to floor framing, roof framing, and foundation structures), considered individually (i.e., percentages are calculated by the individual structural component being altered, and are not additive between different structural components), 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 ivii) an increase of the existing building footprint equal to 50 percent or more; but excluding any of the following:
i) alteration, removal, or replacement, or maintenance of nonstructural exterior or interior components, of exterior walls such as nonstructural: decorative i) plywood roof sheathing;
ii) underlayment;
iii) siding;
iiiv) shingles;
iv) other nonstructural roofing materials;
vi) windows and doors (including garage doors) that do not alter width or location; vii) exterior waterproofing/weatherproofing materials;
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Packet Pg. 285 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
10 viii) appliance installations and replacements, such as water heaters, generators, and solar panels, that do not involve structural modifications; viiix) nonstructural remedial actions to address termite infestation and dry rot; and xi) other nonstructural modifications required to comply with State and/or Federal laws and regulations, such as disabled accessibility improvements and seismic retrofits/upgrades.
ii) development on any site which is protected from coastal erosion by an existing, permitted shoreline 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. Incremental changes to floor area and individual major structural components changes that cumulatively amount to alteration, removal, or replacement of 50 percent or more over time shall also be considered a SSM.
5. Policy CR-I-21 Coastal Hazard Risk Disclosure
Earlier on in the LUP update process, the City added the following clause to the end of the disclosure policy in response to Council comments:
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/or Tsunami Inundation Zone for the Anticipated Life of the project.
Commission staff requested this language be deleted via our June 19 correspondence because it raises concerns. Commission staff notes that the City did strike this language from the draft LUP, but is requesting further input on this language from City Council per its June 26 staff report: “CR-I-21 Coastal Hazards Risk Disclosure (previously CR-I-45 Assumption of Risk by Private Landowners): …City Council directed staff to include an exception clause to this policy. CCC staff does not agree with the exception
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Packet Pg. 286 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4)
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105-2421
VOICE (415) 904-5200
WEB: WWW.COASTAL.CA.GOV
11 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.” Commission staff continues to ask the City not to include this language. As previously stated, the exception clause included in an earlier draft in response to Council/public questions raises concerns for Commission staff. As originally written, the zones where the disclosure statement policy applies are already determined to carry a level of risk. The added exception language opens up the possibility of property owners obtaining technical studies with varying standards, assumptions, etc. to try and prove a hazard does not exist. It seems probable that this will lead to the need for City and Commission staff to review numerous technical reports, have disagreements over the validity or content of those reports, and could lead to additional project appeals.
It is important to note that disclosure policies like this are critical for helping to ensure that property owners and purchasers can understand and plan with identified hazards in mind. Similarly, requiring developers to assume the risks of developing in hazardous locations will help avoid the need to spend public funds on disaster recovery for private development and will ensure future owners are aware of the need for potential future adaptation options. For these and related reasons, the Coastal Commission Local Government Working Group has highlighted the importance of disclosure policies, and they are routinely included in Coastal Commission planning and permitting work.
In this specific case, these disclosures would only be added if and when work is being done that needs a permit – for those homeowners not making any changes to their homes, nothing happens. Furthermore, this is just a disclosure about possible hazards based on completed scientific studies in the area and what may happen as a result of the actual occurrence of those hazards, but it does not trigger any action beyond the disclosure unless and until the hazard actually occurs. Lastly, rather than individual sitespecific studies that attempt to prove hazards do not exist (which raises concerns as described above), if errors in hazard mapping are identified through new information or evolving conditions, the appropriate means of correction would be through updates to the maps and an LCP amendment.
Commission staff thanks you again for the opportunity to comment and work with the City towards a successful LUP update certification. Please let us know if you have any questions or concerns leading up to or after your City Council hearing.
Sincerely,
Brittney Cozzolino
Statewide Planning Unit
California Coastal Commission
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Packet Pg. 287 Attachment: Attachment C - CCC comment letter to City of Pacifica 8-6-24 (5753 : LCLUP #5.4) 1 826 Stanyan St., San Francisco, CA 94117 • 415-290-5718 • [email protected] September 9, 2024
Pacifica City Council
Mayor Susan Vaterlaus
540 Crespi Dr.
Pacifica, CA. 94044
Re: Pacifica City Council Continued Special LCLUP Study, September 17, 2024 Further SF Public Golf Alliance comment on the Confusion over Tsunami Issues in Pacifica’s Draft LCLUP, and strong suggestion that Pacifica Follow Half Moon Bay Tsunami Policies Approved by Coastal Commission in April 2021.
Dear Mayor Vaterlaus and Councilmembers,
This is a follow-on to our August 6, 2024 letter to Your Council1 (incorporated herein by this reference as Exhibit 1), in which we objected to the overreach and confusion in Tsunami policies found in Pacifica’s Draft Local Coastal Plan {“Draft LCLUP”).2 Among others, we objected to the Draft LCLUP’s use of Tsunami as a development restriction, and noted that the Coastal Commission has recently approved Local Coastal Plans in other coastal cities, including Half Moon Bay, that do not use the Tsunami risk to restrict or condition infill development. When, about midway through Your Council’s August 12, 2024 Council meeting Councilmembers Bier, Beckmeyer and Boles asked City Staff for a legal opinion responding to issues raised in our August 6, 2024 letter,3 City Manager Woodhouse demurred, saying that Staff believes “we’ve clearly responded to the comments that we have tonight.”4
But the Draft LCLUP’s Tsunami policies are NOT COHERENT but are instead internally inconsistent and confusing to the public, to Councilmembers and to Pacifica City Staff. At that August 12 Council Meeting, Staff’s responses were confused, confusing, and incorrect 1 San Francisco Public Golf Alliance Letter to Pacifica City Council, Aug. 6, 2024:
https://drive.google.com/file/d/19ghnzI-ZLO6rkfzJWvD_4hwtpU01iWaP/view?usp=drive_link 2 Pacifica Local Coastal Land Use Plan (August 2024 Revised Draft), Pacifica City Council August 12, 2024 Agenda Packet, Item 14, Attachment C, at Packet Pgs. 389-707 https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544 3 Pacific Coast TV U-Tube, Pacifica City Council Meeting, Aug. 12, 2024 (https://www.youtube.com/watch?v=D0R5J9ls6Xc), at 3:05:35 – 3:06:30 (Bier and Beckmeyer) and 3:07:12 – 3:07:35 (Boles and Beckmeyer)
4 Pacific Coast TV U-Tube, Pacifica City Council Meeting, Aug. 12, 2024 (https://www.youtube.com/watch?v=D0R5J9ls6Xc), at 1:48:48 – 1:49:49
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Packet Pg. 288 Attachment: Attachment D - Public Comment (5753 : LCLUP #5.4) 2 to many of the Councilpersons’ questions about Tsunami, and to issues raised in our August 6 letter and by other members of the public.
1. Tsunami risk is a development restriction in Pacifica’s Draft LCLUP At Council’s August 12, 2024 meeting, Acting Assistant Planning Director Cervantes repeatedly told Councilmembers that the Draft LCLUP does not use Tsunami risk as a development restriction, and does not mandate “Technical Reports”5 or “Siting and Design”6 requirements on property development located outside mapped Coastal Vulnerability Zones.7 Responding to a question from Councilmember Boles, Ms. Cervantes also advised City Council that the extensive “Tsunami Evacuation Area” mapped in the Draft LCLUP’s Natural Hazards Chapter at the Flood Zones Map, Figure 5-38 is “not . . tied to any policy.”9 5 Pacifica Draft LCLUP, supra, at p. 6-32-33 (Pkt.Pgs. 592-593), Coastal Resiliency Implementing Policy CR-I-19, Technical Reports https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544 6 Pacifica Draft LCLUP, supra, at p. 6-33 (Pkt.Pg. 593), Coastal Resiliency Implementing Policy CR-I-20, Siting and Design https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544 7 Pacific Coast TV Video, City Council August 12, 2024 meeting: https://www.youtube.com/watch?v=D0R5J9ls6Xc:
(1) Boles at 1:46:06: “And just to clarify something that you told me separately, but we don’t have restrictions on development in tsunami inundation zones, right? “ Cervantes: 1:46:17: “Correct. So, if your property is in a tsunami inundation zone and just a tsunami inundation zone, the only requirement is that you record a deed disclosure – a risk disclosure. There’s no other prohibitions on development, there’s no requirements for additional technical reporting or siting or design. Those policies are only applicable to the Coastal Vulnerability Map.”
(2) Bigstyck: 1:48:02 If it’s a Tsunami Inundation Zone but not a Coastal Vulnerability Zone, the only requirement is you put a disclosure “this is a Tsunami Inundation Zone,” and that’s the entirety of the requirement.
Cervantes: 1:48:18: Correct.
(3) Boles:2:57:37. A couple of things with the tsunamis. I think even after your clarification, there’s still confusion that there’s any limitation on development in tsunami zones. Can you say that really clearly one last time.
Cervantes: 2:57:51. Again, the City’s LCLUP does not contain any prohibition, any requirements for development in Tsunami Inundation Zones only. The only requirement is that if you are going to obtain a Coastal Development Permit in a tsunami inundation zone is that you record a risk disclosure on the property, that you are in a tsunami inundation zone. . . .
Cervantes: 2:59:10. Our LCLUP does not require Siting, Design, Technical Reporting for Tsunami Inundation.
8 Pacifica Local Coastal Land Use Plan (August 2024 Draft), Pacifica City Council August 12, 2024 Agenda Packet, Item 14, Attachment C, at Packet Pgs. 389-707
https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544, at Pg. 8-16, Packet Pg. 664 9Pacific Coast TV U-Tube, Pacifica City Council Meeting, Aug.12,2024:https://www.youtube.com/watch?v=D0R5J9ls6Xc Boles: 1:50:14. So what will happen with our maps. Because the tsunami evacuation area right now is overlaid.
Does that go away completely, or is that something that is still showing up in our LCP? Cervantes: 1:50:24 – 1:50:57. The Tsunami Evacuation Zone will likely remain on our map overlay on our maps, not because it’s tied to any policy, but because it’s important information for property owners and for the city to be aware of, and for that to be easily available to the public. That would be the only reason it would stay and Tsunami FN 10, cont. Evacuation Zones are important information to know and understand for preparedness, but it would not be tied to any policy.
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Packet Pg. 289 Attachment: Attachment D - Public Comment (5753 : LCLUP #5.4) 3 But both of these statements by Ms. Cervantes are incorrect. To begin with, the Draft LCLUP’s Chapter 5, Natural Hazards, includes Guiding Policy NH-G-2 and Implementing Policy NH-I-30 that impose siting and design requirements on development in “tsunami hazard zones” and specifically in the “Tsunami Evacuation Zone” (mapped at Figure 5-3), without reference to whether or not the properties lie in mapped Coastal Vulnerability Zones.
Guiding Policies
NH-G-2 Development in Hazardous Areas. 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).10
Implementing Policies
NH-I-30 Tsunami Evacuation Zone. For new development in the tsunami evacuation zone, require use of low impact engineering techniques, such as elevating structures above projected water levels, to mitigate impacts to people and structures.11 (emphasis added)
Moreover, Ms. Cervantes’ answers to Councilmembers’ questions did not deal with the newly-added provision in the final sentence of the Draft LCLUP’s Coastal Resilience Implementing Policy CR-I-1, which provides that proposed development on properties located outside of Coastal Vulnerability Zones will be reviewed as if they were located inside Coastal Vulnerability Zones, where “best available science” shows that development would be “vulnerable to coastal hazards”.12 As discussed at pages 3-4 of our August 6 letter to Your Council, this “reviewed as if” language of Implementing Policy CR-I-1 invokes the Figure 5-3 Flood Zones map and the “best available science” identified in the Legend at the bottom right-hand corner of that map, including the extraordinarily improbable (once-in-975-year recurrence probability) “Tsunami Hazard Area for San Mateo County, Department of Conservation, State of California, 2021.”13 This creates an effective backdoor for imposing the burdensome and potentially impossibly expensive 10 Pacifica Local Coastal Land Use Plan (August 2024 Draft), supra, https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544, Natural Hazards Chapter, at Pg. 5-19, Packet Pg. 551.
11 Pacifica Local Coastal Land Use Plan (August 2024 Revised Certification Draft), supra, https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544, Natural Hazards Chapter, at Pg. 5-20, Packet Pg. 552.
12 Pacifica Local Coastal Land Use Plan (August 2024 Draft), supra, https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544, Coastal Resilience Chapter, Implementing Policy CR-I-1, at Pg. 6-13, Packet Pg. 573.
13 California Geological Survey Tsunami Hazard Area Map County of San Mateo, Mar. 23, 2021 https://www.conservation.ca.gov/cgs/Documents/Publications/TsunamiMaps/Tsunami_Hazard_Area_Map_San_Mateo_County_a11y.pdf
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Packet Pg. 290 Attachment: Attachment D - Public Comment (5753 : LCLUP #5.4) 4 requirements of Coastal Resiliency Implementing Policies CR-I-19 (Technical Reports)14 and CR-I20 (“Siting and Design”)15 on virtually all Pacifica properties west of the Coast Highway.
2. Pacifica’s Draft LCLUP Coastal Hazards Risk Disclosure Policy -- Implementing Policy CR-I-21 -- is severe and disproportionate and far exceeds any reasonable relationship to the Tsunami risk. At City Council’s August 12, 2024 LCLUP Study Session, Pacifica Planning Staff and City Manager told the Council that “in practice the details of the [Pacifica Draft LCLUP] risk disclosure are the same” as in the Half Moon Bay Local Coastal Plan approved by the Coastal Commission in April 2021. But this is wrong.
At pages 2-3 of our August 6 letter to Your Council we cited the City of Half Moon Bay’s Coastal Commission-approved Local Coastal Plan, whose Shoreline Hazards policies include a narrowly targeted Tsunami risk disclosure and limited hold harmless policy:
“Policies – Shoreline Hazards
“7-9. New Development in Tsunami Inundation Zone. Limit the creation of new building sites in the tsunami inundation zone. Infill development on existing building sites may be permitted in the tsunami inundation zone, provided that a disclosure of hazard presence and a hold harmless clause indemnifying the City from any harm caused to permitted development by tsunami inundation are recorded against the property.16” (emphasis added)
By contrast, Pacifica’s Draft LCLUP’s Coastal Hazard Risk Disclosure Implementing Policy CR-I-21, with its eight subparagraphs and a catchall “waive[r of] any rights that might exist under applicable law for shoreline protection structures,”17 goes far beyond Half Moon Bay’s narrow and tailored Shoreline Hazard Policy 7-9. At Council’s August 12 meeting, Acting Deputy Planner Cervantes compared the Pacifica and Half Moon Bay policies by showing a slide captioned “Tsunami Inundation Zones” (a copy of which is attached hereto as EXHIBIT 2), which included a copy of what she described as the first two pages of a 4-page Half Moon Bay Tsunami Risk Disclosure and Waiver form which Ms. Cervantes said “is very similar to what we’re requiring . . . disclosure of hazards that need to be recorded against the property.”18 City Manager 14 Pacifica Draft LCLUP, supra, at p. 6-32-33 (Pkt.Pgs. 592-593), Coastal Resiliency Implementing Policy CR-I-19, Technical Reports: https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544 15 Pacifica Draft LCLUP, supra, at p. 6-33 (Pkt.Pg.593), Coastal Resiliency Implementing Policy CR-I-20, Siting and Design: https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544 16 Half Moon Bay Local Coastal Plan, Id. https://documents.coastal.ca.gov/reports/2021/4/Th9a/Th9a-4-2021- exhibits.pdf, at Exhibit 2, Pg. 324/480, first full paragraph, and Pg. 326/480 17 Pacifica Local Coastal Land Use Plan, June 2024 Draft, Attachment E to City Council June 26, 2024 Agenda Packet, https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1540, at Pg. 6-33 to 635, Packet Pg. 277-279. 18 Pacific Coast TV U-Tube, Pacifica City Council Meeting, Aug.12,2024:https://www.youtube.com/watch?v=D0R5J9ls6Xc Cervantes: 1:43:30 – 1:46:00: “… the Half Moon Bay LCLUP that has similar policies to what we are proposing to do with the risk disclosure, so that’s Policy 7-9 as you can see here on the slide. And so it does include the second sentence that says that “infill development on existing building sites will be permitted in tsunami inundation zones provided that a disclosure of hazard presence and a hold harmless clause indemnifying the city from any harm caused to permitted development by tsunami inundation are recorded against the property.” Very simple sentence, just has two clauses. Well, on the left-hand side of on the screen you
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Packet Pg. 291 Attachment: Attachment D - Public Comment (5753 : LCLUP #5.4) 5 Woodhouse followed-up, telling Council: “. . .. when we’re talking about Inundation Zones and comparing to Half Moon Bay. . . in practice the . . details of the risk disclosure are the same. We’re just putting it upfront and transparently in the policy in the LCP, whereas in Half Moon Bay, you get that later on, when you work with city staff and you have this covenant that you have to record.”19 But both Ms. Cervantes and Mr. Woodhouse were mistaken. The Half Moon Bay form, captioned “Restrictive Covenant,” recites at Page 1-2, Recitals A thru F, that the property is located in a tsunami inundation zone, that Policy 7-9 of Half Moon Bay’s Local Coastal Plan requires that developers of infill development “must provide a disclosure of hazard presence and a hold harmless clause indemnifying the City from any harm caused to permitted development by tsunami inundation,” and that the Covenant is intended to fulfill the requirements of Policy 7-9.
Paragraphs 1 and 2 of the Half Moon Bay Tsunami Covenant (at page 2 of the document) then (i) disclose that the property ”is within a tsunami inundation zone and any development there is thus subject to the risk of tsunami inundation,” and (ii) covenant that the developer agrees to hold the City harmless against potential liabilities arising out of the City’s approval of the Permit. There are no further waivers of rights in Half Moon Bay’s “Restrictive Covenant” document. (A full 4-page copy of the complete Half Moon Bay “Restrictive Covenant” form was courteously provided to us by Ms. Cervantes, and is linked at the footnote below.)20 By contrast, the eight subparagraphs of Pacifica Draft LCLUP Hazard Risk Disclosure Implementation Policy CR-I-21 are not limited to tsunami disclosure and are not limited to waiver of claims against the city for tsunami-caused damage only. Rather, Pacifica’s Draft LCLUP Implementing Policy CR-I-21 would require property owners to “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,” [and] “assume and accept the risks to themselves and their properties of injury and damage from such coastal hazards in connection with the permitted development,. . . [and] “waive any rights that may exist under applicable law for shoreline protection structures.” 21 There is no such
wholesale waiver of rights in the Half Mood Bay Tsunami Restrictive Covenant.
FN 18, cont. can see what that actually entails. these are just the first two pages, this is a 4-page document, so again the policy might be very straightforward and simple to read, but when you’re actually considering what that entails for implementation, what it entails for a property owner, it is a more detailed process, and so really what we’re trying to do with our policy for risk disclosure is, it has essentially the language that we are anticipating will be in our risk disclosure that will be a template for Coastal Development Permit approvals,. . but the idea that just because your policy is one sentence means that it’s easier to implement is really false. I think the policy itself is very similar to what we’re requiring. It’s disclosure of hazards that need to be recorded against the property.” (emphasis added) 19 Pacific Coast TV U-Tube, Pacifica City Council Meeting, Aug.12,2024:https://www.youtube.com/watch?v=D0R5J9ls6Xc Woodhouse, 1:48:48 – 1:49:48: “I want to just emphasize the point that I think Ms. Cervantes was saying that’s important at this point when we’re talking about Inundation Zones and comparing to Half Moon Bay. . . in practice the details of the risk disclosure are the same. We’re just putting it upfront and transparently in the policy in the LCP, whereas in Half Moon Bay, you get that later on, when you work with city staff and you have this covenant that you have to record.” (emphasis added)
20 Here is a link to the full 4-page Covenant provided to us by Ms. Cervantes: City of Half Moon Bay, Restrictive Covenant Form (Tsunami) https://drive.google.com/file/d/1_zcrImr3UVgIitP9kgJRporIYAqMetnI/view?usp=drive_link 21 Pacifica Draft LCLUP (August 2024), supra,
https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544, Coastal Resilience Implementing Policy CR-I-21, Coastal Hazards Risk Disclosure, at Pgs. 6-33 to 6-35, Packet Pgs. 593-595
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Packet Pg. 292 Attachment: Attachment D - Public Comment (5753 : LCLUP #5.4) 6 3. The waiver of rights in Pacifica’s Implementing Policy CR-I-21 may be an illegal “taking”.
Pacifica’s Draft LCLUP’s Coastal Resiliency Implementing Policy CR-I-21 is the sort of overreaching, disproportionate mandated waiver of rights which the United States Supreme Court described in Sheetz vs. County of El Dorado, California22 as an illegal “taking” of property rights in violation of the 5th Amendment to the United States Constitution, all as discussed at pages 6-7 of our June 25, 2024 letter to Your Council,23 which letter is incorporated herein by this reference and attached as EXHIBIT 3.
4. The Draft LCLUP’s “Tsunami Inundation Zone” map is uncertain, unscientific, uncredentialed, unverifiable, and unsuitable for inclusion in the Draft LCLUP.
Staff’s Written Report for Council’s August 12 Study Session lists “updated maps” first among its list of the “many benefits to having an updated LCLUP.”24 But the “Figure 6-2 Tsunami Inundation Zone” map (found at Packet Page 667 of the August 12 Agenda Packet) is so badly flawed in so many ways as to be unfit for inclusion in the Draft LCLUP. Let us count the ways. (1) The creator of the map is unidentified by either name of qualifications beyond Acting Deputy Planning Director Cervantes’ response to a question from Council at the August 12 Council meeting that “. . . this map was created [by] our community resources department summer intern who has some experience with GIS.”25 She did not name the summer intern or describe the intern’s qualifications beyond “some experience with GIS.” (2) The map is unscientific and unverifiable because it does not adequately identify its sources. A legend at the bottom left-hand corner of Figure 6-2 lists the following sources: “California State Parks, Esri, TomTom, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, US Census Bureau, USDA, USFWS, Esri Community Maps Contributors, California State Parks” No publications are identified from any of these entities. (3) Pacifica Planning Staff and City Council appear uncertain of what scale of Tsunami should be used to define a Pacifica “Tsunami Inundation Zone”. So the “Figure 6-2 Tsunami Inundation Zone” provides limited information to the public.
The map Legend at the top left of “Figure 6-2 Tsunami Inundation Zone” identifies a 475-year “Average Return Period” frequency for the Tsunami Inundation being mapped.
But a new term -- “Tsunami Inundation Zone” – proposed by Pacifica Staff for inclusion in 22 Sheetz vs. County of El Dorado, California, United States Supreme Court, October Term 2023, No. 22-1074 https://www.supremecourt.gov/opinions/23pdf/22-1074_bqmd.pdf 23 Letter, SF Public Golf Alliance to Pacifica City Council, June. 25, 2024, re, inter alia, Tsunami, at pp. 7-8 https://drive.google.com/file/d/1i7-fIm98PVzqArhsfkV-xBv_ycZavINH/view?usp=sharing 24 Pacifica City Council August 12, 2024 Agenda Packet, Item 14, City Council Agenda Summary Report, Aug. 12, 2024, at page 2 (Pkt. Pg. 326) https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544 25 Pacifica StaƯ’s Agenda Summary Report, Aug. 12, 2024, Id., at page 5 (Pkt. Pg. 329), says only “The draft TIZ [Tsunami Inundation Zon] map was created using limited staƯ resources.” At Council’s August 12, 2024 LCLUP Special Study session, Acting Deputy Planning Director Cervantes told Council: “. . . our community development summer intern who has some experience with GIS, so they were able to create this map.” Pacific Coast TV U-Tube, Pacifica City Council Meeting, Aug.12,2024:https://www.youtube.com/watch?v=D0R5J9ls6Xc, at 1:42:57, ff.
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Packet Pg. 293 Attachment: Attachment D - Public Comment (5753 : LCLUP #5.4) 7 the Draft LCLUP’s Glossary clearly shows uncertainty whether ultimately a 475-year period -- or some other frequency -- will be used to define Pacifica’s “Tsunami Inundation Zone.”26
The same uncertainty and indecision can be seen in the Minutes of Council’s June 26, 2024 LCLUP Special Study Session, 27 which records the following comments by Mayor Pro Tem Beckmeyer and former Planning Director Christian Murdock.
Mayor pro Tem Beckmeyer stated . . . with the terminology of tsunami inundation zone, she does not know how we are exactly defining that. (Minutes, at page 31.) Mayor Pro Tem Beckmeyer. . . . wanted to come back to this inundation versus evacuation and the maps.
She . . . wants to understand what our position is or how can we provide some security around this since we do not have the maps and have not identified what epic we are trying to map to. (Minutes, at page 33.)
Former Planning Director Christian Murdock “ . . . agreed, and stated there is a proposed definition of tsunami inundation zone which gives the example of a comparable 475-year average return period tsunami event . . . He stated that we are not going to get to a precise outcome. Council has given policy direction with the definition to strive to shrink the affected area to that which would be subject to a more probable tsunami event than essentially the worst case tsunami event that the Coastal Commission’s tsunami evacuation zone would have caused.” (Minutes, at page 33.)
5. Tsunami Over the Top. The Legend at upper left of the Figure 2 Tsunami Inundation Zone map marks the projected “475 year Average Return Period” with blue diagonal striping. If this draft map is accurate, it appears that substantial areas in both the Sharp Park and Rockaway Beach neighborhoods -- including the City of Pacifica’s Beach Boulevard properties, the Palmetto district, and popular restaurants and hotels in Rockaway Beach, including Nick’s, Moonraker, the Sea Breeze, Lighthouse Hotel, and others – will be subject under the Tsunami provisions of Pacifica’s August Draft LCLUP to the Siting and Design and Technical Reports requirements, notwithstanding those properties location in “Special Resiliency Areas”, because the existing shoreline protective structures are projected to be overtopped by a once-in-475-year Tsunami.28 26 Draft LCLUP, supra, Glossary, P. G-12 (Pkt.Pg. 644)
https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544 The new proposed Glossary definition reads as follows: “Tsunami Inundation Zone: 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)” (emphasis added).
27 Minutes, Pacifica City Council Meeting, June 26, 2024:
https://drive.google.com/file/d/1a67PcS9iXEKd2uJRm7IZZfCJuH3PiqEq/view?usp=sharing 28 The elevation of the top of the Beach Boulevard Seawall between the Pacifica Pier (West end of Santa Rosa St.) and Clarendon Rd. is between 23-26 feet NAVD according to Pacifica’s Notice of Preparation of a Draft Environmental Impact Report for the Proposed Beach Boulevard Infrastructure Resiliency Project, etc., July 31, 2024, at p. 4, first sentence: https://www.cityofpacifica.org/home/showpublisheddocument/18566/638580359795200000. The height of the Rockaway Beach shoreline protective structure west of Nick’s Restaurant is barely more than the elevation of the restaurant’s parking lot, which is less than 15 feet above sea level NAVD. See topographic map below at footnote 30.
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Packet Pg. 294 Attachment: Attachment D - Public Comment (5753 : LCLUP #5.4) 8 See the interactive Pacifica topographic map, footnoted below, which shows the elevations of the shoreline protective structures and streets and buildings in the neighborhoods.29
6. Special Resiliency Areas Appear Now Less Than Advertised. Some may be surprised.
In its current iteration, the Draft LCLUP’s general description of the “Special Shoreline Resiliency Areas” reads, in part: “The purpose of modifying policies applicable to this area is to allow ongoing reliance on the existing shoreline protection structures . . .”30 (emphasis added) But a Coastal Commission Staff-originated change (which change first publicly appeared in Council’s June 26, 2024 Agenda Packet31) to Coastal Resources Implementing Policy CR-I-39 would limit the “ongoing reliance” only to “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-19 and CR-I-20.” (emphasis added) One implication of this change is that the SSRAs’ shoreline protection structures might not be “relied on” with respect to flood mitigation. The Pacifica Staff Report’s June 26 summary comments on the renumbered and revised Implementing Policy CR-I-39 as follows: “CR-I-39 allows development to rely on any existing shoreline protection structure” and “While the changes to Chapter 6 may seem extensive compared to the version of Chapter 6 published for the May 23rd City Council meeting, the intent of the Chapter 6 and the SSRA policies is mostly unchanged. The SSRA policies will still allow development behind the designated SSRA to use protection from coastal hazards that may be provided by the existing shoreline protection structures.”32 These Staff comments appear to overlook the point of the new limited application of CR-I-29 to “setbacks”.
We suggest that this matter of Implementing policy CR-I-39 merits a detailed and focused discussion at Council’s September 17 meeting.
CONCLUSION AND RECOMMENDATION: LOOK TO HALF MOON BAY
As detailed in our August 6 letter to Your Council, Half Moon Bay’s Local Coastal Plan effectively deals with the Tsunami problem by permitting infill development in Tsunami Inundation Areas, without development restrictions, while requiring a targeted tsunami-only disclosure and waiver. The Coastal Commission recent, unanimous and enthusiastic approval of Half Moon Bay’s Local Coastal Plan includes the Commission’s determination that the Half Moon Bay plan – including its Tsunami provisions – fully comply with the Coastal Act.
29 Pacifica Topographic Map (interactive): https://en-us.topographic-map.com/map-kpc57/Pacifica/ 30 Draft LCLUP, supra, Coastal Resilience, p. 6-41 (Pkt. Pg. 601 https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1544 31 Pacifica City Council Agenda Packet for Special Meeting re LCLUP, June 26, 2024, Implementing Policy CR-I-39, at P. 6-41 (Pkt.P.285) https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1540 32 Pacifica City Council Agenda Packet for Special Meeting re LCLUP, June 26, 2024, Id. Staff Report, pp. 6-7 (Pkt Pgs. 9-10). https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1540
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Packet Pg. 295 Attachment: Attachment D - Public Comment (5753 : LCLUP #5.4) 9 We respectfully recommend the Half Moon Bay approach, closely adapting for Pacifica’s use the following language from that Half Moon Bay’s Local Coastal Plan, which permits infill development in tsunami areas and provides a narrow disclosure and hold harmless agreement specifically and narrowly targeted to the tsunami risk.
Mitigation of tsunami risk consists mainly of improved early warning systems and evacuation routes and information, rather than restrictions on development for infill development sites.
Policies – Shoreline Hazards
7-9. New Development in Tsunami Inundation Zone. Limit the creation of new building sites in the tsunami inundation zone. Infill development on existing building sites may be permitted in the tsunami inundation zone, provided that a disclosure of hazard presence and a hold harmless clause indemnifying the City from any harm caused to permitted development by tsunami inundation are recorded against the property.
33 Respectfully submitted,
Richard Harris
President, San Francisco Public Golf Alliance
cc: City Manager Kevin Woodhouse, Interim Deputy Planning Director Stefanie Cervantes, Interim Community Development Director Kavitha Kumar, Planning Commission and Commissioners, City Clerk Sarah Coffey, Phil Ginsburg, Gen. Mgr., San Francisco Recreation and Parks Dept., Spencer Potter, Esq., San Francisco Recreation and Parks Dept.; Stephanie Rexing, North Central Coast District Manager, California Coastal Commission; Oceane Ringuette, CCC District Supervisor; Julian Honey, CCC Planner; Mr. Jeff Guillet 33 Half Moon Bay Local Coastal Plan, supra. https://documents.coastal.ca.gov/reports/2021/4/Th9a/Th9a-4-2021- exhibits.pdf, at Exhibit 2, Pg. 324/480, first full paragraph, and Pg. 326/480
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Packet Pg. 296 Attachment: Attachment D - Public Comment (5753 : LCLUP #5.4) 10 EXHIBITS
EXHIBIT 1
Letter, August 6, 2024, San Francisco Public Golf Alliance to Pacifica City Council https://drive.google.com/file/d/19ghnzI-ZLO6rkfzJWvD_4hwtpU01iWaP/view?usp=drive_link EXHIBIT 2
Slide from Staff Presentation to Pacifica City Council Aug. 12, 2024 LCLUP Study Session / Half Moon Bay Form: Restrictive Covenant (Tsunami Inundation Zone) EXHIBIT 3
Letter, June 25, 2024, San Francisco Public Golf Alliance to Pacifica City Council, pp. 7-8 https://drive.google.com/file/d/1cmSqBoq6wCgji5PSMxjyyU4thwgohFjU/view?usp=sharing
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Packet Pg. 297 Attachment: Attachment D - Public Comment (5753 : LCLUP #5.4)