Pacifica City Council
October 28, 2024

Edits to ensure that implementing
the recommendations of this outside
(non-LCP) document would occur in
a Coastal Act consistent way.
3 3.6B PR-I-50 Continue to require bicycle parking facilities in new high density residential, mixed use, and non-residential
development.

N/A N/A The October 2023 GP consistency
changes removed “high density
residential, mixed use, and” from the
policy. Staff recommends keeping
the original 2020 language. City
Council reviewed this language
during the 9/17/2024 meeting.
3 3.7 PR-I-57:

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

PR-I-57: Bicycle Roadway Retrofits
Additional analysis will be required to identify
roadway retrofits to create complete streets. such
as coastal hazard concerns in areas within the
Coastal Zone. Retrofits will be consistent with this
LCP.

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

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

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

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

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

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

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

City staff’s alternative modification
indicates a CDP may be required (as
opposed to requiring it in all
instances). It is possible certain
vacations may be exempt from CDP
requirements.
3 3.9 PR-I-69
Service
Optimization
Continue coordination efforts with transit agencies (i.e., SamTrans) to maintain transit service that is safe and
efficient, provides convenient connections to high-use
activity areas and key destinations outside the City,
enhances access to the coast, and responds to the
needs of all passengers, including seniors, youth, and
persons with disabilities.

N/A N/A The October 2023 GP consistency
changes removed “enhances access
to the coast” from the policy. Staff
recommends keeping the original
2020 language. City Council reviewed
this language during the 9/17/2024
meeting.
3 3.10 PR-I-72
TransitOriented
Developmen
t
Work with Samtrans to facilitate transit-oriented
development in all appropriate locations where existing or projected future rider demand will support it.

N/A Work with Samtrans to facilitate transit-oriented
development on all or part of the Linda Mar
Boulevard Park-and-Ride lot and on any future
Park-and-Ride lots that may be developed by
SamTrans.

The October 2023 GP consistency
changes removed “in all appropriate
locations where existing or projected
future rider demand will support it.”
And added “on all or part of the

4.d
Packet Pg. 778 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
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and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Linda Mar Boulevard Park-and-Ride
lot.” from the policy. Staff
recommends the proposed
alternative modification to be
consistent with CCC
recommendations. City Council
reviewed this language during the
9/17/2024 meeting.
3 GP 1A PR-I-74 Establish a Transportation Demand Management (TDM) program for City employees that may include transit
passes or subsidies, preferential carpool parking, car
share programs, bicycle lockers, and other incentives to employees choosing transportation modes other than
driving.

N/A Incorporate conditions of approval for
development project that the Congestion
Management Program (CMP) threshold for impacts
to the CMP transportation network to require
adoption of transportation demand management
(TDM) measures authorized by the CMP to make
measure reduction in their trip generation and to
require a monitoring plan to determine if
established trip reductions targets are met or
exceeded.

The October 2023 GP consistency
changes modified this policy. Staff
recommends the proposed
alternative modification to be
consistent with CCC
recommendations. City Council
reviewed this language during the
9/17/2024 meeting.
3 GP 1B PR-G-27 Facilitate beach and recreational use by providing safe and well-located public parking. Distribute parking areas throughout the Coastal Zone to mitigate against the
impacts of overcrowding or overuse by the public of any single area.

N/A Facilitate beach and recreational use by providing
safe and well-located public parking. When
appropriate and feasible, distribute parking areas
throughout the Coastal Zone to mitigate against
the impacts of overcrowding or overuse by the
public of any single area.

The October 2023 GP consistency
changes modified this policy. Staff
recommends the proposed
alternative modification to be
consistent with CCC
recommendations. City Council
reviewed this language during the
9/17/2024 meeting.
4 4.1 Surface
Water
Some of the watersheds drain directly into the ocean,
while other feed one of five.

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

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

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

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

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

Requiring a minimum of 100 feet setbacks from the top
of creek banks, or from the outer edge of riparian
vegetation, where it exists, for development proposed
adjacent to creeks, in keeping with City regulations and Best Management Practices. Exceptions to such buffer
requirements should be supported by a biological
report demonstrating that the adjusted buffer, in
combination with incorporated siting, design or other
mitigation measures, shall prevent impacts that
significantly degrade the creek. Buffer adjustments
should also be limited to where the entire subject legal lot is within the buffer or where it is demonstrated that development outside the buffer would have a greater
impact on the creek.

Requiring a minimum of 100 feet setbacks from
the top of creek banks, or from the outer edge
of riparian vegetation, where it exists,
whichever is further, for development proposed
adjacent to creeks, in keeping with City
regulations and Best Management Practices.

The 100-foot buffer may be reduced by the
minimum necessary (1) to avoid a taking (for
private development), or (2) to provide required
public services (for public development),
provided that the buffer is as close to 100 feet
as possible, and no less than 50 feet in any case,
and provided that creek resource impacts are
avoided as much as possible, and unavoidable
Requiring a minimum of 100 feet setbacks buffers
from the top of creek banks, or from the outer
edge of riparian vegetation, where it exists,
whichever is further, for development proposed
adjacent to creeks, in keeping with City regulations
and Best Management Practices. The 100-foot
buffer may be reduced by the minimum necessary
(1) to avoid a taking (for private development), or
(2) to provide required incidental public services
(for public development, such as burying cables
and pipes or inspection of piers, maintenance of
existing intake and outfall lines, and emergency
repairs), provided that any unavoidable impacts are
commensurately mitigated, that the buffer is as
CCC suggested modification amends
the text to clarify exceptions;
however, the statement “no less
than 50 feet in any case” is too
prescriptive and does not consider
the quality of habitat or design
alternatives. City staff proposes to
eliminate the statement and the
buffer will be decided on a case-bycase basis as informed by a qualified biologist. Additional text to clarify
mitigation may be needed.

4.d
Packet Pg. 779 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification impacts commensurately mitigated, all as
conclusively demonstrated by a qualified
biologist to the satisfaction of the City, USFWS,
and CDFW.
close to 100 feet as possible, and no less than 50
feet in any case, and provided that creek resource
impacts are avoided as much as possible, and
unavoidable impacts commensurately mitigated, all
as conclusively demonstrated by a qualified
biologist to the satisfaction of the City and
applicable resource agencies
4 4.3 ER-I-1: Creek
Protection
and
Restoration.

N/A Permitted uses within buffer zones are limited
to uses dependent on the resources within
these areas and their buffer zones (i.e. habitat
management and restoration, scientific
research and educational activities, and lowintensity public access and recreation).

Temporary disruption (e.g. less than six months)
for the construction, alteration, repair, and
maintenance of existing or newly permitted
facilities or structures is allowed if there are no
feasible alternatives, the disruption area is
restored to its pre- disruption state or better
within one year from the initial point of impact
and there is no significant ground disturbance.

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.

CCC suggested modification added
language to Policy ER-I-2 that
specified allowed uses within a
designated buffer area. City staff is
generally in support of the suggested
modification; however, City staff is
proposing an alternative
modification to clarify that takings
avoidance is a relevant factor for
consideration, as is provision of
public services. City staff is also
clarifying that temporary disruptions
may be permissible if reviewed and
recommended by a qualified
biologist.

The last portion of the first sentence
is redundant and should be
removed.
4 GP 1C ER-I-8
Continued
Moved of
Sediment
and
Nutrients
Allow sediment removed from erosion and flood control
facilities to be placed at appropriate points on the
shoreline, where environmental effects will be minimal.

Allow suitable sediment removed from erosion and
flood control facilities to be placed at appropriate
points on the shoreline, where environmental
effects will be minimal.

The October 2023 GP consistency
changes modified this policy. Staff
recommends the proposed
alternative modification to be
consistent with CCC
recommendations. City Council
reviewed this language during the
9/17/2024 meeting.
4 4.4 Plant
Communities
and Wildlife
Habitats
The EIR for the General Plan and Local Coastal Land Use Plan Update includes a more detailed description of
each of these communities and habitats. The listed
species and habitats here are not intended to preclude
the possibility that other species or habitat occur within Pacifica. Species identified with various plant
communities or habitats are not necessarily present in
the Planning Area. Some of these communities are
recognized as “special status communities,” or provide
critical habitat for special status species.

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

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

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

Additionally, some of the City’s
General Plan consistency changes
eliminated portions of this text.
4 4.5 Annual
Grasslands
Annual Grasslands Grasslands N/A The City’s General Plan consistency changes eliminated the term
“annual” from the header and the

4.d
Packet Pg. 780 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification suggested modification is no longer
applicable.
4 4.6 Northern
Coastal
Scrub
Northern coastal scrub habitat is found on undeveloped
slopes, often in a mosaic with annual grasslands.

Northern maritime chaparral, a special-status
community, is included in this category. Northern
coastal scrub is dominated by either coyote brush or
California sagebrush, depending on slope aspect.

Northern coastal scrub habitat is found on
undeveloped slopes, often in a mosaic with
grasslands. Northern maritime chaparral, a
special-status community, is included in this
category. Northern coastal scrub dominated by
either coyote brush or California sagebrush,
primarily depending on slope aspect.

N/A CCC suggested modification removes
the term “annual” and generalizes
language.
4 4.7 Seasonal
Wetlands
and Ponds
Seasonal Wetlands and Ponds Wetlands and Ponds N/A CCC suggested modification generalizes language
4 4.7 Seasonal
Wetlands
and Ponds
Seasonal Wetlands occur in smaller drainages and
localized depressions, forming ponds or flowing water,
and are underlain by saturated soils during the winter
and spring. Seasonal wetlands also occur along the
banks and sediments that accumulate in creeks.

Wetlands in Pacifica are found along riparian areas,
drainages, along the coast, and as fresh and brackish
water marshes (such as on the Sharp Park Golf Course).

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

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

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

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

CCC suggested modification clarifies
the language; however, City staff is
proposing an alternative
modification to address typos.
4 4.7 SpecialStatus
Species

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

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

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

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

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

4.d
Packet Pg. 781 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.8 N/A N/A Dunes
Dune habitat includes areas with sandy
substrates proximate to the marine
environment and may range from bare to
vegetated with species typical of foredune and
dune scrub communities, including non-natives
such as ice plant and invasive grasses. Dune
form topography may or may not be evident,
depending on the condition of the dune and
past land use or invasions, but may be readily
restored. While most dunes occur near sea
level, there are several examples of perched
dune systems atop bluffs in Pacifica, where
aeolian forces have created the substrate and
processes appropriate to support dune
vegetation. All areas that meet this definition of
Dunes are categorically considered ESHA.

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

Figure 4-3 identifies potential ESHAs in the
Planning Area in three general categories:
wetland, stream/riparian, and other terrestrial
ESHAs. These potential ESHAs include all current
designated critical habitat for Endangered or
Threatened Species; known special status
communities; and areas designated as “other
potential Environmentally Sensitive Habitat
Areas”. Figure 4-3 is meant to serve as a flag for
further studies to be undertaken when
development is proposed. However, the map is
illustrative and for information purposes only;
site-specific biological studies are required as
part of proposed development review to
determine the presence and extent of ESHA and
its required buffer zone. And other information
than Figure 4-3 may dictate the need for such
studies as well (e.g., site evaluation, other
studies nearby, etc.), even if the area is not
mapped as potential ESHA on Figure 4-3.

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

However, the map is illustrative and for
information purposes only; site-specific biological
studies are required as part of proposed
development review to determine the presence
and extent of ESHA and its required buffer zone.

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

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

N/A Grasslands/Prairie vegetation communities shown
on Figure 4-2 are also mapped on Figure 4-3 as
Potential ESHA. Any proposed development on
land designated on the Potential Environmentally
Sensitive Habitat Areas map (Figure 4-3) as having
potential to include an Environmentally Sensitive
Habitat Area requires a site-specific evaluation by
qualified biologists
Edits for consistency with the name
and content of Figure 4-3.

4.d
Packet Pg. 782 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.10 ER-G-6:

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

Conserve and protect beaches, sand dunes,
coastal bluffs, and special status communities,
particularly the Coastal bluff scrub on the
northern bluffs. Prohibit development in coastal
dunes to preserve dune formations, vegetation,
and wildlife habitats. Prevent overuse in dune
areas by mechanisms such as restricting parking
and directing pedestrian traffic through signage
and sand fencing to areas capable of sustaining
such use. Prohibit motor vehicles in dune areas
except for emergency purposes, and prohibit
motor vehicles in non-dune beach areas except
for emergency and essential maintenance
purposes and where previously coastal
permitted.

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

Creeks and
Riparian
Areas as
Habitat
Protect year-round creeks and
their riparian habitats.

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

N/A CCC suggested modification adds
clarifying language.
4 GP2A ER-I-21:

Protection of
Biological
Resources
with New
Developmen
t
1) The City shall avoid development and/or
buildout in critical habitat of special status
species during the development review process.

N/A The City should discourage development and/or
buildout in critical habitat of special status species
during the development review process in a
manner that is consistent with LD-I-5 to avoid
takings.

This is an alternative modification to
a general plan consistency change.

Discussed at the 9/17/2024 meeting.
4 4.12 ER-I-21:

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

Project applicants shall engage a qualified
biologist to conduct presence/absence
biological surveys for sensitive plant and wildlife
species prior to construction adjacent to or
within areas identified as potential ESHAs on
Figure 4-3, or as otherwise indicated and
needed. If special status species are identified,
the qualified biologist shall consult with the
California Department of Fish and Wildlife
(CDFW) and establish no-disturbance buffers
around the special status specie to avoid
disturbance and direct impacts to these
resources during construction. If no special
status species are detected during surveys, then
construction-related activities may proceed.

Nesting birds, in particular, are protected by
two means; they receive protection under the
Migratory Bird Treaty Act, and nesting raptors
(in the order Falconiformes or Strigiformes) are
protected under the State Fish and Game Code,
§3503.5.

N/A CCC suggested modification adds
clarifying language.

4.d
Packet Pg. 783 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.12 ER-I-21:

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

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

Protection of
Biological
Resources
with New
Developmen
t
4) Require on-site monitoring of biological resources
by a qualified biologist throughout the duration of
construction activity.
4) Require on-site monitoring of biological
resources by a qualified biologist throughout
the duration of construction activity and
afterwards, should approval conditions warrant.

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

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

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

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

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

Managemen
t of ESHA
• Buffer areas shall be established around all sensitive resources, providing a minimum of 100 feet, and
varying as needed to account for feeding, breeding,
nesting, and other habitat requirements. Exceptions to
such buffer requirements should be supported by a
biological report demonstrating that the adjusted
buffer, in combination with incorporated siting, design or other mitigation measures, will prevent impacts that significantly degrade the ESHA and will be compatible
with the continuance of the ESHA. Buffer adjustments
should also be limited to where the entire subject legal lot is within the buffer or where it is demonstrated that development outside the buffer would have a greater
impact on the ESHA.
• Buffer areas shall be established around all
ESHA, providing a minimum of 100 feet, and
may be expanded as needed to account for
feeding, breeding, nesting, and other habitat
requirements. The 100-foot buffer may be
reduced by the minimum necessary (1) to avoid
a taking (for private development), or (2) to
provide required public services (for public
development), provided that the buffer is as
close to 100 feet as possible, and no less than
50 feet in any case, and provided that ESHA
resource impacts are avoided as much as
possible, and unavoidable impacts
commensurately mitigated, all as conclusively
demonstrated by a qualified biologist to the
satisfaction of the City, USFWS, and CDFW.
• Buffer areas shall be established around all ESHA
and Wetlands, providing a minimum of 100 feet,
and may be expanded as needed to account for
feeding, breeding, nesting, and other habitat
requirements. The 100-foot buffer may be reduced
by the minimum necessary (1) to avoid a taking (for
private development), or (2) to provide required
incidental public services (for public development,
such as burying cables and pimped or inspection of
piers, maintenance of existing intake and outfall
lines, and emergency repairs), provided that any
unavoidable impacts are commensurately
mitigated, that the buffer is as close to 100 feet as
possible, and no less than 50 feet in any case, and
provided that ESHA resource impacts are avoided
as much as possible, and unavoidable impacts
commensurately mitigated, all as conclusively
demonstrated by a qualified biologist to the
satisfaction of the City and applicable resource
agencies.

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

Additional text to clarify that
mitigation may be necessary.

Some additional modifications were
discussed at the 9/17/2024 meeting.

4.d
Packet Pg. 784 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.14 ER-I-24:

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

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

Construction
during
Nesting
Season
If site work or construction occurs during the nesting
season (February 1 through August 31), then preconstruction breeding bird surveys shall be performed by a qualified wildlife biologist prior to any site
disturbance to ensure that no nests will be disturbed or destroyed during Project implementation. If an active
nest is found sufficiently close to work areas to be
disturbed by construction activities, then the biologist shall create a no-disturbance buffer of 250 feet around passerine nests and a 500 foot buffer around raptor
nests. Work-free buffer zones shall be maintained until after the breeding season or until after the qualified
biologist determines the young have fledged (usually
late June through mid-July).

Nests initiated during active construction would be
presumed to be unaffected by the activity, and a buffer zone around such nests is not necessary. However,
nests shall be flagged and construction activity shall
avoid killing and/or injuring nesting birds.

If site work or construction occurs during the
nesting season (February 1 through August 31),
then pre-construction breeding bird surveys
shall be performed by a qualified wildlife
biologist prior to any site disturbance to ensure
that no nests will be disturbed or destroyed
during Project implementation. If an active nest
is found sufficiently close to work areas to be
disturbed by construction activities, then the
biologist shall create a no-disturbance buffer of
250 feet around passerine nests and a 500 foot
buffer around raptor nests. Work-free buffer
zones shall be maintained until after the
breeding season or until after the qualified
biologist determines the young have fledged
(usually late June through mid-July).

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

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

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

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

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

N/A CCC suggested modification adds
clarifying language.

4.d
Packet Pg. 785 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.17 ER-I-39: Bowl
Site
Establish appropriate zoning for the “Bowl” site along
the east side of Palmetto Avenue in Fairmont West for
Planned Development to ensure site planning that
clusters development, avoiding potential flooding or
geotechnical hazards and protecting open space
resources.

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

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

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

Edited to match the terminology
used in Figure 4-4.
4 GP2B ER-I-44
Minimize
Visual
Impacts of
Hillside
Developmen
t.

Seek first to avoid impacts on hillside formations
through site planning and design;
N/A Seek first to avoid impacts to visual resources, such as those shown in Figure 4-4, through site planning
and design;
Alternative modification to use
consistent terms. Discussed at the
9/17/2024 meeting.
4 GP3 ER-I-53:

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

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

N/A Staff agrees with the CCC suggested
modification from June 2024. The
sentence is deleted to clarify that the
policy applicable only within the
coastal zone.
5 5.1 Natural
Hazards
Ensuring the safety of community members, through
protection from hazards, is an essential service of public agencies and a critical priority for maintaining
community health. The purpose of the Natural Hazards
chapter is to establish goals and policies to mitigate the potential impacts from natural and man-made hazards
that pose a threat to public health, and safety.

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

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

Deleted N/A CCC suggested modification deletes
text in an introductory paragraph.
5 GP4 Soil Erosion This edit was added in October 2023 as part of the GP consistency changes. It added the following to the
policy: Within the Coastal Zone, the City requires new
development to be set back from coastal bluffs enough
to accommodate a 100-year event, whether caused by
seismic, geotechnical, or storm conditions (unless this limitation makes a property undevelopable). Areas
determined by the study to be unsuitable for
CCC Suggested Modification from June 2024
recommended deletion of two paragraphs.

N/A Staff agrees with the CCC suggested
modification from June 2024. The
paragraph is deleted because it is
inconsistent with policies within
Chapter 6.

4.d
Packet Pg. 786 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification development shall be set aside for permanent
environmental protection as part of any development.

And continued.
5 5.3 NH-G-1:

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

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

N/A CCC suggested modification adds
clarifying language.
5 5.3A NH-I-3: Fault
Zone
New development shall be sited and designed to
minimize risks from seismic events. Building for human
occupancy shall avoid surface traces of active faults,
consistent with the Alquist-Priolo Earthquake Fault Zone Act and other relevant state laws. (See the Liquefaction and Fault Zones map, Figure 5-1).

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

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

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

Deleted NH-I-9: Hillside Erosion Prevention.

Encourage erosion prevention of hillside areas to
maintain slope stability by revegetation. Other
slope stability methods may be acceptable,
consistent with this LCP.

CCC suggested modification deleted
the entire policy related to hillside
erosion prevention. City staff
alternative modification clarifies that
the policy is intended for hillside
erosion, and not bluff erosion.
5 5.5 NH-I-10:

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

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

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

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

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

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

Developmen
t in Coastal
Zone
Small improvement projects are exempt, including
improvements that would increase height, bulk or floor
area by less than ten percent.

N/A N/A CCC suggested modification deletes
text related to small improvements
to align with the Substantial
Structural Modification definition.
5 5.7 Flood Zones Flood hazards mapped by FEMA to support the development of Flood Insurance Rate Maps (FIRMs)
generally identify areas of greater flood risk (100 and 500 year events) in the lower reaches of the main
stream channels, and the risk of coastal flooding along the shoreline. Flood zones based on the FIRMs are
shown in Figure 5-3.

Flood hazards mapped by FEMA to support the
development of Flood Insurance Rate Maps
(FIRMs) generally identify areas of greater flood
risk (100 and 500 year events) in the lower
reaches of the main stream channels, and the
risk of coastal flooding along the shoreline,
although they do not account for climate
change or sea level rise, and thus should be
reviewed in conjunction with Appendix B
(“Coastal Zone Vulnerability Maps”). Flood
zones based on the FIRMs are shown in Figure
5-3.

N/A CCC suggested modification adds
clarifying language.

4.d
Packet Pg. 787 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 5 5.8 NH-G-2:

Developmen
t in
Hazardous
Areas
Protect development in 100-year floodplains and
tsunami hazard zones with flood damage prevention
programs.

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

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

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

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

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

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

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

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

CCC suggested modification removed
streambeds from the policy.

Significant areas of Pacifica are
serviced by creeks as critical
stormwater infrastructure that
require regular maintenance. City
staff alternative modification
clarifies that all routine maintenance
in streambeds will conform to the
Coastal Act.
5 5.11 NH-I-27:

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

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

N/A CCC suggested modification amends
policy text to include rivers, water
supply, and mention of fish and
wildlife habitat.
5 5.11A NH-I-31
Tsunami
Evacuation
Zone
NH-I-31Tsunami 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
N/A NH-I-310 Tsunami Inundation Zone. For new
development in the tsunami inundation zone,
require use of low impact engineering techniques,
such as elevating structures above projected water
levels, to mitigate impacts to people and structures
Replacement of “evacuation” with
“inundation” to be consistent with
policies in Chapter 6.
5 5.12 NH-I-31:

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

Site critical public facilities including hospital
and healthcare facilities, emergency shelters,
police and fire stations, and emergency
communications facilities outside of the
tsunami evacuation zone, 100-year flood plains,
and other portions of the Coastal Vulnerability
Zone over the anticipated life of the
development. If no feasible alternative location
is available and a new or expanded critical
facility must be located in a shoreline hazard
N/A CCC suggested modification amends
policy text to include Coastal
Vulnerability Zones.

4.d
Packet Pg. 788 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification area, require the new development to
incorporate siting and design measures based
on worst-case sea level rise projections and
extreme weather event scenarios to promote
continued functionality and public services,
resist structural damage, facilitate evacuation
on short notice, and minimize risk to life,
property, and coastal resources.
5 5.12A NH-1-32:

Existing
Critical
Facilities
N/A NH-I-32Existing Critical Facilities. Coordinate
with NCCWD and others to identify existing
critical facilities that are vulnerable to shoreline
hazards, and work to establish measures to
protect continued function of critical
infrastructure, or the basic facilities, service
networks, and systems needed for the
functioning of a community. Coordination
efforts may include, but are not limited to:
• developing strategies for retiring,
moving, or replacing critical infrastructure and
public facilities at risk of damage from shoreline
hazards including sea level rise impacts that
may occur over the economic life of the
structure (at least 150 years for critical
facilities);
• providing for functional continuity of
the critical services provided by critical
infrastructure at risk from shoreline hazards and
extreme weather events; and
• assessing options for the use of
protective devices, if necessary to ensure the
continuation of needed services, as a temporary
option while longer-term strategies are
identified and implemented. Update the LCP as
necessary to incorporate additional strategies to
address existing critical facilities and
infrastructure.

N/A Recommended new policy by
NCCWD, modified by CCC.
5 5.12B NH-I-34:

Adequate
Peak Load
Water
Supply
Adequate Peak Load Water Supply. Work with North
Coast County Water District to maintain adequate water
supply for firefighting, including capacity for peak load under a reasonable worst case wildland fire scenario, to be determined by the North County Fire Authority.

N/A NH-I-33NH-I-34 Adequate Fire Flow and Fire Flow
Upgrades. Work with the North Coast County
Water District and the North County Fire Authority
to maintain and establish priorities for upgrading
fire flow capabilities in neighborhoods that may
have inadequate fire flows. Work with NCCWD to
maintain adequate water supply for firefighting,
including capacity for peak load under a reasonable
worst case wildland fire scenario, to be determined
by the North County Fire Authority.

Recommended policy change by
NCCWD.

4.d
Packet Pg. 789 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 5 5.13 NH-I-35:

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

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

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

Vegetation
Managemen
t
Promote and support the North County Fire Authority’s
Vegetation Management Program to reduce
urban/wildland interface fire hazards.

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

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

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

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

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

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

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

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

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

4.d
Packet Pg. 790 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.2 Coastal Act
Policies
Therefore, the policies focus on protection and
armoring of the shoreline and reassessment of the
adaptation plan in the future. The policies do not
include managed retreat as an adaptation strategy
unless and until a future Local Coastal Land Use Plan
amendment and public input process culminates in
supporting the strategy.

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

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

Deleted However, because the Coastal Vulnerability Zone Maps show significant erosion for areas that are
protected by existing shoreline protection
structures, the Maps highlight the protection
provided by the structures.

CCC suggested modification deletes
introductory text. City staff is
proposing an alternative
modification to add language related
to the existing shoreline protections
in the City.
6 6.4 Adaptation
Plan
The cost-benefit analysis section of the Adaptation Plan was not adopted or approved by the City of Pacifica.

The purpose of the cost benefit analysis was to provide information regarding various sea level rise scenarios
and adaptation options and was not intended to
prescribe specific adaptation policies. The cost-benefit analysis shall not be used for any future purpose by the City of Pacifica or its planning processes, including
implementation of the Local Coastal Program, public
infrastructure investment, permitting or other
regulatory purposes.

Deleted The cost-benefit analysis section of the Adaptation Plan was not adopted or approved by the City of
Pacifica. The purpose of the cost benefit analysis
was to provide information regarding various sea
level rise scenarios and adaptation options and was
not intended to prescribe specific adaptation
policies. The cost-benefit analysis was perceived to
require additional work to adequately analyze the
value of public recreational amenities.

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

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

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

Deleted Therefore, changes to the cost-benefit analysis are not necessary to inform the Coastal Resiliency
policies.

CCC suggested modification deletes
introductory text. City staff is
proposing an alternative
modification to add language related
to the cost-benefit analysis.
6 6.4 Adaptation
Plan
The Adaptation Plan was prepared to inform City
decision making about a variety of sea level rise
adaptation policies, but does not include or dictate the ultimate policies selected by the City. Although
managed retreat alternatives are analyzed in the
Adaptation Plan in accordance with the City’s grant
agreement with the CCC, these analyses do not, in
themselves, equate to a managed retreat policy. To the
contrary, the City has rejected managed retreat as a sea Deleted The Adaptation Plan was prepared to inform City decision making about a variety of sea level rise
adaptation policies, but does not include or dictate
the ultimate policies selected by the City. Although
managed retreat alternatives are analyzed in the
Adaptation Plan in accordance with the City’s grant
agreement with the CCC, these analyses do not, in
themselves, equate to a managed retreat policy.

The City uses other sea level rise adaptation
CCC suggested modification deletes
introductory text. City staff is
proposing an alternative
modification to add language related
to the Adaptation Plan and potential
future changes.

4.d
Packet Pg. 791 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
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City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification level rise adaptation policy in this LCP and managed
retreat could only become the policy of the City
subsequent to a future amendment to the LCP.
policies in this LCP and any future changes to these
policies will require an amendment to this LCP.
6 6.5A CR-I-1:

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

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

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

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

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

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

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

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

Developmen
t in Coastal
Vulnerability
Zones
Adaptation alternatives evaluated in the Adaptation
Plan that are not specifically expressed in these Coastal Resilience policies shall not be implemented without an amendment to the LCP, public notice, and opportunity
for public input.

Deleted N/A CCC suggested modification deletes
text
6 6.6A CR-I-2
Developmen
t in Coastal
Vulnerability
Zones
The City shall implement its Sea Level Rise Adaptation
Plan as expressed in the general and sub-area Coastal
Resilience policies. Adaptation alternatives evaluated in the Adaptation Plan that are not specifically expressed in these Coastal Resilience policies shall not be
implemented without an amendment to the LCP, public
notice, and opportunity for public input. The City shall monitor implementation and, consistent with Coastal
Resilience Policy CR-I-4, update the Sea Level Rise
Adaptation Plan to strengthen public safety, preserve
existing neighborhoods, assure local economic vitality, respond to climate change, promote environmental
N/A Deleted An additional modification removes
this entire text.

4.d
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City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification justice, implement the Coastal Act, and protect the
public trust.
6 6.6B CR-I-2
Developmen
t in Coastal
Vulnerability
Zones
Development in Coastal Vulnerability Zones may be
approved consistent with the sub-area policies in
Section 6.6 if the following findings can be made:

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

Alternative modification to
demonstrate compliance with
Coastal Act.
6 6.6C CR-I-2
Developmen
t in Coastal
Vulnerability
Zones
a. The proposed development is sited and designed to
avoid, and where unavoidable, to minimize coastal
hazards and impacts to coastal resources to the
maximum extent feasible, consistent with the
Adaptation Plan;
N/A a. To avoid, and where unavoidable, to minimize
risks from coastal hazards to the maximum
feasible;
Alternative modification to
demonstrate compliance with
Coastal Act.
6 6.6 CR-I-2:

Developmen
t in Coastal
Vulnerability
Zones
b. All project impacts on coastal resources are mitigated to the maximum extent feasible through the City’s
Shoreline Mitigation Program (Coastal Resilience Policy CR-I-5) or consistent with Coastal Resilience Policy CR-I59. b. All project impacts on coastal resources are
avoided, and where unavoidable, minimized
and mitigated to the maximum extent
consistent with Coastal Resilience Policy CR-I59.
b. To avoid, and where unavoidable, to minimize
and mitigate to the maximum extent;
CCC suggested modification amends
policy to prioritize avoidance of
coastal resource impacts
6 6.6 CR-I-2:

Developmen
t in Coastal
Vulnerability
Zones
c. The project will not pose unacceptable risks to life or property or otherwise create a nuisance; and
c. The project will not pose unacceptable risks
to life or property for the anticipated life of the
development or otherwise create a nuisance;
c. To avoid creating a nuisance; Clarification to align with proposed added definition of “anticipated life”
6 6.6 CR-I-2:

Developmen
t in Coastal
Vulnerability
Zones
d. The project will not encroach on public trust lands. d. The project will not encroach on public trust lands for the anticipated life of the
development; and
d. To avoid encroachment onto public trust lands;
and
Clarification to align with proposed
added definition of “anticipated life”
6 6.6 CR-I-2:

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

CCC suggested modification is an
addition of a Coastal Act provision.

City staff alternative modification
clarifies that the policy relates to the
anticipated life of the development
consistent with other policies in the
LCP.
6 6.7 CR-I-3:

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

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

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

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

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

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City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.7A CR-I-4
Assessing
Coastal
Resiliency
Provisions
Implementat
ion
The City shall reassess its Sea Level Rise Adaptation Plan as expressed in the general and sub-area Coastal
Resilience policies every five years or sooner as required by the shoreline monitoring program (Coastal Resilience Policy CR-I-3). The reassessment shall consider the
following:
• Efficacy of Adaptation Plan and implemented
measures.
• Updated sea level rise projections and risks.
• Potential need to revise adaptation measures or
implement new measures, including review of
emerging engineering, science, and
technologies.
• Funding needs and potential funding sources.

The draft findings of the City’s reassessment shall be
disseminated to the public for review and comment
prior to being finalized.

N/A The City shall assess implementation of the LCP’s
coastal resiliency provisions at least every five
years, where such assessment shall at the
minimum consider the following:
• The efficacy of such provisions at
protecting and enhancing the City’s beach
and shoreline area resources, critical
infrastructure, and other built and natural
environment features.
• Updated sea level rise projections and
risks.
• The potential need to revise coastal
resiliency measures and/or implement new
measures, including review of emerging
engineering, science, and technologies.
• Funding needs and potential funding
sources.
• The results of the City’s shoreline
monitoring program (CR-I-3), shoreline
adaption program (CR-I-5), adaptation
funding efforts (CR-I-6), consideration of an
LCP transfer of development rights
program (CR-I-7), critical transportation
infrastructure efforts (CR-I-8), hazard prone
infrastructure efforts (CR-I-9), business
outreach efforts (CR-I-10), high water mark
efforts (CR-I-11), flood ordinance and
LHMP consistency efforts (CR-I-11 and CR-I12), sediment management and beach nourishment programs (CR-I-14 and CR-I15), additional flood protection efforts (CRI-16), groundwater monitoring efforts (CRI-17), and Caltrans coordination efforts (CRI-18).

The City shall use such assessment efforts to form
the basis for LCP updates and changes to better
address coastal hazards in a way that can protect
and enhance bluff, shoreline, offshore, and sandy
beach recreational areas for public use and
enjoyment while ensuring all development
(including private structures and public
infrastructure) are safe from coastal hazards as
much as possible both now and in the future.

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

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

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

Within 10 years of the certification of this LUP the
City shall develop a Shoreline Adaptation Program
for the City’s shoreline and obtain Coastal
Commission certification of an LCP amendment
informed by the Program. The Program is
encouraged to be made up of sub-area plans for
smaller sections of the coastline that share similar
. Alternative modification to
demonstrate compliance with
Coastal Act. This policy has been
expanded to included specific details
regarding CCC’s expectation of what
the scope of the Program should be
and sets a 10-year timeline by which

4.d
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City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification attributes, shall build on past adaptation planning
work, and identify adaptation approaches that will
be implemented to address vulnerabilities and
protect coastal resources throughout the City.

The Program shall be consistent with and help to
support and implement the Coastal Access and
Resilience Program developed per CR-I45 and at a
minimum address the following topics:
a) Existing and Future Conditions.

Leveraging any existing relevant data
or studies, describe the relevant
shoreline area in terms of its resources
and constraints. Identify baseline
conditions in terms of existing public
and private development; shoreline, sandy beach, and offshore public access and recreational areas; and
environmental resources. Include an
assessment of beach widths
throughout tidal and seasonal ranges.

Additionally, analyze how conditions
are expected to change as coastal
hazards (including short- and long-term
erosion and flooding) are exacerbated
by sea level rise. Describe how the
presence or absence of development
and shoreline protection structures has
impacted and is projected to impact
conditions over time, particularly how
such development would or would not
allow for natural migration of beaches
over time and impact public use and
availability of the sandy
beach/shoreline. Identify areas where
beaches would likely be able to persist
if able to migrate as sea levels rise
versus those areas where the
geology/conditions are such that the
continued presence of beaches in such
areas is unlikely.
b) b) Goals and Actions. Describe the
overall vision for Pacifica’s coastline
(and each sub-area) over the short-,
medium-, and long-term horizon. This
vision shall relate to the opportunities
and constraints identified above and
shall include specific goals and actions
for protection of public access and
coastal resources and minimization of
the Program needs to be certified.

This program is meant to
compliment the Coastal Access and
Resilience Program, associated with
the Special Shoreline Resiliency
Areas.

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Packet Pg. 795 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
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City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification coastal hazard risks. The Program shall
provide requirements for adapting
existing and future development,
including public and private structures,
community infrastructure, coastal
accessways, and other shoreline area
development to meet specific goals in
line with the overall vision of the City’s
shoreline (and each sub-area),
including as such objectives may differ
by sub-areas. Strategies to consider
shall include but are not limited to
sediment management, beach
nourishment, green infrastructure,
shoreline protection structures,
elevation of development, structural
modifications, and removal of
development as part of a Transfer of
Development Rights Program (Policy
CR-I-7) or other voluntary process for
property owners. Additionally, the
Program shall identify the timeline over
which different options may be
applied, including how different
strategies would be phased over time,
and shall explicitly define triggers for
when different adaptation options
would need to be implemented. The
Program shall also describe the policy
options (e.g., land use and zoning
requirements, development approval
conditions, deed restrictions, design
guidelines, etc.), specific projects, and
funding mechanisms necessary to
ensure adaptation actions are carried
out.
c) Special Shoreline Resilience Areas.

Considering the existing and future
shoreline conditions and the City’s
goals and actions described in parts (a)
and (b) above, evaluate phased
adaptation approaches for the Special
Shoreline Resilience Areas. Consider the extent to which shoreline protection structures may continue to
be the preferred adaptation approach
or whether alternatives may better
achieve City goals and result in
preferred coastal resource outcomes.

Furthermore, analyze the ability of the
shoreline protection structures to

4.d
Packet Pg. 796 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
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and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification withstand coastal hazard conditions
over time as sea levels rise, the
feasibility and costs of anticipated
maintenance activities, any anticipated
augmentations or replacement that
may be necessary over time as sea
levels rise, and any threshold hazard
conditions beyond which the shoreline
protection structures may not be able
to function and the associated
adaptation measures that would be
necessitated for the development that
relies on the shoreline protection
structures.
d) Sandy Beach Areas. The City shall
identify all sandy beach areas that
provide for associated recreational
opportunities, including but not limited
to Sharp Park south of the Pacifica pier,
southern Rockaway Beach, and Pacifica
State Beach. For areas where public
beach access has already been or is
likely to be limited and eventually lost
due to the presence of development
that prevents natural beach
formation/migration, the Program shall
focus on strategies that will result in
the removal of development to allow
for natural beach migration processes.

The Program for these sandy beach
areas (broken down by each sub-area
as well as overall) shall also include the
following:
i. Minimum Sandy Beach Widths. An
analysis of the minimum width of
sandy beach necessary to maintain
optimum public recreational access
and habitat function. This analysis shall
include considerations of daily tidal
range, seasonal erosion, and short-
term, storm- driven erosion when
determining optimum beach widths.

Additionally, the analysis shall assess
the types of adaptation strategies,
including but not limited to sediment
management, beach nourishment, and
removal of development (subject to
voluntary mechanisms available to
property owners, as described above),
along with appropriate triggers for
when different adaptation strategies

4.d
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and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification should be implemented to ensure that
minimum sandy beach widths are
maintained over time as sea levels rise.
ii. Sandy Beach Monitoring. The
Program shall include monitoring
protocols for the width of the beach as
well as recreational access, sandy
beach use, and habitat values
throughout the year and over time.

Such monitoring protocols shall identify
and track locations, times, and
durations throughout the year when
the sandy beach is too narrow to be
adequate for public recreation and/or
lateral access. Such monitoring will
ensure that the minimum beach width
established through the analysis above
is adequate for maintaining public
access and coastal resource values and
will provide the necessary information
for when adaptation triggers are met,
as described below.
iii. Sandy Beach Adaptation. The
Program shall identify the suite of
actions and programs that will be
implemented over time to maintain
sandy beach utility. The Program shall
also include explicit triggers for
sediment management, beach
nourishment, voluntary development
removal, and/or alternative strategies
that are designed to ensure that the
identified minimum sandy beach width
is maintained. The Program shall
identify “maintenance” triggers for
when beach nourishment or related
strategies to protect sandy beach areas
should occur as well as “adaptation”
triggers for when new adaptation
strategies will have to be implemented
in order to preserve beach recreational
access as sea levels rise and erosion
worsens.
iv. Mitigation. The Program shall
include provisions designed to offset
loss of sandy beach area, including
application of complementary
provisions for offsetting such losses

4.d
Packet Pg. 798 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
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City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification through enhancements in other
beach/shoreline areas in the City if
applicable.
e. Alternative Access. Where geologic
conditions or land use patterns and
shoreline armoring approaches will
limit the ability of sandy beaches to
persist (even without the presence of
development and shoreline protection
structures), the Program shall identify
options to allow for alternative types of
shoreline access. Such options may
include, but are not limited to, vertical
access to rocky shorelines or to the
ocean, lateral access along blufftops or
as part of shared vertical seawalls,
viewing platforms, and parks. The
Program shall identify preferred
locations for such features and tools
for ensuring such features are
constructed and maintained (e.g.
conditions of approval, shoreline
protection structure design
requirements, acquisition of easements
or other areas, voluntary removal of
development, etc.). Additionally, the
Program shall identify and describe
how such features should be adapted
and modified over time as sea levels
rise to ensure access is maintained
over time.
f) Funding Opportunities.

Identification of potential funding
opportunities to support short-,
medium-, and long-term adaptation
options. This shall include funding for
implementation of specific adaptation
projects (e.g. sediment management,
beach nourishment, green
infrastructure, habitat restoration,
development removal, etc.);
construction of public access features;
purchase of deed restrictions,
easements, or similar interests; and
structural buyouts and related
opportunities for acquisition and
removal of structures encroaching
within the established sandy beach
areas. Potential funding opportunities

4.d
Packet Pg. 799 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
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and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification may include in-lieu fees (including
those generated from mitigation for
shoreline protection structures per
Policy CR-I-34), grants, state/federal
funds, and GHADs/CSAs. Opportunities
to integrate adaptation strategies with
other planning processes (e.g., Local
Hazard Mitigation Plans, Capital
Improvement Plans, Climate Action
Plans, etc.), including in order to
leverage funding options, shall also be
explored.
g) GHADs/CSAs. Identification of
measures necessary to support
creation of Geologic Hazard Abatement
Districts, City Service Areas, or other
similar entities involving one or more
sections of the coastline, as a preferred
mechanism for implementation of
Shoreline Adaptation Program (and
related LCP amendment) requirements.
6 6.8 CR-I-5:

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

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

Deleted CCC suggested modification requires
LCP amendment to incorporate
shoreline mitigation program
6 6.8A CR-I-7
Transfer of
Developmen
t Rights
Program
Use the City’s transfer of development rights (TDR)
ordinance to relocate development rights from Coastal
Vulnerability zones (sending sites) to receiving sites
outside of Coastal Vulnerability zones. Identify areas
where densities and heights may be increased using
TDR credits, including to facilitate affordable housing.

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

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

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

The City will pursue opportunities to preserve ,
protect, or relocate critical local transportation
infrastructure, or provide alternative access, to
mitigate against isolation and economic loss,
and to ensure public safety, while avoiding (and
where unavoidable minimizing and mitigating)
impacts to coastal resources, including public
access and recreation, to the maximum extent
feasible, and being consistent with prior permit
conditions and/or legal obligations pursuant to
the California Coastal Act.

The City will pursue opportunities to preserve,
protect, or relocate critical local transportation
infrastructure, or provide alternative access, to
mitigate against isolation and economic loss, and to
ensure public safety, while avoiding (and where
unavoidable minimizing and mitigating) impacts to
coastal resources, including public access and
recreation, to the maximum extent feasible, and
being consistent with prior permit conditions
and/or legal obligations pursuant to the California
Coastal Act.

City staff alternative modification
would delete the word “prior,”
which clarifies that a permit must be
obtained and can be modified
through the appropriate approval
process over time.

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

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

The City will preserve, protect, or relocate
hazard prone infrastructure to maintain critical
services and protect coastal resources, including
if required by prior permit conditions and/or
legal obligations pursuant to the California
Coastal Act. Preservation/protection in situ with
shoreline armoring shall be required to meet
the requirements of Policies.

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

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

City staff alternative modification
would delete the word “prior,”
which clarifies that a permit must be
obtained and can be modified
through the appropriate approval
process over time.
6 6.10A CR-I-13:

LHMP
Alignment
The City will coordinate its departments and programs
to align the Local Hazard Mitigation Plan (LHMP) with
the LCP to ensure proactive, coordinated and
streamlined adaptation efforts and response to future
coastal hazards. The City shall leverage FEMA funding
opportunities for hazard mitigation and other related
funding mechanisms to implement the Sea Level Rise
Adaptation Plan as expressed in the general and subarea Coastal Resilience policies.

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

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

Shoreline
Protection
Structures
N/A Shoreline Protection Structures. Shoreline
protection structures shall be avoided except
that existing shoreline protection structures
may be maintained or new shoreline protection
structures constructed to protect existing
structures in danger from erosion if found to be
the least environmentally-damaging alternative,
impacts to beach, public access and recreation,
and other coastal resources are fully mitigated
consistent with CR-I-5 and CR-I-59, and
compliant with any prior permit conditions
and/or legal obligations pursuant to the
California Coastal Act . Allow shoreline
protection structures for the public road and
sewer line existing structures if necessary and
consistent with Policies CR-I-56 and CR-I-57,
other LCP policies, and the Coastal Act. New
development on blufftops shall comply will all
LCP setback policies, including CR-I-44.

Deleted
An additional modification deletes
this that was a CCC suggested
modification.
6 6.12 CR-I-15:

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

Repeat as necessary. Mitigate all adverse
impacts and monitor effectiveness over time.

In coordination with the California Coastal
Commission and other permitting agencies (e.g.,
State Lands Commission, U.S. Army Corps of
Engineers), the City shall evaluate a beach
nourishment program, in conjunction with sand
retention structures (see artificial headlands
concept in the Adaptation Plan) as described in CRI-55, to reduce shoreline protection structure maintenance requirements and maintain beaches
of at least 100 feet in width on average, consistent
with other LCP policies and the Coastal Act. The
beach nourishment program will need to be
evaluated to be the least environmentally
CCC suggested modification was an
attempt to organize the document
by taking several policies in the
subarea sections related to Beach
Nourishment and putting them in
Section 6.5 Coastal Resiliency
Policies to apply to the entire Coastal
Zone. However, City staff proposes
an alternative modification that is
more inclusive of all the language
that is included in the 2020 Revised
Certification Draft related to Beach
Nourishment by deleting CR-I-55 and

4.d
Packet Pg. 801 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
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and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification damaging feasible alternative and will include
measures to protect water quality and to avoid
(and where unavoidable to minimize and mitigate)
potential adverse coastal resource impacts,
including biological resource impacts, from
deposition of material, including measures such as
sand compatibility specifications, restrictions on
volume of deposition, timing or seasonal
restrictions, and identification of environmentally
preferred locations for deposits.
incorporating the language into CR-
1-15
6 6.12A CR-I-16:

Additional
Flood
Protection
Measures.

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

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

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

An additional modification that
reorganizes the document.

4.d
Packet Pg. 802 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
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and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.13A Subarea
Descriptions
The following policies and programs implement the
near-term sea level rise adaptation priorities for each sub-area in Pacifica, and identify mid- and long-term
adaptation measures, subject to feasibility and
monitoring concerns. These priorities were developed
based on existing conditions and existing/near term
vulnerabilities for each sub-area, as well as the City’s adopted goals for sea level rise adaptation.

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

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

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

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

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

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

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

In addition, the City should, when appropriate,
evaluate and pursue floodproofing infrastructure
that may be currently exposed to coastal erosion
and flooding to reduce the consequences of underperformance of protection measures, only if such floodproofing infrastructure is designed to
eliminate or mitigate adverse impacts on local
shoreline sand supply, consistent with LCP and
Coastal Act policies (CR-I-16).

CCC suggested modification amends
text to related to floodproofing
infrastructure. City staff is proposing
an alternative modification to clarify
requirements for sand supply.
6 6.13 Sub-area
Policies and
Programs
The City’s overall approach for new development is to
minimize or avoid current and projected future coastal
hazards through siting and design. At the same time,
managed retreat is not included in any of the near-term policies. Managed retreat would be reconsidered if
feasibility and monitoring warranted, as detailed in
Coastal Resilience Policies CR-I-3 and CR-I-4.

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

N/A CCC suggested modification deletes
introductory language specific to
managed retreat. Since the text is
not policy language, staff is not
proposing an alternative
modification.
6 6.14 N/A N/A The Special Resiliency Areas (SRA) include the existing shoreline protection structures in the
Rockaway Beach and West Sharp Park sub-areas.

These areas have existing development patterns

4.d
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Number
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and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification with significant amounts of Pre-Coastal Act
development, a mix of public streets and
infrastructure, land use prioritized by the Coastal
Act, and significant unified public coastal access, all protected by broad existing shoreline protection,
that warrant a unique policy approach. The
purpose of modifying policies applicable to this
area is to allow ongoing economic use and vitality
of property, provision of public services, operation
of visitor-serving uses, and protection of robust
coastal access for all persons including persons
with disabilities within a Special Resiliency Area
(SRA). The two SRA locations are identified in
Figure 6-2 and 6-3.

The Special Shoreline Resilience Area
policies are incorporated at the end
of the chapter.
6 6.15 N/A N/A
The Shoreline Management Plan is
intended to provide other types of
coastal enhancements and benefits,
such as increased coastal access,
while allowing the existing shoreline
protection structures in Rockaway
Beach and West Sharp Park to be
used in technical analysis of hazards
for development in those areas.

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

Shoreline
Protection
Structures
(0-1foot SLR
or 260 foot
offset from
bluff toe to
infrastructur
e)
Shoreline Protection Structures (0-1 foot SLR or 260-
foot offset from bluff toe to infrastructure). Shoreline protection structures shall be avoided except that the
existing shoreline protection structures may be
maintained or new shoreline protection structures
constructed to protect existing structures in danger
from erosion if found to be the least environmentallydamaging alternative, impacts are fully mitigated consistent with CR-I-5, and compliant with any prior
permit conditions and/or legal obligations pursuant to
the California Coastal Act . Allow shoreline protection structures for the public road and sewer line existing
structures if necessary and consistent with Policies CR-I56 and CR-I-57, other LCP policies, and the Coastal Act.

New development on blufftops shall comply will all LCP
setback policies, including CR-I-44.

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

Beach
Nourishment
(2 feet SLR or
260-foot
offset from
bluff toe to
Beach Nourishment (2 feet SLR or 260-foot offset from
bluff toe to infrastructure). Evaluate the feasibility of using beach nourishment, in conjunction with sand
retention structures (see artificial headlands concept in the Adaptation Plan) as described in CR-I-55, to reduce shoreline protection structure maintenance
requirements and maintain beaches of at least 100 feet
Deleted N/A CCC suggested modification
reorganizes the document.

4.d
Packet Pg. 804 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification infrastructur
e).
in width on average. If feasible and approved through a coastal development permit, secure funding and
implement as soon as possible. Repeat as necessary.

Mitigate all adverse impacts and monitor effectiveness
over time.
6 6.17A CR-I-17
Transfer of
Developmen
t Rights
(ongoing).

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

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

Shoreline
Protection
Structures
(0-1 foot SLR
or 220-foot
offset from
bluff toe to
infrastructur
e or
development )
Shoreline Protection Structures (0-1 foot SLR or 220-
foot offset from bluff toe to infrastructure or
development). Maintain existing or construct new
shoreline protection structures to protect existing
public infrastructure structures, including between Bill Drake Way and Manor Drive. Allow private property
owners to maintain existing or construct new shoreline
protection structures if allowed pursuant to Policies CR- I-56 and CR-I-57, and if consistent with prior permit conditions and/or legal obligations pursuant to the
California Coastal Act, and require mitigation of beach, public access and recreation and other coastal resource impacts, consistent with CR-I-5 or CR-I-59, as necessary.

Deleted N/A CCC suggested modification
reorganizes the document.
6 6.19 CR-I-19:

Beach
Nourishment
(0-1 foot SLR
or 220-foot
offset from
bluff toe to
infrastructur
e or
development )
Beach Nourishment (0-1 foot SLR or 220-foot offset
from bluff toe to infrastructure or development).

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

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

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

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

Private landowners may maintain, expand, or construct
new shoreline protection structures to protect existing structures in danger from erosion, consistent with CR-I2 and any prior permit conditions and/or legal obligations pursuant to the California Coastal Act.

Deleted N/A CCC suggested modification
reorganizes the document.

4.d
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Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.21 CR-I-21:

Beach
Nourishment
(0-2 feet SLR
or 70-foot
offset from
bluff toe to
development
or
infrastructur
e).

Beach Nourishment (0-2 feet SLR or 70-foot offset from
bluff toe to development or infrastructure). Evaluate
the feasibility of using beach nourishment, in
conjunction with sand retention structures (artificial
headlands concept), to reduce shoreline protection
structure maintenance requirements and maintain
beaches of at least 100 feet in width on average. If
feasible and approved through a coastal development
permit, secure funding and implement as soon as
possible. Repeat as necessary. Mitigate all adverse
impacts and monitor effectiveness over time.

Deleted N/A CCC suggested modification
reorganizes the document.
6 6.22 Flood Protection (1 feet SLR). Enable property owners to modify development structures (e.g., elevate a
residence) to manage impacts of wave run-up and
overtopping of bluff face.

Flood Protection. Enable property owners to
modify development structures to manage
impacts of wave run-up and overtopping of
bluff face provided such modifications are
consistent with the LCP and any prior permit
conditions and/or legal obligations pursuant to
the California Coastal Act.

Deleted City staff alternative modification
would delete the word “prior,”
which clarifies that a permit must be
obtained and can be modified
through the appropriate approval
process over time.

An additional modification removes
this policy to reorganizes the
document and condense the policies.
6 6.23 Sharp Park Golf Course. Strongly support the City and County of San Francisco’s maintenance of the Sharp
Park Golf Course berm and armoring, consistent with
the Coastal Development Permit issued by the
California Coastal Commission, including adaptation
planning for the course, and protecting public access.

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

Deleted Deleted CCC suggested modification deleted
the entire policy related to the Sharp
Park Golf Course. City staff is
proposing an alternative
modification that would keep a
policy related to the Sharp Park Golf
Course but would focus on public
access and resource enhancements.

An additional modification removes
this policy to reorganize the chapter.

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

Shoreline
Protection
Structures (0
feet SLR)
Shoreline Protection Structures (0 feet SLR). Maintain
existing or construct shoreline protection structures to protect existing public infrastructure structures if
consistent with Policies CR-I-56 and CR-I-57. Extend the Beach Boulevard seawall to the Sharp Park Golf Course
berm if consistent with Policies CR-I-56 and CR-I-57.

Deleted N/A CCC suggested modification
reorganizes the document.

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

Structure
Elevation (0-
2 feet SLR)
Structure Elevation (0-2 feet SLR). Maintain existing or construct shoreline protection structures if consistent with Policies CR-I-56 and CR-I-57 to limit wave
overtopping unless beach nourishment strategies are
effective in reducing wave run-up on the backshore.

Elevate development structures if consistent with Policy CR-I-61 as necessary to mitigate flood damage,
consistent with height limitations. Elevations of wave
run-up and associated development thresholds shall be
determined via a site-specific study.

Structure Elevation. Maintain existing or
construct shoreline protection structures if
consistent with Policies CR-I-56 and CR-I-57, and
with any prior permit conditions and/or legal
obligations pursuant to the California Coastal
Act to limit wave overtopping unless beach
nourishment strategies are effective in reducing
wave run-up on the backshore. Elevate
development structures if consistent with Policy
CR-I-61, and with any prior permit conditions
and/or legal obligations pursuant to the
California Coastal Act as necessary to mitigate
flood damage, consistent with height
limitations, determined via a site-specific study.

Deleted City staff alternative modification
would delete the word “prior,”
which clarifies that a permit must be
obtained and can be modified
through the appropriate approval
process over time.

An additional modification removes
this policy to reorganize the chapter
and condense the policies.
6 6.26 CR-I-26:

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

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

Flood
Protection (0
foot SLR)
(0 foot SLR) Deleted N/A CCC suggested modification
generalize policy and reorganized
the document.
6 6.27A CR-I-27 Flood
Protection
Evaluate and construct appropriate flood protection
measures, which may include a Clarendon Road
stormwater basin, pump station, and/or interior Sharp
Park Golf Course levee, to protect homes and
businesses from existing fluvial storm flood hazard
zone.

N/A Deleted Reorganization of chapter.
6 6.28 CR-I-28:

Flood
Protection (3
feet SLR).
(3 feet SLR) Deleted N/A CCC suggested modification
generalize policy and reorganized
the document.
6 6.28 CR-I-28 Flood
Protection
Evaluate the future need to construct a West Fairway
Park stormwater basin, pump station, and interior
Sharp Park Golf Course levee to protect western homes
from future coastal/fluvial flood hazard zone.

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

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

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

Deleted N/A CCC suggested modification
reorganizes the document.

4.d
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Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.30 CR-I-30:

Shoreline
Protection
(2-3 feet SLR,
or when
backshore
toe is 100
feet from
Highway 1).
(2-3 feet SLR, or when backshore toe is 100 feet from
Highway 1)
Deleted N/A CCC suggested modification
generalize policy and reorganized
the document.
6 6.30A CR-I-30:

Shoreline
Protection
Coordinate with Caltrans to evaluate the need for a
revetment or other appropriate shoreline protection for the Highway 1 embankment.

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

Public Access
(0 feet SLR).
(0 feet SLR) Deleted N/A CCC suggested modification
generalize policy and reorganized
the document.
6 6.31A CR-I-31:

Public Access
Plan and provide for enhanced public access, consistent with the City’s Shoreline Mitigation Program (CR-I-5).

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

Beach
Nourishment
/Public
Access (0
feet SLR).

Beach Nourishment/Public Access (0 feet SLR). Plan and
implement beach nourishment for Rockaway Beach.

Monitor and measure performance and any reduction
of shoreline protection structure maintenance needs.

Establish mechanisms through the City’s Shoreline
Mitigation Program (CR-I-5) to receive and use beach
impact mitigation funds from other sub-areas of the
City.

Deleted N/A CCC suggested modification
reorganizes the document.
6 6.32A CR-I-33
Developmen
t Setbacks
(ongoing).

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

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

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

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

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

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

Deleted N/A CCC suggested modification
reorganizes the document.

4.d
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Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.34 CR-I-37:

Beach
Nourishment
(2 ft SLR or
100 foot
offset from
shoreline to
infrastructur
e).

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

Deleted N/A CCC suggested modification
reorganizes the document.
6 6.34A CR-I-36
Highway One
Protections
Coordinate with Caltrans to evaluate options for
protecting Highway 1, if necessary.

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

Flood
Protection (0
feet SLR).
(0 feet SLR) Deleted N/A CCC suggested modification
generalize policy and reorganized
the document.
6 6.35A CR-I-38:

Flood
Protection
Analyze need for floodwall along commercial property
to manage flooding from San Pedro Creek under
existing conditions with sea level rise allowance. Future flood studies that include climate-driven changes in
precipitation should inform any floodwall design.

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

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

Flood
Protection (2
feet SLR or
100-foot
offset from
shoreline to
infrastructur
e).
(2 feet SLR or 100-foot offset from shoreline to
infrastructure)
Deleted N/A CCC suggested modification
generalize policy and reorganized
the document.
6 6.36A CR-I-39:

Flood
Protection
Floodproof the Linda Mar pump stations (sewer and
stormwater) to mitigate future coastal storm flooding
vulnerabilities to wave run-up as necessary.

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

Groundwate
r
Managemen
t (0-2 feet
SLR).
(0-2 feet SLR) Deleted N/A CCC suggested modification
generalize policy and reorganized
the document.
6 6.37A CR-I-40:

Groundwate
r
Managemen t
Begin groundwater monitoring to determine needs for
dewatering wells in the lowest portions of the West
Linda Mar neighborhood.

N/A Deleted Reorganization of chapter.

4.d
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Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.38 CR-I-41:

Shoreline
Protection
Structure
Upgrades.

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

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

Flood
Protection
(0-1 feet
SLR).
(0-1 feet SLR) Deleted N/A CCC suggested modification
generalize policy and reorganized
the document.
6 6.38A CR-I-42:

Flood
Protection
Allow private property owners to raise homes and other
development structures above wave run-up hazards if
consistent with Policy CR-I-61, consistent with height
limitations.

N/A Deleted Reorganization of chapter.
6 6.40 CR-I-19:

Technical
Reports.

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

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

N/A CCC suggested modification amends
the text to make the policy
applicable to Coastal Vulnerability
Zones, instead of shoreline
properties.
6 6.41 CR-I-19:

Technical
Reports.
• consider the impacts from the med-high projection
(CalNRA & OPC 2018) of sea-level rise for the
anticipated duration of the proposed development;
• consider the impacts from the med-high
projection (CalNRA & OPC 2018; or similar
precautionary projections as reflected in future
updated statewide guidance) of sea-level rise
for the anticipated life of the proposed
development;
consider the impact from the intermediate-high
projection (CalNRA & OPC 2024; or similar
precautionary projections as reflected in future
updated statewide guidance) of sea-level rise for
the anticipated life of the proposed development
CCC suggested modification amends
the text to reflect that best available
science may change over time.
6 6.42 CR-I-19:

Technical
Reports.
• demonstrate that the development will avoid (or if
unavoidable, minimize) impacts from coastal hazards to
the maximum extent feasible; and
• demonstrate that the development will avoid
(or if unavoidable, minimize) impacts from
coastal hazards for the anticipated life of the
proposed development without reliance on any
existing or future shoreline protection devices;
demonstrate that the development will avoid (or if
unavoidable, minimize) impacts from coastal
hazards for the anticipated life of the proposed
development without reliance on any existing or
future shoreline protection devices, except that
development behind Special Shoreline Resiliency
Areas may consider CR-I-38, CR-I-39 and CR-I-41.

CCC suggested modification reflects
language from the Sea Level Rise
adopted policy guidance. City staff is
generally in support of the
modification; however, staff is
proposing an alternative
modification to address the Special
Shoreline Resiliency Areas. The
alternative modification will give the
SRA the ability to use the existing
shoreline protections structures
when analyzing coastal hazards
impacts.
6 6.43 CR-I-19:

Technical
Reports.

N/A • demonstrate that the factor of safety for
blufftop development will be greater than or
equal to 1.5 for static conditions and greater
than or equal to 1.1 for seismic conditions; and
for blufftop and/or shoreline development, be set
back a sufficient distance from the blufftop edge or
highest predicted water line, accounting for wave
runup, highest astronomical tide, storm surge, and
other relevant factors (not less than 25 feet, or as
determined by site-specific conditions) to avoid
coastal hazard risks to the maximum degree
CCC suggested modification adds
clarifying language related to safety
requirements.

4.d
Packet Pg. 810 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification possible while ensuring stability and structural
integrity in light of potential erosion and other
coastal hazards, where such minimum required
setback shall be the distance necessary for all
structural development (including any decks,
fences, patios, arbors, and other ancillary
development, and generally not including native
landscaping, minor grading for
landscaping/restoration purposes, and other
similar non-structural development) to stay inland
of a line that identifies the future predicted
location of the blufftop edge or highest predicted
water line, accounting for wave runup, highest
astronomical tide, storm surge, and other relevant
factors, accounting for expected erosion and a bluff
stability factor of safety of at least 1.5 for static
conditions and at least 1.1 for seismic conditions
(where K=0.15) or sea level rise and other climate
change impacts as applicable; and
6 6.44 CR-I-20:

Siting and
Design.

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

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

Development in Coastal Vulnerability Zones shall be
sited, designed, and setback from the blufftop
and/or shoreline to be safe from erosion, bluff
failure, wave run-up, flooding and other coastal
hazards for at least 100 years the anticipated life of
the development or in accordance with CR-I-19,
without shoreline protection, considering projected
sea level rise and other climate change effects to
be determined from best available science and
current guidance at the time of approval of the
proposed development, as demonstrated by sitespecific analyses and/or technical reports. Coastal development permit approvals shall prohibit
shoreline protection structures for the authorized
development, require the property owner to
record an acknowledgement that the development
does not qualify as an existing structure entitled to
construction of a shoreline protection structure
under Coastal Act Section 30235, and any other
laws, that waive any rights to such protection
structures that might exist, and that, where
necessary, requires a removal and restoration plan,
including bonding for large projects, to avoid future
shoreline protection structures or project failure.

However, behind Special Shoreline Resiliency Areas
development may consider CR-I-38, CR-I-39, and
CR-I-44.

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

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

4.d
Packet Pg. 811 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.45 CR-I-21:

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

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

New Proposed Modification based on Del Norte
Co. Risk Disclosure:

As a condition of coastal permit approval for new
development in an area subject to current or future
hazards in Coastal Vulnerability Zones or Tsunami
Inundation Zones (Figure 6-2), applicants shall be
required to acknowledge and agree, and private
applicants must also record a deed restriction on
the property to acknowledge and agree:
1) that the development is located in an hazardous
area subject to current or reasonably foreseeable
future coastal hazards, or an area that may become
hazardous in the future;
2) that the applicant permittee assumes the risks of
injury and damage from such coastal hazards in
connection with the permitted development;
3) that the applicant permittee unconditionally
waives any claim of damage or liability against the
County of Del NorteCity of Pacifica, and the Coastal
Commission if the permit is appealed, its officers,
agents, and employees for injury or damage from
such coastal hazards;
4) that the applicant permittee indemnifies and
holds harmless the County of Del NorteCity of
Pacifica, and the Coastal Commission if the permit
is appealed, its officers, agents, and employees
with respect to approval of the project against any
and all liability, claims, demands, damages, costs
(including costs and fees incurred in defense of
such claims), expenses, and amounts paid in
settlement arising from any injury or damage due
to such coastal hazards;
5) that the permittee waives any rights that might
exist under applicable law for shoreline protection
structures for the duration the permitted
development is present on the property;that,
except for coastal-dependent structures, the
applicant has no rights under Coastal Act Section
30235 and related LCP policies to shoreline
armoring in the future;
6) that sea level rise could render it difficult or
impossible to provide services to the site (e.g.,
maintenance of roadways, utilities, sewage or
water systems), thereby constraining allowed uses
of the site or rendering it inoperable or
uninhabitable;
7) (for structures not already located on public trust
lands) that the boundary between public land
(tidelands) and private land may shift with rising
seas, the structure may eventually be located on
public trust landslands impressed with a public
City staff discussed using the City of
Del Norte Co. Risk Disclosure, and
CCC staff agrees with modifying the
Coastal Hazards Risk Disclosure using
the Del Norte Co. Crescent City
Harbor segment LUP language as a
starting point, however there are
some details that are relevant to
Pacifica but not Crescent City (and
vice versa) that CCC staff continue to
feel are important to include. These
edits are included in the Draft
alternative modifications for CR-I-21.
(The previously considered policy is
included below to facilitate
comparison of the old and new
policy language.)

4.d
Packet Pg. 812 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification trust interest, the development approval does not
permit encroachment development to be located
onto public trust landsuch lands, any development
that comes to be located on such lands except for
coastal-dependent and/or public trust uses, any
future encroachment must be removed unless the
Coastal Commission determines that the
encroachment is legally permissible pursuant to the
Coastal Act and authorizes it to remain, and any
future encroachment would also be subject to the
State Lands Commission’s (or other trustee
agency’s) leasing approval; and 8) that the structure
may be required to be removed or relocated and
the site restored, at the property owner’s expense,
if it becomes unsafe for occupancy or use due to
coastal hazards, including as outlined above; when
coastal hazards would necessitate construction of a
shoreline protection structure to ensure safe
occupancy of the development, and/or as part of
shoreline protection structure repair/maintenance
if the development is not permitted to obtain
shoreline protection; or in response to certain
defined triggers identified in the LCLUP and Implementing Programs and/or as identified by the terms and conditions of the CDP.

Previous Policy:

As a condition of coastal permitCoastal
Development Permit approvals of for new
development in Coastal Vulnerability Zones or
Tsunami Inundation Zones (Figure 6-2),
applicants shall be required to acknowledge and
agree, and private applicants must also record a
deed restriction on the property to acknowledge
and agree: the property owners of all affected
properties to record deed disclosure against all
such properties prior to issuance of coastal
development permits for the development wherein
the property owners acknowledge and agree, on
behalf of themselves and all successors and assigns
that they • that the development is located in an area
subject to current or reasonably foreseeable
future coastal hazards; 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,

4.d
Packet Pg. 813 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification and the interaction of same, and all as impacted
by sea level rise; • that the permittee assumes the risks assume and accept the risks to themselves and
their properties of injury and damage from such
coastal hazards in connection with the permitted
development; • that the permittee unconditionally waive s
any claim of damage or liability against the City,
and the Coastal Commission if the permit is
appealed, and its officers, agents, and
employees, for injury and/or damage from such
coastal hazardsin connection with the permitted
development;
• that the applicant indemnify indemnifies
and holds harmless the City, and the Coastal
Commission if the project is appealed, and its
officers, agents, and employees with respect to
the City’s approval of the project development
against any and all liability, claims, demands,
damages, costs (including costs and fees incurred
in defense of such claims), expenses, and
amounts paid in settlement arising from any
injury and/or damage due to such coastal
hazardsin connection with the permitted
development, including in terms of the approval
or issuance of the coastal permit, the
interpretation and/or enforcement of coastal
permit terms and conditions, or any other matter
related to the coastal permit;
• that sea level rise could render it difficult or
impossible to provide services to the site
acknowledge public funds may not be available in
the future to repair, maintain, and/or continue to
provide infrastructure and related services to the
property (e.g., maintenance of roadways, and
utilities, sewage or water systems), thereby
constraining allowed uses of the site or and that
the occupancy of structures may be prohibited if
such services are no longer available to serve the
development, including where sewage disposal
and/or water systems are rendered rendering it
inoperable or uninhabitable;
• that the boundary between public land
(tidelands) and private lands may shift with rising
seas, the structure may eventually be located on
lands impressed with public trust interest , the
approval does not permit development to be
located on such lands, any development that
comes to be located on such lands must be
removed unless the Coastal Commission

4.d
Packet Pg. 814 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification determines that the encroachment is legally
permissible pursuant to the Coastal Act and
authorizes it to remain, and any future
encroachment would also be subject to the State
Lands Commission’s (or other trustee agency’s)
leasing approvalwaive any rights that might exist
under applicable law for shoreline protection
structures for the duration the permitted
development is present on the property; and
• acknowledge the development may need
to be removed and the site restored in response
to future hazard conditions and/or certain
defined triggers identified in the LCLUP and
implementing Programs and/or as identified by
the terms and conditions of the CDP including
when deemed unsafe, if land comes to be
impressed with a public trust interest, when
within 10 feet of the blufftop edge, when within
10 feet of the mean high tide line, when no
longer served by necessary
utilities/infrastructure, when coastal hazards
would necessitate construction of a shoreline
protection structure to ensure safe occupancy of
the development, and/or as part of shoreline
protection structure repair/maintenance if the
development is not permitted to obtain shoreline
protection; and • that the structure may be required to be removed or relocated and the site restored, at
acknowledge any adverse effects to property
caused by the approved development shall be
fully the responsibility of the property owner’s
expense, if it becomes unsafe for occupancy or
use including any cost associated with abatement
and/or future relocation/removal of structures
due to coastal hazards, including as outlined
above; when coastal hazards would necessitate
construction of a shoreline protection structure
to ensure safe occupancy of the development,
and/or as part of the shoreline protection
structure repair/maintenance if the development
is not permitted to obtain shoreline protection;
or in response to certain defined triggers
identified in the LCLUP and Implementation
Programs and/or as identified by the terms and
conditions of the CDP and acknowledge approval
of coastal development permits shall not
constitute a waiver of any public rights that may
exist on the affected properties (including but
not limited to the public’s right of access onto or
across the property), and such property owner

4.d
Packet Pg. 815 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification shall not use any such approval as evidence of a
waiver of any public rights that may exist on the
affected properties now or in the future.

Except that an applicant shall not be required to
record a deed restriction as described in this policy
if a site-specific geotechnical hazard analysis
prepared by a qualified professional licensed by the
State of California determines that the project site
would not be subject to the hazard(s) identified in
the Coastal
Vulnerability Zones and Tsunami Inundation Zone
for the Anticipated Life of the project.
6 6.45A CR-I-23 Bluff
Face
Developmen
t
Shoreline protection structures, grading, and landform
alteration on bluff faces are prohibited, except for the following:
• Public access structures where no feasible
alternative means of public access exists; and
N/A Development on bluff faces is prohibited, except
for the following:
• Native bluff landscaping; public
recreational access improvements (e.g.
stairways, paths, overlooks, ramps, etc.)
and critical public infrastructure (e.g. public
roads, public utility infrastructure, etc.)
where no feasible alternative means of
providing such
improvements/infrastructure exists; and
Clarifies policy.
6 6.46 CR-I-25:

Substantial
Modification
s to Existing
Structures.

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

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

Substantial Structural Modifications. When
proposed modifications to a structure constitute a
Substantial Structural Modification (SSM), as
defined, such proposed development shall correct
any existing legal nonconformities and shall be
undertaken consistent with the LCP and the Coastal
Act, including but not limited to Policies CR-I-19
and CR-I-20. Nonconformities related to noncoastal resource issues may be maintained at the discretion of the decision-making body so long as
they do not lead to significant impacts to coastal
resources.

CCC suggested modification requires
projects that meet the SSM
definition to correct any existing
legal nonconformities, in order to
the entire site to be compliant with
the LCP and Coastal Act. Staff is
generally in support; however, staff
is proposing an alternative
modification to address the Special
Resiliency Areas. The alternative
modification will give the SRA the
ability to correct only existing
nonconformities associated with
coastal hazards present on the site,
rather than a broader range of
potential LCLUP or zoning
nonconformities.
6 6.47 CR-I-27:

Habitat Sea
Level Rise
Migration
Buffers.

A sea level rise buffer area shall be added to require
new development habitat buffers if necessary to allow
for the migration of wetlands and other coastal habitats caused by sea level rise over the anticipated duration
(i.e., economic life) of the development. Habitats
include all wetlands, riparian, intertidal/shoreline and terrestrial environmentally sensitive habitat areas
(ESHAs) as defined by the Coastal Act. The sea level rise projection considered shall be determined for the type
of development from CalNRA and OPC (2018) guidance
or the latest update.

An additional sea level rise buffer area shall be
added to required habitat buffers if necessary
to allow for the migration of wetlands and other
coastal habitats caused by sea level rise over
the anticipated life of the development.

Habitats include all wetlands, riparian,
intertidal/shoreline and terrestrial
environmentally sensitive habitat areas (ESHAs)
as defined by the Coastal Act. The sea level rise
projection considered shall be determined
N/A CCC suggested modification would
require an additional seal level rise
buffer. Staff is generally in support of
the modification; however, staff is
proposing an alternative
modification to clarify that a buffer
area should include all the buffer
requirements.

During the May 23 discussion, City
Council directed staff to keep the

4.d
Packet Pg. 816 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification based on the type of development and current
State guidance.

CCC suggested modification and
remove the alternative modification.
6 6.47A CR-I-29
Subdivision
Limitations
Update the Zoning Ordinance to prohibit the division of shoreline property that creates hazardous or
unbuildable parcels due to erosion, bluff failure, wave run-up, flooding and other coastal hazards for at least 100 years without shoreline protection, considering
projected sea level rise and other climate change effects to be determined from best available science and
current guidance at the time of approval of the
proposed development. Only allow new lots to be
created if they can be developed without ever requiring shoreline protection for the development.

N/A Prohibit the division of shoreline property that
creates hazardous or unbuildable parcels due to
erosion, bluff failure, wave run-up, flooding and
other coastal hazards for at least 100 years without
shoreline protection, considering projected sea
level rise and other climate change effects to be
determined from best available science and current
guidance at the time of approval of the proposed
development. Only allow new lots to be created if
they can be developed without ever requiring
shoreline protection for the development.

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

Consider combining beach replenishment with groin
construction to maintain beaches and protect
development. (see subarea policies).

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

Consider combining beach replenishment with
groin construction to maintain beaches and protect
development.

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

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

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

Delete and incorporated into CR-I-1 CCC suggested modification clarified that beach nourishment needs to be
in compliance with the Coastal Act.

City staff proposes an alternative
modification that would delete CR-I55 and incorporate the language into CR-I-16.
6 6.49 CR-I-31:

Existing
Shoreline
Protection
Structures
Except as may be otherwise provided in the LCP subarea policies, legally permitted shoreline protection structures may be repaired and maintained, as
supported by Section 30235 of the Coastal Act, subject
to all coastal development permit requirements
Except as may be otherwise provided in the LCP
sub-area policies, legally permitted shoreline
protection structures may be repaired and
maintained, as supported by Section 30235 of
the Coastal Act, subject to all coastal
Legally permitted shoreline protection structures
may be repaired and maintained, as supported by
Section 30235 of the Coastal Act, subject to all
coastal development permit requirements
(including those associated with the construction of
CCC suggested modification revises
the policy to align with other
provisions in the LCP, Coastal Act,
and CCC policy. Staff is not proposing
alternative modification. Minor

4.d
Packet Pg. 817 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification (including those associated with the construction of the structure and/or prior repair and maintenance
episodes) until the development they are protecting is
removed or no longer requires shoreline protection
structures, at which time the shoreline protection
structure shall be reevaluated for consistency with the LCP and removed if no longer necessary. Activities
considered “repair and maintenance” shall not result in any enlargement or extension of the shoreline
protection structure, or any seaward encroachment or
impairment of public trust resources, and shall provide mitigation for any new coastal resource impacts not
previously or otherwise mitigated, including through
the City’s Shoreline Mitigation Program (CR-I-5) and/or Policy CR-I-59.
development permit requirements (including
those associated with the construction of the
structure and/or prior repair and maintenance
episodes) until the development they are
protecting is removed or redeveloped pursuant
to the definition of a Substantial Structural
Modification (SSM) or no longer requires
shoreline protection structures, at which time
the shoreline protection structure shall be
reevaluated for consistency with the LCP,
removed if no longer necessary and/or allowed,
and the area restored. Activities considered
“repair and maintenance” shall not result in any
enlargement or modification to the shoreline
protection structure, or any replacement of
materials in excess of 50%, or any seaward
encroachment or impairment of public trust
resources, and shall provide mitigation for any
new coastal resource impacts not previously or
otherwise mitigated, including through the
City’s Shoreline Mitigation Program (CR-I-5)
and/or Policy CR-I-59.
the structure and/or prior repair and maintenance
episodes) until the development they are
protecting is removed or redeveloped pursuant to
the definition of a Substantial Structural
Modification (SSM) or no longer requires shoreline
protection structures, at which time the shoreline
protection structure shall be reevaluated for
consistency with the LCP, removed if no longer
necessary and/or if found to be inconsistent with
the LCP by the reevaluation, and the area restored.

Activities considered “repair and maintenance”
shall not result in any enlargement or modification
to the shoreline protection structure, or any
replacement of materials in excess of 50%, or any
seaward encroachment or impairment of public
trust resources, shall provide mitigation for any
new coastal resource impacts not previously or
otherwise mitigated, including through the City’s
Shoreline Adaptation Program (CR-I-5), Coastal
Access and Resilience Program (CR-I-44) and/or
Policy CR-I-34, shall minimize impacts, and must be
found to be the least environmentally damaging
feasible alternative.
revision to clarify policy and correct
references.
6 6.50 CR-I-31:

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

Deleted Modifications to existing shoreline protection
structures which fall within the limitations of an
exclusion contained in the definition of Substantial
Structural Modification shall be considered to be
allowed without the above-mentioned
considerations.

CCC suggested modification deletes
text related to modifications to
existing structures. City staff is
proposing an alternative
modification to clarify that
maintenance and modification of
existing shoreline protection
structures is allowed.
6 6.51 CR-I-32: New
Shoreline
Protection
Structures
Shoreline protection structures, including revetments,
breakwaters, groins, seawalls, cliff retaining walls, deep piers and caissons, and other such construction that
alters natural shoreline processes shall be permitted
consistent Section 30235 of the Coastal Act and with
the LCP’s sub-area policies only when required to serve coastal-dependent uses or protect existing structures or public beaches in danger from erosion, when designed
to eliminate or mitigate adverse impacts on local
shoreline sand supply.

Shoreline protection structures, including
revetments, breakwaters, groins, seawalls, cliff
retaining walls, deep piers and caissons, and
other such construction that alters natural
shoreline processes shall only be permitted if
consistent Section 30235 of the Coastal Act and
with the LCP’s sub-area policies, and only when
required to serve coastal-dependent uses or
protect existing structures or public beaches in
danger from erosion, when there is no less
environmentally damaging feasible alternative
and when designed to avoid, and where
unavoidable, minimize to the maximum extent
feasible adverse impacts on local shoreline sand
supply and other coastal resources, where
unavoidable coastal resource impacts are
required to be commensurately mitigated.

Shoreline protection structures, including
revetments, breakwaters, groins, seawalls, cliff
retaining walls, deep piers and caissons, and other
such construction that alters natural shoreline
processes shall only be permitted if consistent with
Section 30235 of the Coastal Act, and only when
required to serve coastal-dependent uses or
protect existing structures (including existing
critical infrastructurepublic roads and sewer lines if
necessary) or public beaches in danger from coastal
hazards erosion, when there is no less
environmentally damaging feasible alternative and
when designed to avoid, and where unavoidable,
minimize to the maximum extent feasible adverse
impacts on local shoreline sand supply and other
coastal resources, where unavoidable coastal
resource impacts are required to be
commensurately mitigated.

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

4.d
Packet Pg. 818 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
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and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.52 CR-I-33:

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

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

N/A CCC suggested modification amends
the policy related to time limits on
shoreline protection structures. Staff
is generally in support of the
modification, if alternative
modifications to other policies
related to the Special Resiliency
Areas (SRAs) remain.
6 6.53 CR-I-34:

Mitigating
Impacts of
New
Shoreline
Protection
Structures.

This policy may be met through compliance with the
City’s Shoreline Mitigation Program (CR-I-5).

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

Correction to references
6 6.54 CR-I-36:

Emergency
Shoreline
Protection
Structures
N/A N/A In cases of emergency, an emergency shoreline
protection structure may only be approved on a
temporary basis, and only under the condition that
the structure is required to be removed unless a
regular CDP is approved for retention of the
structure. In such cases, a complete CDP application
shall be required to be submitted within 60 days
following construction of the temporary emergency
shoreline protective structure, unless an alternate
deadline is authorized by the Planning Director for
good cause, including continued good faith efforts
toward submittal of such application. Any such
temporary emergency shoreline protective
structure shall be sited and designed to be the
minimum necessary to abate the identified
emergency, and to be as consistent as possible with
all LCP shoreline protective structure standards,
including in terms of avoiding coastal resource
impacts to the maximum possible extent.

Mitigation for impacts will be required through the
regular CDP process, including mitigation
commensurate with the duration of impacts caused
by the emergency temporary structure. The City
shall notify the Executive Director upon receipt of a
request for an emergency shoreline protective
structure within the City’s CDP jurisdiction.

New policy.
6 6.55 CR-I-37:

Sharp Park
Golf Course
N/A N/A Strongly support the City and County of San
Francisco’s ability to provide public access along the
coast, protect Environmentally Sensitive Habitat
Area, and provide flood protection.

Reorganization of chapter
6 6.56 CR-I-38:

Public
Infrastructur
e Along the
Shoreline in
N/A N/A Public infrastructure (e.g., public roads, sidewalks, parking areas, accessways, water and sewer
infrastructure) on the immediate oceanfront of the
Special Shoreline Resilience Areas mapped in
Figures 6-3 and 6-4 shall be consistent with all LCP
SSRA policy

4.d
Packet Pg. 819 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Special
Resiliency
Areas
provisions except that, to establish the safety and
stability of the proposed development, such
development may rely on a shoreline protection
structure that is existing at the time of the
application and/or that is proposed in the same
permit application as the infrastructure itself.
6 6.57 CR-I-39:

Developmen
t Directly
Inland of
Public
Infrastructur
e in Special
Resiliency
Area
N/A N/A Notwithstanding Policy CR-I-2, development
located directly inland of the public infrastructure
on the immediate oceanfront of the Special
Shoreline Resilience Areas mapped in Figures 6-3
and 6-4 may rely on a shoreline protection
structure in that area that is existing at the time of
the permit application to help demonstrate that its
setbacks meet the requirements of Policies CR-I-19
and CR-I-20. In addition to meeting the
requirements of Policy CR-I-21, such development
shall be conditioned to require the applicant to
acknowledge that the development’s long-term
safety may be based in part on shoreline protection
structures located seaward of the development,
which may or may not be effective, and/or be
maintained, and/or be present in the future.
6 6.58 CR-I-40
Armoring in
Special
Resiliency
Areas
N/A N/A In the Special Shoreline Resilience Areas mapped in Figures 6-3 and 6-4, repair and maintenance,
enhancement, realignment, and
redevelopment/replacement of a shoreline
protection structure that is existing at the time of
the permit application, including minor extensions
in order to fill gaps or otherwise ensure the overall shoreline protection structure is effective may be approved when required to protect public
infrastructure (e.g., public roads, sidewalks, parking
areas, accessways, water and sewer infrastructure)
on the immediate oceanfront of the Special
Shoreline Resilience Areas mapped in Figures 6-3
and 6-4. Such shoreline protection structure must
comply with all relevant LCP policies except that it
may be approved regardless of whether such
shoreline protection structure is required to protect
a coastal dependent use, a public beach in danger
of erosion, or a structure that qualifies as an
"existing structure" within the meaning of Coastal
Act Section 30235. Any such shoreline protection
structure shall incorporate public access elements
into its design, be the least environmentally
damaging feasible design, and improve coastal
resource conditions relative to conditions that exist
at the time of permit approval (examples of
improved conditions could include restoring
intertidal habitat, enhancing public access, having a
smaller footprint than a shoreline protection

4.d
Packet Pg. 820 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification structure that already lawfully exists, enhancing
scenic and visual qualities of the area).
6 6.58 CR-I-41
Effective
Date of
Policies etc.

N/A N/A Policies CR-I-38, CR-I-39, and CR-I-40 shall only be of force and effect when and if, as
determined by the Coastal Commission’s
Executive Director: • In accordance with Policy CR
-I44,
the initial Coastal Access and Resilience
Program is developed and submitted for
Commission review, and • In accordance with Policy CR
-I-5,
the development of the Shoreline
Adaptation Program has been initiated,
including, at a minimum, that the City
has developed a public engagement
plan, workplan, timeline, and identified
funding for completion of the technical
studies and planning work.
6 6.59 CR-I-42
Suspension
of Policies
N/A N/A Policies CR-I-38, CR-I-39, and CR-I-40 shall be suspended, and shall have no further force and
effect during the period of suspension, upon
the occurrence of any of the following
conditions, as determined by the Coastal
Commission’s Executive Director:
• In accordance with Policy CR-I-43, if:
o the Coastal Access and
Resilience Program is not
certified by the Commission
within 15 months of
acceptance of the LCP
amendment for filing as
identified in Policy CR-I-41, or
o any of the CDP
applications that are
required every5 years
to implement projects
are not submitted in
complete form, or
o any of the projects required in the
Coastal Access and Resilience
Program are not
developed/implemented.
• In accordance with Policy CR-I-5, if:
o The City has not completed the
technical studies to accomplish
part (a) of the Shoreline
Adaptation Program within6

4.d
Packet Pg. 821 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification years of effective certification of
the Land Use Plan Amendment
that created the requirement for
the Shoreline Adaptation
Program (i.e., created Policy CR- I-5), or
o The City has not prepared a
Draft Shoreline Adaptation
Program within8 years of
effective certification of the
LUPA that created the
requirement for the Shoreline
Adaptation Program (i.e.,
created Policy CR-I-5), or
o The Coastal Commission has
not certified a Final Shoreline
Adaptation Program within 10
years of effective certification
of the LUPA that created the
requirement for the Shoreline
Adaptation Program (i.e.,
created Policy CR-I-5).

In the event that the Coastal Commission’s
Executive Director determines that the City has not
met one or more of the above conditions, the
Executive Director shall provide a preliminary
written determination to the City explaining that
one or more conditions set forth above have not
been met and that suspension of Policies CR-I-38,
CR-I-39 and CR-I-40 shall occur after fifteen working
days, unless the City submits written objections to
the preliminary determination and the Executive
Director concurs with the objections. The City may
submit to the Executive Director a written notice of
objection within seven working days of the date of
the preliminary determination. The Executive
Director will promptly review and either concur or
disagree, in writing, with any objection submitted
by the City prior to the fifteenth working day from
the date of the preliminary determination. The
period of suspension will end, and Policies CR-I-38,
CR-I-38 and CR-I-40 will once again become
effective, at the beginning of the fifth working day
after the Executive Director provides a written
determination to the City that all necessary
conditions have been satisfied.
6 6.60 CR-I-43: End
Date of
Policies CR-IN/A N/A Additionally, as of January 1, 2045, no new development may rely on Policies CR-I-38, CR-I-39,
or CR-I-40 , unless the Commission has certified an

4.d
Packet Pg. 822 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
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and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 38, CR-I-39,
CR-I-40.

LCP amendment extending that deadline. As of
January 1, 2045 (or such later date as specified in an
LCP amendment), development approved based on
Policies CR-I-38 and CR-I-39 that relied on a
shoreline protection structure to demonstrate
safety, stability, and adequate setbacks (including in
relation to the requirements of Policies CR-I-19 and
CR-I-20) shall become legal nonconforming and,
moving forward, a Substantial Structural
Modification to such development shall, in
accordance with Policy CR-I-25, be required to be
consistent with all LCP provisions, including but not
limited to Policies CR-I-2, CR-I-19, and CR-I-20
related to setbacks and safety without relying on
shoreline protection to establish safety, and Policy
CR-I-32 regarding approvable shoreline protection.
6 6.61 CR
-I-44:

Coastal
Access and
Resilience
Program.

N/A N/A The City shall develop a Coastal Access and
Resilience Program to ensure continued and
increased access to the coast, including as sea levels
rise. The Program shall include, but is not limited to, methods to maximize public access to and along
the coast despite sea level rise and address the
coastal resource impacts associated with shoreline
protection structures along the City’s shoreline,
including as required per Policy CR-I-34, and
impacts associated with the perpetuation of
shoreline protection structures within Special
Shoreline Resilience Areas allowed by Policies CR-I38, CR-I-39, and CR-I-40. The priority for such access benefits and mitigation shall be efforts/projects
designed to maintain and enhance sandy beaches
and public access to and along the City’s shoreline
in a manner that is most protective of coastal
resources and general public access utility. The
Program shall include, at a minimum, all of the
following: • A prioritized list of public access projects within the City’s Coastal Zone that can help
maximize access to the coast and serve as
required mitigation. Projects shall be
organized in terms of expected
implementation dates within 5-year
increments and shall be developed with full
community input. Some opportunities may
include enhancement of public recreational
access facilities (e.g., pathways, overlooks),
removal of existing armoring, nature-based
adaptation, beach nourishment, and
acquisition/conservation of properties
subject to coastal hazards. Potential
projects include but are not limited to:

4.d
Packet Pg. 823 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification • Enhanced public pathway system seaward of private development in the Rockaway
Beach area.
• Coordinated vertical accessways,
landscaping, benches, picnic tables, bicycle
racks, garbage and recycling receptacles,
doggie mitt stations, and enhanced signage
in the Sharp Park area.
• The following projects listed in the
program: Rockaway to Pacifica State Beach
Trail Rehabilitation, Rockaway Beach
Parking Structure, Rockaway Parking Area,
Beach Boulevard Promenade Park
Improvements, Sharp Park Priority
Development Area (PDA) Access Pedestrian
Improvement project
• A timeline and benchmarks for
implementation of identified projects,
including measures by which progress and
success can be measured over time, as well
as necessary monitoring and tracking. At a
minimum, projects shall be designed to be
implemented in at most 5 year increments.
• Identification and development of a funding
mechanism (or mechanisms) sufficient to
cover all identified projects. Such
mechanisms may include, but are not
limited to:
• Development of a protocol for requiring
mitigation for development within Special
Shoreline Resilience Areas that is allowed to
rely on existing shoreline protection
structures pursuant to CR-I-38 and CR-I-39,
thus resulting in continued impacts from
that armoring.
• Formation of a GHAD, CSA, or similar. • State or Federal grant funding • Other funding mechanisms identified for adaptation planning and projects as
discussed in Policy CR-I-5.

An initial program shall be developed and should be
submitted as an amendment to the LCP by 3 years
from the date of LUP Update certification]. By 5

4.d
Packet Pg. 824 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification years from the date of Coastal Commission
approval of the initial Coastal Access and Resilience
Program (and every subsequent 5 years) the City
shall submit a complete CDP application to the
Coastal Commission, or where applicable the City
itself shall approve projects via City CDPs, to
implement projects identified in the Program. The
Program shall be monitored, evaluated, updated,
and resubmitted as an amendment to the LCP at
least every 10 years thereafter.
6 6.61 6.9 Costal
Flooding and
Other
Hazard
Standard
Policies
CR-I-61 Flood Risk Reduction. The City should, when
appropriate, evaluate and pursue, floodproofing of
infrastructure and other development in danger from
projected flooding by 2050. Allow and facilitate (if
feasible) private owners to floodproof development
structures, consistent with other LCP policies.

N/A Deleted Reorganization of chapter.

Glossary 7.1A Acronyms N/A N/A CSA: City Service Area Clarification Glossary 7.1B Acronyms N/A N/A SCS: Sustainable Communities Strategy Clarification Glossary 7.1 Anticipated
Life
N/A The period over which a development is
expected to be usable, with normal repairs and
maintenance, for the purpose for which it was
designed, typically a minimum of 75-100 years
for residential and commercial development
and a minimum of 100-150 years for critical
infrastructure.

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

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

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

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

4.d
Packet Pg. 825 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 1) From a distinct linear feature (e.g., a seawall,
road, or bluff, etc.);
2) From the inland edge of the further inland
beach berm as determined from historical
surveys, aerial photographs, and other records
or geological evidence; or
3) Where a beach berm does not exist, from the
further point separating the dynamic portion of
the beach from the inland area as distinguished
by vegetation, debris or other geological or
historical evidence.

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

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

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

N/A CCC suggested modification adds
clarifying language.

Glossary 7.4A Critical
Facilities
Critical Facilities: Includes hospitals and healthcare; emergency shelters; police and fire stations; water
supply and wastewater treatment; and energy
production facilities.

N/A N/A New definition proposed by City staff
and confirmed by CCC staff.

Glossary 7.4B Critical
Infrastructur
e
Critical Infrastructure: Includes transportation, such as highways, roads, railroads; water, such as wastewater,
stormwater, and water supply infrastructure; electrical; gas; and communication facilities.

N/A N/A New definition proposed by City staff
and confirmed by CCC staff.

Glossary 7.5 Developmen
t
On land, in or under water, the placement or erection of any solid material or structure; dis- charge or disposal of any dredged material or of any gaseous, liquid, solid, or thermal waste; grading, removing, dredging, mining, or
extraction of any materials; change in the density or
intensity of use of land, including, but not limited to, subdivision pursuant to the Subdivision Map Act
(commencing with Section 66410 of the Government
Code), and any other division of land, including lot
splits, except where the land division is brought about 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
N/A CCC suggested modification adds
new text to clarify terms used in
document and be consistent with
the Coastal Act.

4.d
Packet Pg. 826 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 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.
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.’
Glossary 7.6 Environment
al Justice
The fair treatment of people of all races, cultures, and incomes with respect to the development, adoption,
implementation, and enforcement of environmental
laws, regulations, and policies
The fair treatment and meaningful involvement
of people of all races, cultures, and incomes
with respect to the development, adoption,
implementation, and enforcement of
environmental laws, regulations, and policies
N/A The City’s General Plan consistency
changes eliminated this sentence
and the suggested modification is no
longer applicable. However, the
proposed CCC Suggested
Modification is consistent with the
Coastal Act and thus should remain.

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

Glossary 7.7A Mean-High
Tide Line
N/A N/A The intersection of the tidal plane of the mean high water with the shore. Determined by survey
prepared by a licensed professional land surveyor
based on field data collected within 12 months. The
survey must be conducted in consultation with and
approved by the California State Lands
Commission.

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

While the Coastal Act makes several
mentions of “mean high tide,” the
Coastal Act does not contain a
definition. Staff is recommending an
alternative modification to add a
new definition similar to Policy CR-I46.

4.d
Packet Pg. 827 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
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and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Glossary GP5 Mitigation This edit was added in October 2023 as part of the GP consistency changes. It replaced the definition with the following: As defined in Section 15370 of the State
Guidelines for Implementation of the California
Environmental Quality Act, mitigation includes:

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

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

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

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

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

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

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

Glossary GP6 Mitigation
Measure
This edit was added in October 2023 as part of the GP
consistency changes. It added the following: Action
taken to avoid, minimize, or eliminate environmental
impacts. Mitigation includes: avoiding the im-pact
altogether by not taking a certain action or parts of an action; minimizing impacts by limiting the degree or
magnitude of the action and its implementation;
rectifying the impact by repairing, rehabilitating, or
restoring the affected environment; reducing or
eliminating the impact over time by preservation and
maintenance during the life of the action; and
compensating for the impact by repairing or providing
substitute resources or environments.

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

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

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

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

Seaward of the base of coastal bluffs and/or at
or near the sandy beach/ocean elevation,
including as depicted in Appendix B (“Coastal
Zone Vulnerability Maps”) and denoted as
“wave run-up,” “storm flood area,” and “flood
prone area.”
N/A CCC suggested modification adds
clarifying language to be consistent
with CCC guidance
Glossary GP7 Special
Status
Species
Any species which is listed, or proposed for listing, as threatened or endangered by the U.S. Fish and Wildlife
Service (USFWS), National Marine Fisheries Service, or
California Department of Fish and Wildlife (CDFW)
under the provisions of the State and Federal
Endangered Species Act. It also includes any species
N/A Any species which is listed, or proposed for listing, as threatened or endangered by the U.S. Fish and
Wildlife Service, or 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
The definition was changed as a
General Plan Consistency change;
however, alternative modifications
were needed in order to comply with
the Coastal Act. Discussed at the
9/17/2024 meeting.

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Packet Pg. 828 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification designated by the USFWS U.S. Fish and Wildlife Service
as a “candidate” or “species of concern”, species
designated by CDFW as a “species of special concern”,
species that may be considered rare or endangered
pursuant to Section 15380(b) of the CEQA Guidelines, or species identified on California Native Plant Society’s Lists 1A, 1B, or 2, implying potential danger of
extinction
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.

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

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

Any physical improvement which modifies an
existing structure in any of the following ways:
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 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
ivii) an increase of the existing building
footprint equal to 50 percent or more;
but however excluding, but not limited to
alteration, removal, or replacement, of
nonstructural exterior components, such as
nonstructural: decorative
i) plywood roof sheathing;
ii) underlayment;
iii) siding;
iv) shingles;
v) other nonstructural roof materials;
vi) windows and doors (including garage
doors) that do not alter width or location;
CCC suggested modification deletes
text to be consistent with CCC
guidance. Staff is generally in
support of the modification;
however, staff is proposing an
alternative modification to clarify
that nonstructural elements and
waterproofing materials are not part
of the SSM definition.

Upon further discussion with CCC
staff, City staff agrees with the
removal of language referencing
subdivision (g) of Section 30610 of
Public Resources Code from the
exclusion language of the SSM
definition. This code provision within
the Coastal Act is applicable to
properties within the City and would
not equate to a SSM and thus does
not need to be included as an
exclusion in the SSM definition. CCC
staff prefers, and City staff agrees,
that this provision and definition not
be interpreted together. Staff is
proposing an alternative
modification, new Modification No.

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

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

4.d
Packet Pg. 829 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Chapter Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 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. vii) exterior
waterproofing/weatherproofing materials
viii) appliance installations and
replacements, such as water heaters,
generators, and solar panels, that do not
involve structural modifications;
x) 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.

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.

Glossary 7.11 Tsunami
Inundation
Zone
N/A N/A An area of likely tsunami inundation under a
tsunami scenario. The applicable tsunami scenario
should balance a reasonable probability of event
occurrence with a reasonable potential of the
tsunami event causing substantial loss of life and/or
damage to property. Such a tsunami scenario could
include, but is not necessarily limited to, 475-year
Average Return Period (ARP) event described in the
publication Probabilistic Tsunami Hazard Maps for
the State of California (Phase 2), California
Department of Conservation (2023).

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

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Packet Pg. 830 Attachment: Attachment D - Summary Table -w Alternative Mods (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Attachment E:

CCC responses to NCCWD requested modifications
This attachment summarizes the outcome of City staff’s discussion with CCC staff regarding the North Coast County Water District’s comments on the draft LCLUP.

1. At the City’s meeting with NCCWD on October 9, 2024, City representatives and NCCWD representatives agreed that having definitions of “critical infrastructure” and “critical facilities” in the LCLUP would be beneficial. CCC staff approved the following definitions to be included as proposed by City Staff:
o Critical infrastructure: Includes transportation, such as highway, roads, railroads; water, such as wastewater, stormwater, and water supply infrastructure; electrical; gas; and communication infrastructure.
o Critical facilities: Includes hospitals and healthcare; emergency shelters; police and fire stations; water supply and wastewater treatment; and energy production facilities.

Recommendation: City Staff agrees with these recommended modifications and they are included in the Redline Version of the LCLUP in Attachment B

2. The NCCWD’s comment letter includes numerous suggestions for revisions to existing policies in the draft LCLUP. City staff discussed these suggestions with CCC staff, and CCC staff agreed with the proposed changes to the following policies with minor edits (please note NCCWD memo referenced incorrect policy numbers and have been corrected below). The track changes are provided by CCC staff to the recommendations made by NCCWD.

LD-I-27 Public Service Priorities. Ensure that existing and planned public works facilities accommodate needs generated by development or uses permitted by the buildout allowances of this Land Use Plan or by the General Plan to serve the City’s non-coastal zone areas. Plan for the maintenance, operation, expansion and improvement to public works facilities considering threats from coastal hazards and avoid locating new or expanded public service works facilities in the Coastal Vulnerability Zone unless no feasible alternative exists. Support studies that evaluate the condition of critical infrastructure and critical facilities, especially public works infrastructure that has been identified as vulnerable to hazards. Studies shall include alternatives analyses for potential retrofit, improvements, relocation, or other considerations.

LD-I-28 Water Supply. Support North Coast County Water District in its efforts to develop sustainable, drought-proof local supplies. Support the Bay Area Water Supply & Conservation Agency in advocating for reliable and fairly priced water from the San Francisco regional water system.

NH-I-34 Adequate Peak Load Water Supply Fire Flow and Fire Flow Upgrades. Work with the North Coast County Water District and the North County Fire Authority to maintain and establish priorities for upgrading fire flow capabilities in neighborhoods that

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Packet Pg. 831 Attachment: Attachment E – CCC responses to NCCWD requested modifications (5783 : Draft Local Coastal Land Use Plan (LCLUP) with may have inadequate fire flows. Work with NCCWD to maintain adequate water supply for firefighting, including capacity for peak load under a reasonable worst case wildland fire scenario, to be determined by the North County Fire Authority.

CR-I-9 Hazard Prone Infrastructure. The City will Hazard prone infrastructure will be preserved, protected, or relocated hazard prone infrastructure to maintain critical services and protect coastal resources, including if required by prior permit conditions and/or legal obligations pursuant to the California Coastal Act. Preservation/protection in situ with shoreline armoring shall be required to meet the requirements of Policies CR-I-31 and CRI-32.

CR-I-32 New Shoreline Protection Structures. Shoreline protection structures, including revetments, breakwaters, groins, seawalls, cliff retaining walls, deep piers and caissons, and other such construction that alters natural shoreline processes shall only be permitted if consistent with Section 30235 of the Coastal Act, and only when required to serve coastal-dependent uses or protect existing structures (including existing critical infrastructure public roads, water infrastructure, and sewer lines if necessary) or public beaches in danger from coastal hazards, when there is no less environmentally damaging feasible alternative and when designed to avoid, and where unavoidable, minimize to the maximum extent feasible adverse impacts on local shoreline sand supply and other coastal resources, where unavoidable coastal resource impacts are required to be commensurately mitigated.

Recommendation: City Staff agrees with these recommended modifications and they are included in the Redline Version of the LCLUP in Attachment B The following policies/language derived from the Half-Moon Bay LCP and the NCCWD comment letter requests they be included in Pacifica’s LCLUP.

3. CCC staff observed this change went from not allowing critical facilities in the vulnerability zone to allowing that if no feasible alternative exists but without any additional discussion about appropriate siting/design considerations like there are in the HMB policy. They recommend that to make such an allowance, additional language from HMB’s certified policy is required as added below.

NH-I-31 Critical Facilities Location. Site critical public facilities including hospital and healthcare facilities, emergency shelters, police and fire stations, and emergency communications facilities outside of the tsunami evacuation zone, 100-year flood plains, and other portions of the Coastal Vulnerability Zone over the anticipated life of the development., unlessIf no feasible alternative location is available and a new or expanded critical facility must be located in a shoreline hazard area, require the new development to incorporate siting and design measures based on worst-case sea level rise projections and extreme weather event scenarios to promote continued functionality and public services, resist structural damage, facilitate evacuation on short notice, and minimize risk to life, property, and coastal resources.

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Packet Pg. 832 Attachment: Attachment E – CCC responses to NCCWD requested modifications (5783 : Draft Local Coastal Land Use Plan (LCLUP) with

4. CCC staff observed that in the context of HMB’s LCP it was understood that this policy referred to future work and developing additional strategies, and are agreeable with including this policy if the suggested edits are included to clarify that additional approaches for addressing existing critical facilities/infrastructure (particularly as related to SPDs) would need to be incorporated through future LCP amendment(s) rather than this language opening up new approaches/allowances in this LCP.

NH-I-32 (NEW) Existing Critical Facilities. Coordinate with NCCWD and others to Iidentify existing critical facilities that are vulnerable to shoreline hazards, and work to establish measures to protect continued function of critical infrastructure, or the basic facilities, service, networks, and systems needed for the functioning of a community., Coordination efforts may include, but are not limited toincluding: a. Developing strategies for tretiring, moving, or replacing infrastructure and public facilities at risk of damage from shoreline hazards including sea level rise impacts that may occur over the economic life of the structure (at least 150 years for critical facilities); b. Providing for functional continuity of the critical services provided by infrastructure at risk from shoreline hazards and extreme weather events; and c. Providing aAssessing options for the use of protective devices, if necessary to ensure the continuation of needed services, as a temporary option while longer-term strategies are identified and implemented. Update the LCP as necessary to incorporate additional strategies to address existing critical facilities and infrastructure.

5. CCC staff is NOT agreeable with the inclusion of this policy. Many of the conversations over the past several months have specifically addressed usage of armoring in certain contexts and they observed this language would appear to open additional use of armoring in contexts that they do not agree with/are inconsistent with other parts of the LCP.

Not included in Staff Recommendations
(NEW) Protection for Critical Facilities. Notwithstanding the shoreline protective device limitations of Policy CR-I-32, shoreline protective devices may be permitted to protect critical public infrastructure and facilities that may require shoreline protective devices or other shoreline hazard adaptation measures in order to continue providing needed services to the community. Such protection shall be permitted on a temporary basis only, with required check-ins and trigger points to determine when it is feasible to relocate such critical infrastructure inland and away from shoreline hazard risks in the future. As a CDP condition, a long-term adaptation plan that identifies relocation options shall be required.

Recommendation: City Staff agrees with the CCC staff’s modifications in #3 above, the addition of the new policy in #4 above as modified by CCC staff, and not including #5. These recommendations are reflected in the Redline Version of the LCLUP in Attachment B.

The following Policy recommendations were considered by CC and City Staff, and were resolved as described below:

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Packet Pg. 833 Attachment: Attachment E – CCC responses to NCCWD requested modifications (5783 : Draft Local Coastal Land Use Plan (LCLUP) with

6. NH-I-15 Water Tank Rupture
NCCWD has no tanks in the coastal zone.

City and CCC staff agreed to remove this policy from the LCLUP.

CR-I-2 Development in Coastal Vulnerability Zones and CR-I-20 Shoreline Protection Structures
NCCWD staff requested adding a new Policy and modifying the two policies listed above. CCC did not agree to the modifications requested by NCCWD for these policies, and no changes are recommended by City staff.

Critical Infrastructure Improvements NCCWD staff recommended a new policy be added to allow system improvements to occur to address health and safety needs such as replacing aging infrastructure, ensuring sufficient water capacity for fire flow, and improving system capacity to prevent sewer overflows.

CCC and City staff agreed that these needs have been covered by the current policies in the LCLUP , CR-I-9 and CR-I-38, therefore no modifications are recommended by City staff.

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Packet Pg. 834 Attachment: Attachment E – CCC responses to NCCWD requested modifications (5783 : Draft Local Coastal Land Use Plan (LCLUP) with 1 From: Adrianne Carr <[email protected]>
Sent: Monday, October 21, 2024 5:00 PM
To: Vaterlaus, Sue; Beckmeyer, Sue; Bier, Mary; Bigstyck, Tygarjas; Boles, Christine Cc: Woodhouse, Kevin; Public Comment
Subject: Comment on LCLUP - for next City Council meeting on this topic (assumed October 28) Attachments: NCCWD_to_City_RE_LCLUP_Oct_21_2024.pdf
[CAUTION: External Email]
Dear Honorable Councilmembers,
Please see attached letter.

Very best regards,
Adrianne
Adrianne Carr, Ph.D.

General Manager
North Coast County Water District
80 Eureka Dr., Suite #219
Pacifica, CA 94044
Tel: (650) 355-3462
Fax: (650) 355-0735
On the web at www.nccwd.com
[email protected]
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 835 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications)

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Packet Pg. 836 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications)

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Packet Pg. 837 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) Submitted Via Email to City of Pacifica
October 11, 2024
Comments from NCCWD to City on LCLUP sections and policies Section 2.5 Development Capacity and Adequacy of Public Services Modify Policy LD-I-28 (suggest to add red text)
Public Service Priorities. Ensure that existing and planned public works facilities accommodate needs generated by development or uses permitted by the buildout allowances of this Land Use Plan or by the General Plan to serve the City’s non-coastal zone areas. Plan for the maintenance, operation, expansion and improvement to public works facilities considering threats from coastal hazards, and avoid locating new or expanded public service facilities in the Coastal Vulnerability Zone unless no feasible alternative exists. Support studies that evaluate the condition of critical infrastructure and critical facilities, especially public works infrastructure that has been identified as vulnerable to hazards, including water storage and transmission facilities and wastewater treatment and transmission facilities.. Studies shall include alternatives analyses for potential retrofit, improvements, relocation, or other considerations.

Modify Policy LD-I-29 Water Supply. Support North Coast County Water District in its efforts to develop sustainable, drought-proof local supplies. Support the Bay Area Water Supply & Conservation Agency in advocating for reliable and fairly priced water from the San Francisco regional water system.

ADD Policy to this section:

Critical Infrastructure Improvements: Allow system improvements to occur to address health and safety needs such as replacing aging infrastructure, ensuring sufficient water capacity for fire flow, and improving system capacity to prevent sewer overflows.

Section 5.2 Seismic and Geologic Hazards
• NH-I-15 Water Tank Rupture
o We have no tanks in the coastal zone. Please remove this policy from the LCLUP.

Section 5.3 Flooding
Modify Policy NH-I-30 Critical Facilities Location. Site critical public facilities including hospital and healthcare facilities, emergency shelters, police and fire stations, and emergency communications facilities outside of the tsunami evacuation zone, 100-year flood plains, and

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Packet Pg. 838 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) Submitted Via Email to City of Pacifica
October 11, 2024
other portions of the Coastal Vulnerability Zone over the anticipated life of the development, unless no feasible alternative location is available.

Section 5.4 Fire Hazards
Modify Policy NH-I-32 Adequate Peak Load Water Supply Fire Flow and Fire Flow Upgrades.

Work with the North Coast County Water District and the North County Fire Authority to maintain and establish priorities for upgrading fire flow capabilities in neighborhoods that may have inadequate fire flows. Work with NCCWD to maintain adequate water supply for firefighting, including capacity for peak load under a reasonable worst case wildland fire scenario, to be determined by the North County Fire Authority.

Section 6.5 Coastal Resilience Policies
Modify Policy CR-I-2
CR-I-2: Development in Coastal Vulnerability Zones – should include a carve out for under part “e” related to a policy pointing to using protection devices to protect Critical Infrastructure. “e. To assure stability and structural integrity without reliance on shoreline protection devices, except as provided in CR-I-38, CR-I-39, and CR-I-40 and for critical facilities that are allowed to be protected on a temporary basis as described in CR-I-32A.” Modify Policy CR-I-9
“Hazard Prone Infrastructure. Hazard prone critical infrastructure will be preserved, protected, or relocated to maintain critical services and protect coastal resources, including if required by prior permit conditions and/or legal obligations pursuant to the California Coastal Act.” Modify Policy CR-I-20
Add to last line, similarly to CR-I-2:
“…. However, behind Special Shoreline Resiliency Areas development may consider CR-I-38, CR-I-39, and CR-I-41, and critical facilities may rely on CR-I-32A.

ADD Policy.

Existing Critical Facilities. Identify existing critical facilities that are vulnerable to shoreline hazards, and establish measures to protect continued function of critical infrastructure, or the basic facilities, service, networks, and systems needed for the functioning of a community, including: a. Developing strategies for tretiring, moving, or replacing infrastructure and public

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Packet Pg. 839 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) Submitted Via Email to City of Pacifica
October 11, 2024
facilities at risk of damage from shoreline hazards including sea level rise impacts that may occur over the economic life of the structure (at least 150 years for critical facilities); b.

Providing for functional continuity of the critical services provided by infrastructure at risk from shoreline hazards and extreme weather events; and c. Providing for the use of protective devices, if necessary to ensure the continuation of needed services, as a temporary option while longerterm strategies are identified and implemented.

Section 6.7 New Shoreline Development Standard Policies Modify Policy CR-I-32
New Shoreline Protection Structures. Shoreline protection structures, including revetments, breakwaters, groins, seawalls, cliff retaining walls, deep piers and caissons, and other such construction that alters natural shoreline processes shall only be permitted if consistent Section 30235 of the Coastal Act, and only when required to serve coastal-dependent uses or protect existing structures (including existing public roads, water infrastructure, and sewer lines if necessary) or public beaches in danger from coastal hazards, when there is no less environmentally damaging feasible alternative and when designed to avoid, and where unavoidable, minimize to the maximum extent feasible adverse impacts on local shoreline sand supply and other coastal resources, where unavoidable coastal resource impacts are required to be commensurately mitigated.

ADD Policy – Hypothetical CR-I-32A (referred to earlier).

Protection for Critical Facilities. Notwithstanding the shoreline protective device limitations of Policy CR-I-32, shoreline protective devices may be permitted to protect critical public infrastructure and facilities that may require shoreline protective devices or other shoreline hazard adaptation measures in order to continue providing needed services to the community.

Such protection shall be permitted on a temporary basis only, with required check-ins and trigger points to determine when it is feasible to relocate such critical infrastructure inland and away from shoreline hazard risks in the future. As a CDP condition, a long-term adaptation plan that identifies relocation options shall be required.

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Packet Pg. 840 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) 1 From: Samuel Casillas <s >
Sent: Wednesday, October 23, 2024 11:18 AM
To: Public Comment; Boles, Christine; Vaterlaus, Sue; Beckmeyer, Sue; Bier, Mary; Bigstyck, Tygarjas
Cc: Honey, Julian@Coastal; Ringuette, Oceane@Coastal; Rexing, Stephanie@Coastal Subject: October 28, 2024 City Council Meeting: Continuation of Consideration of a Resolution of the City Council of the City of Pacifica Certifying that the Revised Certification Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications.

Attachments: LCLUP city council CEQA fatal flaws comments casillas 10 28 24.docx; LCLUP city council CEQA fatal flaws comments casillas 6 26 24.docx
[CAUTION: External Email]
Dear City Council Members,
Please see attached comments for the 10/28/24 meeting discussing the LCLUP. It should be noted that it was recently discovered that the Pedro Point Field & Wetland at 315 San Pedro Ave was formerly utilized by the city as a sewage disposal site with a retention basin. This is disturbing information that was never disclosed and never documented as remediated; my comments detail the scope of the omission.

Regards,
Sam Casillas
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 841 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) Pacifica City Council
1800 Francisco Boulevard
Pacifica, CA 94044
[email protected]
CC: California Coastal Commission Staff
Date: October 28, 2024
Subject: October 28, 2024 City Council Meeting: Continuation of Consideration of a Resolution of the City Council of the City of Pacifica Certifying that the Revised Certification Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications.

Dear City Council:

The current draft of Pacifica’s Proposed LCLUP is fatally flawed and requires multiple changes due to the current draft’s CEQA and Coastal Act violations. These fatal flaws would require the full revision of Pacifica’s 2040 General Plan as it will not align with the LCLUP once the CEQA and Coastal Act (CA) violations are rectified. These issues have not been addressed after multiple comment letters from the Pedro Point Community Association and me. Most recently these comments were submitted at the 6/24/24, 8/12/24 and 9/17/24 meetings (please see attachments for 6/24/24 letter).

NOTE: In the draft LCLUP the site defined as “The Undeveloped San Pedro Site” is more accurately referred to in this comment letter as “The Pedro Point Field & Wetland Site” at 315 San Pero Ave.

In addition to previous comments from the Pedro Point Community Association, multiple experts and concerned citizen comments it has been recently discovered that The Pedro Point Field & Wetland Site previously served as a sewage retention basin/pond for the Linda Mar Valley and the Pedro Point neighborhood. Historical documented pictures from circa 1950s clearly show The Pedro Point Field & Wetland Site with a constructed retention basin (see exhibit A). USGS maps from 1956, 1968 and 1980 clearly show the field labeled as “sewage disposal” (See Exhibit B, C and D). We are skeptical that the city never had this information and demand that the city search all historical documentation of how this information was omitted as a remediation plan would have been necessary and housing construction on sewage retention ponds is not allowed under CEQA and California municipal codes strictly prohibit building on former sewage retention basins. Based on this omission the City of Pacifica also needs to search documentation of other sewage retention ponds that were potentially omitted in the Rockaway Quarry and Linda Mar Valley so we can have full disclosure of sewage disposal sites that have been omitted. As part of the CEQA review, the city must test the site for contamination and include a remediation plan before changing any land use designation while prohibiting construction that can become a public nuisance.

Also, The Pedro Point Field & Wetland Site at 315 San Pero Ave. has recently been put on the market and the realtor environmental risk disclosers state that the environmental risk for flooding is “SEVERE” (see exhibit E) If the realtors own disclosers state that the flooding risk in this property is severe why would the city consider a change in land use designation to residential? A home adjacent to the site at 312 Kent has also been recently put up for sale and its environmental risk assessment is even more disturbing; it states that the flood severity is a 7 out of 10 and that flood insurance will be necessary (see

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Packet Pg. 842 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) exhibit F). Again I ask if these realtor sites are disclosing severe flood hazard risk what has led to the city into thinking this is a great place for residential development? Of the many prior violations we have voiced and not addressed I would like to highlight the following:

1. CEQA Guidelines, Section15125(a)(3) explicitly prohibits use of future plans and permits as the baseline and the two preceding sections (a) (2) and (a) 1 clarify the correct baseline conditions should describe physical environmental conditions as they exist at the time the notice of preparation is published. There are at least three violations of this guideline where re-zoning and updated Land Use Designations have not considered “baseline conditions”. These identified parcels in the CZ are the sites known as the Rockaway Quarry where Planned Development is being considered, Aramai Point where commercial is being considered and the Pedro Point Field & Wetland Site where residential is being considered. The city ignored flooding and groundwater data on all three sites but especially the flooding data in the Pedro Point Field & Wetland Site (see exhibit A and C in 6/26/24 Casillas comment letter). With the city is in violation of this CEQA guideline in these three sites then where else has the city violated CEQA section 15125?

2. Staff is conflating land use plan designations in the LCLUP to requirements for project permit-level environmental review. Inherently, projects are speculative and planning around a speculative project is circuitous and prejudicial. It assumes impacts caused by a project will be feasible to mitigate, which is the reverse of mitigation sequencing to first avoid, then minimize, and as a last resort compensate for unavoidable impacts; in other words the city is setting itself up for a taking. The LCP land use designation that is supposed to build in the avoidance of avoidable impacts like placing incompatible residential development in flood-prone hazard zones that are also vulnerable to the escalating risk and conflict forced by SLR and potentially contain ESHA with protected species highlight the violations to both CEQA and the Coastal Act. These violations are not just present in the Quarry, Aramai Point and The Pedro Point Field & Wetland Site at 315 San Pero Ave, but also nullify any changes to the general plan outside of the Coastal Zone due to the inherit conflicts that must be rectified prior the 2040 general plan’s implementation.

3. Coastal Act (CA) Section 30240(a): ESHA must be protected against any significant disruption of habitat values, and only uses dependent on such resources shall be allowed. The city has not fully mapped all ESHA in the CZ and has data in one specific area known as the “undeveloped San Pedro Avenue Site” from the Coastal Commission biologist (exhibit B in 6/26/24 Casillas comment letter) showing adjacent ESHA with a protected species (The California Red Leg Frog). By not acknowledging this ESHA what other ESHA sites has the city ignored? The city is also required to standardize ESHA buffer zones.

4. CA (Sections 30121, 30230, 30231 and 30233) and California Code of Regulations section 13577 require wetland sites to be identified, designated AND restored as wetlands based on the latest available data including ground water data (see exhibit C in Casillas 6/26/24 comment letter).

5. The city is also required under SB379 to utilize/restore identified appropriate sites to employ as nature-based solutions for climate resiliency, yet the city is again deferring the selection of SB379 sites without explanation. The Pedro Point Field & Wetland Site and Quarry sites should be recorded as SB379 sites.

6. The attempt to bypass an LCLUP review through the Special Resiliency Areas (SRAs) and the project specific review of the Quarry are not legal under the Coastal Act. The LCLUP must address these two

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Packet Pg. 843 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) areas as part of the LCLUP process now and cannot be set aside for future review as an exemption and/or amendment.

7. The city Planning Director also previously stated that the city does not have to conduct a full CEQA compliance review and instead is stating it is the responsibility of the Coastal Commission; in essence admitting that no CEQA review has been conducted. This further invalidates the FEIR until a full review is conducted and invalidates the approval of the FEIR from the City.

In the agenda packet from 9/17/24 starting on page 670 we agree with the comments from the California Coastal Commission staff (CCCS) in that:

The LUP alignment standard needs to have consistency with the Coastal Act rather than the City’s General Plan especially considering the 2040 General Plan is not valid until the LUP has been approved and changes are made in the GP to align with the CCC approved LUP In Chapter 2: Land Use and Development; we agree that land that has not be annexed cannot have a designated land use prior to annexation as a proper use of land outside the boundaries of the city cannot be properly evaluated until it is within city limits and therefore would only be premature and hypothetical.

For Policy ER-I-8 on page 4-12, the City’s needs to include the term “suitable” or “suitability” with respect to the quality of sediment that can be placed on the shoreline and I would like to add that it would also require an EIR to determine if the sediment (sand) if proper for the ecosystem for each beach where it is proposed to be utilized. This policy also needs to be updated to stipulate how the city would be held accountable for sand nourishment in areas with proposed hard armoring which will devastate adjacent beaches.

The City’s attempt to replace the definitions of “easement” and “special status species” with entirely new definitions is alarming.

Easement: An Easement is not necessarily “a right given by the owner of land to another party”. An easement can be a rightful use by another party once that use has been established over 5 years without permission by the owner of that land (Warsaw v. Chicago Metallic Ceilings, Inc. (1984) 35 Cal.3d 564, 570-72; Felgenhauer v. Soni (2004) 121 Cal.App.4th 445, 449-50). The city neglects to fully address these coastal access easement points throughout the city of Pacifica but most notably in the Pedro Point Field & Wetland Site.

I also agree with the CCCS that 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” which include multiple protected species including the California Red Leg Frog (CRLF), Western Pond Turtle and potentially others like the Tidewater Goby . This is bold attempt by City Staff to eliminate the protected species from any protection and allow unmitigated development in the Pedro Point Field & Wetland Site where the CRLF is present. The CCCS staff goes further to state “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, 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

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Packet Pg. 844 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) term in Chapter 4 (see page 4-23).” Notably the City is trying to eliminate the inclusion of the CRLF as a protected species which is present in The Pedro Point Field & Wetland Site and Quarry site and other potential sites yet to be determined due to the City’s negligent behavior to recognize the CRLF in sites known to have CRLF habitat like The Pedro Point Field & Wetland Site which was previously identified by CCCS biologist L. Garske-Garcia (CDP application 2-19-0026 F13a exhibit 11). As noted by CCCS this is a violation of Coastal Act Section 30240.

Although I am in agreement with the CCCS Regarding Policies ER-I-1 and ER-I-24, creek and ESHA buffer zones need to be maximized for the requirements of ESHA and also for protected species habitat. A reduction below 50 feet is not adequate for the CRLF and in fact CCCS biologist L. Garske-Garcia (CDP application 2-19-0026 F13a exhibit 11) cites a need for a 300 foot buffer for CRLF habitat in accordance with USFWS recommendations. Additionally, a noted in my comment letter from 6/26/24 the city is actually setting itself up for a taking by changing the LUD in the Pedro Point Field & Wetland Site to residential when it more closely matches “Low-Intensity Visitor-Serving Commercial” (LIVC) or “Conservation” (C) and considering the CEQA and Coastal Act violations noted above makes a change to residential negligent on the City’s part.

I am also alarmed as the CCCS is with their concern with Chapter 4 which is lacking a policy that addresses wetland buffer requirements and should be a minimum of 100 feet. Such a policy is necessary for compliance with the Coastal Act. Within Policies ER-I-1 and ER-I-24 The City also attempts to freeze out the CCC from conducting their own biology reviews and instead wants to only defer biology reviews by the City, USFWS, and CDFW. I am aware that these agencies often defer to the biology report from the developer which by definition is biased. Trying to eliminate the CCC from biology reviews would only benefit the developer at the expense of ESHA and protected species as it would eliminate biology reports similar to the above referenced biology report from L. Garske-Garcia for CDP application 2-19- 0026 which determined the adjacent waterway to the Pedro Point Field & Wetland Site to contain both ESHA and CRLF habitat.

The CCCS recommended policy needs to include “the 100-foot buffer may also be expanded as needed to account for feeding, breeding, nesting, and other habitat requirements”.

We request additional changes to comments from CCC addressing:

For Policy LD-I-20 Undeveloped San Pedro Avenue Site (AKA, Pedro Point Field & Wetland Site) on page 2-31 in Chapter 2: although I agree with CCCS recommendations based on their concerns about the sensitivity of the site and to appropriately plan for this site to avoid and protect coastal resources. If the City is intending to allow any development it, at best, would only allow LIVC and considering the owner had prior knowledge to the hazard constraints prior to purchasing the property Conservation would be appropriate and not a taking, but LIVC development would be “reduced as necessary to account for coastal resource protections”. As noted previously, the City’s attempt of a zoning change to any type of residential would set the city up for a taking due to the erroneous zoning change in violation of the Coastal Act and CEQA.

Additionally:

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Packet Pg. 845 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) The City continues to use 5.7 feet of sea level rise(SLR) by 2100 while the 2024 State of California Sea Level Rise Guidance stipulate the use of 6.6 feet of sea level rise by 2100. In the interest of utilizing “best available science” this change needs to be incorporated.

Figure 4-1: Hydrology mapping is not utilizing the latest USGS ground water data from the COSMoS data model which shows the Pedro Point Field & Wetland Site and the Quarry with shallow water tables Figure 2-2: Existing Land Use in the Coastal Zone: The Pedro Point Field & Wetland Site is currently zoned CR; “undeveloped vacant land” is not a valid zoning
Figure 3-2:Parks and Open Space System: Agree that the whole of Pedro Point Field & Wetland Site is a Park Opportunity Site due to present hazards, ESHA, previous wetland designation and the presence of protected species.

Figure 4-3: Potential Environmentally Sensitive Habitat Areas: Ignores CCC biologist data in Pedro Point Field & Wetland Site for known CRLF habitat and ESHA that needs to be added based on best available science (CDP application 2-19-0026 F13a exhibit 11).

Figure 5-3: Flood Zones: Ignores flood data in Pedro Point Field & Wetland Site from USGS CoSMoS model which is best available science.

The definition for “erosion” needs to include wave and underground water impacts which is directly responsible for the bluff erosion in Pacifica
Also, in the previous LCLUP meeting City staff once again purposely mispresented the vast majority of the concerns from the PPCA and the multiple comment letters from residents of Pedro Point . Our concern has never been to “address the number of residential units” in the Pedro Point Field & Wetland; our concern has always been the suitability of residential zoning in an area with multiple hazards that make it unsuitable for residential development. Furthermore, City Staff has refused to answer community concerns as to how the decision was made to change the zoning from the 1980 LCLUP from Commercial Recreation (CR) to its closest zoning definition in the LUP update to Low Intensity Visitor Commercial (LIVC) or more appropriately, due to the present hazard and ESHA conditions, to designate it Conservation.

Please also see previous attached comment letters from me and the Pedro Point Community Association(PPCA) which include input from CEQA and environmental legal experts that find substantial violations with the Coastal Act and CEQA guidance which have not be addressed.

Regards,
Samuel Casillas
Board member, PPCA
Past Vice-Chair, Pacifica Economic Development Committee Past Member, Pacifica Sea Level Rise Adaptation Planning Committee Past Co-Chair GGNRA Board Liaison Committee
Past Member, Pacifica GPU Community Outreach Committee

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Packet Pg. 846 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications)

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Packet Pg. 847 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications)

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Packet Pg. 848 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications)

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Packet Pg. 849 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) Exhibit F: 312 Kent adjacent property to 315 San Pedro Ave realtor disclosures (Zillow Realtor listing on adjacent 312 Kent property; https://www.zillow.com/homedetails/312-Kent-Rd-Pacifica-CA94044/15504828 zpid/)

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Packet Pg. 850 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) Pacifica City Council
1800 Francisco Boulevard
Pacifica, CA 94044
[email protected]
CC: California Coastal Commission Staff
Date: June 26, 2024
Subject: June 26, 2024 Special Council meeting: Consideration of a Resolution Certifying the Revised Certification Draft Local Coastal Land Use Plan (LCLUP) Dear City Council:

The current draft of Pacifica’s Proposed LCLUP is fatally flawed and requires multiple changes due to the current draft’s CEQA and Coastal Act violations. These fatal flaws would require the full revision of Pacifica’s 2040 General Plan as it will not align with the LCLUP once the CEQA and Coastal Act (CA) violations are rectified.

Staff is conflating land use plan designations in the LCLUP to requirements for project permit-level environmental review. Inherently, projects are speculative and planning around a speculative project is circuitous and prejudicial. It assumes impacts caused by a project will be feasible to mitigate, which is the reverse of mitigation sequencing to first avoid, then minimize, and as a last resort compensate for unavoidable impacts; in other words the city is setting itself up for a taking. The LCP land use designation that is supposed to build in the avoidance of avoidable impacts like placing incompatible residential development in flood-prone hazard zones that are also vulnerable to the escalating risk and conflict forced by SLR and potentially contain ESHA with protected species highlight the violations to both CEQA and the Coastal Act. These violations are not just present in the Quarry, Aramai Point and the Undeveloped San Pedro Ave Site, but also nullify any changes to the general plan outside of the Coastal Zone due to the inherit conflicts that must be rectified prior the 2040 general plan’s implementation.

It is negligence by our elected officials to take direction from outside lobbying groups like SMCAR and SMART Coast so that Pacifica can be used as a test case for CEQA and CA violations to see what they can get away with at the cost of the tax payers of this city.

Also, by not acknowledging that the continued efforts to rebuild the Sharp Park seawall at a cost of over $500 million in order to protect mostly STR properties while devastating Sharp Park Beach in violation of the CA will also bankrupt the city is willful negligence.

The previous planning director constantly stated that the LCLUP has utilized “best available science”, but this is false. The willful disregard of scientific data including the biology report from the CCC biologist for the adjacent ESHA and CRLF habitat (CDP application 2-19-0026) will lead to litigation where the city again will be found liable.

Pacifica’s proposed LCLUP is in violation of:
• Coastal Act (CA) Section 30240(a): ESHA must be protected against any significant disruption of habitat values, and only uses dependent on such resources shall be allowed. The city has not fully

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Packet Pg. 851 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) mapped all ESHA in the CZ and has data in one specific area known as the “undeveloped San Pedro Avenue Site” from the Coastal Commission biologist (exhibit B) showing adjacent ESHA with a protected species (The California Red Leg Frog). By not acknowledging this ESHA what other ESHA sites has the city ignored? The city is also required to standardize ESHA buffer zones. • CA (Sections 30121, 30230, 30231 and 30233) and California Code of Regulations section 13577 require wetland sites to be identified, designated AND restored as wetlands based on the latest available data including ground water data (see exhibit C). • CEQA Guidelines, Section15125(a)(3) explicitly prohibits use of future plans and permits as the baseline and the two preceding sections (a) (2) and (a) 1 clarify the correct baseline conditions should describe physical environmental conditions as they exist at the time the notice of preparation is published. There are at least three violations of this guideline where re-zoning and updated Land Use Designations have not considered “baseline conditions”. These identified parcels in the CZ are the sites known as the Rockaway Quarry where Planned Development is being considered, Aramai Point where commercial is being considered and the San Pedro site where residential is being considered. The city ignored flooding and groundwater data on all three sites but especially the flooding data in the San Pedro Ave site (see exhibit A and C). With the city is in violation of this CEQA guideline in these three sites then where else has the city violated CEQA section 15125?
• The city is also ignoring the state guideline recommendation for 6.6 feet of SLR through 2100 from the latest 2024 California Ocean Protection Council Policy Update (California Ocean Protection Council California Sea Level Rise Guidance: 2024 Science and Policy Update. 2024. California Sea Level Rise Science Task Force, California Ocean Protection Council, California Ocean Science Trust.) • The city is also required under SB379 to utilize/restore identified appropriate sites to employ as nature-based solutions for climate resiliency, yet the city is again deferring the selection of SB379 sites without explanation. The San Pedro and Quarry sites should be recorded as SB379 sites.

The fact that the Pacifica City Staff and council has consistently ignored it owns citizens who present the best available science shows that they are not listening and we will be forced to just wait for the CCC appeal process that is there to uphold the law of the state and perhaps leading to litigation is appalling.

The CCC is there to protect the Public Trust and those living in the Coastal Zone knew where they live are bound by the laws of the Coastal Zone that the majority of the people of California voted for and vilifying the CCC for imaginary property rights is misleading and continues to cause harm to the city.

What is sad is that those who have real fears of losing their homes are not realizing that their anger should be directed at Pacifica’s staff and council for doing the bidding of real estate lobbyists like SMCAR and SMART Coast for developers and not coming up with solutions to help its own citizens with nature based solutions versus hard armoring that will not work. Be honest with Pacificans and help the people who’s homes are vulnerable and not developers for new development that further puts us in danger.

In the Staff report for LD-I-20: Undeveloped San Pedro Avenue Site: CCC staff recommends keeping their original suggested modification from March 2023 that states “some low density” instead of the staff drafted alternative modification that proposed a specific density range. Staff strongly believes that a specified density is necessary to address community concerns regarding potential future development of the site and to assure that the City’s internal land use documents, e.g. General Plan, and LUP are consistent with regard to density designations.---Once again the city is misrepresenting what the community “concerns” are about. The Pedro Point Community Association and the vast majority of the

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Packet Pg. 852 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) feedback the city has received from individuals on this parcel clearly state that the “concerns” are that residential should not be considered at all at this due to the present hazards, ESHA and protected species. The further concerns are that how the city came to the conclusion that residential is a good idea when the present conditions clearly point to a Conservation (C) LUD/zoning.

The violations to the Coastal Act, CEQA and California Code of Regulations renders the whole of the LCLUP and potentially the whole 2040 GP fatally flawed and would require a new EIR and considerable revisions to both the LCLUP and the required alignment with the 2040 GP. The city needs to stop hiding behind blaming the CCC and be accountable for following the law which is the Coastal Act and quit pretending the CCC is some out of control bureaucratic entity; The Coastal act has been law since 1979 and the citizens of Pacifica need to be educated instead the hostile environment this staff and council created which has mis-informed its residents and continued blaming the CCC for the city’s continued poor planning which only moves from one emergency evacuation to another without future planning that helps all of us. The staff and council always talk about this great relationship it has cultivated with the CCC, but in action it has never actually been there and is revisionist history that is why we are still working on this LCLUP for over 10 years and still are nowhere closer to resolution of a plan that is from 1980.

Noting that on multiple occasions the CCC Staff has requested additional data due to the extensive changes to the 1980 LCP for specific sites, including the Undeveloped San Pedro Avenue Site and the Quarry from the City of Pacifica and that multiple concerned citizens and community organizations have provided the latest environmental hazards and biology reports including those from USGS and the CCC itself, none-the-less the city continues to disregard this data. By ignoring the presented hazard and environmental restraints data for these undeveloped sites, including flooding (which includes the annual formation of a lake on the San Pedro Ave site (see exhibit A), ground water hazards, erosion, soil stability and SLR, liquefaction, tsunami danger, federally designated wetlands, as well as ESHA and protected species habitat the city is in violation of multiple CEQA and state laws. The city instead continues to attempt to change these property’s LUDs to residential and planned development although all scientific data dictates they should be designated Conservation. The City’s DRAFT Local Coastal Land Use Plan’s “Environmental and Scenic Resources” and “Natural Hazards” chapters ignore all this data for these sites and also ignores the erosion data for the area known as Aramai Point which invalidates the Land Use Designations (LUD) for these areas and may jeopardize the whole 2040 GP with these willfully misinformed policies.

On the San Pedro site the CCC has already determined “this undeveloped site is known to contain wetlands and ESHA supporting California Red Legged Frog habitat, and the presence of such coastal ecological resources could significantly constrain the development potential of this site.” (see exhibit B).

By not acknowledging the ESHA it is a violation of Coastal Act (CA) Section 30240. The latest hydrology data from USGS also shows the groundwater hazard at both the Quarry and San Pedro sites with a very shallow water table (see exhibit C). The city is required to use the latest data available for the GPU and its EIR. The CA (Section 30121) and California Code of Regulations section 13577 would require these two sites to be designated wetlands as “lands within the coastal zone which may be covered periodically…with shallow water <and> Areas where the water table is at, near, or above the land surface at some time during each year may be identified as wetlands.” This is also required in CA sections 30230, 30231 and 30233. Since the city has chosen not to utilize this data it is in violation of CEQA and other state laws and therefore may invalidate the whole 2040 GP.

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Packet Pg. 853 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) CEQA Guidelines, Section15125(a)(3) explicitly prohibits use of future plans and permits as the baseline and the two preceding sections (a) (2) and (a) 1 clarify the correct baseline conditions should describe physical environmental conditions as they exist at the time the notice of preparation is published.

Due to the violation of this CEQA guideline the current DRAFT LUD/LCLUP is in violation of CEQA. The city is aware that it should be using existing conditions to determine the new LUDs, which would heavily favor Conservation. Section 15125 backs this view and "ensuring all biological constraints are considered" is not adequately addressed as existing conditions in the Quarry (See exhibit D for Western Pond turtle), Aramai Point and the Pedro Point site would dictate otherwise and this potentially applies to the whole of the 2040 GP and its associated FEIR. Additionally, as policy the city’s GP/LCP/EIR erroneously allows a deferred analysis as “site-specific as part of proposed development review” for hazards and biological studies to be done at the time a project is proposed. The city has chosen to defer biologic and hazard analysis as policy throughout the LCLUP and the 2040 GP which potentially invalidates the whole of the 2040 GP update where the city has chosen to change LUD/zoning from the 1980 GP/LCLUP. The city is advised that this policy is in violation of CEQA and may end up invalidating the whole 2040 GPU. By changing LUDs without proper CEQA/CA review the city is also purposely setting itself up for a “taking” of private land and would therefore violate its fiduciary duty to protect the city from potential liability.

Also, the city’s Sea Level Rise risk assessment to the year 2050 is inadequate due to the lack of acknowledging scientific data that we should be planning for a 100-year time horizon as dictated by design life policies.

The Coastal Act dictates how to manage development with coastal resources and public access guarantees across a physically dynamic environment. It is also the ultimate intent of the CCC to safeguard the permanent protection of the state’s natural and scenic resources that are of paramount concern to present and future residents of the state, along with the necessity of protecting the ecological balance of the Coastal Zone by preventing its deterioration and destruction. Exempting the Coastal Act with the proposed SSRAs removes a substantial law that gives the CCC the ability to mitigate impacts to public access guarantees, lower-cost recreation opportunities, critical habitats such as wetlands, and sea level rise preparedness efforts. Simply because an area is being proposed for residential zoning does not mean that the zoned parcel is devoid of natural resources or public access opportunities that the city and CCC must consider prior to changing of zoning. It also does not mean that such a zoning change may avoid the impacts of climate change such as the inevitable rise in sea levels. After all, the Coastal Act purports that sound and timely scientific recommendations are necessary for coastal planning and development decisions and that the CCC should, in addition to its own expertise in significant applicable fields of science, interact with members of the scientific and academic communities, especially with regard to issues such as the cumulative impact of Coastal Zone development. By essentially exempting the Coastal Act through SSRAs it fails to give the public the legally mandated opportunity to utilize scientific information to analyze the potential cumulative impacts that future and additional Coastal Zone developments pose.

Pacifica’s LCLUP and related CEQA review is fatally flawed and requires a full re-draft due to the current draft’s CEQA and Coastal Act violations. These errors need to consider the impact of building seawalls that will lead to erosion to the adjacent non-hardened bluffs beyond these seawalls as well as the effect seawalls will have on beaches north and south of these seawalls and any environmental degradation

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Packet Pg. 854 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) seawalls will cause. The piecemeal placement of seawalls will cause significant damage to the adjacent beaches and bluff areas do not have hard armoring. The degradation of coastal environmental and recreational assets along the coast is a violation of both CEQA and Coastal Act and these violations need to fully reviewed and rectified before this seawall plan can continue.

The proposed LCLUP are in violation of the Coastal Act including:
• The violation of CEQA Section 21081. Where by its implementation the monitoring program for hard armoring is moot because the seawalls themselves cannot avoid significant effects on the environment.
• Coastal Act (CA) Section 30240(a): ESHA must be protected against any significant disruption of valuable habitat, and only uses dependent on such resources shall be allowed. The LCLUP has not fully mapped ESHA in this area of the CZ, including in the Undeveloped San Pedro Site. The city is also required to standardize ESHA buffer zones along the beach/bluff interface which has not occurred.

The city is also ignoring groundwater data at this site that could show soil degradation in along Pacifica’s coast. The latest hydrology data from USGS shows the groundwater hazard through its coSmoS database that would create an erosion hazard and become a public nuisance.

The violations to the Coastal Act, CEQA and California Code of Regulations renders the whole of the LCLUP invalid and would require a new EIR and considerable revisions to the LCLUP and the 2040 GP.

By ignoring the potential hazard and environmental restraints data in the LCLUP including ground water hazards, erosion, soil stability, SLR and potential protected species habitat the city is in violation of multiple CEQA and state laws, including the Coastal Act.

Please also see comments previously submitted by the Pedro Point Community Association (PPCA) which include input from CEQA and environmental legal experts.

Regards,
Samuel Casillas
Board member, PPCA
Past Vice-Chair, Pacifica Economic Development Committee Past Member, Pacifica Sea Level Rise Adaptation Planning Committee Past Co-Chair GGNRA Board Liaison Committee
Past Member, Pacifica GPU Community Outreach Committee

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Packet Pg. 855 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) Exhibit A: consistent flooding of Undeveloped San Pedro Ave Site Pedro Point Field flooding Oct 24th, 2021
Exhibit B: CCC Biologist Report findings at San Pedro Ave site with ESHA and protected species

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Packet Pg. 856 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) Exhibit C: Hydrology and Ground modeling by USGS OCOF CoSMoS

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Packet Pg. 857 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) Exhibit D: Documented sighting of Western Pond Turtle by private citizen (to be listed by USFWS for protected status)

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Packet Pg. 858 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) 1 From: Beckmeyer, Sue
Sent: Wednesday, October 23, 2024 2:06 PM
To: Public Comment
Subject: Fw: I support Coastal Commission Staff Modifications From: serge de grandpre < >
Sent: Wednesday, October 23, 2024 8:32:06 AM
To: _City Council <[email protected]>
Subject: I support Coastal Commission Staff Modifications [CAUTION: External Email]
Dear Pacifica City Council,
I am writing in opposition to the City of Pacifica’s Land Use Plan update, which is over reliant on seawalls. Seawalls make erosion worse. They fix the back of the beach as seas rise and threaten to drown our beaches.The City should accept Coastal Commission staff’s original suggested modifications to the LUP Update from March 2023, which will address the long-term impacts of sea level rise in a manner more protective of our public beaches, bluffs and waves. I support more effective adaptation alternatives consistent with California Coastal Commission recommendations and the Coastal Act, which include community-led relocation of infrastructure, implementation of living shorelines and avoidance of hard armoring.

I oppose the City’s suggested “Alternative Adaptation Strategies” and “Special Resiliency Areas.” The proposed alternative policies would provide a carve out from state law, the California Coastal Act, that otherwise prohibits seawalls for new development built after 1976. This is a well established policy that has protected the coast from beach destroying seawalls for nearly half a century. Not only is this proposed carveout unlawful, it condemns our beaches and waves to drown for private benefit. The City’s proposed mitigation is NOT adequate. We must not sacrifice our beaches at Rockaway and Sharp Park for promises of “improved amenities” - what good are amenities if there is no beach left to access?
As a local beachgoer, I support long-term solutions that benefit my right to beach access, protect coastal resources and habitats, and preserve the coast from rising seas as required by the California Coastal Act. The City’s current proposal will instead erode our beaches over time and make access impossible. The plan could be devastating for popular surf and recreational beaches such as Linda Mar, Rockaway and Sharp Park Beach. By failing to consider alternatives, it also dooms the beaches fronting Beach Boulevard, Esplanade and Palmetto to permanently drown as seas rise.

One third of the City’s six miles of coast are already armored. More coastal armoring will fundamentally alter our remaining waves and beaches by exacerbating beach erosion and eventually drowning our beaches and waves.

I urge the City of Pacifica to accept the entirety of Coastal Commission staff’s suggested modifications to protect our public resources and preserve our precious coast.

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Packet Pg. 859 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications) 2 Sincerely,
serge de grandpre
san carlos, CA 94070
United States
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 860 Attachment: Attachment F - Public Comment (5783 : Draft Local Coastal Land Use Plan (LCLUP) with Alternative Modifications)