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 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.
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:
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.