Attachment A - Exhibit A. Findings of Fact and Statement of Overriding Considerations_250811

Pacifica Housing Element
(6th Cycle) Targeted
General
Plan Amendments,
Rezoning, and Objective
Development
Standards Program EIR
CEQA Findings and Facts
in Support of Findings and
Statement of Overriding
Considerations
SCH No. 2024050168
May 16, 2025
Prepared for the
City of Pacifica by
CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR ii
Table of Contents
Role of Findings...................................................................................................................................................1 Findings Under CEQA.......................................................................................................................................2 Alternatives........................................................................................................................................................23 Proposed General Plan Benefits....................................................................................................................25 Overriding Considerations Conclusions.....................................................................................................27 CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR iii
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CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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CEQA Findings and Facts in Support of
Findings and Statement of Overriding
Considerations for the Pacifica Housing
Element GP Amendments and Rezoning
Program EIR
CEQA requires the Pacifica City Council (the Council) to balance the benefits of the Pacifica Housing Element (6th Cycle) Targeted General Plan (GP) Amendments, Rezoning, and Objective Development Standards Program (Project) against its significant and unavoidable environmental effects in determining whether to approve the Project. Since the EIR identifies significant impacts of the Project that cannot feasibly be mitigated to below a level of significance, the City must state in writing its specific reasons for approving the Project in a “statement of overriding considerations” pursuant to Sections 15043 and 15093 of the CEQA Guidelines. This Statement of Overriding Considerations sets forth the specific reasons supporting the City’s action in approving the Project, based on the Final Environmental Impact Report (Final EIR, which incorporates the Draft EIR by reference) and other information in the administrative record.

In making the statement of overriding considerations, “CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered ‘acceptable’.” (CEQA Guidelines, Section 15093, subd. (a).)
The following sections provide findings and statements of facts supporting the findings, describe the general Project benefits considered by decision makers in determining to adopt the proposed Pacifica Housing Element GP Amendments and Rezoning Program despite its potentially significant adverse environmental effects, and then provide conclusions.

Role of Findings
The following findings are hereby adopted by the City Council of Pacifica pursuant to the requirements of the California Environmental Quality Act, California Public Resources Code CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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Section 21000 et seq. (CEQA), and the Guidelines for California Environmental Quality Act, Title 14, California Code of Regulations Section 15000 et seq. (CEQA Guidelines).

These Findings and Facts in Support of Findings relate to the approval of the Pacifica Housing Element (6th Cycle) Targeted General Plan Amendments, Rezoning, and Objective Development Standards Program (Project). The City Council of Pacifica is the Lead Agency for the Project.

The Findings state the City Council’s conclusions regarding the significance of the potential environmental impacts of the Project after all feasible mitigating policies have been adopted.

These findings have been prepared to comply with the requirements of CEQA and the CEQA Guidelines and are based on information in the Draft and Final Environmental Impact Report (EIR) for the Project and on all other relevant information contained in the administrative record for the Project.

CEQA requires agencies to identify mitigation measures that would avoid or substantially lessen a project’s significant impacts or potential significant impacts if such measures are feasible. The mitigating measures identified in the Final EIR mitigate the potential significant impacts of the Project, to the extent feasible, as described in the Final EIR. All mitigating policies identified in the Final EIR (as listed in Table ES-3 of the Draft EIR) that are within the City Council’s authority to impose are hereby adopted by the Council. Future projects must comply with CEQA, including implementation of project-specific mitigation measures where applicable and feasible. Subsequent environmental review for specific projects identified in the Project may tier off the programmatic analysis or incorporate information from this analysis by reference (CEQA Guidelines, Sections 15150, 15152, and 15168).

Public Resources Code Section 21002 provides that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]” (Emphasis added.) The same statute states that the procedures required by CEQA “are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.” (Emphasis added.) Section 21002 goes on to state that “in the event [that] specific economic, social, or other conditions make infeasible such project alternatives or such mitigation measures, individual projects may be approved in spite of one or more significant effects thereof.” (Pub. Resources Code, Section 21002.) The mandate and principles set forth in Public Resources Code Section 21002 are implemented, in part, through the requirement that agencies must adopt findings before approving projects for which EIRs are required. (See Pub. Resources Code, Section 21081, subd. (a); CEQA Guidelines, Section 15091, subd. (a).)
Findings Under CEQA
The Final EIR examined the environmental impacts of the Project in the areas of Aesthetics and Visual Resources; Air Quality; Biological Resources; Cultural, Tribal, and Historic Resources; Energy and Greenhouse Gas Emissions; Geology, Soils, and Seismicity; Hydrology and Water CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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Quality; Land Use, Population, and Housing; Noise and Vibration; Public Services and Recreation; Transportation; Utilities and Service Systems; Wildfire; Significant Irreversible Environmental Changes; Growth-Inducing Impacts; and Cumulative Impacts.

IMPACTS DETERMINED TO BE LESS THAN SIGNIFICANT
Under Public Resources Code section 21081(a)(1) and CEQA Guidelines sections 15091(a)(1) and 15092(b), the City determines that the following potential impacts would not occur or would be less than significant, as defined by the EIR:
a) Aesthetics: The following impacts were found to be less than significant:
i. Impact 3.1-1: Implementation of the Proposed Project would not have a substantial adverse effect on scenic vistas.
ii. Impact 3.1-2: Implementation of the Proposed Project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.
iii. Impact 3.1-3: Implementation of the Proposed Project would not substantially degrade the existing visual character or quality of public views of the site and its surroundings in non-urbanized areas or conflict with applicable zoning and other regulations governing scenic quality in urbanized areas. iv. Impact 3.1-4: Implementation of the Proposed Project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.
b) Air Quality: The following impacts were found to be less than significant:
i. Impact 3.2-1: Implementation of the Proposed Project would not conflict with or obstruct implementation of the applicable air quality plan. c) Biological Resources: The following impacts were found to be less than significant:
i. Impact 3.3-1: Implementation of the Proposed Project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
ii. Impact 3.3-2: Implementation of the Proposed Project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service. iii. Impact 3.3-3: Implementation of the Proposed Project would not have a substantial adverse effect on federally protected wetlands, as defined by Section 404 of the Clean Water Act (including, but not limited to, marshes, vernal pools, coastal areas, etc.), through direct removal, filling, hydrological interruption, or other means.
iv. Impact 3.3-4: Implementation of the Proposed Project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species, or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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v. Impact 3.3-5: Implementation of the Proposed Project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
vi. Impact 3.3-6: Implementation of the Proposed Project would not conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or State habitat conservation plan.
d) Cultural and Tribal Cultural Resources: The following impacts were found to be less than significant:
i. Impact 3.4-1: Implementation of the Proposed Project would not cause a substantial adverse change in the significance of a historical resource, as defined as physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historic resource would be materially impaired (Guidelines Section 15064.5).
e) Energy and Greenhouse Gas Emissions: The following impacts were found to be less than significant:
i. Impact 3.5-3: Implementation of the Proposed Project would not cause wasteful, inefficient, and unnecessary consumption of energy during project construction, operation, and/or maintenance.
ii. Impact 3.5-4: Implementation of the Proposed Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. f) Geology, Soils, and Seismicity: The following impacts would not occur or were found to be less than significant:
i. Impact 3.6-1: Implementation of the Proposed Project would not expose residents, visitors, and employees, as well as public and private structures, to substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault; strong seismic ground shaking; seismically related ground failure, including liquefaction; or landslides. ii. Impact 3.6-2: Implementation of the Proposed Project would not result in substantial soil erosion or topsoil loss.
iii. Impact 3.6-3: Implementation of the Proposed Project would not locate structures on expansive soils or on a geologic unit or soil that is unstable, or that would become unstable as a result of new development under the Proposed Project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse, or create substantial risks to life or property. iv. Impact 3.6-4: Implementation of the Proposed Project would not have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater.
v. Impact 3.6-5: Implementation of the Proposed Project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.
g) Hydrology and Water Quality: The following impacts were found to be less than significant:
i. Impact 3.7-1: Implementation of the Proposed Project would not violate any federal, state, or local water quality standards or waste discharge requirements.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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ii. Impact 3.7-2: Implementation of the Proposed Project would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.
iii. Impact 3.7-3: Implementation of the Proposed Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces in a manner which would result in substantial erosion, siltation, or flooding on- or off-site; substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite; create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or impede or redirect flood flows.
iv. Impact 3.7-4: In flood hazard, tsunami, or seiche zones, implementation of the Proposed Project would not risk release of pollutants due to project inundation. v. Impact 3.7-5: Implementation of the Proposed Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
h) Land Use, Population, and Housing: The following impacts would not occur or were found to be less than significant:
i. Impact 3.8-1: Implementation of the Proposed Project would not physically divide an established community.
ii. Impact 3.8-2: Implementation of the Proposed Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.
iii. Impact 3.8-3: Implementation of the Proposed Project would not induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure).
iv. Impact 3.8-4: Implementation of the Proposed Project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.
i) Noise: The following impacts were found to be less than significant:
i. Impact 3.9-2: Implementation of the Proposed Project would not result in a generation of excessive groundborne vibration or groundborne noise levels. ii. Impact 3.9-3: Implementation of the Proposed Project would not expose people residing or working in the project area to excessive noise levels within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport. j) Public Services and Recreation: The following impacts were found to be less than significant:
i. Impact 3.10-1: Implementation of the Proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: fire protection, police protection, schools, parks, or other public facilities. ii. Impact 3.10-2: Buildout of the Proposed Project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. iii. Impact 3.10-3: Buildout of the Proposed Project would not require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.
k) Transportation: The following impacts were found to be less than significant:
i. Impact 3.11-1: Implementation of the Proposed Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, and bicycle and pedestrian facilities. ii. Impact 3.11-3: Implementation of the Proposed Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible land uses (e.g., farm equipment). l) Utilities and Service Systems: The following impacts were found to be less than significant:
i. Impact 3.12-2: Implementation of the Proposed Project would have sufficient water supplies available to serve the Planning Area and reasonably foreseeable future development during normal, dry and multiple dry years. ii. Impact 3.12-3: Implementation of the Proposed Project would not result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments. iii. Impact 3.12-4: Implementation of the Proposed Project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. iv. Impact 3.12-5: Implementation of the Proposed Project would not conflict with federal, state, and local management and reduction statutes and regulations related to solid waste.
m) Wildfire: The following impacts were found to be less than significant:
i. Impact 3.13-1: Implementation of the Proposed Project would not substantially impair an adopted emergency response plan or emergency evacuation plan. ii. Impact 3.13-2: Implementation of the Proposed Project would not exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. iii. Impact 3.13-3: Implementation of the Proposed Project would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.
iv. Impact 3.13-4: Implementation of the Proposed Project would not people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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IMPACTS DETERMINED TO BE LESS THAN SIGNIFICANT WITH

MITIGATION
Under Public Resources Code section 21081(a)(1) and CEQA Guidelines sections 15091 (a)(1) and 15092(b), and to the extent reflected in the EIR, the City finds that changes or alterations have been required in, or incorporated into, the Plan that mitigate to a less than significant level or avoid the following potentially significant effects on the environment:

Air Quality, Impact 3.2-2 Implementation of the Proposed Project would not result in a cumulatively considerable net increase in any criteria pollutant for which the project region is classified as a nonattainment area under an applicable federal or state ambient air quality standard. (Less than Significant with Mitigation)
Facts in Support of Finding: The Bay Area Air Quality Management District’s (BAAQMD) project-level thresholds were developed to analyze emissions generated by a single project.

Although the construction emission impacts associated with each new individual development would be short-term in nature and limited to the period of time when construction activity is taking place for that particular development, the concurrent construction of a multitude of individual development projects that could occur at any one time in the Planning Area under the Proposed Project could generate combined criteria pollutant emissions on a daily basis that would exceed the BAAQMD’s project-level thresholds. In addition, depending on the size and scale of an individual development project, along with its construction schedule and other parameters, there may also be instances where the daily construction emissions generated by a single development project within the Planning Area could also exceed the BAAQMD’s criteria pollutant thresholds.

These emissions could contribute to ozone formation and other air pollution in the SFBAAB, which at certain concentrations, can contribute to short- and long-term human health effects.

Effects of Proposed General Plan Policies and Remaining Impacts: During construction of a development project, the activity that typically generates the highest NOX and PM exhaust emissions is the operation of off-road equipment, whereas the activity that typically generates the highest reactive organic gas (ROG) emissions is the application of architectural coatings. The City of Pacifica has amended and adopted the California Green Building Code, which contains VOC content limits for architectural coatings, sealants, and adhesives, as Chapter 7, Section 8-7.01 of the City’s Municipal Code. With regards to construction equipment, General Plan policy CO-I-56 would require all construction equipment to be maintained and tuned to meet appropriate EPA and CARB emission requirements. Policy CO-I-52 also requires contractors to use best management practices to reduce particulate emissions and dust associated with construction activities, including regular materials and vehicle tire watering; covering of stockpiles; phasing or extension of grading operations; suspension of grading during high wind periods; and revegetation of graded areas. The extent to which these measures would reduce emissions is unknown.

Rationale and Conclusion: As such, to ensure individual projects achieve consistency with the BAAQMD’s construction screening criteria or, if consistency with the construction screening criteria cannot be demonstrated, the City is incorporating Mitigation Measure AQ-1 into future project development projects. MM AQ-1 requires future projects that cannot meet construction screening criteria to prepare a detailed construction air quality impact assessment to: 1) estimate CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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potential project construction emissions; 2) compare potential project construction emissions against BAAQMD project-level construction thresholds of significance; and 3) incorporate measures to reduce construction emission impacts to levels below the BAAQMD’s construction thresholds of significance for criteria air pollutants and TACs. Thus, the implementation of Proposed Project policies and MM-AQ-1 would ensure that the construction-related emissions under the Proposed Project would be reduced to the maximum extent practicable and as such impacts related to air quality would be less-than-significant with mitigation incorporated.

MM-AQ-1: Prepare Project-level Construction Emissions Assessment. The City shall require new development projects to submit a quantitative project-level construction criteria air pollutant and toxic air contaminant emissions analysis prior to the start of construction activities that shows project construction activities would not exceed BAAQMD project-level thresholds of significance to the satisfaction of the City. The analysis may rely on BAAQMD construction screening criteria to demonstrate that a detailed assessment of criteria air pollutant and toxic air contaminant construction emissions is not required for the project. If the project does not satisfy all BAAQMD construction screening criteria, the analysis shall estimate and compare construction criteria air pollutant and toxic air contaminant emissions against the project-level thresholds of significance maintained by BAAQMD and, if emissions are shown to be above BAAQMD thresholds, then the project must implement measures to reduce emissions below BAAQMD thresholds. Mitigation measures to reduce emissions could include, but are not limited to:
a) Watering exposed surfaces at a frequency adequate to maintain a minimum soil moisture content of 12 percent, as verified by moisture probe or lab sampling; b) Suspending excavation, grading, and/or demolition activities when average wind speeds exceed 20 miles per hour;
c) Selection of specific construction equipment (e.g., specialized pieces of equipment with smaller engines or equipment that will be more efficient and reduce engine runtime);
d) Installing wind breaks that have a maximum 50 percent air porosity; e) Restoring disturbed areas with vegetative ground cover as soon as possible; f) Limiting simultaneous ground-disturbing activities in the same area at any one time (e.g., excavation and grading);
g) Scheduling/phasing activities to reduce the amount of disturbed surface area at any one time;
h) Installing wheel washers to wash truck and equipment tires prior to leaving the site;
i) Minimizing idling time of diesel-powered construction equipment to no more than two minutes or the shortest time interval permitted by manufacturer’s specifications and specific working conditions;
CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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j) Requiring equipment to use alternative fuel sources (e.g., electric-powered and liquefied or compressed natural gas), meet cleaner emission standards (e.g., U.S.

EPA Tier IV Final emissions standards for equipment greater than 50- horsepower), and/or utilizing added exhaust devices (e.g., Level 3 Diesel Particular Filter);
k) Requiring that all construction equipment, diesel trucks, and generators be equipped with Best Available Control Technology for emission reductions of NOx and PM;
l) Requiring all contractors use equipment that meets CARB’s most recent certification standard for off-road heavy-duty diesel engines; and m) Applying coatings with a volatile organic compound (VOC) that exceeds the current regulatory requirements set forth in BAAQMD regulation 8, Rule 3 (Architectural Coatings).

Air Quality, Impact 3.2-3 Implementation of the Proposed Project would not expose sensitive receptors to substantial pollutant concentrations. (Less than Significant with Mitigation)
Facts in Support of Finding: Regarding construction TAC emissions, based on the preceding discussion and analysis, implementation of the Proposed Project could have a potentially significant impact with regard to construction TAC emissions that would be generated during construction, which requires mitigation. Regarding high-volume roadways, BAAQMD recommends that at least a 500-foot overlay zone should be established on each side of all freeways, high-volume roadways, railyards, Ports, rail lines using diesel locomotives. BAAQMD considers roadways with greater than 10,000 average daily traffic (ADT) as “high volume roadways”. In addition to freeways, segments of Hickey Boulevard and Fassler Avenue are expected to have ADT greater that 10,000 by 2040, accounting for the Proposed Project.

Effects of Proposed General Plan Policies and Remaining Impacts: Accordingly, General Plan Policy CO-I-52 requires contractors to use best management practices to reduce particulate emissions and dust associated with construction activities, including regular materials and vehicle tire watering; covering of stockpiles; phasing or extension of grading operations; suspension of grading during high wind periods; and revegetation of graded areas. Further, General Plan Policy CO-I-49 would continue to use the BAAQMD modeling tools and guidance documents as appropriate to identify and mitigate air quality impacts from proposed development projects, including for projects within 500 feet of a major freeway.

Rationale and Conclusion: Regarding construction TAC emissions, the City would implement Mitigation Measure AQ-1 which requires future projects that cannot meet construction screening criteria to prepare a detailed construction air quality impact assessment to: 1) estimate potential project construction emissions; 2) compare potential project construction emissions against BAAQMD project-level construction thresholds of significance; and 3) incorporate measures to reduce construction emission impacts to levels below the BAAQMD’s construction thresholds of significance for criteria air pollutants and TACs. Mitigation Measure AQ-2 would also require individual developments to review and identify permitted stationary sources within CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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1,000 feet of the project that may result in risks and hazards to new receptors. If screening-level information indicates potential stationary source risks and hazards would exceed the BAAQMD’s thresholds, the project applicant shall: 1) incorporate site and building design measures into the project that reduce exposure to pollutants; or 2) conduct refined, site-specific modeling, using the latest information and guidance from the BAAQMD, demonstrating sources risks and hazards would not exceed BAAQMD thresholds for new receptors. Therefore, with the implementation of Mitigation Measures AQ-1 and AQ-2, TAC construction emissions associated with the Proposed Project would not result in significant adverse health risks at receptor locations. This impact would be less than significant with incorporated mitigation.

Regarding high-volume roadways, Mitigation Measure AQ-3 would require projects to implement health reduction measures in order to mitigate any potential air quality impacts on sensitive receptors within 500 feet of a freeway, major roadway, or rail line. With Policy CO-I-49 and Mitigation Measure AQ-3, recommended CARB and BAAQMD overlay zones along freeways and high-volume roadways would be adhered to and the impact would be less than significant.

MM-AQ-1: Prepare Project-level Construction Emissions Assessment.

MM-AQ-2: Review Air Quality Risks to New Housing Sites. The City shall require new residential development projects to conduct a screening analysis in accordance with the Bay Area Air Quality Management District (BAAQMD) CEQA Guidelines.

Projects must also review and identify, using the BAAQMD’s publicly available Stationary Source Screening Map or another standard methodology (e.g., BAAQMD public records request), permitted stationary sources within 1,000 feet of the project that may result in risks and hazards to new receptors. If screeninglevel information indicates potential stationary source risks and hazards would exceed the BAAQMD’s thresholds, the project applicant shall: 1) incorporate site and building design measures into the project that reduce exposure to pollutants as to not exceed BAAQMD thresholds for new receptors; or 2) conduct refined, site-specific modeling, using the latest information and guidance from the BAAQMD, demonstrating sources risks and hazards would not exceed BAAQMD thresholds for new receptors. Site and building design measures that may reduce potential exposure to pollutants would include, but are not limited to, buffering/increasing the distance between sources and receptors, designing the site to limit exposure to the highest pollutant concentrations, and incorporating enhanced filter systems into heating, ventilation, and air conditioning equipment.

MM-AQ-3: Exposure to Air Pollution (Toxic Air Contaminants).

Mitigation Measure AQ-3 would apply if the project involves any residential uses (new dwelling units, excluding accessory dwelling units); and The project is located within 500 feet (or other distance as specified below) of one or more of the following sources of air pollution:
• Freeway;
• Roadway with significant traffic (at least 10,000 vehicles per day); CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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• Railyards or rail lines using diesel locomotives; and The project exceeds the health risk screening criteria after a screening analysis is conducted in accordance with the Bay Area Air Quality Management District (BAAQMD) CEQA Guidelines.

If the above three criteria are met, the following reduction measures are required. a) Health Risk Reduction Measures
Requirement: The Project applicant shall incorporate appropriate measures into the project design in order to reduce the potential health risk due to exposure of toxic air contaminants. The project applicant shall choose one of the following methods:
i. The project applicant shall retain a qualified air quality consultant to prepare a Health Risk Assessment (HRA) in accordance with California Air Resources Board (CARB) and Office of Environmental Health and Hazard Assessment requirements to determine the health risk of exposure of project residents/occupants/users to air pollutants. The HRA shall be submitted to the City for review and approval. If the HRA concludes that the health risk is at or below acceptable levels, then health risk reduction measures are not required. If the HRA concludes that the health risk exceeds acceptable levels, health risk reduction measures shall be identified to reduce the health risk to acceptable levels. Identified risk reduction measures shall be submitted to the City for review and approval and be included on the project drawings submitted for the construction-related permit or on other documentation submitted to the City. The approved risk reduction measures shall be implemented during construction and/or operations as applicable. -ORii. The project applicant shall incorporate health risk reduction measures, including but not limited to the following measures detailed below. The project applicant must retain a qualified air quality consultant to conclude that such chosen measures shall reduce the health risk to acceptable levels.

These features shall be submitted to the City for review and approval and be included on the project drawings submitted for the construction-related permit or on other documentation submitted to the City:
a. Installation of air filtration to reduce cancer risks and Particulate Matter (PM) exposure for residents and other sensitive populations in the project that are in close proximity to sources of air pollution.

Air filter devices shall be rated MERV-13 or higher. As part of implementing this measure, an ongoing maintenance plan for the building’s HVAC air filtration system shall be required. b. Where appropriate, install passive electrostatic filtering systems, especially those with low air velocities (i.e., 1 mph). c. Phasing of residential developments when proposed within 500 feet of freeways such that homes nearest the freeway are built last, if feasible.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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d. The project shall be designed to locate sensitive receptors as far away as feasible from the source(s) of air pollution. Operable windows, balconies, and building air intakes shall be located as far away from these sources as feasible.
e. Sensitive receptors shall be located on the upper floors of buildings, if feasible.
f. Planting trees and/or vegetation between sensitive receptors and pollution source, if feasible. Trees that are best suited to trapping PM shall be planted, including one or more of the following: Pine (Pinus nigra var. maritima), Cypress (X Cupressocyparis leylandii), Hybrid poplar (Populus deltoids X trichocarpa), and Redwood (Sequoia sempervirens).
g. Sensitive receptors shall be located as far away from truck activity areas, such as loading docks and delivery areas, as feasible. h. Existing and new diesel generators shall meet CARB’s Tier 4 emission standards, if feasible.
i. Emissions from diesel trucks shall be reduced through implementing the following measures, if feasible:
i. Installing electrical hook-ups for diesel trucks at loading docks.
ii. Requiring trucks to use Transportation Refrigeration Units (TRUs) that meet Tier 4 emission standards.
iii. Requiring truck-intensive projects to use advanced exhaust technology (e.g., hybrid) or alternative fuels.
iv. Prohibiting trucks from idling for more than two minutes. v. Establishing truck routes to avoid sensitive receptors in the project. A truck route program, along with truck calming, parking, and delivery restrictions, shall be implemented. b) Maintenance of Health Risk Reduction Measures
Requirement: The project applicant shall maintain, repair, and/or replace installed health risk reduction measures, including but not limited to the HVAC system (if applicable), on an ongoing and as-needed basis. Prior to occupancy, the project applicant shall prepare and then distribute to the building manager/operator an operation and maintenance manual for the HVAC system and filter including the maintenance and replacement schedule for the filter.

Cultural and Tribal Cultural Resources, Impact 3.4-2 Implementation of the Proposed Project would not cause an adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. (Less than Significant with Mitigation) Facts in Support of Finding: There are no previously recorded historic-period archaeological resources within the Proposed Project sites. However, review of historical literature and maps indicated historic-period activity within the Proposed Project Planning Area. Early San Mateo County maps indicated the project area was located within the lands of several landowners (Bromfield 1894). In addition, other San Mateo County maps indicate buildings and/or roads CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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within or immediately adjacent to these project areas (1896, 1899, 1915). With this in mind, there is a high potential for unrecorded historic-period archaeological resources to be within the Proposed Project Planning Area.

Effects of Proposed General Plan Policies and Remaining Impacts: Although implementation of the Proposed Project may result in actions that could adversely affect archaeological resources, General Plan policies and actions would minimize or avoid impacts by requiring the protection and preservation of such resources. Public Resources Code Section 21083.2 and CEQA Guidelines Section 15064.5(f) recognize that historical or unique archaeological resources may be accidentally discovered during project construction. As such, Implementing Policy CO-I-68 states that if potentially significant cultural resources are discovered during ground-disturbing activities associated with project preparation, construction, or completion, work shall halt in that area until a qualified archaeologist can assess the significance of the find, and, if necessary, develop appropriate treatment measures in consultation with San Mateo County and other appropriate agencies and interested parties. For example, a qualified archaeologist shall follow accepted professional standards in recording any find including submittal of the standard Department of Parks and Recreation (DPR) Primary Record forms (Form DPR 523) and location-specific information to the California Historical Resources Information Center office (Northwestern Information Center). The consulting archaeologist shall also evaluate such resources for significance per California Register of Historical Resources eligibility criteria (Public Resources Code Section 5024.1; Title 14 CCR Section 4852). If the archaeologist determines that the find does not meet the CEQA standards of significance, construction shall proceed. On the other hand, if the archaeologist determines that further information is needed to evaluate significance, the Community Development Department staff shall be notified, and a data recovery plan shall be prepared.

Rationale and Conclusion: In addition, Mitigation Measure CUL-1 is recommended which requires developers to conduct cultural resource awareness training as recommended by the NAHC. Specifically, this measure requires construction personnel to receive cultural awareness training on existing regulations and unanticipated discovery protocol. Therefore, the impact of implementation of the Proposed Project on archaeological resources would be less than significant, with implementation of existing State regulations, local policies, and Mitigation Measure CUL-1.

MM-CUL-1: Conduct Cultural Resources Awareness Training. Prior to the start of any ground disturbance or construction activities, the developer shall retain a qualified professional archaeologist to conduct cultural resource awareness training for construction personnel. This training shall include an overview of what cultural resources are and why they are important, archaeological terms (such as site, feature, deposit), project site history, types of cultural resources likely to be uncovered during excavation, laws that protect cultural resources, and the unanticipated discovery protocol.

Cultural and Tribal Cultural Resources, Impact 3.4-3 Implementation of the Proposed Project would not have the potential to disturb human remains, including those interred outside of formal cemeteries. (Less than Significant with Mitigation) CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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Facts in Support of Finding: Human remains, particularly those interred outside of formal cemeteries, could be disturbed during grading, excavation, or other ground-disturbing activities associated with future development or redevelopment projects allowed under the Proposed Project. Pacifica’s environmental setting and its long history of habitation by Native people make it likely that unrecorded cultural resources are present in the Planning Area. As such, there is always the possibility that subsurface construction activities associated with the Proposed Project, such as trenching and grading, could potentially damage or destroy previously undiscovered human remains.

Effects of Proposed General Plan Policies and Remaining Impacts: In the event of the accidental discovery or recognition of any human remains, CEQA Guidelines Section 15064.5, Health and Safety Code Section 7050.5, and Public Resources Code Section 5097.94 and Section 5097.98 must be followed. Compliance with these existing regulations would reduce impacts to a less than significant level.

Rationale and Conclusion: Further, implementation of Mitigation Measure CUL-1 would also reduce any potential impact on archaeological resources, including human remains, through cultural awareness training for construction personnel on unanticipated discovery protocol.

Therefore, impacts would be less than significant with implementation of existing regulations.

MM-CUL-1: Conduct Cultural Resources Awareness Training.

Cultural and Tribal Cultural Resources, Impact 3.4-4 Implementation of the Proposed Project would not cause an adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is:
(a) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or (b) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe. (Less than Significant with Mitigation)
Facts in Support of Finding: The results of the NWIC records search indicate that there is a high potential for unrecorded Native American resources to be within the Planning Area, especially in areas marginal to the coast, and inland on ridges, midslope benches, in valleys, near intermittent and perennial watercourses and near areas populated by oak, buckeye, manzanita, and pine, as well as near a variety of plant and animal resources. Therefore, future development or redevelopment projects allowed under the Proposed Project could result in indirect impacts through grading, overland construction vehicle travel, or other ground-disturbing activities, or through facilitation of public access to culturally significant sites.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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Effects of Proposed General Plan Policies and Remaining Impacts: In addition to consultation with tribes required by State law, Pacifica General Plan Implementing Policy CO-I68 ensures that new development analyzes and avoids potential impacts to archaeological resources by requiring pre-construction surveys and monitoring during any ground disturbance for all development in areas of archaeological sensitivity; and by implementing appropriate measures as a condition of project approval—such as avoidance, preservation in place, and excavation, —to reduce or avoid impacts. In the event that archaeologic resources are accidentally discovered during construction, grading activity in the immediate area shall cease and materials and their surroundings shall not be altered or collected. A qualified archaeologist or paleontologist must make an immediate evaluation and avoidance measures, or appropriate mitigation should be completed, according to CEQA Guidelines. The State Office of Historic Preservation has issued recommendations for the preparation of Archaeological Resource Management Reports that may be used as guidelines. In addition, the City’s General Plan Implementing Policy CO-I-70 incorporates the recommendations from the Amah Mutsun Tribal Band of San Juna Bautista.

Rationale and Conclusion: Mitigation Measure CUL-1 is required for all developments under the Proposed Project since they are all located in areas marginal to the Pacific Ocean and inland along areas of the first coastal range which have a high potential for uncovering archaeological deposits or tribal cultural resources. This measure requires construction personnel to receive cultural awareness training on existing regulations and unanticipated discovery protocol. Overall, compliance with existing regulations, General Plan policies, and implementation of Mitigation Measure CUL-1 would reduce impacts to the maximum extent practicable. Impacts would be less than significant with mitigation.

MM-CUL-1: Conduct Cultural Resources Awareness Training.

Noise, Impact 3.9-1 New development under the Proposed Project would not generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. (Less than Significant with Mitigation) Facts in Support of Finding: The Proposed Project would not result in noticeable changes in traffic noise levels relative to 2040 conditions without the Project at any roadway segment.

However, where noise would be greater than the “Normally Acceptable” noise level in 2040, a traffic noise impact is considered to be potentially significant. Many of the Proposed Project sites (shown as R-#, MU-#, and MU-I-# in Table 3.9-5) are located in contours that are not normally acceptable for multifamily residential uses. Some small portions of the sites adjacent to SR 1 fall within the “clearly unacceptable” range, including sites 10,11, 12, 18, 25, 38, and J.

Effects of Proposed General Plan Policies and Remaining Impacts: The California Building Code and General Plan policies require that projects incorporate buffering and other noise design features that reduce noise to less than significant levels. The City’s General Plan policies NO-G-3, NO-I-1, and NO-I-2 outline noise exposure regulations for sensitive receptors if noise levels exceed current guidelines. Policy NO-I-7 directs the City to work with Caltrans and Sam Trans to mitigate transportation-related noise impacts on residential areas and sensitive uses, including encouraging installation of sound barriers or bus stop relocation in select locations. Actions to CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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mitigate noise levels are required if exterior noise levels exceed these standards. The interior noise exposure level for residences, schools, and other noise sensitive development is limited to 45 dBA, consistent with State noise standards.

Rationale and Conclusion: Sites within “clearly unacceptable” noise contours will also be subject to Mitigation Measure NO-1, which requires specific acoustical noise analysis. As such, implementation of General Plan policies and compliance with the California Building Code would ensure potential noise impacts to sensitive receptors along major roadways in the Planning Area will be less than significant despite increases in traffic noise.

MM-NO-1: Acoustical Noise Analysis and Mitigation. Prior to the construction of sites 10, 11, 12, 18, 24, 38, and J, an acoustical noise analysis shall be prepared prior to the submittal of final tentative tract maps for review and approval by the City to ensure that exterior and interior noise levels are met. The acoustical analysis shall demonstrate that the buildings have been designed to limit interior noise levels to 45 dBA CNEL and exterior noise (backyards and habitable balconies and patios) to less than 65 dBA CNEL. Individual developments shall, to the extent feasible, implement site-planning techniques which include but are not limited to the following:
• Increase the distance between the noise source and the receiver; • Use non-noise sensitive structures such as garages to shield noise-sensitive areas;
• Orienting buildings to shield outdoor spaces from a noise source; • Individual developments shall incorporate architectural design strategies, which reduce the exposure of noise-sensitive spaces to stationary noise sources (i.e., placing bedrooms or balconies on the side of the structure facing away from noise sources). These design strategies shall be implemented based on recommendations of acoustical analysis for individual developments as required by the City to comply with City noise standards; • Individual developments shall incorporate noise barriers, walls, or other sound attenuation techniques, based on recommendations of acoustical analysis for individual developments as required by the City to comply with City noise standards; and
• Elements of building construction (i.e., walls, roof, ceiling, windows, and other penetrations) shall be modified as necessary to provide sound attenuation. This may include sealing windows, installing thicker or doubleglazed windows, locating doors on the opposite side of a building from the noise source, or installing solid-core doors equipped with appropriate acoustical gaskets
The City shall require that the noise attenuation measures be installed and be verified as effective in meeting the 45 (interior) and 65 (exterior) dBA CNEL CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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requirement by an acoustical engineer prior to the issuance of certificates of occupancy.

Utilities and Service Systems, Impact 3.12-1 Implementation of the Proposed Project would not require or result in the relocation or construction of new or expanded water, or wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects. (Less than Significant with Mitigation) Facts in Support of Finding: The City’s Housing Element states that rainfall dependent infiltration/inflow (RDI&I) is a chronic issue that impacts the capacity of Pacifica’s sewer pump stations. Additional infrastructure improvement projects would occur along Crespi Drive, Linda Mar Boulevard, Fremont Avenue, and Catalina Avenue to increase capacity of peak wet weather flows, as detailed in the Environmental Setting. It is also anticipated that two rehabilitation and replacement (R&R) projects in the Vallemar and Rockaway Beach communities which have been included in the City’s adopted 2023-2028 Capital Improvement Plan will address this issue. The City commissioned an analysis to evaluate the effectiveness of these planned rehabilitation and replacement projects and determined the current Rockaway Pump Station could support up to an additional 200 units in these neighborhoods.

Effects of Proposed General Plan Policies and Remaining Impacts: The City has commissioned an additional analysis and modeling study to better evaluate and understand the current capacity of the Rockaway Pump Station. Since the results are not yet known, it is not clear whether the Rockaway Pump Station will have adequate capacity to serve additional units over 200. Further, while the R&R projects discussed above are intended to address these issues, the timing of this projects is still not certain. Therefore, the impacts are potentially significant.

Rationale and Conclusion: Potential impacts would be mitigated by implementation of MM UTIL-1 below. With adherence to MM-UTIL-1, this impact is considered less than significant with mitigation incorporated regarding wastewater treatment conveyance infrastructure.

MM-UTIL-1: Infiltration/Inflow (I/I) Reductions in Rockaway Area. Developers of any project served by the Rockaway Pump Station are required to have a study performed to determine the capacity of the pump station to serve proposed development, which study would be subject to review and approval by the City’s Public Works Department. In the event that it is determined that the Rockaway Pump Station does not have sufficient capacity to serve the proposed development, the developer must pursue one or more of the following options, to the satisfaction of the Public Works Department, to either reduce I/I or pursue alternative methods of conveyance:
• Installation of systemwide upgrades to infrastructure for the purposes of eliminating sanitary sewer spills and reducing I/I.
• Rerouting of sewer flows such that the development does not negatively impact the Rockaway Pump Station.
• Installation of a new pump station facility.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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• Installation of new infrastructure improvements to contribute to the necessary reduction of I/I.

SIGNIFICANT AND UNAVOIDABLE IMPACTS
Under Public Resources Code section 21081(a)(1) and CEQA Guidelines sections 15091(a)(1) and 15092(b), the City determines that the following significant effects on the environment, as reflected in the EIR, and as mitigated as shown below, remain significant and unavoidable despite the fact that changes or alterations to the Project have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effects identified in the EIR. Further, the City finds that the following significant and unavoidable impacts are acceptable due to the overriding considerations described below. The City also finds that further mitigation measures and a No Project Alternative that may reduce the significance of any of these impacts are rejected as infeasible for the reasons given below.

Impact 3.5-1 Implementation of the Proposed Project would generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. (Significant and Unavoidable)
Facts in Support of Finding: With the consideration of General Plan policies, GHG operational emissions under the 2040 General Plan with Proposed Project scenario were reduced an additional 14,210 MTCO2e, from 86,864 MTCO2e to 72,654 MTCO2e. At a minimum, the Proposed Project would need to meet the 2030 target, which is within the planning period.

Operational emissions under the Proposed Project are on track to meet the target of 40 percent below 1990 levels by 2030 with an estimated 54 percent reduction in emissions. However, the emissions under the Proposed Project would need to be reduced by an additional 48,773 MTCO2e in order to meet the State’s more stringent 2045 goal of carbon neutrality or 85 percent below 1990 levels.

Effects of Proposed General Plan Policies and Remaining Impacts: As the transportation and energy sectors are the largest source of emissions within the Planning Area in 2020 and are projected to remain the largest sources in 2040, these sectors have the most opportunity for reductions. There are many General Plan policies that aim to reduce GHG emissions. Such policies relate to pedestrian improvements, increased connectivity, streetscape improvements, traffic calming measures, transit service, trip reduction programs, clean City fleet, increased density and affordability, reduced parking, water conservation, waste reduction, commute trip reduction programs, municipal energy efficiency, and outdoor lighting. In addition, General Plan policy CO-I-59 requires the City to maintain and update the Climate Action Plan (CAP). Given that the updated CAP and GHG reduction measures are not yet available, the GHG reduction potential cannot be quantified for the purposes of this analysis.

Implementation of the Proposed Project would reduce generation of GHG emissions by 40 percent compared to existing conditions. This reduction is on track to meet the State’s 2030 goal; however, it is not on track to meet the State’s 2045 goal nor Pacifica’s 2050 CAP goal. Therefore, on a local scale, implementation of the Proposed Project would generate GHG emissions that CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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could have a significant impact on the environment and this impact would be potentially significant and mitigation measures would be required.

Rationale and Conclusion: Implementation of MM-GHG-1 and MM-GHG-2 would reduce transportation- and energy-related GHG emissions because they include quantifiable targets for the expansion of Zero Emissions Vehicles and renewable energy; and voluntary Mitigation Measure MM-GHG-3 would support energy efficiency in the Planning Area. However, it is conservatively assumed that additional reductions are needed in order to meet the CAP’s 2050 and State’s 2045 targets. Without further State action, it is unlikely that local efforts alone would be sufficient to meet carbon neutrality by 2045 and thereby reduce the impact to a less-thansignificant level. Moreover, CARB’s 2022 Scoping Plan indicates that carbon sequestration from natural and working lands will not be enough to attain carbon neutrality, and doing so will require research, development, and implementation of additional measures. CARB maintains authority to adopt regulations as necessary to meet future GHG targets under SB 32, EO S-3-05, EO B-55-18, and AB 1279, but the specific path to carbon neutrality is unknown and dependent on development of technologies and programs that are not currently known or available.; therefore, this impact remains significant and unavoidable after mitigation.

MM-GHG-1: For new residential and commercial development, require installation of the electric vehicle recharging station network and other alternative fuel vehicle support infrastructure and adopt requirements for electric vehicle parking in new developments, consistent with Title 24 requirements, with the goal of increasing electric vehicle ownership by 20 percent.

MM-GHG-2: In order to build upon the requirements of existing State law, require installation of photovoltaic systems in new single family residential, multifamily residential, and commercial to increase solar capacity, with a target of an equivalent of 15 percent of projected electricity by 2040. Photovoltaic panel installation is already required for new low-rise residential buildings which include single-family dwellings, and multi-family dwellings with three habitable stories or less pursuant to California Energy Code section 150.1.c.14. Photovoltaic panel installation is also required for new nonresidential buildings with three habitable stories or fewer, other than health care facilities; hotel/motel occupancies; and, high-rise multi-family buildings with 10 habitable stories or fewer, pursuant to a local amendment to the California Energy Code codified in PMC section 8-6.08.

MM-GHG-3: Develop and implement a program to encourage the use of available grants for residential and commercial efficiency retrofits and voluntary cool roofing practices in new development with the goal of a 50 percent energy reduction compared to baseline in 30 percent of the total existing residential units and nonresidential square feet citywide by 2040. This measure is voluntary.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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FINDINGS
Based on the EIR and the entire record before the Council, the Council finds that there are no feasible mitigation measures that would reduce the impact of the generation of greenhouse gas emissions that may have a significant impact on the environment with implementation of the Proposed Project. Although the City’s CAP and General Plan polices reduce this impact, the Council finds the impact significant and unavoidable.

Impact 3.5-2 Implementation of the Proposed Project would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases. (Significant and Unavoidable)
Facts in Support of Finding: The City of Pacifica adopted a CAP in 2014 to reduce community and municipal GHG emissions. The City’s CAP is a roadmap that outlines a path for the City to achieve its GHG reduction goals of 35 percent below 2005 levels by 2020, and 80 percent below 1990 levels by 2050. The CAP features goals and reduction strategies in the categories of energy, transportation and land use, solid waste, water, and education and outreach. General Plan policies, which development under the Proposed Project must adhere to, directly support all CAP measures.

Effects of Proposed General Plan Policies and Remaining Impacts: General Plan policy CO-I59 requires the City to maintain and update the CAP based on the General Plan update, which would include the Proposed Project. As part of the update, the CAP must set a target for the reduction of GHG emissions, in line with targets established by the State, which would include the 2045 carbon neutrality target. However, as discussed in Impact 3.5-1, it is conservatively assumed that additional reductions are needed in order to meet the CAP’s 2050 and State’s 2045 targets.

MM-GHG-1: For new residential and commercial development, require installation of the electric vehicle recharging station network and other alternative fuel vehicle support infrastructure and adopt requirements for electric vehicle parking in new CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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developments, consistent with Title 24 requirements, with the goal of increasing electric vehicle ownership by 20 percent.

FINDINGS
Based on the EIR and the entire record before the Council, the Council finds that there are no feasible mitigation measures that would reduce the impact of conflicting with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases with implementation of the Proposed Project. Although the City’s CAP and General Plan polices reduce this impact, the Council finds the impact significant and unavoidable.

Impact 3.11-2 Implementation of the Proposed Project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). (Significant and Unavoidable) Facts in Support of Finding: CEQA Guidelines Section 15064.3 requires that the determination of significance for transportation impacts be based on VMT instead of a congestion metric such as LOS. The change in the focus of transportation analysis is the result of SB 743. For the purposes of this EIR, the following thresholds of significance are used to determine if the proposed General Plan has an impact under the terms of Criteria 2:
(a) Vehicle Miles Traveled: 1. A significant impact would occur if the proposed General Plan Update increases the Vehicle Miles Traveled (VMT) per person above the baseline conditions.

In the case of the Proposed Project scenario, the baseline condition is considered the 2015 No Project condition, as established for the current General Plan EIR. Table 3.11-5 also establishes thresholds based on a 15 percent reduction from the various baseline VMT rates. The threshold of significance based on a 15 percent reduction would be a VMT per capita of 13.4 miles per resident CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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for the City of Pacifica; and a home-based work VMT per employee of 14.2 at the countywide level.

Table 3.11-5 summarizes the VMT calculations for Pacifica under the 2015 Base Year, 2040 Preferred General Plan, and 2040 Proposed Project conditions. As expected with the addition of multifamily units and retail employment, the VMT per capita for Pacifica is expected to drop to

12.4 by 2040 under the Proposed Project scenario, which is below the threshold of significance.

The Pacifica VMT per employee for the Proposed Project scenario also decreases relative to the Preferred General Plan scenario. However, the resulting VMT per employee under the 2040 Proposed Project scenario is 19.83, which falls above the threshold of significance. Home-based work VMT per employee for jobs located in Pacifica is expected to increase by 22.9 percent under the Proposed Project. While VMT per capita would decrease by 8.6 percent and home-based VMT would increase by only 0.5 percent, these rates all fall above the threshold of significance.

Effects of Proposed General Plan Policies and Remaining Impacts: Buildout under the Proposed Project would be required to comply with several General Plan policies that reflect multiple recommended California Air Pollution Control Officers Association (CAPCOA) strategies, resulting in additional reduction in the significant VMT per employee impact from new development under the Proposed Project. Specifically, General Plan Implementing Policy CII-50 would reduce potential impacts by requiring TDM measures for developments that exceed the CMP threshold for impacts and by requiring a monitoring plan to determine if established trip reduction targets are met or exceeded for individual developments. Additionally, General Plan goals and policies strive to develop a multi-modal transportation network that would provide transportation alternatives to the single-occupant vehicle and encourage complete street design.

The City will implement all applicable policies in the General Plan Circulation Element to reduce the demand for vehicle travel within and through the Planning Area, as well as work with local, regional, and state agencies to implement regional transportation improvements. Additionally, new developments under the Proposed Project would be required to evaluate their projectspecific impacts on the transportation system and fund improvements to maintain acceptable levels of service, except where exemptions are identified in the Circulation Element of the General Plan. However, even with implementation of these policies, the impact would remain significant and unavoidable and require further mitigation.

Rationale and Conclusion: In order to further reduce VMT per employee, mitigation measures VMT-1 and VMT-2 are recommended. These measures would require businesses that employ 20 or more people to implement an employee commute trip reduction program as well as encourage telecommuting. Implementation of commute trip reduction programs and remote work options could reduce VMT per employee, however it is difficult to quantify the exact reduction potential of these mitigation measures as MM-VMT-1 applies only to new non-residential development of a certain size and MM-VMT-2 is a voluntary measure. MM-VMT-2 responds to the recent surge of remote and hybrid work schedules following the COVID-19 pandemic. While both measures could reduce VMT metrics, it is unlikely that either would be sufficient in reducing these metrics to the proposed thresholds and the impact would conservatively remain significant and unavoidable.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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MM-VMT-1: Require applicants for non-residential projects that employ 20 of more people— which is equivalent to 12,000 square feet of retail space, 6,000 square feet of office space, 20,000 square feet of industrial space, or 22 hotel rooms to implement an employee commute trip reduction (CTR) program approved by the City. The CTR program shall identify alternative modes of transportation to the project, including transit schedules, bike and pedestrian routes, and carpool/vanpool availability. Information regarding these programs shall be readily available to employees and clients. The project applicant or designee shall implement at least one of the following incentives for commuters as part of the CTR program, or another equally effective incentive:
• Ride-matching assistance
• Subsidized public transit passes
• Vanpool assistance or employer-provided vanpool/shuttle • Car-sharing program (e.g. Zipcar)
• Bicycle end-trip facilities, including bike parking, lockers, and showers.

MM-VMT-2: Encourage businesses to implement telecommuting, hybrid, and alternative work schedules that allow employees to utilize remote work options while reducing vehicle-based commutes.

FINDINGS
Based on the EIR and the entire record before the Council, the Council finds that there are no feasible mitigation measures that would reduce the impact of VMT per employee with implementation of the Proposed Project. Although there are polices in the General Plan to reduce this impact, the Council finds the impact significant and unavoidable.

Alternatives
The Final EIR analyzed two alternatives to the Project, examining the environmental impacts and feasibility of each alternative, as well as the ability of the alternatives to meet Project objectives.

The Project objectives are listed in Chapter 2 (Project Description) of the Draft EIR; the potentially significant environmental effects of the Project, including feasible mitigation measures identified to avoid these impacts, are analyzed in Chapter 3 (Environmental Evaluation) of the Draft EIR; and the alternatives are described in detail in Chapter 4 (Alternatives to the Proposed Project) of the Draft EIR. Brief summaries of the alternatives are provided below. A brief discussion of the Environmentally Superior Alternative follows the summaries of the alternatives.

All analysis in Final EIR Chapter 4 is incorporated by reference.

ALTERNATIVE 1: NO PROJECT ALTERNATIVE
Consistent with Section 15126.6(e)(2) of the CEQA Guidelines, the No Project Alternative represents what would be reasonably expected to occur in the foreseeable future if the Proposed Project were not implemented. Under this scenario, implementation of the existing Pacifica General Plan 2040 would continue, excluding the implementation of Program HE-1-1 which is CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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Proposed Project’s General Plan Amendments and Rezoning Program and Objective Development Standards. Under this Alternative, there would be no changes to the current zoning and General Plan land use designations in order for the City to accommodate its share of regional housing. However, development would still occur at many of the Proposed Project sites identified for development under the No Project Alternative. Since the sites are not being rezoned, they would be developed at densities that the current Zoning Code permits which is much lower than the rezoned densities under the Proposed Project.

The No Project Alternative is infeasible, as it would not meet the project objective of achieving the RHNA and would not be consistent with State law. However, the alternatives analysis will still include and assess the No Project Alternative as required by CEQA.

ALTERNATIVE 2: HIGH DENSITY SHOPPING CENTERS ALTERNATIVE In order to reduce the Proposed Project’s significant and unavoidable impact on vehicle miles traveled (VMT), the High Density Shopping Centers Alternative was designed. This Alternative aims to focus housing within Pacifica’s existing commercial centers and promote a more intense mixed-use development pattern. The Alternative would modify objective development standards to increase density and heights on parcels located in the Linda Mar, Fairmont, Brentwood, Pacifica Manor, and Park Mall shopping centers, and decrease the amount of development on largely vacant sites, including the Caltrans right-of-way to the northeast, and the area between Reina Del Mar Ave and Rockaway Beach Ave.

Compared to the Proposed Project, Alternative 2 would increase densities and heights at sites 28, 29, 32, 16A, 16B, and 27B. Densities would be increased up to 80 dwelling units per acre and heights of up to 75 feet for MU- designation and 70 feet for R- designation. Alternative 2 would also reduce densities and heights at sites 2, 10, 11, 12, 21, 25, G, H, I, J. Those sites currently designated as MU-60 or R-60 would be reduced to MU-50 or R-50. Those sites currently designated as MU-40 or R-40 zones would be reduced to MU-30 or R-30. Alternative 2 would still contain approximately the same amount of residential development as the Proposed Project, but less commercial development.

ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA Guidelines require the identification of an environmentally superior alternative among the alternatives analyzed in an EIR. The Guidelines also require that if the No Project Alternative is identified as the environmentally superior alternative, then another environmentally superior alternative must be identified.

The No Project Alternative reduces the greatest number of environmental impacts. Since the CEQA guidelines require another environmentally superior alternative other than the No Project Alternative to be identified, the High Density Shopping Center Alternative would be the environmentally superior alternative. However, the Alternative does not meet the Project’s objective of reflecting community priorities that value coastal views and scenic vistas.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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Proposed Project Benefits
CEQA does not require lead agencies to analyze “beneficial impacts” in an EIR. Rather, EIRs focus on potential “significant effects on the environment” defined to be “adverse” (Public Resources Code Section 21068). Nevertheless, decision makers may be aided by information about project benefits. These benefits can be cited, if necessary, in a statement of overriding considerations (CEQA Guidelines Section 15093). The Council’s decision to adopt the proposed General Plan rather than any of the alternatives is based on considering the balance of these benefits of the Project against its identified unavoidable environmental impacts.

Each benefit of the proposed Project, as stated below, is determined to be a basis for overriding all unavoidable adverse environmental impact identified above. This Statement of Overriding Considerations sets forth the specific reasons supporting the Council’s actions in approving the Proposed Project. In making this Statement of Overriding Considerations in support of the findings of fact and the project, the Council has considered the information contained in the Findings and in the documents comprising the record of proceedings for the project.

CEQA Guidelines Section 15093(a) provides the following guidance for a statement of overriding considerations:

CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable.” The results of the environmental analysis on the Proposed Project are discussed in detail in the Draft EIR, the Final EIR, and the Findings. The Council reached the conclusions below pursuant to Public Resources Code Section 21081 and State CEQA Guidelines Section 15093. The following statements describe the Proposed Project’s benefits considered by decisionmakers in determining whether to adopt the Proposed Project despite its potentially significant adverse environmental effects. The Council concludes that any one of the statements below is independently sufficient to justify approval of the project. The substantial evidence supporting the various benefits of the project can be found in public records on the General Plan update process, which are incorporated by reference into this section, and in the documents found in the Record of Proceedings.

Statement 1: The Proposed Project prioritizes open space preservation and infill development. Pacifica’s scenic vistas, hillsides, beaches, and other protected open space are prized by community members for their scenic, recreational, and habitat values. Continued preservation is seen as a key accomplishment over the next 20 years. The Proposed Project reflects the priority given in the General Plan and Housing Element to focus redevelopment in existing commercial shopping centers and other already-developed areas.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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Statement 2: The Proposed Project promotes sustainable development and practices. Pacifica residents want to allow a responsible amount of development while ensuring that habitat and the community’s unique, small-town character are protected. Residents also want to see green building and other sustainable practices promoted by the City. The Project adheres to General Plan and Housing Element policies that aim to set a good land use balance and to promote sustainable site planning and design, water conservation, waste reduction, and use of alternative transportation modes.

Statement 3: The Proposed Project revitalizes shopping areas and produces walkable, mixeduse areas. Pacifica residents desire more attractive and successful commercial areas, and also envision the development of walkable, mixed-use areas with good transit access. The Plan seeks to support commercial revitalization and redevelopment at key locations, advancing the City’s fiscal health, its quality of life, and its sustainability all at once.

Statement 4: The Proposed Project creates a unique, vital center for Pacifica. Many community members expressed interest in creating a center for Pacifica, to provide a community gathering place and strengthen the City’s identity. Palmetto Avenue was most often pointed to as having great potential to grow into such a vital, unique district. The Project aims to facilitate the enhancement of Palmetto as a pedestrian-oriented retail area, anchored by new mixed-use development at the Pacifica Manor Shopping Center parking lot.

Statement 5: The Proposed Project ensures diversity of housing and population. Residents are proud of the diversity of housing in the community and want to ensure that this is carried on. As such, the General Plan Amendments and Rezoning component of Program HE-I-1 will redesignate and rezone sites within the City to allow the additional 2,042 housing units. The Project aims to make Pacifica more accessible and ensure adequate housing options for people of all ages and incomes by providing enough sites at a higher density and creating opportunities for mixed-use development in transit-accessible locations.

Statement 7: The Proposed Project improves existing infrastructure. The need for the City to maintain and improve existing infrastructure was a clear consensus point for the community.

Most notable is the chronic issue of rainfall dependent infiltration/inflow (RDI&I) that impacts the capacity of Pacifica’s sewer pump stations. The Project supports coordination and solutions to better evaluate and understand the current capacity of the Rockaway Pump Station. The Project would ensure that the Rockaway Pump Station has sufficient capacity to serve all proposed development or alternative methods of conveyance are pursued.

These key goals and initiatives were developed through an extensive public outreach process that accompanied the General Plan, which engaged stakeholders, decision-makers, the General Plan Outreach Committee, and members of the general public in discussion and debate over priorities for Pacifica’s future. Members of the public as well as elected officials were consulted and engaged at each key decision point in the update process, ensuring that the proposed General Plan reflects the community’s priorities to the greatest extent possible. During this public process, the Council examined alternatives to the Proposed Project, none of which meet the stated project objectives to the same extent as the Proposed Project.

CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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Overriding Considerations Conclusions
The Council finds that the proposed City of Pacifica Housing Element Targeted General Plan Amendments and Rezoning Program (6th Cycle) has been carefully reviewed and that mitigating policies have been included in the Final EIR to be certified by the Council. Nonetheless, the Proposed Project may have certain environmental effects that cannot be avoided or substantially lessened. As to these significant environmental effects that are not avoided or substantially lessened to a point less than significant, the Council finds that specific fiscal, economic, social, technological, or other considerations make additional mitigation of those impacts infeasible, in that all feasible mitigation measures have been incorporated into the Proposed Project.

The Council has carefully considered all of the environmental impacts that have not been mitigated to a less than significant level, as listed above. The Council has also carefully considered the fiscal, economic, social, and environmental benefits of the proposed General Plan, as listed above, and compared these with the benefits and impacts of the alternatives, which were evaluated in the Final EIR. The Council has balanced the fiscal, economic, social, and environmental benefits of the Proposed Project against its unavoidable and unmitigated adverse environmental impacts and, based upon substantial evidence in the record, has determined that the benefits of the Proposed Project outweigh, and therefore override, the remaining adverse environmental effects. Such benefits provide the substantive and legal basis for this Statement of Overriding Considerations.

In approving the Proposed Project, the Council makes the following Statement of Overriding Considerations pursuant to Public Resources Code Section 21081 and State CEQA Guidelines Section 15093 in support of its findings on the Final EIR:

The Council has considered the information contained in the Final EIR and has fully reviewed and considered all of the public testimony, documentation, exhibits, reports, and presentations included in the record of these proceedings. The Council specifically finds and determines that this Statement of Overriding Considerations is based upon and supported by substantial evidence in the record.

The Council has carefully weighed the benefits of the Proposed Project against any adverse impacts identified in the Final EIR that could not be feasibly mitigated to a level of insignificance, which are enumerated below. While the Council has required all feasible mitigation measures, such impacts remain significant for purposes of adopting this Statement of Overriding Considerations:
§ Impact 3.5-1 Implementation of the Proposed Project would generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. (Significant and Unavoidable) § Impact 3.5-2 Implementation of the Proposed Project would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases. (Significant and Unavoidable)
CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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§ Impact 3.11-2 Implementation of the Proposed Project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). (Significant and Unavoidable)

FINDINGS
Pursuant to CEQA Guidelines section 15091(a)(3), specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the Final EIR. These specific considerations have been analyzed in the context of the Proposed Project and the Project alternatives. Based on the evidence in the record, the City Council finds the Proposed Project is critical in meeting key General Plan guiding policies relating to economic sustainability, community design, land use, circulation, open space and community facilities, conservation safety, and noise.

This Statement of Overriding Considerations applies specifically to those impacts found to be significant and unavoidable as set forth in the Final EIR and the record of these proceedings. In addition, this Statement of Overriding Considerations applies to those impacts that have been substantially lessened but not necessarily lessened to a level of insignificance.

Based upon the goals and objectives identified in the Proposed Project and the Final EIR, following extensive public participation and testimony, and notwithstanding the impacts that are identified in the Final EIR as being significant and potentially significant and which arguably may not be avoided, lessened, or mitigated to a level of insignificance, the Council, acting pursuant to Public Resources Code Section 21081 and Section 15093 of the State CEQA Guidelines, hereby determines that specific economic, legal, social, environmental, technological, and other benefits and overriding considerations of the Proposed Project sufficiently outweigh any remaining unavoidable, adverse environmental impacts of the Proposed Project and that the Proposed Project should be approved.

Based on the foregoing and pursuant to Public Resources Code section 21081 and State CEQA Guidelines Section 15093, the Council further determines that the unavoidable adverse environmental effects of the Proposed Project are acceptable, and that there are overriding considerations that support the Council’s approval of the Proposed Project, as stated in the above sections.

The Council believes that it is prudent to select the Proposed Project over the alternatives because it creates the regulatory framework to accommodate the city’s regional housing need, and most closely embodies the project objectives. In making this determination, the Council incorporates by reference all of the supporting evidence cited within the Draft and Final EIR, and in the administrative record.

In reaching this conclusion and approving the Proposed Project:
• The Council has considered the information contained in the Final EIR and fully reviewed and considered all of the public testimony, documentation, exhibits, reports, and presentations included in the record of these proceedings. The Council specifically CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica Housing Element GP Amendments and Rezoning Program EIR

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finds and determines that this Statement of Overriding Considerations is based upon and supported by substantial evidence in the record.
• The Council has carefully weighed the benefits of the Proposed Project against any adverse impacts identified in the Final EIR that could not be feasibly mitigated to a level of insignificance. While the Council have required all feasible mitigation measures, some impacts remain potentially significant.

This Statement of Overriding Considerations applies specifically to those impacts found to be potentially significant and unavoidable as set forth in the Final EIR and the record of these proceedings.

Pacifica City CouncilAugust 11, 2025

Pacifica City Council
August 11, 2025