Agenda packet — Pacifica City Council, December 2, 2025 (part 3 of 8)

1.1 TYPE AND PURPOSE OF THE EIR
The 570 Crespi Drive Project Environmental Impact Report (EIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) of 1970, Public Resource Code (PRC) Sections 21000-21189, as amended, and the Guidelines for Implementation of the California Environmental Quality Act, California Code of Regulations (CCR) Title 14, Sections 15000-15387 (CEQA Guidelines). The City of Pacifica is the lead agency for the environmental review of the 570 Crespi Drive Project (proposed project) evaluated herein and has the principal responsibility for approving the project. As required by Section 15121 of the CEQA Guidelines, this EIR will (a) inform public agency decision-makers, and the public generally, of the environmental consequences of approving the proposed project, (b) identify possible ways to minimize the significant adverse environmental effects, and (c) describe reasonable and feasible project alternatives which reduce environmental effects. The lead agency is required to consider the information in the EIR along with any other available information in deciding whether to approve the application. The basic requirements for an EIR include discussions of the environmental setting, environmental impacts, mitigation measures, alternatives, growth inducing impacts, and cumulative impacts.

As provided in the CEQA Guidelines Section 15021, public agencies are charged with the duty to avoid or minimize environmental damage where feasible. The public agency has an obligation to balance a variety of public objectives, including economic, environmental, and social issues.

CEQA requires the preparation of an EIR prior to approving any project that may have a significant effect on the environment. For the purposes of CEQA, the term “project” refers to the whole of an action, which has the potential for resulting in a direct physical change or a reasonably foreseeable indirect physical change in the environment (CEQA Guidelines Section 15378[a]).

With respect to the proposed project, the City has determined that the proposed mixed-use project is a project within the definition of CEQA, which has the potential for resulting in significant environmental effects.

The CEQA Guidelines identify several types of EIRs, each applicable to different project circumstances. This EIR has been prepared as a project-level EIR pursuant to CEQA Guidelines Section 15161, which is an analysis that examines the environmental impacts of a specific development project. A project-level EIR focuses primarily on the changes in the environment that would result from the development of the project, and examines all phases of the project including planning, construction, and operation.

1.2 KNOWN RESPONSIBLE AND TRUSTEE AGENCIES
“Responsible agency” means a public agency that proposes to carry out or approve a project for which a lead agency is preparing or has prepared an EIR or Negative Declaration. For the purpose of CEQA, the term responsible agency includes all California public agencies other than the lead agency that have discretionary approval power over the project or an aspect of the project. The San Francisco Regional Water Quality Control Board (RWQCB) and Bay Area Air Quality Management District (BAAQMD) are identified as potential responsible agencies.

1. INTRODUCTION
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“Trustee agency” means a State agency having jurisdiction by law over natural resources affected by a project, which are held in trust for the people of the State of California. The only known possible trustee agency for the project is the California Department of Fish and Wildlife (CDFW).

Although not subject to California law, and, thus, outside the definitions of responsible agency or trustee agency, the U.S. Army Corps of Engineers (USACE), U.S. Fish and Wildlife Service (USFWS), and Federal Emergency Management Agency (FEMA) may also be called upon to grant approvals under federal law necessary for the development of the proposed project. The above agencies do not have duties under CEQA, but, rather, are governed by a variety of federal statutes, such as the Clean Water Act, which governs the dredging and filling of waters of the U.S. (e.g., wetlands), and the federal Endangered Species Act, which requires USACE to consult with the USFWS as part of the review process for any wetland or fill permits that may be required.

1.3 PROJECT SUMMARY
A summary of the project location, description, and approvals is provided below. Please refer to Chapter 3, Project Description, of this EIR for a detailed description of the proposed project and entitlements, as well as a full list of the project objectives.

Project Location
The proposed project would include development on a 1.68-acre project site comprised of two parcels in the City of Pacifica, California. Parcel 1 is located at 570 Crespi Drive (Assessor’s Parcel Number [APN] 022-162-310) and is designated Mixed Use Center in the City of Pacifica General Plan 2040. Parcel 2 is located on a portion of APN 022-162-420 located at 540 Crespi Drive. The northern portion of Parcel 2 is designated Public and Semi Public, while the southern half is designated Park. Both sites are zoned Controlled Manufacturing District (M-1). Surrounding land uses include the Pacifica Community Center, Pacifica Skatepark, and State Route (SR) 1 to the west; commercial businesses and Ocean View Senior Apartments to the north, across Crespi Drive; the Cabrillo Elementary School and commercial businesses to the east; and single-family residences to the south.

Project Description
The proposed project would include a two-story mixed-use building (Building A) and two threestory residential buildings (Buildings B and C). The project would also include a condominium subdivision to create one commercial condominium and 19 residential condominiums. Building A would consist of 3,165-square feet (sf) of commercial space on the ground floor and three residential units totaling 3,692 sf on the second floor for a total building square footage of 6,857 sf. Building B would consist of seven townhomes totaling 16,196 sf, and Building C would consist of nine townhomes totaling 20,643 sf, for a project-wide total of 19 units. All three buildings would be constructed on the northernmost half of the site, while the southernmost half of the site would remain undisturbed. A portion of the units would be ownership Below Market Rate (BMR) units pursuant to the City’s Inclusionary Ordinance. In addition, the project would involve off-site improvements, including removal of two trees and construction of a new driveway associated parking spaces north of the existing Pacifica Community Center located at 540 Crespi Drive.

The proposed project would require approval of a General Plan Amendment, Rezone, Zoning Text Amendment, Use Permit, Site Development Permit, Development Agreement, Parking Exception, Sign Permit, Tree Permit, Tentative Subdivision Map, Lot Merger and/or Lot Line Adjustment (LLA). The Development Agreement, among other things, would require the proposed IL

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project to provide affordable units, and construct a driveway and 17 parking spaces at the adjacent Community Center.

1.4 EIR PROCESS
Pursuant to CEQA Guidelines Section 15063, following preliminary review, the Lead Agency shall conduct an Initial Study to determine if the project may have a significant effect on the environment. If the Lead Agency can determine that an EIR will clearly be required for the project, an Initial Study is not required but may still be desirable. The purpose of an Initial Study includes, but is not limited to, providing the Lead Agency with information to use as the basis for deciding whether to prepare an EIR. Furthermore, an Initial Study may assist in the preparation of an EIR (if one is required) by focusing the EIR on the effects determined to be potentially significant. (CEQA Guidelines Section 15063(c)(3)(A)). Impacts identified as potentially significant in the Initial Study prepared for the proposed project, have focused the content of this EIR, are discussed in further detail below, under Section 1.5, Scope of the EIR.

Once the decision is made to prepare an EIR, the lead agency sends a Notice of Preparation (NOP) to appropriate government agencies and, when required, to the State Clearinghouse (SCH) in the Office of Land Use and Climate Innovation (LCI), which will ensure that responsible and trustee State agencies reply within the required time. The SCH assigns an identification number to the project, which then becomes the identification number for all subsequent environmental documents on the project. Commenting agencies have 30 days to respond to the NOP and provide information regarding alternatives and mitigation measures they wish to have explored in the Draft EIR and to provide notification regarding whether the agency will be a responsible agency or a trustee agency for the project.

Upon completion of the Draft EIR and prior to circulation to State and local agencies and interested members of the public, a notice of completion is filed with the SCH and a public notice of availability is published to inform interested parties that a Draft EIR is available for agency and public review. In addition, the notice provides information regarding the location where copies of the Draft EIR are available for public review and any public meetings or hearings that are scheduled. The Draft EIR is circulated for a minimum period of 45 days, during which time reviewers may submit comments on the document to the lead agency. The lead agency must respond to comments in writing. If significant new information, as defined in CEQA Guidelines Section 15088.5, is added to an EIR after public notice of availability is given, but before certification of the EIR, the revised EIR or affected chapters must be recirculated for an additional public review period with related comments and responses.

A Final EIR will be prepared, containing public comments on the Draft EIR and written responses to those comments, as well as a list of changes to the Draft EIR text necessitated by public comments, as warranted. Before approving a project, the lead agency shall certify that the EIR (consisting of the Draft EIR and Final EIR) has been completed in compliance with CEQA, and that the EIR has been presented to the decision-making body of the lead agency, which has reviewed and considered the EIR. The lead agency shall also certify that the EIR reflects the lead agency’s independent judgment and analysis.

Pursuant to CCR Title 14, Section 15091, a public agency shall not approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The IL

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findings prepared by the lead agency must be based on substantial evidence in the administrative record and must include an explanation that bridges the gap between evidence in the record and the conclusions required by CEQA. If the decision-making body elects to proceed with a project that would have unavoidable significant impacts, then a Statement of Overriding Considerations explaining the decision to balance the benefits of the project against unavoidable environmental impacts must be prepared.

1.5 SCOPE OF THE EIR
Pursuant to the CEQA Guidelines, the scope of this EIR addresses specific issues and concerns identified as potentially significant in the Initial Study prepared for the proposed project (see Appendix A). Accordingly, the sections of the CEQA Guidelines Appendix G Checklist identified for study in this EIR include the following:
x Biological Resources;
x Greenhouse Gas Emissions; and
x Transportation.

The evaluation of effects is presented on a resource-by-resource basis in Chapters 4.1 through

4.3 of the EIR. Each chapter is divided into the following four sections: Introduction, Existing Environmental Setting, Regulatory Context, and Impacts and Mitigation Measures. Impacts that are determined to be significant in Chapters 4.1 through 4.3, and for which feasible mitigation measures are not available to reduce those impacts to a less-than-significant level, are identified as significant and unavoidable. Chapter 5 of the EIR presents a discussion of growth-inducing impacts, summary of cumulative impacts, significant irreversible environmental changes, and significant and unavoidable impacts associated with the project. Alternatives to the proposed project are discussed in Chapter 6 of the EIR.

1.6 DEFINITION OF BASELINE
According to CEQA Guidelines Section 15125, an EIR must include a description of the existing physical environmental conditions in the vicinity of the project to provide the “baseline physical conditions” against which project-related changes could be compared. In addition, CEQA Guidelines Section 15126.2(a) states that an EIR shall identify and focus on the significant environmental effects of the proposed project. The CEQA Guidelines, Section 15126.2(a), states:

An EIR shall identify and focus on the significant environmental effects of the proposed project. In assessing the impact of a proposed project on the environment, the lead agency should normally limit its examination to changes in the existing physical conditions in the affected area as they exist at the time the notice of preparation is published, or where no notice of preparation is published, at the time environmental analysis is commenced.

Normally, the baseline condition is the physical condition that exists when the NOP is published.

The NOP for the proposed project was published on October 4, 2024. Therefore, conditions existing at that time are considered to be the baseline against which changes that would result from the proposed project are evaluated. Impacts could include both direct and indirect physical changes to the baseline condition. The baseline condition for the project site is described in Chapter 3, Project Description, of this EIR. The baseline conditions pertaining to each resource area are described in the “Existing Environmental Setting” section of the respective chapters of this EIR.

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1.7 NOTICE OF PREPARATION AND SCOPING
In accordance with CEQA Guidelines Section 15082, an NOP as well as an attached Initial Study (see Appendix A), was circulated to the public, local, State and federal agencies, and other known interested parties for a 30-day public and agency review period from October 4, 2024 to November 4, 2024. The purpose of the NOP was to provide notification that an EIR for the proposed project was being prepared and to solicit public input on the scope and content of the document.

In addition, pursuant to CEQA Guidelines Section 15082, the City held an NOP scoping meeting during the public review period on October 22, 2024, for the purpose of receiving comments on the scope of the environmental analysis to be prepared for the proposed project. Agencies and members of the public were invited to attend and provide input on the scope of the EIR. Verbal comments were not received. A total of two comment letters were received during the NOP public review period. The comment letters are provided as Appendix B to this EIR. All comments were taken into consideration during the preparation of this Draft EIR, and a summary of the NOP comments received is provided in Section 1.8 below.

1.8 COMMENTS RECEIVED ON THE NOTICE OF PREPARATION
As noted above, the City received two comment letters during the public review period. A copy of each letter is provided in Appendix B of this EIR. The comment letters received during the NOP public review period were authored by representatives of the following public agencies:
x California Department of Fish and Wildlife; and
x California Department of Transportation.

The following list, categorized by issue, summarizes the environmental concerns brought forth in the comment letters received on the scope of the EIR.

Biological Resources
(Chapter 4.1)
Concerns related to:
x Impacts to special-status plant and animal species
x Impacts to environmentally sensitive habitat areas (ESHAs); x Mitigations for temporary disturbances to plant and wildlife species related to noise, lighting, reflection, air pollution, traffic, or human presence will be mitigated;
x Obstruction of movement corridors and access to core habitat features;
x Effects of proposed tree removal on nesting birds; and x Impacts to wetland habitat.

Transportation
(Chapter 4.3)
Concerns related to:
x The potential need for encroachment permits; and
x Project access points’ conformity with the American Disabilities Act (ADA).

Initial Study
(Appendix A)
x The loss of open space and agricultural land;
x Changes to the site’s volume of runoff resulting from the increases in impervious surfaces;
x Impacts to downstream creeks and reservoirs; and
x Potential adverse effects of construction and operation of the project on water quality.

All of the foregoing concerns are addressed in this EIR and Initial Study, in the relevant sections identified in the first column of the table above.

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1.9 DRAFT EIR AND PUBLIC REVIEW
This Draft EIR is being circulated for public review and comment for a period of 45 days. During this period, the general public, organizations, and agencies can submit comments to the Lead Agency on the Draft EIR's accuracy and completeness. Release of the Draft EIR marks the beginning of a 45-day public review period pursuant to CEQA Guidelines Section 15105.

The public can review the Draft EIR at the City’s website at:
https://www.cityofpacifica.org/departments/community-development/planning-division/environmentaldocuments or at the following address during normal business hours:

City of Pacifica, Planning Division
1800 Francisco Boulevard
Pacifica, CA 94044
All comments or questions regarding the Draft EIR should be addressed to:

Brianne Harkousha, Deputy Director of Community Development City of Pacifica, Planning Division
170 Santa Maria Avenue
Pacifica, CA 94044
(650) 738-7341
[email protected]

1.10 ORGANIZATION OF THE DRAFT EIR
The EIR is organized into the following sections:

Chapter 1 – Introduction
Provides an introduction and overview describing the intended use of the Draft EIR and the review and certification process, as well as summaries of the chapters included in the Draft EIR, and the issues and concerns received from the public and public agencies during the NOP review period.

Chapter 2 – Executive Summary
Summarizes the elements of the project and the environmental impacts that would result from implementation of the proposed project, describes proposed mitigation measures, and indicates the level of significance of impacts after mitigation. In addition, the Executive Summary includes a summary of the project alternatives and areas of known controversy.

Chapter 3 – Project Description
Provides a detailed description of the proposed project, including the project’s location, background information, objectives, and technical characteristics.

Chapter 4 – Environmental Setting, Impacts, and Mitigation Contains project-specific and cumulative analysis of environmental issue areas associated with the proposed project. The section for each environmental issue contains an introduction and description of the setting of the project site pertaining to that environmental issue area, identifies impacts, and recommends appropriate mitigation measures.

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Chapter 5 – Statutorily Required Sections
Provides discussions required by CEQA regarding impacts that would result from the proposed project, including a summary of cumulative impacts, potential growth-inducing impacts, significant and unavoidable impacts, and significant irreversible changes to the environment.

Chapter 6 – Alternatives Analysis
Describes and evaluates the alternatives to the proposed project. It should be noted that the alternatives will be analyzed at a level of detail less than that of the proposed project; however, the analyses will include sufficient detail to allow for a meaningful comparison of impacts.

Chapter 7 – EIR Authors and Persons Consulted
Lists EIR and technical report authors who provided technical assistance in the preparation and review of the EIR.

Chapter 8 – References
Provides bibliographic information for all references and resources cited.

Appendices
The appendices include the NOP and Initial Study, comments received during the NOP comment period, and technical reports prepared for the proposed project.

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2. EXECUTIVE SUMMARY

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2.1 INTRODUCTION
The Executive Summary chapter of the EIR provides an overview of the proposed project (see Chapter 3, Project Description, for further details) and provides a table summary of the conclusions of the environmental analysis provided in Chapters 4.1 through 4.3. This chapter also summarizes the alternatives to the proposed project that are described in Chapter 6, Alternatives Analysis, and identifies the Environmentally Superior Alternative. Table 2-1 contains the environmental impacts associated with the proposed project, the significance of the impacts, the proposed mitigation measures for the impacts, and the significance of the impacts after implementation of the mitigation measures.

2.2 SUMMARY DESCRIPTION OF THE PROPOSED PROJECT
The proposed project would include development on a 1.68-acre project site consisting of a vacant parcel (Parcel 1) and a 0.7-acre vacant portion of a second parcel (Parcel 2) in the City of Pacifica, California. Parcel 1 is located at 570 Crespi Drive (Assessor’s Parcel Number [APN] 022-162-310) and is designated Mixed Use Center in the City of Pacifica General Plan 2040. The project site also includes a vacant (eastern) portion of Parcel 2, located at 540 Crespi Drive (APN 022-162-420). The northern portion of Parcel 2 is designated Public and Semi Public, while the southern half is designated Park. Both parcels are zoned Controlled Manufacturing District (M-1).

Surrounding land uses include the Pacifica Community Center, Pacifica Skatepark, and State Route (SR) 1 to the west; commercial businesses and Ocean View Senior Apartments to the north, across Crespi Drive; the Cabrillo Elementary School and commercial businesses to the east; and single-family residences to the south.

The proposed project would include a two-story mixed-use building (Building A) and two threestory residential buildings (Buildings B and C). The project would also include a condominium subdivision to create one commercial condominium and 19 residential condominiums. Building A would consist of 3,165-square feet (sf) of commercial space on the ground floor and three residential units totaling 3,692 sf on the second floor for a total building square footage of 6,857 sf. Building B would consist of seven townhomes totaling 16,196 sf, and Building C would consist of nine townhomes totaling 20,643 sf, for a project-wide total of 19 units. All three buildings would be constructed on the northernmost half of the site, while the southernmost half of the site would remain undisturbed. A portion of the units would be ownership Below Market Rate (BMR) units pursuant to the City’s Inclusionary Ordinance.

In addition, the project would involve off-site improvements, including a new trash enclosure area, construction of a new driveway, and associated parking spaces for the existing Pacifica Community Center located at 540 Crespi Drive.

The proposed project would require approval of a General Plan Amendment, Rezone, Zoning Text Amendment, Use Permit, Site Development Permit, Development Agreement, Parking Exception, Sign Permit, Tree Permit, Tentative Subdivision Map, and Lot Merger and/or Lot Line Adjustment (LLA), The Development Agreement, among other things, would include the following developer requirements: (1) the creation of BMR units on-site; (2) an affordable housing

2. E 2 XECUTIVE SUMMARY
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contribution to City; (3) the construction of improvements at the Pacifica Community Center as noted above; (4) a driveway lease with the City to allow the project to use the City’s driveway; and (5) wetland interpretative signage.

Please refer to Chapter 3, Project Description, of this EIR for a detailed description of the proposed project, as well as a full list of the project objectives.

2.3 ENVIRONMENTAL IMPACTS AND PROPOSED AND

RECOMMENDED MITIGATION
Under CEQA Guidelines Section 15382, a significant effect on the environment is defined as a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project, including land, air, water, mineral, flora, fauna, ambient noise, and objects of historic or aesthetic significance. Mitigation measures must be implemented as part of the proposed project to reduce potential adverse impacts to a less-than-significant level. Such mitigation measures are included in this EIR and are found in the following technical chapters:

Biological Resources; Greenhouse Gas Emissions; and Transportation. The mitigation measures presented in the Initial Study (IS) and EIR will form the basis of the Mitigation Monitoring and Reporting Program (MMRP). Any impact that remains significant after implementation of mitigation measures is considered a significant and unavoidable impact.

A summary of the impacts identified in the technical chapters of the IS and this EIR (Chapters 4.1 through 4.3) are presented in Table 2-1 at the end of this chapter. In addition, Table 2-1 includes the level of significance of each impact, any mitigation measures required for each impact, and the resulting level of significance after implementation of mitigation measures for each impact.

2.4 SUMMARY OF PROJECT ALTERNATIVES
The following section presents a summary of the evaluation of the alternatives considered for the proposed project, which include the following:

1. No Project (No Build) Alternative;

2. 100 Percent Affordable Housing Alternative; and

3. Reduced Intensity Alternative.

For a more thorough discussion of project alternatives that were evaluated in this EIR, including alternatives considered but dismissed, please refer to Chapter 6, Alternatives Analysis. Project objectives are referenced throughout this section as CEQA requires an EIR to describe a reasonable range of alternatives that could feasibly attain most of the basic objectives of the project but that would avoid or substantially lessen significant effects of the project. A full list of project objectives can be found in Chapter 3, Project Description.

1. No Project (No Build) Alternative
Under the No Project (No Build) Alternative, current conditions of the project site would remain, and the site would not be developed. The No Project (No Build) Alternative would not meet any of the project objectives. Because changes to the project site would not occur under the No Project (No Build) Alternative, impacts would not occur related to any environmental issue areas.

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2. 100 Percent Affordable Housing Alternative
The 100 Percent Affordable Housing Alternative would consist of a similar buildout of the components of the proposed project. Similar to the proposed project, the 100 Percent Affordable Housing Alternative would include development of a two-story mixed-use building (Building A) and two three-story residential buildings (Buildings B and C). In addition, the project would involve off-site improvements, including the removal of two trees and construction of a new driveway and associated parking spaces within the northern portion of the existing Pacifica Community Center.

Under the 100 Percent Affordable Housing Alternative, the development would change the proposed units from market-rate units to affordable units. As currently proposed, the project includes only a portion of residential units as Below Market Rate ownership units affordable to buyers with low or moderate incomes. Under the alternative, the proposed project would include a total of 19 units affordable to buyers with low or moderate incomes.

The 100 Percent Affordable Housing Alternative would result in fewer impacts related to greenhouse gas (GHG) emissions and vehicle miles traveled (VMT), and similar impacts related to all other environmental issue areas. Because the 100 Percent Affordable Housing Alternative would include development of the same uses as the proposed project, all of the project objectives would be met.

3. Reduced Intensity Alternative
Under the Reduced Intensity Alternative, the proposed project would implement the components as described in Chapter 3, Project Description, of this EIR, but with four fewer residential units.

Under the proposed project’s current plans, the project site would be developed with a total of 19 residences across a two-story mixed-use building (Building A) and two three-story residential buildings (Buildings B and C). Building B would include seven residential units, and Building C would include nine residential units. The remaining three units would be located within Building A above the ground floor hosting the commercial uses.

The Reduced Intensity Alternative would eliminate four residences from the project by reducing Building C by three units and Building B by one unit (see Figure 6-1 of this EIR). Both buildings would remove the units from the end closest to the existing wetlands, thereby increasing the buffer distance between the development and the wetlands. However, because the Reduced Intensity Alternative would still include the potential disturbance and possible fill of the on-site waters of the State, removal of potential riparian vegetation, and the removal of on-site trees, the associated mitigation measures would still be required.

The Reduced Intensity Alternative would result in fewer impacts related to GHG emissions and VMT, and similar impacts to all other environmental issue areas. Because the Reduced Intensity Alternative would include development of the same uses as the proposed project, all of the project objectives would be met. Objective 5 would arguably be better met under the Reduced Intensity Alternative, as the removal of four units would preserve more open space on-site.

Environmentally Superior Alternative
An EIR is required to identify the environmentally superior alternative from among the range of reasonable alternatives that are evaluated. Section 15126(e)(2) of the CEQA Guidelines requires that an environmentally superior alternative be designated and states, “If the environmentally superior alternative is the ‘no project’ alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.” In this case, the No Project (No Build) Alternative would be considered the environmentally superior alternative, because the project site IL

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is assumed to remain in its current condition under the alternative. Consequently, none of the impacts resulting from the proposed project would occur under the Alternative. However, the No Project (No Build) Alternative would not meet any of the project objectives.

As discussed throughout the Alternatives Analysis chapter of this EIR, both the 100 Percent Affordable Housing Alternative and the Reduced Intensity Alternative would result in fewer impacts than the proposed project. Under both alternatives, impacts related to GHG emissions and VMT, which were identified as significant and unavoidable for the proposed project, would not occur. However, the Reduced Intensity Alternative would only include a portion of affordable units, consistent with the City’s Inclusionary Housing Ordinance. Therefore, the 100 Percent Affordable Housing Alternative would more effectively contribute to the City’s goals related to the provision of affordable housing. Based on the above, because the 100 Percent Affordable Housing Alternative would result in fewer significant impacts than the proposed project and would not interfere with the City’s goals related to providing affordable housing, the 100 Percent Affordable Housing Alternative would be considered the environmentally superior alternative.

2.5 AREAS OF KNOWN CONTROVERSY
The CEQA Guidelines, Section 15123(b), require that this EIR consider areas of controversy known to the lead agency, including issues raised by agencies and the public. Areas of controversy that were identified in NOP comment letters on the proposed project should be considered, as well. The areas of known controversy for the proposed project relate to the following:
x Impacts to special-status plant and animal species;
x Impacts to environmentally sensitive habitat areas (ESHAs); x Temporary disturbances to plant and wildlife species related to noise, lighting, reflection, air pollution, traffic, or human presence;
x Obstruction of wildlife movement corridors and access to core habitat features; x Effects of proposed tree removal on nesting birds;
x Impacts to wetland habitat;
x The potential need for encroachment permits;
x Project access points’ conformity with the American Disabilities Act (ADA); x The loss of open space and agricultural land;
x Changes to the site’s volume of runoff resulting from the increases in impervious surfaces; x Impacts to downstream creeks and reservoirs; and
x Potential adverse effects of construction and operation of the project on water quality.

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NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation

4.1 Biological Resources

4.1-1 Have a substantial adverse
effect, either directly (e.g., threaten to eliminate a plant community) or through habitat modifications, on any plant species identified as a candidate, sensitive, or special-status species (San Francisco Bay spineflower).

S 4.1-1(a) Prior to the commencement of construction
associated with the proposed project, focused plant preconstruction surveys shall be conducted by a qualified biologist during the documented bloom periods of San Francisco Bay spineflower. Two site visits, including one early-season (April) and one late-season (July) shall be sufficient to cover the blooming periods. If San Francisco Bay spineflower are not observed during the focused plant surveys, impact to special-status plant species would not occur, and mitigation would not be required. The results of the surveys shall be submitted to the City’s Planning Department.

4.1-1(b) If San Francisco Bay spineflower are identified onsite during the focused plant surveys, the project applicant shall be responsible for ensuring construction activities avoid special-status plants through preparation and submittal to the City’s Planning Department of an Avoidance Plan Report detailing protection and avoidance criteria, measures, and the extent to which special-status plants were successfully avoided. The Avoidance Plan Report shall be subject to approval by the City’s Planning Department and CDFW.If avoidance is infeasible, the qualified biologist shall ensure seed collection for affected special-status plants is completed and plants are re-established at LS
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April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Level of
Significance
After
Mitigation
a minimum of a one-to-one ratio (number of newly established plants relative to the number of plants impacted) in a preserved, suitable habitat approved by the City and CDFW. The project applicant shall document and submit proof of compliance to the City’s Planning Department and CDFW.Re-established special-status plant populations shall be monitored annually by the project applicant in accordance with an approved Habitat Mitigation and Monitoring Plan prepared in consultation with the City’s Planning Department, with annual monitoring taking place for a minimum of five years. The Habitat Mitigation and Monitoring Plan shall include criteria, subject to approval by all applicable agencies, including the City’s Planning Department, USFWS, and CDFW, detailing the survival ratio required of re-established populations and performance standards for further replanting for any re-established special-status plant species that do not survive. Reports describing performance results shall be prepared by a qualified biologist and shall be submitted to the City’s Planning Department for years one, three, and five of the monitoring period.

4.1-2 Have a substantial adverse
effect, either directly (e.g., cause a wildlife population to drop below self-sustaining levels, threaten to eliminate an
animal community) or through
S 4.1-2 To ensure compliance with protections for migratory birds under the MBTA and the CFGC, the measures outlined below shall be implemented prior to the commencement of construction activities. Evidence of compliance shall be submitted to the City’s LS
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April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Level of
Significance
Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
habitat modifications, on saltmarsh common yellowthroat, and other migratory birds and raptors protected under the MBTA.

Planning Department for review and approval prior to the commencement of construction activities.

1. If construction activities are scheduled to
occur outside of the breeding season (i.e., September 1 through January 31), preconstruction surveys or other mitigation measures are not necessary.

2. If construction activities are scheduled to
occur during the breeding season (i.e., February 1 through August 31), a preconstruction nesting bird survey shall be conducted on the identified work area and a buffer zone (see #3, below). The survey shall be performed by a qualified biologist no more than two weeks prior to the initiation of work. If nesting or breeding activity is not observed, work may proceed without restrictions. To the extent allowed by access, all active nests identified within 250 feet of construction activities, including equipment staging, for raptors and 100 feet for other protected bird species shall be mapped.

3. For any active nests found near the
construction limits (76 m [250 ft] for raptors and 33 m [100 ft] for other protected bird species), the project biologist shall make a IL

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570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Significance
Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
determination as to whether or not construction activities are likely to disrupt reproductive behavior. If construction is determined unlikely to disrupt breeding behavior, construction may proceed. If construction is determined to potentially disrupt breeding, the construction-free buffer zone shall be expanded; avoidance is the only mitigation available. The ultimate size of the construction-free buffer zone may be adjusted by the project biologist based on the species involved, topography, lines of site between the work area and the nest, physical barriers, and the ambient level of human activity. For raptors, the project biologist shall contact CDFW and/or the USFWS Division of Migratory Bird Management for guidance regarding site evaluations and buffer adjustments.If construction activities are determined likely to disrupt raptor breeding, construction activities within the construction-free buffer zone may not proceed until the project biologist determines that the nest is unoccupied.

4. If the project contractor, in consultation with
the City, determines that maintenance of a construction-free buffer zone is not IL

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April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
practicable, active nests shall be monitored by a qualified biologist to document breeding and rearing behavior of the adult birds. If construction activities are determined to potentially cause nest abandonment, work shall cease until the project biologist determines that the nest is unoccupied. For raptors, the CDFW and/or the USFWS Division of Migratory Bird Management shall be contacted for guidance.

S 4.1-3 Implement Mitigation Measures 4.1-4(b) and 4.1- 4(c).

4.1-4 Have a substantial adverse
effect on any riparian habitat or other sensitive natural community, or State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

S 4.1-4(a) Prior to the commencement of ground-disturbing activities, the project applicant shall notify CDFW, pursuant to CFGC Section 1600. The notification shall include a description of all of the activities associated with the proposed project, not just those associated with the drainages and/or riparian vegetation. Impacts shall be outlined in the notification and are expected to be in substantial conformance with the impacts to biological resources outlined in the Updated Definition of Potentially Jurisdictional Aquatic Resources and LS
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April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
Effects Analysis prepared for the 570 Crespi Drive Project by Wood Biological Consulting. Impacts for each activity shall be broken down by temporary and permanent impacts. A description of the proposed mitigation for biological resource impacts shall be outlined per activity and then by temporary and permanent impact. Information regarding projectspecific drainage and hydrology changes resulting from project implementation shall be provided, along with a description of stormwater treatment methods. Minimization and avoidance measures shall be proposed, as appropriate, and may include preconstruction species surveys and reporting, protective fencing around avoided biological resources, worker environmental awareness training, seeding disturbed areas adjacent to open space areas with native seed, and installation of project-specific stormwater BMPs. Mitigation for impacts to 0.550-acre of arroyo willow scrub riparian vegetation may include restoration or enhancement of resources on- or off-site, or any other method acceptable to CDFW. Mitigation shall not result in a net loss of a Sensitive Natural Community. If CDFW determines through the course of the CFGC Section 1600 notification process that the project does not require a Lake or Streambed Alteration Agreement (LSAA) to address potential impacts to arroyo willow scrub, further mitigation beyond the proposed mitigation included in the IL

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April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Significance
Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
notice to CDFW regarding the aforementioned vegetation communities shall not be required. Written verification of the applicant’s compliance with the Section 1600 LSAA process shall be submitted to the City of Pacifica Planning Division prior to the start of any construction activities.

4.1-4(b) Prior to the start of any construction activities, a temporary sediment and debris barrier shall be installed on the southern limit of the construction area that slopes toward the arroyo willow and emergent wetland habitat. The fence will also double as a wildlife exclusion fence during construction. The fence shall consist of standard construction silt fence material with a height of 36 inches. The lower six inches of fence material shall either be folded toward the construction side of the fence and weighted down with soil or sandbags, or backfilled in a trench; with both methods, the purpose is to completely contact the surface so that water and sediment would not flow underneath, and wildlife would not enter the work area from the wetland. The barrier shall be maintained throughout the duration of the construction period. Evidence of compliance with this measure shall be submitted to the City of Pacifica Planning Division prior to the start of any construction activities.

4.1-4(c) A qualified biologist, or a designated representative who has been trained by a qualified biologist, shall
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Attachment: ATT A-Draft Resolution EIR+Exhibits-570 Crespi-251202 (6098 : Crespi Drive Mixed Use Draft EIR
570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
inspect the area inside of the sediment and debris barrier for special-status species, including California red-legged frog, every day before construction activities commence. If any specialstatus species are found, the qualified biologist shall be immediately contacted (if the survey was conducted by the designated representative), construction activities shall not be allowed to start, and the USFWS and CDFW shall be consulted on an appropriate course of action. Such action could include leaving the animal alone to move away on its own or the relocation of the animal to an area outside of the construction area. The qualified biologist, in consultation with the CDFW and USFWS, shall make the ultimate determination of the action to be taken. Evidence of compliance with this measure shall be submitted to the City’s Planning Department upon discovery of special-status species and prior to commencement of construction activities.

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Packet Pg. 311
Attachment: ATT A-Draft Resolution EIR+Exhibits-570 Crespi-251202 (6098 : Crespi Drive Mixed Use Draft EIR
570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
outlined in any applicable permit. A copy of the Water Quality Certification or waiver issued for the project shall be submitted to the City’s Planning Department prior to commencement of grading, excavation, or other construction activities.

4.1-5 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.

LS None required. N/A

4.1-6 Conflict with any local policies
or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

S 4.1-6 Prior to issuance of any grading permit, the project applicant shall obtain a Tree Removal Permit for any protected trees to be removed and a Tree Encroachment Permit for any construction activities within 50 feet of a protected tree from the City of Pacifica Director of Public Works. Prior to issuance of a certificate of occupancy, the project applicant shall complete planting of any replacement trees required as part of the Director of Public Works heritage tree removal authorization or other authorizations. In addition, the project applicant shall prepare and submit a Tree Protection and Preservation Plan prior to the protected tree removal or encroachment authorizations or other authorizations in accordance with the City Municipal Code, Sections 4-12.02 through 4-12.11, and shall LS
IL

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April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Level of
Significance
Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
implement any tree protection measures identified to protect trees which will not be removed during construction prior to commencement of any construction activity.

4.1-7 Cumulative impact on
biological resources.

LS None required. N/A

4.2 Greenhouse Gas Emissions

4.2-1 Generate GHG emissions,
either directly or indirectly, that may have a significant impact on the environment, or conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.

CC, S 4.2-1(a) Prior to the approval of project improvement plans, the applicant shall implement the following measure:
x Consistent with BAAQMD’s Transportation
criterion d., a total of four EV Capable parking spaces shall be installed throughout the 15 on-site uncovered parking spaces, and an additional four EV Capable parking spaces shall be installed throughout the 17 community center spaces, consistent with the current CALGreen Tier 2 standards.

Compliance with the foregoing measure shall be ensured by the City of Pacifica Planning Division.

4.2-1(b) Implement Mitigation Measure 4.3-3.

4.3 Transportation

4.3-1 Conflict with a program, plan,
ordinance, or policy addressing the circulation system during construction activities.

S 4.3-1 Prior to grading permit issuance, the project applicant shall prepare a construction traffic management plan for review and approval by the City Engineer. The plan shall include the following:

LS
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570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Impact
Level of
Significance
Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
x A project staging plan to maximize on-site
storage of materials and equipment;
x A set of comprehensive traffic control
measures, including scheduling of major truck trips and deliveries to avoid peak hours; lane closure proceedings; signs, cones and other warning devices for drivers; and designation of construction access routes; x Provisions for maintaining adequate
emergency access to the project site;
x Permitted construction hours, per City of
Pacifica standards;
x Designated locations for construction staging
areas;
x Identification of parking areas for
construction employees, site visitors, and inspectors, including on-site locations; and x Provisions for street sweeping to remove
construction-related debris on public streets.

4.3-2 Conflict with a program, plan,
ordinance or policy addressing the circulation system during operations.

LS None required. N/A

4.3-3 Conflict or be inconsistent with
CEQA Guidelines section 15064.3, subdivision (b).

SU 4.3-3 The project applicant shall implement the following CAPCOA VMT reduction strategy T-9 to reduce the
number of vehicle trips that would be generated by future residents, subject to review and approval by the City Engineer. The timing for the strategy is set forth below:

SU
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Packet Pg. 314
Attachment: ATT A-Draft Resolution EIR+Exhibits-570 Crespi-251202 (6098 : Crespi Drive Mixed Use Draft EIR
570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
Implement subsidized or discounted transit program (CAPCOA Handbook Strategy T-9)The proposed project shall provide subsidized or discounted, or free transit passes for residents of the project’s 19 dwelling units. Prior to occupancy of the multi-family residential units, the project applicant shall provide two free one-year transit passes to residents of the project’s 19 dwelling units.

4.3-4 Substantially increase hazards
due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) or result in inadequate emergency access.

S 4.3-4 Implement Initial Study Mitigation Measure IX-3. LS Initial Study
V. Cultural Resources
a. Cause a substantial adverse
change in the significance of a historical resource pursuant to Section 15064.5? b. Cause a substantial adverse
change in the significance of a unique archaeological
S V-1. If any potentially historic resources, prehistoric or historic artifacts, or other indications of cultural deposits, such as historic privy pits or trash deposits, are found once ground disturbing activities are underway, all work within the vicinity of the find(s) shall cease, the find(s) shall be immediately evaluated by a qualified archaeologist, and the City’s Planning Department shall be notified of the find(s). If the find is determined to be a historical or unique archaeological resource, as determined by the LS
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570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Level of
Significance
After
Mitigation
resource pursuant to Section 15064.5?
c. Disturb any human remains,
including those interred outside of dedicated cemeteries. qualified archeologist, contingency funding and a time allotment to allow for implementation of avoidance measures or appropriate mitigation shall be made available (CEQA Guidelines Section 15064.5). Work may continue on other parts of the project site while historical or unique archaeological resource mitigation takes place (Public Resources Code Sections 21083 and 21087).The requirements of this mitigation measure shall be included via notation on all project improvement plans and building permit plans for review and approval by the City of Pacifica Planning Department.

V-2. In the event of the accidental discovery or
recognition of any human remains, further excavation or disturbance of the find or any nearby area reasonably suspected to overlie adjacent human remains shall not occur until compliance with the provisions of CEQA Guidelines Section 15064.5(e)(1) and (2) has occurred. The Guidelines specify that in the event of the discovery of human remains other than in a dedicated cemetery, no further excavation at the site or any nearby area suspected to contain human remains shall occur until the County Coroner has been notified to determine if an investigation into the cause of death is required. If the Coroner determines that the remains are Native American, then, within 24 hours, IL

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April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Mitigation Measures
Level of
Significance
After
Mitigation
the Coroner must notify the Native American Heritage Commission, which in turn will notify the most likely descendants who may recommend treatment of the remains and any grave goods. If the Native American Heritage Commission is unable to identify a most likely descendant or most likely descendant fails to make a recommendation within 48 hours after notification by the Native American Heritage Commission, or the landowner or his authorized agent rejects the recommendation by the most likely descendant and mediation by the Native American Heritage Commission fails to provide a measure acceptable to the landowner, then the landowner or his authorized representative shall rebury the human remains and grave goods with appropriate dignity at a location on the property not subject to further disturbances. If human remains are encountered, a copy of the resulting County Coroner report noting any written consultation with the Native American Heritage Commission shall be submitted as proof of compliance to the City of Pacifica Planning Department.

The requirements of this mitigation measure shall be included via notation on all project improvement plans and building permit plans for review and approval by the City of Pacifica Planning Department.

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570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
VII. Geology and Soils
a. Directly or indirectly cause
potential substantial adverse effects, including the risk of loss, injury, or death involving:
iii. Seismic-related ground
failure, including liquefaction?
iv. Landslides?
c. Be located on a geologic unit
or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or offsite landslide, lateral spreading, subsidence, liquefaction or collapse? S VII-1. All grading and foundation plans for the development shall be designed by a Civil and Structural Engineer and reviewed and approved by the Director of Public Works/City Engineer, Chief Building Official, and a qualified Geotechnical Engineer prior to issuance of a grading or building permit to ensure that all geotechnical recommendations specified in the Geotechnical Investigation, dated January 2016, and the Response to Geotechnical Peer Review, dated April 30, 2020, prepared for the proposed project by GeoForensics, Inc. are properly incorporated and utilized in the project design.

LS
d. Be located on expansive soil,
as defined in Table 18-1B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? S VII-2. Implement Mitigation Measure VII-1 LS
f. Directly or indirectly destroy a
unique paleontological resource or site or unique geologic feature? S VII-3. In the event that paleontological resources, including individual fossils or assemblages of fossils, are encountered during construction activities all ground disturbing activities shall immediately halt and a qualified paleontologist shall be procured to evaluate the discovery for the purpose of recording, LS
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570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
protecting, or curating the discovery as appropriate. The qualified paleontologist shall provide the City of Pacifica Planning Department with a report detailing the findings and method of curation or protection of the resources for review and approval by City Planning staff prior to recommencing construction.

IX Hazards and Hazardous Materials
b. Create a significant hazard to
the public or the environment through reasonably foreseeable upset and accident conditions involving the likely release of hazardous materials into the environment? S IX-1. Prior to initiation of grading, excavation, or other ground-disturbing activities on the northern portion of the project site, the project applicant shall complete an analysis of on-site soils to determine whether substantial concentrations of soil contaminants are present above the applicable direct exposure Environmental Screening Levels (ESLs) set by the Regional Water Quality Control Board. If contaminants are not detected above applicable ESLs, then further mitigation is not required. If contaminants are detected above the applicable ESLs, then the soils shall be remediated by off-hauling to a licensed landfill facility. Such remediation activities shall be performed by a licensed hazardous waste contractor (Class A) and contractor personnel that have completed 40-hour OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) training, and overseen by the San Mateo County Environmental Health Services Division. The results of soil sampling and analysis, as well as verification of proper remediation and disposal, shall be submitted LS
IL

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570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Significance
Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
to the City of Pacifica Planning Department for review and approval. c. Emit hazardous emissions or
handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? S IX-2. Implement Mitigation Measure IX-1. LS
f. Impair implementation of or
physically interfere with an adopted emergency response plan or emergency evacuation plan? S IX-3. Prior to the issuance of a building permit, the project shall demonstrate compliance with the 26-foot
access road width, or obtain Fire Marshall approval of an Alternative Methods and Materials request by the NCFA to deviate from the 26-foot access road width requirement for the Project.

LS
X. Hydrology and Water Quality
a. Violate any water quality
standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? e. Conflict with or obstruct
implementation of a water quality control plan or sustainable groundwater management plan? S X-1. During construction, the contractor shall implement BMPs to reduce pollutants in stormwater discharges to the maximum extent practicable, which may include but are not necessarily limited to the following practices, or other BMPs identified in the California Stormwater Quality Association (CASQA) Construction BMP Handbook and in the City’s Municipal Regional Permit for stormwater discharges:
x Temporary erosion control measures (such
as silt fences, staked straw bales/wattles, silt/sediment basins and traps, check dams, geofabric, sandbag dikes, and temporary revegetation or other ground cover) shall be LS
IL

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Packet Pg. 320
Attachment: ATT A-Draft Resolution EIR+Exhibits-570 Crespi-251202 (6098 : Crespi Drive Mixed Use Draft EIR
570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
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Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
employed to control erosion from disturbed areas;
x Inactive construction areas (previously
graded areas inactive for 10 days or more) that could contribute sediment to waterways shall be covered or treated with nontoxic soil stabilizers; x Exposed stockpiles of dirt or other loose,
granular construction materials that could contribute sediment to waterways shall be enclosed or covered; x The contractor shall ensure that no earth or
organic material will be deposited or placed where such materials may be directly carried into a stream, marsh, slough, lagoon, or body of standing water; x The following types of materials shall not be
rinsed or washed into the streets, shoulder areas, or gutters: concrete, solvents and adhesives, thinners, paints, fuels, sawdust, dirt, gasoline, asphalt and concrete saw slurry, and heavily chlorinated water; and x Grass or other vegetative cover shall be
established on the construction site as soon as possible after disturbance.

The applicable BMPs shall be included via notation on the project Improvement Plans for review and approval by the City Engineer prior to issuance of a grading, excavation, or building permit.

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570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
Chapter 2 – Executive Summary

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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
X-2. Prior to issuance of a certificate of occupancy for any component of the proposed project, the project applicant shall execute and record a Maintenance Agreement addressing future maintenance of the stormwater treatment measures required to comply with Provision C.3 of the Municipal Regional Permit.The Maintenance Agreement shall be subject to review and approval by the City Engineer and the City Attorney’s Office.

X-3. Prior to issuance of a certificate of occupancy for any component of the proposed project, the project applicant shall install all required stormwater treatment measures, and demonstrate full compliance with the stormwater treatment plans prepared for the proposed project. Evidence of such shall be submitted to the City Engineer for review and approval.

XIII. Noise
b. Generation of excessive
groundborne vibration or
groundborne noise levels?
S XIII-1. Pile driving shall be prohibited during construction of the proposed project. Compliance with such shall be ensured by the City of Pacific Planning Division.

LS
IL

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570 Crespi Drive Project
April 2025
NI = No Impact; N/A = Not Applicable; LS = Less Than Significant; LCC = Less Than Cumulatively Considerable; S = Significant; CC = Cumulatively Considerable; SU = Significant and Unavoidable
Chapter 2 – Executive Summary

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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
XVIII. Tribal Cultural Resources
a. Listed or eligible for listing in
the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k). 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 Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

S XVIII-1. Implement Mitigation Measures V-1 and V-2. LS IL

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3. PROJECT DESCRIPTION

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3.1 INTRODUCTION
Section 15124 of CEQA Guidelines requires an EIR to contain a project description, including the location and boundaries of the project, statement of project objectives, general description of the project’s technical, economic and environmental characteristics, and a statement briefly describing the intended uses of the EIR.

The Project Description chapter of the EIR provides a comprehensive description of the 570 Crespi Drive Project (proposed project) in accordance with Section 15124. It should be noted that, while this chapter provides an overall general description of the existing environmental conditions, detailed discussions of the existing setting in compliance with CEQA Guidelines Section 15125 are included in each technical chapter of this EIR.

3.2 PROJECT LOCATION
The 1.68-acre project site is located just south of Crespi Drive in the City of Pacifica, California (see Figure 3-1 and Figure 3-2). The site consists of the entirety of the 0.98-acre lot identified by Assessor’s Parcel Number (APN) 022-162-310, located at 570 Crespi Drive (Parcel 1), and the southeastern 0.70-acre portion of APN 022-162-420, located at 540 Crespi Drive (Parcel 2).

Parcel 1 is designated Mixed Use Center (MUC) in the City’s General Plan, and Parcel 2 is designated Public and Semi Public (approximately northern half) and Park (approximately southern half). Both parcels are zoned Controlled Manufacturing District (M-1).

3.3 BACKGROUND
On December 8, 2021, the City released an Initial Study/Mitigated Negative Declaration (IS/MND) for the proposed project. The public review period was from December 8, 2021, to January 10, 2022. Public hearings for consideration of the project and IS/MND were held on March 7, 2022, by the City Planning Commission, and on November 14, 2022, by the City Council. Based on public comments, the City determined that an EIR was required. As such, the City revised the IS/MND to an Initial Study (IS), and released a new NOP with the revised IS for public review (see Appendix A to this EIR). The public review period for the new NOP was from October 4, 2024, to November 4, 2024. A NOP scoping meeting was held on October 22, 2024, before the City Planning Commission.

On January 5, 2022, prior to preparation and publication of the revised IS and NOP, the City of Pacifica released a Draft General Plan Update and associated Draft EIR, and on July 11, 2022, the Draft General Plan Update and associated Draft EIR were adopted and certified by the City.

Therefore, the analysis contained within the revised IS and this Draft EIR relies on the information contained therein.

3. PROJECT DESCRIPTION

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570 Crespi Drive Project
April 2025
Chapter 3 – Project Description

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Figure 3-2
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3.4 PROJECT SETTING AND SURROUNDING LAND USES
The site historically included residential uses, but is currently undeveloped and covered in dense vegetation. Several trees and shrubs are located throughout the project site. The western portion of the site was recently disturbed during landscape improvements, while the southern portion of the site is predominantly characterized by a seasonal drainage and wetland area. The existing drainage is located adjacent to a wooden backyard fence and an existing underground storm drain.

3.5 PROJECT OBJECTIVES
The project applicant has identified the following specific objectives for the proposed project:

1. Create a viable mixed-use project that responsibly maximizes the potential for the development of the site.

2. Accentuate and strengthen the commercial streetscape by fronting the mixed-use building on Crespi Drive.

3. Take advantage of combining vehicle circulation with the existing Community Center.

4. Consider parking demand over time for commercial and residential uses to minimize the overall need to devote land to parking.

5. Concentrate development towards the front of the site, preserving a generous amount of open space at the rear of the property in its natural state.

6. Foster connectivity and interaction with the Pacifica Community Center.

3.6 PROJECT COMPONENTS
The proposed project would include the purchase from the City of Pacifica of a 0.70-acre portion of Parcel 2 and a Lot Merger and/or Lot Line Adjustment (LLA) to combine the 0.70-acre portion of Parcel 2 and Parcel 1. The new 1.68-acre parcel would be developed with one two-story mixeduse building (Building A) and two three-story residential buildings (Buildings B and C) (see Figure 3-3). The project would include a condominium subdivision to create one commercial condominium and 19 residential condominiums. In addition, the project would include tree removal and construction of off-site improvements, including the construction of a new driveway and parking spaces north of the existing Pacifica Community Center.

Additional details regarding the requested approvals and entitlements are discussed below.

General Plan Amendment
A General Plan Amendment would be required to redesignate the 0.70-acre portion of Parcel 2 from the two current General Plan land use designations (Public and Semi-Public, and Park) to MUC, consistent with the existing land use designation of Parcel 1.

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Figure 3-3
Site Plan

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Rezoning/Zoning Text Amendment/Use Permits
As part of the proposed project, the project site would be Rezoned from M-1 to the Community Commercial (C-2) zoning district. Pursuant to Pacifica Municipal Code Section 9-4.1101(b)(8), residential dwelling units are conditionally allowable within the C-2 zone when located above the ground floor in the same building as a commercial use. Therefore, approval of a Use Permit would be required in order to develop the three proposed units on the second story of Building A.

A Zoning Text Amendment is proposed as part of the project to allow residential uses as a conditional use on the ground level and in buildings that do not contain commercial uses in areas zoned C-2. Approval of the proposed Zoning Text Amendment is required to allow for the development of Buildings B and C, which are both residential buildings, in the C-2 zoning district, which would encompass the entire project site following City approval of the requested Rezone.

The Zoning Text Amendment would also allow other projects in the C-2 zoning district to apply for Use Permits for residential uses within the C-2 zoning district. As approval of Use Permits is subject to the requirements of CEQA, development of any new residential uses on other sites would require site-specific environmental review and would not be allowed by-right by the proposed Zoning Text Amendment. Therefore, this Draft EIR analyzes only the impact of the proposed project.

Tentative Subdivision Map, Lot Merger and/or Lot Line Adjustment The proposed project would include approval of a Tentative Subdivision Map and a Lot Merger and/or LLA to combine Parcel 1 and the southeastern 0.70-acre portion of Parcel 2. The Tentative Subdivision Map would include the creation of one commercial structure and 19 residential condominiums on the site. The Tentative Subdivision Map is provided as Figure 3-4. The proposed buildings, access and circulation, landscaping, utilities infrastructure, and off-site improvements are discussed in further detail below.

Proposed Buildings
Building A would consist of 3,165 square feet (sf) of commercial space on the ground floor and three residential units on the second floor. Buildings B and C would be three stories each and would contain seven and nine townhomes, respectively, for a project-wide total of 19 units. The buildings would be constructed on the northernmost half of the site, while the southernmost half of the site would remain undisturbed. A portion of the residential units would be Below Market Rate (BMR) ownership units, which would be affordable to buyers with low or moderate incomes.

Refer to Figure 3-5, Figure 3-6, and Figure 3-7 for the first-, second-, and third-story floor plans for all proposed buildings. Construction is anticipated to occur over an approximately two-year period. Grading would involve importing approximately 2,400 cubic yards of soil.

As previously discussed, Building A would be developed as a mixed-use building, with the ground floor consisting of 3,165-sf of commercial space and three residential units on the second floor.

The western and easternmost units in Building A would each be approximately 1,312 sf with one bedroom, two bathrooms, and two balconies. The center unit in Building A would be approximately 925 sf with one bedroom, one bathroom, and a single balcony.

Building B would include seven townhomes, and Building C would include nine townhomes. The residential units would be located on the second and third floors of the three-story buildings.

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Figure 3-4
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April 2025
Chapter 3 – Project Description

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April 2025
Chapter 3 – Project Description

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April 2025
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The first-floor entryway, second floor, and third floor of each unit would total approximately 1,521 sf, with the exception of the southernmost unit in Building B which would be 2,212 sf and the southernmost unit in Building C which would be 2,227 sf. A roof deck would be provided above each unit in Buildings B and C.

Parking, Access, and Circulation
Primary access to the project site would be provided from Crespi Drive. The one-way driveway entrance would be provided along the eastern side of Building A and loop around the southern portion of Building A, before exiting the site to the west through a connection to the existing twoway driveway that would be shared with the Pacifica Community Center (see Figure 3-3). A new two-way drive aisle would connect to the proposed loop to allow residents access to Buildings B and C.

The proposed project would include private tandem garages for each proposed unit within Buildings B and C, as well as an additional 15 uncovered parking spaces, for a total of 47 parking spaces on-site. Of the 47 total parking spaces provided on-site, three would provide electric vehicle charging. Of the 15 uncovered parking spaces, five would be located on the east side of Building A, seven located directly south of Building A, two south of Building B, and one south of Building C.

The proposed project would also include off-site circulation improvements north of the Pacifica Community Center. The improvements would include construction of 17 uncovered parking spaces and a drop-off area intended for use by the Pacifica Community Center (see Figure 3-8).

Additional off-site improvements adjacent to and north of the project site would include construction of 17 parking spaces, a drop-off area, and a new trash containment area for use by the Pacifica Community Center, as well as the removal of trees and landscape improvements.

Landscaping
The proposed project would include landscaping features throughout the development area, the off-site improvement area, and along the Crespi Drive frontage (see Figure 3-9 and Figure 3-10).

Proposed plant types include, but are not limited to, crape myrtle, desert willow, sea lavender, dwarf mat rush, and Cleveland sage. All landscaping improvements would be consistent with the City’s landscape design requirements (which require a minimum of 10 percent of the area in commercial zoning districts to be landscaped), and would include at least two inches of mulch.

Utilities
Sewer service for the proposed project would be provided by the City. Each building would be served by an eight-inch sanitary sewer line to connect to the proposed residential units (see Figure 3-11). In addition, each building would be constructed with a new sanitary sewer cleanout connected to the eight-inch sewer lines. The proposed eight-inch lines would eventually connect to an existing sanitary sewer line within Crespi Drive to be routed to the City’s wastewater treatment plant.

Water service would be provided by the North Coast County Water District (NCCWD) through connection to the existing water main located within Crespi Drive. A four-inch water line would be routed to all three buildings to provide fire service, while a three-inch water line would be routed to the proposed buildings to provide domestic water services. Electricity services would be provided by Pacific Gas & Electric (PG&E).

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April 2025
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Chapter 3 – Project Description

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April 2025
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April 2025
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A new vault would be constructed by PG&E in the northern portion of the project site, near Building A, to provide electricity to the proposed structures. In addition, the proposed project would connect to existing telecommunications infrastructure in the project area.

All runoff from impervious areas within the project site, including all hardscape, parking areas, and driveways would be collected by new four-, six-, eight- and 10-inch storm drain pipes within the proposed driveway and parking areas (see Figure 3-12 and Figure 3-13). Runoff flowing through the storm drains would empty into proposed bioswales on the western and eastern boundaries of the site or be directed to a bioretention area in the southeast corner of the project site. Treated stormwater would either be discharged into the vacant land to the south of the development area or into the City’s stormwater system through connection to an existing six-inch storm drain west of the site. An 18-inch emergency overflow riser would be installed in the western corner of the project site and would connect to the existing 12-inch storm drain that extends along the site’s southwestern boundary (see Figure 3-13). The proposed driveway and parking area north of the existing Community Center would be a self-treating area.

Site Development Permit/Use Permit/Development Agreement A Site Development Permit and an additional Use Permit would be required to allow a clustered housing development pursuant to Pacifica Municipal Code Section 9-4.2403. The project would also include approval of a Development Agreement consistent with Title 9, Chapter 4, Article 50 of the Pacifica Municipal Code, which would require the proposed project to: (1) provide affordable units; (2) make an affordable housing contribution to the City; (3) construct 17 parking spaces at the adjacent Community Center; and (4) install wetland signage.

Parking Exception/Sign Permit/Tree Permit
Based on the number of dwelling units and commercial square footage proposed, the Municipal Code would require the proposed project to include at least 58 parking spaces. As previously discussed, the proposed project would include a total of 47 spaces. Therefore, a Parking Exception would be required to allow an exception to the off-street parking requirements related to the number of parking spaces provided, as allowed pursuant to Sections 9-4.2824(a) and 9-

4.5105(a).

Additionally, a Sign Permit would be required to ensure consistency with a master sign program prepared for the future commercial tenants of the project. The master sign program would be consistent with Pacifica Municipal Code Section 9-42907(b).

Finally, because the proposed project would include removal of on-site trees, a Tree Removal Permit would be required prior to removing any protected or City trees, as defined by the City’s current tree protection ordinance.

3.7 REQUESTED DISCRETIONARY ACTIONS
Implementation of the proposed project would require the following discretionary actions by the City of Pacifica:
x Certification and adoption of the 570 Crespi Drive Project EIR and Mitigation Monitoring and Reporting Program;
x General Plan Amendment to redesignate the off-site improvement area from Public and Semi-Public and Park land uses to Mixed Use Center (MUC);

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x Rezoning of the site from Controlled Manufacturing District (M-1) to Community Commercial (C-2);
x Zoning Text Amendment to allow residential uses in buildings that do not contain commercial uses in C-2 zoning district;
x Use Permit to allow residential uses within the C-2 zone; x Tentative Subdivision Map to create new residential and commercial condominiums; x Development Agreement to require certain public benefits and to provide certain developer benefits;
x Site Development Permit and a second Use Permit, the approval of which would allow the development of a clustered residential housing development; x Parking Exception to allow an exception to the number of off-street parking spaces required;
x Sign Permit to allow a master sign program for commercial tenants; x Lot Merger and/or LLA to merge APN 022-162-310 and a portion of APN 022-162-420; and
x Tree Removal Permit to authorize tree removal.

The proposed project would require the following discretionary approvals from other agencies:
x Clean Water Act Section 404 Permit (USACE); and
x Clean Water Act Section 401 Water Quality Certification/Waiver or Issuance of Waste Discharge Requirements (San Francisco Bay RWQCB).

The proposed project may also require approval of an Alternative Methods and Materials request by the North Country Fire Authority (NCFA).

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4.0 INTRODUCTION TO THE ANALYSIS

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4.0.1 INTRODUCTION
The technical chapters of this EIR include the analysis of the potential impacts of buildout of the proposed project on a range of environmental issue areas. Chapters 4.1 through 4.3 describe the focus of the analysis, references and other data sources for the analysis, the environmental setting related to each specific issue area, project-specific impacts and mitigation measures, and the cumulative impacts of the project in combination with other development within the cumulative setting for each issue area. The format of each of the technical chapters is described at the end of this chapter. All technical reports are either attached to this EIR, available in person at the City of Pacifica, Planning Division (located at 1800 Francisco Boulevard, Pacifica, CA 94044) by request, or available online at the following page: cityofpacifica.org/departments/communitydevelopment/planning-division/environmental-documents.

4.0.2 DETERMINATION OF SIGNIFICANCE
Under CEQA, a significant effect is defined as a substantial or potentially substantial adverse change in the environment (PRC Section 21068). The CEQA Guidelines require that the determination of significance be based on scientific and factual data. The specific criteria for determining the significance of a particular impact are identified within each technical chapter and are consistent with significance criteria set forth in the CEQA Guidelines or as based on the professional judgment of the EIR preparers.

Significance Criteria
The CEQA Guidelines define a significant effect on the environment as “a substantial, or potentially substantial adverse change in any of the physical conditions within the area affected by the project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic and aesthetic significance.” In addition, the Guidelines state, “An economic or social change by itself shall not be considered a significant effect on the environment. A social or economic change related to a physical change may be considered in determining whether the physical change is significant.” (CEQA Guidelines Section 15382).

As presented in Section 4.0.5 below, the level of significance of an impact prior to mitigation is included at the end of each impact discussion throughout the technical chapters of this EIR. The following levels of significance prior to mitigation are used in this EIR:
1) Less than Significant: Impacts that may be adverse, but that do not exceed the specified thresholds of significance;
2) Significant: Impacts that exceed the defined standards of significance and require mitigation;
3) Less than Cumulatively Considerable: Where cumulative impacts have been identified, but the project’s incremental contribution towards the cumulative impacts would not be considered significant; and
4) Cumulatively Considerable: Where cumulative impacts have been identified and the project’s incremental contribution towards the cumulative impact would be considered significant.

4.0 INTRODUCTION TO THE ANALYSIS

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If an impact is determined to be significant or cumulatively considerable, mitigation is included, if available, in order to reduce the specific impact to the maximum extent feasible. A statement of the level of significance of an impact after mitigation is also included in each impact discussion throughout the technical chapters of this EIR. The following levels of significance after implementation of mitigation are used in the EIR:
1) Less than Significant: Impacts that exceed the defined standards of significance but can be eliminated or reduced to a less-than-significant level through the implementation of feasible mitigation measures;
2) Less than Cumulatively Considerable: Where the project’s incremental contribution towards cumulative impacts would be eliminated or reduced to a less than cumulatively considerable level through the implementation of feasible mitigation measures; and 3) Significant and Unavoidable Impact: An impact (project-level or cumulative) that cannot be eliminated or reduced to a less-than-significant or less than cumulatively considerable level through the implementation of feasible mitigations measures.

Each environmental area of analysis uses a distinct set of significance criteria. The significance criteria are identified at the beginning of the Impacts and Mitigation Measures section in each of the technical chapters of this EIR. Although significance criteria are necessarily different for each resource considered, the provided significance levels ensure consistent evaluation of impacts for all resource areas evaluated.

4.0.3 ENVIRONMENTAL ISSUES DISMISSED IN THE INITIAL STUDY The Initial Study prepared for the proposed project (included in Appendix A to this EIR) includes a detailed environmental checklist addressing a range of technical environmental issues. For each technical environmental issue, the Initial Study identifies the level of impact for the proposed project. The Initial Study identifies the environmental effects as “no impact,” “less than significant,” “less than significant with mitigation incorporated,” and “potentially significant.” Impacts identified in the Initial Study as less than significant with mitigation incorporated, less than significant, or no impact are summarized below. All remaining issues identified in the Initial Study as potentially significant are discussed in the subsequent technical chapters of this EIR. x Aesthetics (All Checklist Questions): The proposed project site is not located within the vicinity of a designated scenic vista and would not damage scenic resources. In addition, the Initial Study concluded that impacts related to conflicts with applicable zoning and other regulations governing scenic quality, as well as the introduction of new sources of light and glare would be less than significant. Overall, the proposed project would result in impacts that are less than significant related to aesthetics. x Agriculture and Forest Resources (All Checklist Questions): The project site is identified by the California Department of Conservation Farmland Mapping and Monitoring Program as Urban and Built-Up Land. In addition, the site is not under a Williamson Act contract, is not zoned for agricultural uses, is not considered forest land or timberland, and is not zoned for Timberland Production. Therefore, the proposed project would have no impact or a less-than-significant impact related to agricultural and forest resources. x Air Quality (All Checklist Questions): The applicable regional air quality plans include the 2001 Ozone Attainment Plan and the 2017 Clean Air Plan. Because the proposed project

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would not result in construction-related or operational emissions of criteria air pollutants in excess of Bay Area Air Quality Management District’s (BAAQMD) thresholds of significance, conflicts with or obstruction of the implementation of regional air quality plans would not occur. In addition, the project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard. Due to the size of the proposed project and the anticipated number of trips generated by the project, the proposed project would not be expected to expose sensitive receptors to substantial concentrations of localized carbon monoxide (CO). The proposed project would not involve any land uses or operations that would be considered major sources of toxic air contaminants (TACs), including diesel particulate matter (DPM), and construction would not result in cancer risk, acute hazards, or chronic hazards in excess of BAAQMD’s standards. As such, the proposed project would not generate any substantial pollutant concentrations. In addition, compliance with all established BAAQMD regulations and rules would ensure construction and operation of the proposed project would not result in emissions (such as those leading to odors) adversely affecting a substantial number of people. Overall, the proposed project would result in impacts that are less than significant with regard to the aforementioned impacts related to air quality.
x Biological Resources (Checklist Question f): Adopted Habitat Conservation Plans or Natural Conservation Community Plans covering the project site do not exist. Therefore, the proposed project would not conflict with the provisions of such a plan, and no impact would occur. It should be noted that all other potential impacts related to biological resources are analyzed in Chapter 4.1, Biological Resources, of this Draft EIR. x Cultural Resources (All Checklist Questions): The project site is currently vacant, and, thus, does not contain any permanent structures which could be considered historical resources pursuant to Section 15064.5 of the CEQA Guidelines. Additionally, portions of the project site that would be developed as part of the project have been subject to previous disturbance. According to the records search of the California Historic Resources Information System (CHRIS), the project site does not contain any documented archaeological resources. However, the California Inventory of Historic Resources lists one of the Portola Expedition camps in close proximity to the project site. In addition, Portola’s San Francisco Bay Discovery site is located in close proximity to the project site.

Based on such, the project site has a moderate potential for unrecorded archaeological resources to occur. While the potential exists for the proposed project to result in the uncovering of previously unknown historical or archaeological resources, including human remains, during ground-disturbing activities associated with project construction, the Initial Study includes mitigation sufficient to ensure that, in the event that any such resources are encountered during construction, significant impacts would not occur. Overall, the proposed project would result in impacts that are less than significant with mitigation incorporated with regard to the aforementioned impacts related to cultural resources. x Energy (All Checklist Questions): The temporary increase in energy use occurring during construction of the proposed project would not result in a significant increase in peak or base demands or require additional capacity from local or regional energy supplies. In addition, the proposed project would be required to comply with all applicable regulations related to energy conservation and fuel efficiency, which would help to reduce the temporary increase in demand. During operation, the proposed project would be subject to all relevant provisions of the most recent update of the California Building Standards

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Code (CBSC), which requires efficient building design and the use of renewable sources of energy. In addition, the proposed project would comply with all applicable regulations associated with vehicle efficiency and fuel economy. Finally, future residents/commercial tenants would have access to electricity generated from renewable sources through Peninsula Clean Energy. Therefore, construction and operations of the proposed project would not result in wasteful, inefficient, or unnecessary consumption of energy resources or conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Overall, the proposed project would result in impacts that are less than significant with regard to the aforementioned impacts related to energy. x Geology and Soils (All Checklist Questions): Given the vicinity of the project site to the San Andreas Fault System, the project site could be subject to strong ground shaking due to a major earthquake in one of the above-listed fault zones. However, conformance with the appropriate engineering standards set forth by the California Building Standards Code (CBSC) would ensure that impacts related to seismic surface rupture or strong seismic ground shaking would be less than significant. In addition, the development of the proposed project would not result in adverse impacts related to landslides and lateral spreading. However, a rigid foundation is required to minimize any potential movements due to liquefaction, expansive soils, and subsidence/settlement. Therefore, the Initial Study includes mitigation sufficient to ensure that such impacts would be reduced to a less-than-significant level. Furthermore, while the potential exists for the proposed project to result in the uncovering of previously unknown paleontological resources, the Initial Study includes mitigation sufficient to ensure that, in the event that any such resources are encountered during construction, significant impacts would not occur. Finally, because the proposed project would connect to existing City sewer lines in the project vicinity, the construction or operation of septic tanks or other alternative wastewater disposal systems is not included as part of the proposed project, and no impact would occur regarding the capability of soil to adequately support the use of such systems. Overall, the proposed project would have no impact, or result in impacts that are less than significant, or less than significant with mitigation incorporated with regard to the aforementioned impacts related to geology and soils.
x Hazards and Hazardous Materials (All Checklist Questions): Residential and the commercial uses permitted by the C-2 zoning district are not associated with the routine use, transport, or disposal of hazardous materials, with the exception of common household cleaning products, fertilizers, and herbicides. However, such materials would be used in accordance with label instructions and all applicable regulations. The project site was previously developed with a single-family residence and a mechanic shop.

Although not documented at the project site, activities within the project site may have included the use of fuels, coolants, or other chemicals associated with the mechanic shop.

Operations associated with the mechanic shop could result in concentrations of residual chemicals being present in the near surface soil if use or storage of chemicals has occurred. Although evidence of contamination does not exist, past activities on-site associated with the mechanic shop could have resulted in soil contamination within the project site. However, the Initial Study includes mitigation to ensure any related impacts associated with hazardous materials would be reduced to less-than-significant levels.

Such mitigation would ensure that, although the project site is located within a quartermile of Cabrillo Elementary School, the project would not create hazardous emissions or handle hazardous materials, substances, or waste.

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In addition, the project site is not identified on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. The project site is not located within two miles of a public airport or within a safety zone as identified by an airport land use plan, and would not result in a safety hazard for people working in the project area. Furthermore, development of the proposed project would not expose people or structures to the risk of loss, injury, or death involving wildland fires. The proposed project could impair the implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan because the required emergency access width of 26 feet would not be met with the proposed site plan. As such, the Initial Study includes mitigation to require the access road to be at least 26 feet wide, thereby reducing impacts to a lessthan-significant level. Overall, the proposed project would have no impact, or result in impacts that are less than significant or less than significant with mitigation incorporated related to hazards and hazardous materials.
x Hydrology and Water Quality (All Checklist Questions): Because construction activities on the northern portion of the project site and the off-site improvement area would disturb greater than one acre of land, construction activities would be subject to the San Mateo Countywide Pollution Prevention Program, which provides a list of construction best management practices (BMPs). Should the project applicant fail to implement BMPs, pollutants from construction activities could runoff into local waterways and degrade downstream water quality, particularly during heavy winter rain events. Therefore, the Initial Study includes mitigation sufficient to ensure the project would not violate water quality standards or waste discharge requirements, substantially degrade water quality, or result in a conflict with a water quality control plan. Groundwater supplies would not be used to serve the proposed project, and, therefore, the proposed project would not deplete groundwater supplies or interfere with groundwater recharge. Compliance with the City’s stormwater control and water quality standards would ensure the proposed project would not substantially alter the existing drainage pattern of the site or area in a manner that would result in substantial erosion, siltation, or flooding on- or off-site, 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. In addition, the proposed project would not impede or redirect flood flows or pose a risk related to the release of pollutants due to project inundation caused by flooding, tsunami or seiche.

Overall, the proposed project would result in impacts that are less than significant or less than significant with mitigation incorporated related to hydrology and water quality. x Land Use and Planning (All Checklist Questions): The proposed project would not physically divide an established community. Although the project would include a General Plan, Rezone, and a Zoning Text Amendment, the types of uses and building forms allowed would be consistent with the existing C-2 zoning standards. Thus, approval of the requested entitlements would not result in any significant environmental impacts on the project site or surrounding area, or conflict with any plans or policies adopted for the purpose of avoiding an environmental effect. In addition, the type and intensity of the proposed uses has been generally anticipated by the City. Overall, the proposed project would result in impacts that are less than significant related to land use and planning. x Mineral Resources (All Checklist Questions): The State Division of Mines and Geology indicates that the project site does not contain any identified mineral resources of regional or Statewide significance (Mineral Resource Zone 2). The City’s adopted General Plan recognizes the existence of mineral resources at the Rockaway Quarry and Picardo

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Ranch (now Millwood Ranch) and cites unmined limestone deposits underlying development elsewhere in the City, but does not specifically refer to the project site.

Therefore, the proposed project would not result in a significant loss of availability of a known mineral resource that would be of value to the region and the residents of the State.

Furthermore, the City’s General Plan does not identify the project site as being a locallyimportant mineral resource recovery site. Therefore, the proposed project would result in no impact related to mineral resources.
x Noise (All Checklist Questions): Project construction could result in a maximum increase in noise of up to nine A-weighted decibels (dBA) above existing ambient noise levels. The increase of nine dBA would not exceed the Caltrans 12 dBA increase criteria. Additionally, noise associated with construction activities would occur intermittently and would be limited to the hours specified in Section 8-1.08 of the City’s Municipal Code. The City of Pacifica would ensure that project construction complies with Section 8-1.08 of the Municipal Code as a condition of project approval. Furthermore, construction activities would be exempted from the noise standards by the City, provided they take place between the specified hours. As a result, a less-than-significant impact would occur during project construction. The maximum increase in traffic noise at the nearest sensitive receptor is predicted to be 0.1 dBA. Therefore, the proposed project would not result in the generation of a substantial permanent increase in traffic noise levels. Because construction of the proposed project could expose people to or generate excessive groundborne vibration or groundborne noise levels associated with the use of pile drivers, the Initial Study includes mitigation prohibiting such activity. Finally, the project site is not located within two miles of a public or private airport, and, thus, would not expose people residing or working in the project area to excessive noise levels associated with airports.

Overall, the proposed project would result in impacts that are less than significant or less than significant with mitigation incorporated related to noise. x Population and Housing (All Checklist Questions): Parcel 1 is currently undeveloped and Parcel 2 is not developed with any residential structures; thus, the proposed project would not result in the displacement of existing housing or residents. Development of the proposed project is anticipated to result in a 0.14 percent increase in the City’s population, which would not be considered substantial growth. The project would not result in any indirect population growth from extension of major infrastructure because adequate utility infrastructure already exists in the project area to support the proposed project. Therefore, the population growth associated with the proposed project has been previously anticipated by the City and evaluated in the General Plan EIR. Therefore, the proposed project would result in a less-than-significant impact related to population and housing. x Public Services (All Checklist Questions): The North Country Fire Authority (NCFA) would provide adequate fire protection services to the proposed project, which would include adequate fire safety design elements. The minor population growth associated with the proposed project would not necessitate the construction of new or expanded facilities.

Additionally, the proposed project is located within existing police patrol routes and service areas. Furthermore, the proposed project would be subject to the payment of development impact fees pursuant to Chapter 14 of the City’s Municipal Code related to public facilities, impact fees applied to new development by the Pacifica School District and Jefferson Union High School District, and park impact fees established by Chapter 19 of the City’s Municipal Code. Finally, due to the relatively small project size, implementation of the proposed project would not result in a substantial increase in demand for library services.

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Therefore, the proposed project would not require the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection services, police protection services, schools, parks, libraries, or other public facilities. Overall, the proposed project would result in a less-than-significant impact with regard to the aforementioned impacts related to public services.
x Recreation (All Checklist Questions): Recreational or park facilities are not proposed as part of the project. However, the project would be subject to payment of a park impact fee pursuant to Chapter 19 of the City’s Municipal Code to provide funding for future parkland or recreational facilities. Due to the relatively small project size and the proximity to existing recreational facilities in the City, development of the proposed project is not expected to substantially increase the use of existing parks or recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Overall, a less-than-significant impact would occur related to recreation. x Tribal Cultural Resources (All Checklist Questions): Portions of the project site that would be developed as part of the project, as well as the off-site improvement area, have been previously and recently disturbed. Additionally, recent construction of an equalization basin in the southern portion of 540 Crespi Drive included substantial excavation, and tribal cultural resources were not identified during such ground disturbance. Due to the previous disturbance of the site, the probability of finding tribal cultural resources on the surface of the site is unlikely. While previously undiscovered tribal cultural resources could be uncovered during ground-disturbing activities associated with construction of the proposed project, the Initial Study includes mitigation sufficient to ensure that, in the event that any such resources are encountered during construction, significant impacts would not occur. Overall, the proposed project would result in impacts that are less than significant with mitigation incorporated with regard to impacts related to tribal cultural resources.
x Utilities and Service Systems (All Checklist Questions): Sufficient water supplies are available to adequately serve the proposed project during normal, dry, and multiple dry years. The City’s wastewater facility also has sufficient remaining available capacity to serve the proposed project, and residents are required to pay an annual sewer charge based on water consumption rates for each unit, pursuant to Chapter 6 of the City Municipal Code. Such charges would help to ensure that adequate capacity is available to serve the project’s demand for services. Stormwater runoff from impervious surfaces associated with the proposed project would be treated on-site prior to discharge, and implementation of mitigation in the Initial Study would ensure that BMPs are implemented during construction activities to reduce pollutants to the maximum extent practicable.

Finally, electricity and telecommunications utilities would be provided by way of connections to existing infrastructure located within the immediate project vicinity without major upgrades to, or extension of, existing infrastructure. The proposed project would not require or result in the relocation or construction of new or expanded water, wastewater treatment, stormwater, electric power, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects. Furthermore, adequate wastewater capacity would be available to serve the project’s projected demand in addition to existing commitments. Finally, the proposed project would be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal

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needs and would comply with federal, State, and local statutes and regulations related to solid waste. Overall, a less-than-significant impact would occur related to utilities and service systems.
x Wildfire (All Checklist Questions): According to the California Department of Forestry and Fire Protection, Fire and Resource Assessment Program, the project site is not located within or adjacent to a State Responsibility Area or a Very High Fire Hazard Severity Zone.

Furthermore, the project site is surrounded by urban development and would include the removal of a portion of the on-site vegetation, which would help prevent the spread of wildfire within the project area. Thus, the proposed project would not be expected to be subject to or result in substantial adverse effects related to wildfires, and a less-thansignificant impact would occur.

4.0.4 ENVIRONMENTAL ISSUES ADDRESSED IN THIS EIR
The EIR provides the analysis necessary to address the environmental impacts of the proposed project. The following environmental issues are addressed in separate technical chapters of this EIR:
x Biological Resources;
x Greenhouse Gas Emissions; and
x Transportation.

See Section 5.3, Cumulative Impacts, of Chapter 5, Statutorily Required Sections, for additional information on the scope of the cumulative impact analysis for each environmental issue addressed in the EIR.

4.0.5 TECHNICAL CHAPTER FORMAT
Each technical chapter addressing a specific environmental issue begins with an introduction describing the purpose of the chapter. The introduction is followed by a description of the project’s existing environmental setting pertaining to that particular environmental issue. The setting description is followed by the regulatory context and the impacts and mitigation measures discussion, which contains the standards of significance, followed by the method of analysis.

The standards of significance section includes references to the specific checklist questions consistent with Appendix G of the CEQA Guidelines. The impacts and mitigation measures discussion includes impact statements prefaced by a number in bold-faced type (for both projectlevel and cumulative analyses). An explanation of each impact and an analysis of the impact’s significance follow each impact statement (see below), followed by all mitigation measures pertinent to each individual impact. The degree of relief provided by identified mitigation measures is also presented. An example of the format is shown below.

Project-Specific Impacts and Mitigation Measures
The following discussion of impacts is based on the implementation of the proposed project in comparison with the standards of significance.

4.X-1 Statement of Project-Specific Impact
Discussion of impact for the proposed project in paragraph format.

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Statement of level of significance of impact prior to mitigation is included at the end of each impact discussion. If an impact is determined to be significant, mitigation will be included in order to reduce the specific impact to the maximum extent feasible. Impacts that cannot be reduced to a less-than-significant level with implementation of all feasible mitigation would be considered to remain significant and unavoidable.

Mitigation Measure(s)
Statement of level of significance after mitigation is included immediately preceding the mitigation measures.

4.X-1(a) Required mitigation measure(s) presented in italics and numbered in consecutive order.

4.X-1(b) Required additional mitigation measure, if necessary.

Cumulative Impacts and Mitigation Measures
The following discussion of cumulative impacts is based on implementation of the proposed project in combination with cumulative development within the applicable area or region.

4.X-2 Statement of Cumulative Impact
Discussion of cumulative impacts for the proposed project in paragraph format.

As discussed in detail in Chapter 5, Statutorily Required Sections, of the EIR, the cumulative setting for the proposed project is generally considered to be development anticipated to occur upon buildout of the proposed project, as well as buildout of the City of Pacifica General Plan.

Statement of level of significance of cumulative impact prior to mitigation is included at the end of each impact discussion. If an impact is determined to be cumulatively considerable, mitigation will be included in order to reduce the specific impact to the maximum extent feasible. Impacts that cannot be reduced to a less than cumulatively considerable level with the implementation of all feasible mitigation would be considered to remain significant and unavoidable.

Mitigation Measure(s)
Statement of level of significance after mitigation is included immediately preceding the mitigation measures.

4.X-2(a) Required mitigation measure(s) presented in italics and listed in consecutive order.

4.X-2(b) Required additional mitigation measure, if necessary.

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4.1 BIOLOGICAL RESOURCES

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4.1.1 INTRODUCTION
The Biological Resources chapter of the EIR evaluates the biological resources known to occur or potentially occur within the project site. The chapter describes the proposed project’s potential impacts to biological resources and identifies measures to eliminate or substantially reduce impacts to a less-than-significant level. Existing plant communities, wetlands, wildlife habitats, and potential for special-status species and communities are discussed for the project region. The information contained in the analysis is primarily based on the Biological Constraints Analysis (Appendix C),1 supplemental response letters responding to public comments (including comments from the California Department of Fish and Wildlife [CDFW]) and peer reviews conducted by the City of Pacifica,2,3,4,5 and the Delineation of Potentially Jurisdictional Aquatic Resources and Effects Analysis (Appendix D)6 prepared for the proposed project by Wood Biological Consulting (WBC). Further information was sourced from the City of Pacifica General Plan 20407 and the City of Pacifica General Plan Update and General Plan Update EIR.8

4.1.2 EXISTING ENVIRONMENTAL SETTING
The following sections describe the regional biological setting in which the project site is located, the biological setting of the project site, and the special-status species known to occur within the project site and surrounding environs.

Regional Setting
The project site is located just south of Crespi Drive in the City of Pacifica, California (see Figure 3-1 and Figure 3-2 in the Project Description chapter of this EIR). The City lies in the northwestern portion of the Bay Area’s peninsula climatological sub-region, in a location where generally strong winds emanate from the ocean, and within the San Francisco-Oakland-San Jose metropolitan area – the northern end of the City is approximately 10 miles from downtown San Francisco. The City experiences a Mediterranean climate, similar to many coastal areas within the State.

Summers are typically comfortable and arid, with mostly clear skies, and winters are generally short, cold, wet, windy, and partly cloudy. The average annual high temperature in the City of Pacifica is 64 degrees Fahrenheit, and the annual average low temperature is 49 degrees 1 Wood Biological Consulting. Biological Constraints Analysis – Updated. August 17, 2020. 2 Wood Biological Consulting. Response Letter: Determination of Incomplete Application – File No. 2016-004 Amendment to Biological Constraints Analysis 570 Crespi Drive, Pacifica CA (APN 022-162-310). February 3, 2021. 3 Wood Biological Consulting. Response Letter: File No. 2016-004, 570 Crespi Drive, Pacifica CA (APN 022-162- 310) Amendment to Biological Constraints Analysis. March 9, 2021. 4 Wood Biological Consulting. Response Letter: File No. 2016-004, 570 Crespi Drive, Pacifica CA (APN 022-162- 310) 570 Crespi – IS/MND Information Needed. September 22, 2021. 5 Wood Biological Consulting. Supplemental Memorandum: Biological Resources, 570 Crespi Project. December 4, 2024. 6 Wood Biological Consulting. Updated Delineation of Potentially Jurisdictional Aquatic Resources and Effects Analysis 570 Crespi Avenue, Pacifica CA. May 31, 2024. 7 City of Pacifica. City of Pacifica General Plan 2040. Adopted July 11, 2022. 8 City of Pacifica. City of Pacifica General Plan Update and Sharp Park Specific Plan Final Environmental Impact Report. Adopted May 25, 2022.

I 4.1 B 4.1 IOLOGICAL RESOURCES
IL

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Fahrenheit. Approximately 29.5 inches of precipitation falls annually, with the majority of rainfall between October and April.

Much of the land to the south and southeast of the City is preserved as units of the Golden Gate National Recreation Area, State and County parks, and the San Francisco watershed. Rural and agricultural land is prevalent to the south. The Pacific Ocean borders the City to the west. Access to the City is primarily from State Route (SR) 1 and SR 35. Land west of SR 1 in the City is part of the State-designated Coastal Zone, which also includes a small amount of land to the east in the vicinity of Shelldance Nursery. The City’s varied topography creates a wide range of habitats, including intertidal areas, beaches, ridges, coastal headlands, woodlands, grasslands, coastal scrub, creeks, and wetlands. Most natural vegetation in the valley and canyon bottoms has been converted by urban development. However, intact native habitats persist along the riparian corridors of San Pedro Creek, Calera Creek, Rockaway Creek, and Milagra Creek, as well as on steep slopes.

Project Setting
The study area analyzed in the Biological Constraints Analysis includes the project site, as well as the off-site improvement area adjacent to the Pacifica Community Center. The project site is currently undeveloped and covered in dense vegetation. Several trees and shrubs are located throughout the project site. It should be noted that the western portion of the site was recently disturbed during landscape improvements, while the southern portion of the site is predominantly characterized by a seasonal drainage and wetland area. The northern portion of the project site supports several large Monterey cypress (Hesperocyparis macrocarpa) trees with an understory of predominantly non-native herbaceous vegetation. The southern portion of the project site is slightly lower in elevation, and gradually becomes dominated by perennial wetland vegetation, such as willows, cattails, and sedges. The project site ranges from approximately 15 feet in elevation, relative to a City benchmark in Crespi Drive, at the northeastern end of the project site, to approximately nine feet at the southwestern boundary. The off-site area adjacent to the Pacifica Community Center that is included as part of the study area currently includes a driveway, sidewalk, several trees, and ruderal grassland.

Surrounding land uses include the Pacifica Community Center and associated parking lot and rain garden, Pacifica Skatepark, and SR 1 to the west; commercial businesses and Ocean View Senior Apartments to the north, across Crespi Drive; the Cabrillo Elementary School and commercial businesses to the east; and single-family residences to the south.

Vegetation Communities Within the Study Area
Vegetation within the study area consists of arroyo willow scrub, emergent marsh, seasonal wetland, non-native annual grassland, and disturbed and ornamental habitats (see Figure 4.1-1).

The study area’s vegetation types are discussed further below.

Arroyo Willow Scrub
As shown in Figure 4.1-1, willow scrub, dominated by arroyo willow (Salix lasiolepis), covers most of the southern portion of the study area on both parcels. Willow scrub also occurs in smaller stands along the western and eastern project site boundaries. The willows form a dense and impenetrable thicket with few associated plant species. The willow scrub is almost entirely within the delineated wetland boundary; the exception is at the northern extent, where soils and hydrology near the edge of the willows failed to meet wetland criteria.

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Figure 4.1-1
Vegetation Communities
N ---- Parcel Line Boundary Disturbed/Ornamental AWS-2 0.45 A [:] StudyArea
-Freshwater Emergent Marsh AWS-3 0.02
AWS-NON-J O 0.08
Vegetation Non-native Grassland NNG-1 0.39 0 50 100
Arroyo Willow Scrub Seasonal Wetland SW-1 0.06
Feet - FEM-1 0.24
Arroyo Willow Scrub (non-JD) 00-1 a.so
00-2 0.01
IL

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Additionally, in the southern portion of the study area, the topography rises slightly because of fill placed for the backyards of single-family residences on Anza Drive. Although willow canopy extends to the parcel boundary, the willows are rooted in the lower part of the topographic depression, away from the fence line. In the southwestern corner of the study area, the topography rises more abruptly toward the berm that separates the project site from the Pacifica Community Center parking lot and rain garden. Non-native ngaio tree (Myoporum laetum), an upland species, replaces willow where the ground surface level is higher.

Emergent Marsh
Emergent marsh occupies a shallow topographic depression in the middle part of the study area (see Figure 4.1-1), corresponding with the area with shallow ponded water in the winter.

Seasonally high groundwater presumably persists, resulting in a predominance of emergent marsh plant species, such as Baltic rush (Juncus balticus), broadleaf cattail (Typha latifolia), Pacific silverweed (Potentilla anserina ssp. pacifica), and dotted smartweed (Persicaria punctata), among others. All emergent marsh area is within the delineated wetland boundary.

Seasonal Wetland
Seasonal wetland occupies a narrow transitional band between the upland and emergent marsh and arroyo willow scrub (see Figure 4.1-1). The vegetation includes species that occupy the margins of the emergent marsh, but also some of the non-native annual grassland species.

Non-Native Annual Grassland
Non-native grassland vegetation is present on the majority of the northern part of the study area, including the former residence site (see Figure 4.1-1). Dominant plant species include annual grasses, such as bromes (Bromus diandrus, B. hordeaceus), slender oats (Avena barbata), hare barley (Hordeum murinum ssp. leporinum), velvet grass (Holcus lanatus), and Italian ryegrass (Festuca perennis), with various non-native broad-leaf herbaceous species. Non-native annual grassland plant species also occur within the area mapped as seasonal wetland within the delineated wetland boundary, where the species appear to be expanding down the topographic gradient in response to drier soil conditions following groundwater pumping during construction of the City’s Wet Weather Equalization Basin.

Disturbed and Ornamental
Disturbed habitat includes land cleared of vegetation or lands that have undergone frequent or extensive alteration to the extent that the site is dominated by non-native plant species. Disturbed habitat also includes areas subject to periodic vegetation management, such as mowing or brush clearing, which preclude the re-establishment of native vegetation communities. To the west of the study area, a parking area adjacent to Crespi Drive that is used by beach visitors and a gravel staging area used during construction of the Wet Weather Equalization Basin are disturbed habitat (see Figure 4.1-1).

Ornamental vegetation consists of maintained and unmaintained landscaping using native and non-native plants. Within the study area, several large Monterey cypress trees are remnants of landscaping associated with the former residence in the northern portion of the study area. An additional area of ornamental vegetation located adjacent to the Pacifica Community Center, within the off-site improvement area, is included within the study area. None of the ornamental vegetation is within the delineated wetland boundary.

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Wetlands
Streams or other surface waters are not located within the study area. All aquatic resources in the study area are wetlands. Table 4.1-1 below summarizes the areas of wetlands and nonwetlands (uplands) in the study area. All areas are preliminary and subject to verification by the U.S. Army Corp of Engineers (USACE) if proposed project activities would result in placement of fill into aquatic resources determined to be jurisdictional.

Table 4.1-1
Wetlands and Uplands in the Study Area
Feature Type
Wetland Upland Total
Acres
Arroyo willow scrub 0.460 0.090 0.550
Emergent marsh 0.240 0.000 0.240
Seasonal wetland 0.060 0.000 0.060
Non-native annual
grassland 0.000 0.400 0.400
Disturbed and
ornamental 0.000 0.980 0.980
Total 0.760 1.470 2.230
Source: Wood Biological Consulting, 2024.

The northern wetland boundary is inferred from the location of one sample point where all three wetland criteria were met (sample point 2A as shown on Figure 4.1-2) and two sample points where direct evidence of wetland hydrology is lacking, but could be inferred from soil indicators (sample points 1A and 3B). The latter two points are considered to be non-wetland, but on the boundary. All three points are located at or below the 10-foot contour, as shown on a topographic survey of the study area. The arroyo willow scrub vegetation type is bisected by the wetland boundary, resulting in a portion of arroyo willow scrub that meets the wetland criteria and a portion that is considered upland. Seasonal wetland is mapped in the transitional zone, which is consistent with the interpretation that site hydrology has changed toward drier conditions since groundwater pumping during construction of the City’s Wet Weather Equalization Basin.

The southern wetland boundary was established between the one sample point where all three wetland criteria were met (SP-3) and two sample points where the criteria were not met (SP-1 and SP-2). Sample point SP-1 is located at the proposed emergency riser within the City’s existing drainage easement, adjacent to the wooden backyard fence and close to an existing underground storm drain that carries stormwater and urban nuisance drainage from residential neighborhoods west toward the Anza Pump Station on Pacifica State Beach. Sample point SP1 is in a small depression that facilitates drainage when water accumulates in the southern portion of the project site. Sample point SP-3 is located in the interior of the arroyo willow thicket and in the topographic depression where soils are inundated or saturated for a significant part of the growing season.

On-Site Special-Status Species
Special-status species are species that have been listed as “threatened” or “endangered” under the federal Endangered Species Act (FESA), California Endangered Species Act (CESA), or are of special concern to federal resource agencies, the State, or private conservation organizations.

A species may be considered special-status due to declining populations, vulnerability to habitat change, or restricted distributions. A description of the criteria and laws pertaining to specialstatus classifications is described below.

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Figure 4.1-2
Wetland Map
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Special-status plant and wildlife species may meet one or more of the following criteria:

1. Listed as threatened or endangered, or proposed or candidates for listing by the U.S. Fish and Wildlife Service (USFWS) or National Marine Fisheries Service (NMFS);

2. Listed as threatened or endangered and candidates for listing by the CDFW;

3. Identified as Fully Protected species or Species of Special Concern by CDFW;

4. Identified as Medium or High priority species by the Western Bat Working Group (WBWG); and

5. Plant species considered to be rare, threatened, or endangered in California by the California Native Plant Society (CNPS) and CDFW (California Rare Plant Rank [CRPR] 1, 2, and 3):
a. CRPR 1A: Plants presumed extinct.
b. CRPR 1B: Plants rare, threatened, or endangered in California and elsewhere. c. CRPR 2A: Plants extirpated in California, but common elsewhere. d. CRPR 2B: Plants rare, threatened, or endangered in California, but more common elsewhere.
e. CRPR 3: Plants about which the CNPS needs more information – a review list.

Listed and Special-Status Plants
Based on a review of the resources and databases discussed above, 29 special-status plant species were documented as part of WBC’s analysis within five miles of the study area (see Figure 4.1-3).

As shown in Table 1 of the Biological Constraints Analysis (see Appendix C of this EIR), suitable habitat is not present within the study area for 28 of the 29 identified special-status species due to the absence of chaparral, coastal bluffs, woodland, etc. In addition, none of the species were identified during the reconnaissance-level field survey of the study area. While sandy soils are present, which would provide potential habitat for San Francisco Bay spineflower (Chorizanthe cuspidata var. cuspidate), the species was not present during the field survey, which occurred during the species’ blooming period. Therefore, low potential exists for special-status plants to occur within the study area.

Listed and Special-Status Wildlife
Based on a review of the resources and databases discussed above, 16 special-status wildlife species were documented within five miles of the study area as part of WBC’s analysis (see Figure 4.1-4). As discussed in Table 2 of the Biological Constraints Analysis (see Appendix C of this EIR), of the 16 special-status wildlife species that were documented, 15 are considered unlikely, or have no potential, to occur in the study area based on habitat features, such as the location of the site outside of the species’ historical range, the lack of suitable aquatic habitat, lack of suitable foraging or nesting habitat, and lack of a den or cave development area.

The saltmarsh common yellowthroat (Geothlypis trichas sinuosa) was identified as having the potential to occur within the study area. Other nesting birds protected by the California Fish and Game Code (CFGC) and the federal Migratory Bird Treaty Act of 1918 (MBTA) may also occur on-site. In addition, while the Biological Constraints Analysis determined that limited breeding habitat for California red-legged frog (Rana aurora draytonii) exists in the study area on a regular basis, the potential for the species to occur in the study area is evaluated herein. Salt marsh common yellowthroat (Geothlypis trichas sinuosa), birds protected by the MBTA, and California red-legged frog are discussed in detail, below.

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Figure 4.1-3
Special-Status Plant Species Within Five Miles of Study Area Source: Wood Biological Consulting, 2024.

Unlabeled Species:

Agrostis blasdalei
Chorizanthe cuspidate var. cuspidata
Eriophyllum latilobum
Hypogymnia schizidiata
Leptosiphon croceus
Monolopia gracilens
Pentachaeta bellidiflora
Trifolium amoenum
Triquetrella californica
LEGEND
ALPE - Allium peninsulare ssp. franciscana
ARMO -Arctostaphylos montara
ARRE - Arctostaphylos regismontana
CEPA - Centromadia parryi ssp. parryi
CIAN - Cirsium andrewsii
COMU - Collinsia multicolor
DIOC - Dirca occidentalis
FRLI - Fritillaria liliacea
GRHI - Grindelia hirsutula var. maritima
HECO - Hemizonia congesta ssp. congesta
HOCU - Horkelia cuneata var. cuneata
HOCU - Horkelia marinensis
LACA - Lasthenia californica ssp.

LERO - Leptosiphon rosaceus
MAAR - Malacothamnus arcu us
POHi - Potentilla hickmanii
PLCH - Plagiobothrys chor, sianus var. c.

SISC - Silene scouleri ss . scouleri
SIVE - Silene verecunda ssp. verecunda
RFL - Triphysaria flori unda
6 N
0 0
IL
COMU
CIAN
5-mile buffer/

1.25 1:144,448

2.5 2 4
August 11 , 2020
5mi
8km Sources : Esri, HERE, Garmin, lntermap, increment P Co~ GEBCO, USGS, FAQ, NPS, NRCAN , GeoBase, IGN, Kadaster L, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), (c) OpenStreetMap contributors, and the GIS User Community, BOB

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Figure 4.1-4
Special-Status Wildlife Species Within Five Miles of Study Area Source: Wood Biological Consulting, 2024.

Unlabeled Species:

Danaus plexippus
Callophrys mossii bayensis
Speyeria zerene myrtleae
LEGEND
AB - American badger
ASSP - Alameda song sparrow
BFB - big free-tailed bat
CRLF - California red-legged frog
FM - fringed myotis
FYLF - foothill yellow-legged frog
HB - hoary bat
MER - merlin
NAP - North American porcupine
SFGS - San Francisco garter snake (aces.
protected throughout region)
SH - steelhead
SMCY - saltmarsh common yellowthroat
TBB - Townsend's big-eared bat
0 0
IL
5-mile buffer/

1.25 1:144,448

2.5 2 4
August 11 , 2020
5mi
8km
. ,
0 Sources : Esri, HERE, Garmin , lni!e ma- , ·nFrement P Corp., GEEl.CO, USGS. FAO, NPS, NRCAN , Geo~e-; G)', Kadasler NL, Or~nance Survey, Esri Japan , METI , Esri CliiM'(l-long Kong), (c)~ i,enStreelMap contributors, and the GIS User Co . nity, BOB

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Saltmarsh Common Yellowthroat
The saltmarsh common yellowthroat is a CDFW Species of Special Concern. The species is a small bird with an olive-brown back and rich yellow throat. The migratory bird ranges from Canada to southern Mexico and winters from the southern U.S. to the West Indies and Panama. A yearround resident of the San Francisco Bay Area, the species inhabits dense vegetation in wetlands, marshes, estuaries, prairies and riparian areas of San Francisco and San Pablo bays, and along the coastal areas of Marin, San Francisco, and San Mateo counties. Saltmarsh common yellowthroat requires thick, continuous cover down to the water surface for foraging and tall grasses, tule patches or willows for nesting, and forage on insects and spiders on the ground or within dense vegetation. Nests are built near the base of dense vegetation, sometimes over water.

Breeding occurs from mid-March to late July, and pairs typically double brood.

The nearest known record (California Natural Diversity Database [CNNDB] Occurrence #5) is located approximately 1.8 miles north of the study area. The potential exists for on-site willows to provide migratory habitat. However, the study area does not provide potential nesting habitat due to its small area and urban setting, and the absence of proximity to water that is usually associated with saltmarsh common yellowthroat nests. The species was observed in the study area during monitoring of the City’s Wet Weather Equalization Basin in 2017-2018, although the nesting status was not determined.

Birds Protected by the MBTA
Nesting birds, including raptors, are protected by CFGC Section 3503. Raptors, passerines, nonpasserine land birds, and waterfowl are further protected under the Federal MBTA of 1918. The MBTA prohibits the take, possession, purchase, sale, or bartering of any migratory bird, including feathers or other parts, nests, eggs, or products, except as allowed by implementing regulations.

All migratory bird species are protected by the MBTA.

Any disturbance that causes direct injury, death, nest abandonment, or forced fledging of migratory birds, is restricted under the MBTA. Any removal of active nests during the breeding season or any disturbance that results in the abandonment of nestlings is considered a ‘take’ of the species under federal law.

In addition to the special-status birds identified within five miles of the study area by the CNDDB, the USFWS Information for Planning and Consulting (IPaC) database also identified 19 species of birds protected under the MBTA and Bald Eagle Protection Act, and are considered Bird Species of Conservation Concern. Six of the identified species (Allen’s hummingbird [Selasphorus sasin], rufous hummingbird [Selasphorus rufus], song sparrow [Melospiza melodia], spotted towhee [Pipilo maculatus], wrentit [Chamaea fasciata], and saltmarsh common yellowthroat) have low probability of nesting in the project site, but cannot be entirely ruled out.

California Red-Legged Frog
The California red-legged frog (Rana draytonii) is covered under FESA. On March 16, 2010, the USFWS issued the final designation for California red-legged frog Critical Habitat. The 2010 Critical Habitat maps (Federal Register dated March 17, 2010 [Volume 75, Number 51:12815- 12864] shows that the project site is not located within mapped Critical Habitat for the species.

The California red- legged frog is also a CDFW Species of Special Concern.

The California red-legged frog is typically found in ponds and slow-flowing portions of perennial and intermittent streams that maintain water in the summer months. The frog is also found in hillside seeps that maintain pool environments or saturated soils throughout the summer months.

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Populations are not likely to be maintained if all surface water disappears (i.e., surface water for egg laying and larval development habitat is unavailable). Larval California red-legged frogs require 11 to 20 weeks of permanent water to reach metamorphosis (i.e., to change from a tadpole into a frog), in water depths of 10 to 20 inches. Riparian vegetation such as willows and emergent vegetation such as cattails are preferred California red-legged frog habitats, though not necessary for the species to be present. Populations of California red-legged frog will be reduced in size or eliminated from ponds supporting non-native species such as bullfrog, Centrarchid fish species (such as sunfish, bluegill, or largemouth bass), and signal and red swamp crayfish (Pacifastacus leniusculus and Procambarus clarkii, respectively), all of which are known California red-legged frog predators. However, the presence of such non-native species does not preclude the presence of the California red-legged frog.

California red-legged frogs also use upland habitats for migration and dispersal. The USFWS Recovery Plan for the California Red-Legged Frog states that frog overland excursions by way of uplands can vary between 0.25-mile up to three miles during the course of a wet season, and that frogs have been observed to make long-distance movements that are straight-line, point to point migrations rather than using corridors for moving in between habitats. Such overland straight-line migrations are primarily limited to periods of heavy rainfall or during periods when ambient conditions exhibit high moisture levels such as in fog belts along the coast.

According to the USFWS Recovery Plan for the California Red-Legged Frog, populations are most likely to persist where multiple breeding areas are embedded within a matrix of habitats used for dispersal. The primary constituent elements for California red-legged frogs are aquatic and upland areas where suitable breeding and non-breeding habitat is interspersed throughout the landscape and is interconnected by unfragmented dispersal habitat.

Based on observations of the emergent wetlands in the study area in July 2020, and conversations with the biologist that monitored the construction of the City’s Wet Weather Equalization Basin, which is located adjacent to the western boundary of the project site and was constructed to eliminate capacity-related sanitary sewer overflows during the rainy season,9 the study area provides suitable breeding or dispersal habitat for the species under rare conditions.

The only potentially aquatic feature in the study area is a small area within the emergent marsh vegetation that, in the past, ponded seasonally, but not consistently between and within years. In particular, permanent water for the minimum duration of 11 to 20 weeks required for larval development does not occur. The groundwater level on and around the study area appears to have been drawn down since construction of the Equalization Basin.

The nearest population of California red-legged frog is located 0.3-mile south of the study area, in San Pedro Creek, but is separated from the study area by dense residential and commercial development, heavily traveled roads (including SR 1), and the frequently-visited Pacifica State Beach. Opportunities for the species to successfully disperse to the study area from San Pedro Creek do not occur. Similarly, populations of the species at Calera Creek (one mile north of the study area; CNDDB Occurrence #504), Laguna Salada (1.9 miles north; CNDDB Occurrence #455), and in Vallemar (1.6 mile northeast; CNDDB Occurrence #918) are separated from the study area by high ridges and other topographic barriers precluding line-of-sight migration, such as residential development and major roads, including SR 1. Therefore, the primary constituent 9 City of Pacifica. Wet Weather Equalization Basin (EQ Basin). Available at:
https://www.cityofpacifica.org/departments/public-works/wastewater-treatment/wet-weather-equalization-basineq-basin. Accessed December 2024.

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elements in the Recovery Plan and cited above that would indicate potential for California red legged frog to occur are not present within the study area.

Trees
Several trees and shrubs are located on-site, with several Monterey cypress trees located in the northern portion of the project site and arroyo willows located in the southern portion of the study area and along the western and eastern parcel boundaries. Three of the on-site trees were evaluated as part of the Arborist Report prepared for the proposed project.10 Tree #1 is a large Monterey cypress. The tree has not been maintained and is in fair health and condition. The tree has multiple trunks from grade, with each trunk’s diameter at breast height (DBH) measured as

35.1, 30.3, 36.7, and 34.3 inches. The canopy is thick and healthy but has collapsed on the south side of the tree. The tree is located in the middle of the lot at the front of the property. Tree #2 is a Monterey pine (Pinus radiata) with a DBH of 33.8 inches, but is in poor health and condition.

Tree #3 is a Monterey cypress located along the frontage of the project site with a DBH of 39 inches. The tree is in fair health and condition; however, the tree has many broken branches, and the canopy has been heavily pruned on one side.

According to Pacifica Municipal Code Section 4-12.08, heritage trees include any trees that are of the species coast live oak (Quercus agrifolia), valley oak (Quercus lobata), California buckeye (Aesculus californica), Monterey pine, or coast redwood (Sequoia sempervirens), which have a trunk diameter of 12 inches or more; or any trees that are of the species toyon (Heteromeles arbutifolia) which have a trunk diameter of four inches or more at breast height. The Director of the Department of Public Works may also designate heritage trees that meet any of the following criteria: tree(s) of historic value; specimen tree(s) of any species; any tree of substantial size of its species; age; or significant habitat value. In addition, according to Section 4-12.02, protected trees include all trees, with the exception of eucalyptus or invasive species, which have a trunk with a DBH of 12 inches or greater, any heritage trees, and any grove of trees. Therefore, Tree #2 is considered a heritage tree pursuant to Pacifica Municipal Code Section 4-12.08, and Tree #1 and Tree #3 are considered protected trees pursuant to Section 4-12.02 of the Pacific Municipal Code.

4.1.3 REGULATORY CONTEXT
A number of federal, State, and local policies provide the regulatory framework that guides the protection of biological resources. The following discussion summarizes those laws that are most relevant to biological resources in the vicinity of the project site.

Federal Regulations
The following are the federal environmental laws and policies relevant to biological resources:

Federal Endangered Species Act
Under the FESA, the Secretary of the Interior and the Secretary of Commerce have joint authority to list a species as threatened or endangered (16 U.S. Code [USC] Section 1533[c]). Two federal agencies oversee the FESA: the USFWS has jurisdiction over plants, wildlife, and resident fish, while the NMFS has jurisdiction over anadromous fish and marine fish and mammals. Section 7 of the FESA mandates that federal agencies consult with the USFWS and NMFS to ensure that 10 Wood Biological Consulting. Response Letter: File No. 2016-004, 570 Crespi Drive, Pacifica CA (APN 022-162- 310) – 570 Crespi – IS/MND Information Needed. September 22, 2021.

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federal agency actions do not jeopardize the continued existence of a listed species or destroy or adversely modify critical habitat for listed species.

Section 10 requires the issuance of an “incidental take” permit before any public or private action may be taken that could take an endangered or threatened species. The permit requires preparation and implementation of a habitat conservation plan (HCP) that would offset the take of individuals that may occur, incidental to implementation of a proposed project, by providing for the protection of the affected species.

Pursuant to the requirements of the FESA, a federal agency reviewing a project within the jurisdiction of the agency must determine whether any federally listed threatened or endangered species may be present on-site and whether the proposed project will have a potentially significant impact on such species. In addition, the agency is required to determine whether the proposed action is likely to jeopardize the continued existence of any species proposed to be listed under FESA or result in the destruction or adverse modification of critical habitat proposed to be designated for such species (16 USC Section 1536[3], [4]).

Migratory Bird Treaty Act
Raptors (birds of prey), migratory birds, and other avian species are protected by a number of state and federal laws. The federal MBTA prohibits the killing, possessing, or trading of migratory birds except in accordance with regulations prescribed by the Secretary of Interior. Section 3503.5 of the CFGC states, “It is unlawful to take, possess, or destroy any birds in the order Falconiformes or Strigiformes (birds-of-prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by the code or any regulation adopted pursuant thereto.” Waters of the U.S. and the Clean Water Act
The USACE regulates discharge of dredged or fill material into waters of the U.S. under Section 404 of the Clean Water Act (CWA). “Discharge of fill material” is defined as the addition of fill material into waters of the U.S., including but not limited to the following: placement of fill that is necessary for the construction of any structure, or impoundment requiring rock, sand, dirt, or other material for the construction; site-development fills for recreational, industrial, commercial, residential, and other uses; causeways or road fills; and fill for intake and outfall pipes and subaqueous utility lines (33 Code of Federal Regulations [CFR] Section 328.2[f]). In addition, Section 401 of the CWA (Title 33 of USC, Section 1341) requires any applicant for a federal license or permit to conduct any activity that may result in a discharge of a pollutant into waters of the U.S. to obtain a certification that the discharge will comply with the applicable effluent limitations and water quality standards.

Waters of the U.S. include a range of wet environments such as lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, and wet meadows. Wetlands are defined as “those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support and under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions” (33 CFR Section 328.3[b]).

Furthermore, jurisdictional waters of the U.S. can be defined by exhibiting a defined bed and bank and ordinary high water mark (OHWM). The OHWM is defined by the USACE as “that line on shore established by the fluctuations of water and indicated by physical character of the soil, destruction of terrestrial vegetation, the presence of litter and debris, or other appropriate means that consider the characteristics of the surrounding areas” (33 CFR Section 328.3[e]).

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In May 2023, the U.S. Supreme Court interpreted the term “waters of the United States” as understood in wetland permitting in its decision in Sackett v. Environmental Protection Agency, 598 U.S. 651, 143 S.Ct. 1322 (2023). The Court’s decision has been generally understood to contract the legal jurisdiction previously asserted by the USACE. In its opinion, the Court held that the “waters” protected under the CWA are limited to “geographic[al] features that are described in ordinary parlance as ‘streams, oceans, rivers, and lakes’” and to adjacent wetlands that are “indistinguishable” from those bodies of water due to a continuous surface connection, though “temporary interruptions in surface connection may sometimes occur because of phenomena like low tides or dry spells.”
On August 29, 2023, in response to the Sackett decision, USACE and the U.S. Environmental Protection Agency (USEPA) issued a final rulemaking that revises the definition of "Waters of the United States" (WOTUS) within USACE and USEPA regulations. The adopted document is known as the WOTUS Rule. The WOTUS Rule defines "waters of the United States" to include the following:
x Traditional navigable waters, the territorial seas, and interstate waters (Jurisdictional Waters);
x Impoundments of Jurisdictional Waters (Jurisdictional Impoundments); x Relatively permanent, standing or continuously flowing tributaries to either Jurisdictional Waters or Jurisdictional Impoundments (Jurisdictional Tributaries); x Wetlands having a continuous surface connection to either Jurisdictional Waters, Jurisdictional Impoundments, or Jurisdictional Tributaries (Jurisdictional Wetlands); and x Relatively permanent, standing or continuously flowing intrastate lakes and ponds with a continuous surface connection to (but are not themselves) a Jurisdictional Water, Jurisdictional Impoundment, Jurisdictional Tributary, or Jurisdictional Wetland.

State Regulations
The following are the State environmental laws and policies relevant to biological resources:

California Department of Fish and Wildlife
CDFW administers a number of laws and programs designed to protect fish and wildlife resources under the CFGC, such as CESA (CFGC Section 2050, et seq.), Fully Protected Species (CFGC Section 3511) and the Lake or Streambed Alteration Agreement Program (CFGC Sections 1600 to 1616). Such regulations are summarized in the following sections.

California Endangered Species Act
The State of California enacted CESA in 1984. CESA is similar to the FESA but pertains to Statelisted endangered and threatened species. CESA requires State agencies to consult with CDFW when preparing CEQA documents to ensure that the State lead agency actions do not jeopardize the existence of listed species. CESA directs agencies to consult with CDFW on projects or actions that could affect listed species, directs CDFW to determine whether jeopardy would occur, and allows CDFW to identify “reasonable and prudent alternatives” to the project consistent with conserving the species. Agencies can approve a project that affects a listed species if they determine that “overriding considerations” exist; however, the agencies are prohibited from approving projects that would result in the extinction of a listed species.

CESA prohibits the taking of State-listed endangered or threatened plant and wildlife species.

CDFW exercises authority over mitigation projects involving State-listed species, including those IL

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resulting from CEQA mitigation requirements. CDFW may authorize taking if an approved habitat management plan or management agreement that avoids or compensates for possible jeopardy is implemented. CDFW requires preparation of mitigation plans in accordance with published guidelines.

Fish and Game Code Section 3505
Birds of prey are protected in California under provisions of the CFGC, Section 3503.5, (1992), which states, “it is unlawful to take, possess, or destroy any birds in the order Falconiformes or Strigiformes (birds of prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by this code or any regulation adopted pursuant thereto.” Construction disturbance during the breeding season could result in the incidental loss of fertile eggs or nestlings, or otherwise lead to nest abandonment. Disturbance that causes nest abandonment and/or loss of reproductive effort is considered “taking” by CDFW.

Lake or Streambed Alteration Program
The CDFW is responsible for conserving, protecting, and managing California’s fish, wildlife, and native plant resources. To meet this responsibility, the CDFG, Section 1602, requires notification to CDFW of any proposed activity that may substantially modify a river, stream, or lake.

Notification is required by any person, business, state or local government agency, or public utility that proposes an activity that will:
x Substantially divert or obstruct the natural flow of any river, stream or lake; x Substantially change or use any material from the bed, channel, or bank of any river, stream, or lake; or
x Deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake.

For the purposes of Section 1602, rivers, streams, and lakes must flow at least intermittently through a bed or channel. If notification is required and CDFW believes the proposed activity is likely to result in adverse harm to the natural environment, the CDFW will require that the parties enter into a Lake or Streambed Alteration Agreement.

CDFW Species of Special Concern
In addition to formal listings under FESA and CESA, plant and wildlife species receive additional consideration during the CEQA process. Species that may be considered for review are included on a list of Species of Special Concern developed by CDFW. Species whose numbers, reproductive success, or habitat may be threatened are tracked by CDFW in California.

Native Plant Protection Act
The Native Plant Protection Act (NPPA) was enacted in 1977 and allows the Fish and Game Commission to designate plants as rare or endangered. Currently 64 species, subspecies, and varieties of plants are protected as rare under the NPPA. The NPPA prohibits take of endangered or rare native plants, but includes some exceptions for agricultural and nursery operations, emergencies, and after properly notifying CDFW for vegetation removal from canals, roads, and other sites, changes in land use, and in certain other situations.

Regional Water Quality Control Board
Pursuant to Section 401 of the CWA and USEPA Section 404(b)(1) guidelines, in order for a USACE federal permit applicant to conduct any activity which may result in discharge into IL

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navigable waters, they must provide a certification from the Regional Water Quality Control Board (RWQCB) that such discharge will comply with the State water quality standards. The RWQCB has a policy of no-net-loss of wetlands in effect and typically requires mitigation for all impacts to wetlands before the RWQCB will issue water quality certification.

Under the Porter-Cologne Water Quality Control Act (California Water Code Section 13000- 14920), the RWQCB is authorized to regulate the discharge of waste that could affect the quality of the State’s waters. Therefore, even if a project does not require a federal permit (i.e., a Nationwide Permit [NWP] from the USACE), the project may still require review and approval by the RWQCB, in light of the approval of new NWPs on March 9, 2000 and the Supreme Court's decision in the case of the Solid Waste Agency of Northern Cook County (SWANCC) vs. USACE.

The RWQCB in response to the above case, issued guidance for regulation of discharges to “isolated” water on June 25, 2004. The guidance states:

Discharges subject to Clean Water Act section 404 receive a level of regulatory review and protection by the USACE and are also subject to streambed alteration agreements issued by the CDFW; whereas discharges to waters of the State subject to SWANCC receive no federal oversight and usually fall out of CDFW jurisdiction. Absent of RWQCB attention, such discharges will generally go entirely unregulated. Therefore, to the extent that staffing constraints require the RWQCB to regulate some dredge and fill discharges of similar extent, severity, and permanence to federally-protected waters of similar value. Dredging, filling, or excavation of “isolated” waters constitutes a discharge of waste to waters of the State, and prospective dischargers are required to submit a report of waste discharge to the RWQCB and comply with other requirements of Porter-Cologne.

When reviewing applications, the RWQCB focuses on ensuring that projects do not adversely affect the “beneficial uses” associated with waters of the State. Generally, the RWQCB defines beneficial uses to include all of the resources, services and qualities of aquatic ecosystems and underground aquifers that benefit the State. In most cases, the RWQCB seeks to protect the beneficial uses by requiring the integration of water quality control measures into projects that will result in discharge into waters of the State. For most construction projects, RWQCB requires the use of construction and post-construction Best Management Practices (BMPs). In many cases, proper use of BMPs, including bioengineering detention ponds, grassy swales, sand filters, modified roof techniques, drains, and other features, will speed project approval from RWQCB.

Development setbacks from creeks are also requested by RWQCB as they often lead to less creek-related impacts in the future.

Local Regulations
The following are the local environmental laws and policies relevant to biological resources:

City of Pacifica General Plan 2040
The following policies from the City of Pacifica General Plan 2040 related to biological resources are applicable to the proposed project:

Conservation Element
Guiding Policies
Policy CO-G-7 Wildlife and Critical Habitat. Conserve and protect indigenous threatened, endangered, and other special status species by preserving critical habitat.

Policy CO-G-8 Coastal Environment and Special Status Communities. Conserve and IL

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protect beaches, sand dunes, coastal bluffs, and special status communities, particularly the Coastal bluff scrub on the northern bluffs.

Policy CO-G-10 Trees. Conserve trees and encourage native forestation and planting of appropriate trees and vegetation.

Policy CO-G-11 Other Environmentally Sensitive Areas. Protect other potential ESHAs, high habitat value areas, and wildlife movement corridors from development that would significantly disrupt habitat values.

Implementing Policies
Policy CO-I-26 Protection of Biological Resources with New Development. Protect sensitive habitat areas and special-status species through implementation of the following measures:
1) Discourage development and/or buildout in critical habitat of special status species during the development review process.
2) Pre-construction plant and wildlife surveys: Project applicants shall engage a qualified biologist to conduct presence/absence biological surveys for sensitive plant and wildlife species prior to construction adjacent to or within identified special status communities and other sensitive areas identified in Figure 7-3 of the proposed General Plan. If special status species are identified, the qualified biologist shall consult with the California Department of Fish and Wildlife (CDFW) and establish no-disturbance buffers around avian nests, bat roosts, and sensitive plants to avoid disturbance and direct impacts to these resources during construction. If no special status species are detected during surveys, then construction-related activities may proceed.

Nesting birds, in particular, are protected by two means; they receive protection under the Migratory Bird Treaty Act, and nesting raptors (in the order Falconiformes or Strigiformes) are protected under the State Fish and Game Code, §3503.5.
3) Require biological resource assessments be conducted prior to approval for any development within 300 feet of creeks, wetlands, or other sensitive habitat areas shown on Figure 7-3 of the proposed General Plan.
4) Require on-site monitoring of biological resources by a qualified biologist throughout the duration of construction activity.
5 Require compensatory mitigation by means of habitat preservation, restoration, and enhancement; for the loss of any critical habitat and/or special status communities.

Policy CO-I-30 Fuel Modification. Ensure that new development is sited and designed to minimize the need for fuel modification and vegetation clearance in order to avoid or minimize the disturbance or destruction of habitat and existing hydrology while still providing for fire safety as necessitated by the North County Fire Authority’s Vegetation Management Program. Prohibit new development that would require fuel modification within ESHAs.

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Policy CO-I-33 Construction during Nesting Season. If site work or construction occurs during the nesting season (February 1 through August 31), then preconstruction breeding bird surveys shall be performed by a qualified wildlife biologist prior to any site disturbance to ensure that no nests will be disturbed or destroyed during Project implementation. If an active nest is found sufficiently close to work areas to be disturbed by construction activities, then the biologist shall create a no-disturbance buffer of 250 feet around passerine nests and a 500 foot buffer around raptor nests. Workfree buffer zones shall be maintained until after the breeding season or until after the qualified biologist determines the young have fledged (usually late June through mid-July).

Policy CO-I-35 Protection of the Californian Red-Legged Frog and San Francisco Garter Snake during Construction. To minimize disturbance, require all grading activity within 100 feet of identified aquatic habitat shall be conducted during the dry season (May 1 and October 15) to protect California red-legged frog and San Francisco garter snake. A qualified biologist shall conduct presence/absence surveys for California red-legged frog and San Francisco garter snake prior to construction in or adjacent to riparian areas, grasslands near ponds/wetlands, or other sensitive habitat. Any individuals identified shall be treated in consultation with USFWS. Construction shall follow accepted procedures for exclusion and avoidance of California red-legged frog and San Francisco garter snake and their habitat. Additionally, the biologist shall supervise the installation of exclusion fencing along the boundaries of the work area, shall conduct environmental awareness training for construction workers, and shall be present during initial vegetation clearing and ground-disturbing activities.

Policy CO-I-36 Invasive Plant Species. Prohibit the use of invasive plant species (i.e., any California Invasive Plant Council (CalIPC)-listed species with a status of high or moderate, or identified such as locally threatened under the limited, alert, or watch status).

Policy CO-I-38 Biological Productivity. Maintain—and where feasible, restore—the biological productivity and the quality of coastal waters, streams, wetlands, and lakes in order to maintain optimum populations of marine organisms and to protect human health.

Policy CO-I-39 Heritage Trees. Update the Heritage Tree ordinance to improve ease of City administration and clarity for applicants and surrounding residents. Consider a canopy goal for heritage and non-heritage trees as part of the Heritage Tree ordinance update or other updates to the City’s tree regulations.

City of Pacifica Heritage Tree Preservation Ordinance
Title 4, Chapter 12 of the City’s Municipal Code (Tree Preservation) stipulates regulations designed to preserve and protect heritage trees on private or city-owned property. In general, heritage trees are defined as any trees that are of the species coast live oak, valley oak, California buckeye, Monterey pine, or coast redwood, which have a trunk diameter of 12 inches or more; or any trees that are of the species toyon which have a trunk diameter of four inches or more at breast height. The Director of the Department of Public Works may also designate heritage trees

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that meet any of the following criteria: tree(s) of historic value; specimen tree(s) of any species; any tree of substantial size of its species; age; or significant habitat value. In addition, according to Section 4-12.02 of the Pacifica Municipal Code, protected trees include all trees, with the exception of eucalyptus or invasive species, which have a trunk with a DBH of 12 inches or greater, all heritage trees, and any grove of trees. The City requires a Tree Removal Permit to remove a protected tree, including all heritage trees, or City tree.

4.3.4 IMPACTS AND MITIGATION MEASURES
The following section describes the standards of significance and methodology used to analyze and determine the proposed project’s potential impacts related to biological resources. A discussion of the project’s impacts, as well as mitigation measures where necessary, is also presented.

Standards of Significance
Consistent with Appendix G of the CEQA Guidelines, the City of Pacifica General Plan 2040, and professional judgment, a significant impact related to biological resources would occur if the proposed project would result in any of the following:
x 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 CDFW or USFWS; x 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 CDFW or USFWS;
x Have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.
x 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;
x Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; or
x Conflict with the provisions of an adopted HCP, Natural Community Conservation Plan (NCCP), or other approved local, regional, or State habitat conservation plan.

Issues Not Discussed Further
The Initial Study prepared for the proposed project (see Appendix A) determined that development of the proposed project would result in no impact related to the following:
x Conflict with the provisions of an adopted HCP, NCCP, or other approved local, regional, or State habitat conservation plan.

For the reasons cited in the Initial Study (Section IV, Biological Resources), the potential impacts associated with the above are not analyzed further in this EIR.

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Method of Analysis
The information contained in the analysis presented herein is primarily based on the Biological Constraints Analysis (Appendix C) and Delineation of Potentially Jurisdictional Aquatic Resources and Effects Analysis (Appendix D) prepared by WBC.

Biological Constraints Analysis
A Biological Constraints Analysis report was first prepared by Monk & Associates, Inc. in 2014 for the single parcel located at 570 Crespi Drive.11 However, the proposed project now also includes the adjacent parcel at 540 Crespi Drive (identified by Assessor’s Parcel Numbers [APNs] 022- 162-420 and 022-162-310), which is currently owned by the City of Pacifica.

A peer review of the 2014 Biological Constraints Analysis conducted by Madrone Ecological Consulting recommended several information items to enable the City to make planning decisions with regard to biological resources.12 The updated Biological Constraints Analysis prepared by WBC in August 2020 referenced herein revises the original report based on peer review recommendations from Madrone Ecological Consulting and the additional parcel.13 Although the foregoing reports were prepared in advance of the EIR, the report was the beginning of an ongoing analysis of the project site over time, including peer review processes and recent supplemental reports. WBC also provided supplemental responses to public comments from the CDFW and peer review comments from the City of Pacifica.

As part of the updated Biological Constraints Analysis, prior to conducting field data collection, potential occurrence of special-status species within the project site was evaluated by first determining which special-status species occur in the project site’s vicinity through a literature and database search. Database searches for known occurrences of special-status species focused on the five-mile radius surrounding the project site. The following sources were reviewed by WBC to determine which special-status plant and wildlife species have been documented to occur in the vicinity of the project site:
x CNDDB records of special-status plant, animal species and natural communities documented as occurring within five miles of the study area; x USFWS IPaC database for federally listed species and migratory birds; x CNPS Inventory of Rare and Endangered Plants;
x A sequence of aerial photo imagery on Google Earth;
x Montara Mountain U.S. Geological Survey 7.5-minute topographic quadrangle map; x Topographic survey map of the study area; and
x CEQA documentation of the City’s recently completed Wet Weather Equalization Basin, which is adjacent to the study area.

In addition, WBC conferred with Mr. Patrick Kobernus of Coast Ridge Ecology, who acted as the City’s biological compliance monitor during construction of the City’s Wet Weather Equalization Basin in 2017-2018, during which Mr. Kobernus made direct observations of biological resources in the study area.
11 Monk & Associates, Inc. Biological Constraints Analysis 570 Crespi Drive, City of Pacifica San Mateo County, California (APNS: 022-162-310) (~1.7 Acres). October 8, 2014. 12 Madrone Ecological Consulting. Peer review for the proposed 570 Crespi Drive, City of Pacifica, San Mateo County, California. April 20, 2020. 13 Wood Biological Consulting. Biological Constraints Analysis – Updated. August 17, 2020.

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A reconnaissance-level survey for biological resources of the study area was conducted by WBC on July 19, 2020. The survey consisted of walking as much of the study area as was physically accessible (dense and impenetrable willow scrub is limiting over a large portion of the study area), and making observations of habitats and plant and wildlife species on and adjacent to the study area.

Delineation of Potentially Jurisdictional Aquatic Resources Aquatic resources within the study area were assessed by WBC on July 19, 2020. As part of the Delineation of Potentially Jurisdictional Aquatic Resources conducted for the proposed project, WBC reviewed relevant background information, including the 2014 Biological Constraints Analysis, the 2020 peer review, a sequence of aerial photo imagery on Google Earth, the National Wetlands Inventory, California Aquatic Resource Inventory, Soil Conservation Service, Montara Mountain U.S. Geological Survey 7.5-minute topographic quadrangle map, a topographic survey map of the parcels, and environmental review documents related to the City’s recently completed Wet Weather Equalization Basin.

WBC conducted an additional assessment on March 31 and April 4, 2022, which focused on reevaluating the wetland boundary in the southern portion of the study area in support of a design modification regarding an emergency drain riser. The entire site was assessed on April 5, 2023, to determine whether the wetland boundary had changed in the intervening period, which included the exceptionally wet winter of 2022-2023. The field data collection consisted of observations of wetland and upland vegetation, soil characteristics, and evidence of hydrology in relation to topography. The delineation used the Routine Determination Method as described in the 1987 USACE Wetland Delineation Manual, in conjunction with the Regional Supplement to the USACE Wetland Delineation Manual: Western Mountains, Valleys and Coasts Region (Version 2.0).

Aquatic resources were classified using commonly accepted habitat types.

In the northern portion of the project site, vegetation, soil and hydrology were documented at nine locations on three transects across the wetland-upland boundary. Sample points were mapped in the field using a Trimble Geo XT 6000, with differential correction. A wetland boundary (subject to verification by the USACE) was mapped on an aerial photograph. Three positive wetland parameters must normally be present for an area to be considered a wetland: dominance of wetland vegetation, presence of hydric soils, and presence of wetland hydrology.

Project-Specific Impacts and Mitigation Measures
The following discussion of impacts related to biological resources is based on implementation of the proposed project in comparison to existing conditions and the standards of significance presented above.

4.1-1 Have a substantial adverse effect, either directly (e.g., threaten to eliminate a plant community) or through habitat modifications, on any plant species identified as a candidate, sensitive, or special-status species. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

As discussed above, suitable habitat is not present on-site for 28 of the 29 specialstatus plant species identified in the five-mile radius of the study area due to the IL

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absence of chaparral, coastal bluffs, woodland, etc. In addition, none of the species were identified during the reconnaissance-level field survey of the study area.

Therefore, low potential exists for the majority of special-status plants to occur on-site.

While sandy soils are present, which would provide potential habitat for San Francisco Bay spineflower, the species was not present during the 2020 field survey. However, given enough time, plants may become established in areas where suitable habitat exists. Therefore, San Francisco Bay spineflower could become established on-site in the interim between surveys/analysis and construction, which could result in potential impacts during construction of the proposed project.

Based on the above and given the substantial time between the 2020 field survey and the commencement of construction activities, without additional field surveys, the proposed project could have a substantial adverse effect, either directly or through habitat modifications, on a plant species identified as a candidate, sensitive, or specialstatus species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Thus, a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

4.1-1(a) Prior to the commencement of construction associated with the proposed project, focused plant preconstruction surveys shall be conducted by a qualified biologist during the documented bloom periods of San Francisco Bay spineflower. Two site visits, including one early-season (April) and one late-season (July) shall be sufficient to cover the blooming periods. If San Francisco Bay spineflower are not observed during the focused plant surveys, impact to special-status plant species would not occur, and mitigation would not be required.

The results of the surveys shall be submitted to the City’s Planning Department.

4.1-1(b) If San Francisco Bay spineflower are identified on-site during the focused plant surveys, the project applicant shall be responsible for ensuring construction activities avoid special-status plants through preparation and submittal to the City’s Planning Department of an Avoidance Plan Report detailing protection and avoidance criteria, measures, and the extent to which special-status plants were successfully avoided. The Avoidance Plan Report shall be subject to approval by the City’s Planning Department and CDFW.

If avoidance is infeasible, the qualified biologist shall ensure seed collection for affected special-status plants is completed and plants are re-established at a minimum of a one-to-one ratio (number of newly established plants relative to the number of plants impacted) in a preserved, suitable habitat approved by the City and CDFW. The project applicant shall document and submit proof of compliance to the City’s Planning Department and CDFW.

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Re-established special-status plant populations shall be monitored annually by the project applicant in accordance with an approved Habitat Mitigation and Monitoring Plan prepared in consultation with the City’s Planning Department, with annual monitoring taking place for a minimum of five years. The Habitat Mitigation and Monitoring Plan shall include criteria, subject to approval by all applicable agencies, including the City’s Planning Department, USFWS, and CDFW, detailing the survival ratio required of re-established populations and performance standards for further replanting for any re-established special-status plant species that do not survive. Reports describing performance results shall be prepared by a qualified biologist and shall be submitted to the City’s Planning Department for years one, three, and five of the monitoring period.

4.1-2 Have a substantial adverse effect, either directly (e.g., cause a wildlife population to drop below self-sustaining levels, threaten to eliminate an animal community) or through
habitat modifications, on migratory birds and raptors
protected under the MBTA. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

The Biological Constraints Analysis determined the proposed project to have the potential to impact special-status and non-special-status native nesting birds protected under the CFGC and MBTA, including Allen’s hummingbird, rufous hummingbird, song sparrow, spotted towhee, wrentit, and saltmarsh common yellowthroat.

As previously discussed, native nesting birds, including raptors, are protected by CFGC Section 3503. Raptors, passerines, non-passerine land birds, and waterfowl are further protected under the MBTA. The MBTA prohibits the take, possession, purchase, sale, or bartering of any migratory bird, including feathers or other parts, nests, eggs, or products, except as allowed by implementing regulations. All migratory bird species are protected by the MBTA. Any disturbance that causes direct injury, death, nest abandonment, or forced fledging of migratory birds, is restricted under the MBTA. Any removal of active nests during the breeding season or any disturbance that results in the abandonment of nestlings is considered a ‘take’ of the species under federal law.

The trees within the northern portion of the project site and proposed off-site areas provide suitable nesting habitat to accommodate nesting songbirds and other raptors protected under the MBTA and CGFC. Several trees are located within the study area and nests could potentially be established prior to project construction. Should construction activities occur during the nesting season, the potential exists that such activities could result in impacts to protected nesting songbirds and raptors if construction activities were to cause nest abandonment and/or loss of reproductive efforts, or direct mortality if active nests occur within the trees in the study area proposed for removal. Furthermore, construction activities adjacent to birds nesting in avoided areas could result in nest abandonment.

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With respect to saltmarsh common yellowthroat, which is protected under the MBTA and considered a CDFW Species of Special Concern, the Biological Constraints Analysis determined that the study area does not support potential nesting habitat for the species. Willow scrub within the study area could provide migration habitat, and the species was observed foraging on-site during 2017 through 2018. Therefore, construction of the proposed project could have a substantial adverse effect on saltmarsh common yellowthroat individuals.

Based on the above, the proposed project could have a substantial adverse effect, either directly or through habitat modifications, on nesting songbirds and raptor species protected under the MBTA and CFGC. Thus, a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measure would reduce the above potential impact to a less-than-significant level.

4.1-2 To ensure compliance with protections for migratory birds under the MBTA and the CFGC, the measures outlined below shall be implemented prior to the commencement of construction activities.

Evidence of compliance shall be submitted to the City’s Planning Department for review and approval prior to the commencement of construction activities.

1. If construction activities are scheduled to occur outside of the breeding season (i.e., September 1 through January 31), preconstruction surveys or other mitigation measures are not necessary.

To the extent allowed by access, all active nests identified within 250 feet of construction activities, including equipment staging, for raptors and 100 feet for other protected bird species shall be mapped.

3. For any active nests found near the construction limits (76 m [250 ft] for raptors and 33 m [100 ft] for other protected bird species), the project biologist shall make a determination as to whether or not construction activities are likely to disrupt reproductive behavior. If construction is determined unlikely to disrupt breeding behavior, construction may proceed. If construction is determined to potentially disrupt breeding, the construction-free buffer zone shall be expanded; avoidance is IL

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the only mitigation available. The ultimate size of the construction-free buffer zone may be adjusted by the project biologist based on the species involved, topography, lines of site between the work area and the nest, physical barriers, and the ambient level of human activity. For raptors, the project biologist shall contact CDFW and/or the USFWS Division of Migratory Bird Management for guidance regarding site
evaluations and buffer adjustments.

If construction activities are determined likely to disrupt raptor breeding, construction activities within the construction-free buffer zone may not proceed until the project biologist determines that the nest is unoccupied.

4. If the project biologist, in consultation with the City, determines that maintenance of a construction-free buffer zone is not practicable, active nests shall be monitored by a qualified biologist to document breeding and rearing behavior of the adult birds. If construction activities are determined to potentially cause nest abandonment, work shall cease until the project biologist determines that the nest is unoccupied. For raptors, the CDFW and/or the USFWS Division of Migratory Bird
Management shall be contacted for guidance.

4.1-3 Have a substantial adverse effect, either directly (e.g., cause a wildlife population to drop below self-sustaining levels, threaten to eliminate an animal community) or through
habitat modifications, on any wildlife species identified as a candidate, sensitive, or special-status species. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

As discussed above, the majority of special-status species identified with the potential to occur within the vicinity of the study areas are considered unlikely, or have no potential, to occur based on habitat features, such as the location of the site outside of the species’ historical range, the lack of suitable aquatic habitat, lack of suitable foraging or nesting habitat, and lack of a den or cave development area. The only potentially aquatic feature in the study area is a small area within the emergent marsh vegetation that, in the past, ponded seasonally, but not consistently between and within years. In particular, permanent water for the minimum duration of 11 to 20 weeks required for larval development does not occur. Groundwater level on and around the study area appear to have been drawn down since construction of the City’s Wet Weather Equalization Basin. However, while suitable breeding habitat for California red-legged frog does not occur within the study area on a regular basis, the potential for California red-legged frog to occur in the study area exists under rare conditions.

As such, potential impacts to California red-legged frog are addressed herein.

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The nearest population of California red-legged frog is located 0.3-mile south of the study area, in San Pedro Creek. However, the study area is surrounded by high ridges and other topographic barriers precluding line-of-sight migration, including residential development and major roads, such as SR 1. Therefore, the primary constituent elements in the Recovery Plan are not present, and California red-legged frog would not be anticipated to occur on-site.

Nonetheless, because California red-legged frog is known to occur in the vicinity of the project site and potentially suitable habitat is present, the proposed project could have a substantial adverse effect, either directly or through habitat modifications, on a wildlife species (California red-legged frog) identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS, and a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measure would reduce the above impact to a less-than-significant level.

4.1-3 Implement Mitigation Measures 4.1-4(b) and 4.1-4(c).

4.1-4 Have a substantial adverse effect on any riparian habitat or other sensitive natural community, or State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

Sensitive biological communities include habitats that fulfill special functions or have special values, such as wetlands, streams, or riparian habitat. The habitats are protected under federal regulations, such as the CWA, and State regulations, such as the Porter-Cologne Act and the CDFW Streambed Alteration Act. Wetlands are considered sensitive environmental resources protected at federal, State, and local levels. Wetlands provide unique habitat functions and values for wildlife, and provide habitat for plant species adapted to wetland hydrology. Throughout the State, the quality and quantity of wetlands has dramatically declined owing to the construction of dams, dikes, and levees, as well as because of water diversions, the filling of wetlands for development, and the overall degradation of water quality by inputs of runoff from agricultural, urban, and infrastructure development and other sources.

As part of the Delineation of Potentially Jurisdictional Aquatic Resources and Effects Analysis, the project site was surveyed to determine the presence of any wetlands, non-wetland waters, or riparian vegetation potentially subject to jurisdiction under the CDFW or the USACE. Wetlands or other surface waters are not identified in the National Wetlands Inventory as occurring on the project site. In addition, the project site is not located on a stream or near other surface waters. As detailed in Table 4.1- 1, a total of approximately 0.550-acre of arroyo willow scrub exists within the study area. Although the area of arroyo willow scrub that would be removed as part of the IL

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proposed project is not associated with a stream or lakebed setting, the CDFW may determine that the arroyo willow scrub area meets its interpretation of riparian vegetation, which would require notification, review, and authorization under the CDFW Streambed Alteration Act. If such is the case, the project applicant would enter into a Lake or Streambed Alteration Agreement.

The Delineation of Potentially Jurisdictional Aquatic Resources and Effects Analysis determined that approximately 0.240-acre of emergent marsh and approximately

0.060-acre of seasonal wetlands are present within the study area. Recent changes to the definition of WOTUS have resulted in changes in the interpretation of the federal jurisdictional status of the on-site wetland. In 2020, at the time of the first wetland delineation update, the USEPA and the USACE Navigable Waters Protection Rule (NWPR) was in effect. The NWPR included adjacent wetlands, which could be separated from waters of the U.S. by an artificial structure so long as the structure allows for a direct hydrologic connection between the adjacent wetlands and waters of the U.S. The 2020 wetland delineation acknowledged that the wetland on the project parcels could be considered jurisdictional by virtue of its potential connection to the ocean by way of the drainage easement, stormwater sewer, and the Anza Pump Station.

In January 2023, the NWPR was repealed and replaced with a new revised rule.

Discussed above in the Regulatory Context section, in response to the Sackett decision, USACE and the USEPA issued a final rule that revises the definition of WOTUS within USACE and USEPA regulations. According to the updated rule, adjacent wetlands must be contiguous with navigable waters with a surface water connection. The on-site wetland does not exhibit a continuous surface water connection to navigable waters (the Pacific Ocean), because the wetland is interrupted by a drainage swale that did not exhibit flow during the wet winter of 2022-2023; a subsurface storm drain system that would capture any flow that occurs; and a system of flood control pumps that would be required to discharge flows to the ocean.

In the southwestern corner of the study area, surface water (i.e., in excess of what percolates on-site or is pumped from neighboring properties) could enter the shallow drainage swale that flows west-northwest toward SR 1, parallel with the backyard fences of existing residences on Anza Drive. The swale follows the route of a buried 24-inch storm drain culvert. At least two drain inlets to the culvert are located at ground surface level within the undeveloped parcel between the Pacifica Skatepark and SR

1. The culvert crosses SR 1 under the north entrance to the parking lot for Pacifica State Beach, and connects to the Anza Pump Station, which discharges directly to the Pacific Ocean. However, following the exceptionally wet winter of 2022-2023, evidence of surface water flow exiting the project site parcels by way of the drainage easement except by way of the underground storm sewer does not exist. Although higher water levels did occur following the large rain events, necessitating pumping from neighboring properties, the water level did not appear to overtop the low berm in the southwest corner of the project site.

The on-site wetland is never inundated by water from the Pacific Ocean by way of the culvert and swale, any tributaries do not enter the project site. Therefore, while the wetlands within the study area exhibit field indicators consistent with jurisdictional wetlands, the wetlands do not meet the current regulatory definition of federal

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jurisdictional waters of the U.S. under Section 404 of the CWA. Because the proposed project does not propose any actions resulting in a discharge of fill into the wetlands, development of the proposed project does not require a Section 404 permit under the USACE regulatory program.

Waters of the State include WOTUS, but may also include areas that do not meet the criteria for federal jurisdictional status. The State wetland definition is:
“An area is wetland if, under normal circumstances, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; (2) the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and (3) the area’s vegetation is dominated by hydrophytes or the area lacks vegetation.”
The State wetland definition relies on the federal delineation method to identify State wetlands. As shown above in Figure 4.1-2, the areas mapped as non-jurisdictional arroyo willow scrub do not satisfy criteria (1) or (2). The proposed project would remove or prune an estimated 784 square feet (sf) of arroyo willow scrub to meet parking and walkway requirements at the southern edge of the proposed Building B.

The portion of arroyo willow scrub does not meet all three wetland criteria (i.e., soil and hydrology indicators are lacking), and, therefore, is not included in the wetland total. The proposed project also would result in planting of 1,170 sf of willow scrub, which would avoid fill discharge into waters of the State. In addition, the 18-inch emergency overflow riser that would be installed in the western corner of the project site and would connect to the existing 12-inch storm drain that extends along the site’s southwestern boundary is located outside of the delineated wetland area.

However, the on-site central area of arroyo willow scrub, freshwater emergent marsh and transitional seasonal wetland have been shown to meet the definition of waters of the State. Therefore, the proposed project could potentially disturb and, possibly, fill, up to 0.87-acre of jurisdictional wetlands and/or remove potential riparian vegetation.

As such, the proposed project could have a substantial adverse effect on riparian habitat or State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means, and a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above impact to a less-than-significant level.

4.1-4(a) Prior to the commencement of ground-disturbing activities, the project applicant shall notify CDFW, pursuant to CFGC Section 1600. The notification shall include a description of all of the activities associated with the proposed project, not just those associated with the drainages and/or riparian vegetation. Impacts shall be outlined in the notification and are expected to be in substantial conformance with the impacts to biological resources outlined in the Updated Definition of Potentially Jurisdictional Aquatic Resources and Effects Analysis prepared for the 570 Crespi Drive Project by Wood Biological Consulting. Impacts for IL

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each activity shall be broken down by temporary and permanent impacts. A description of the proposed mitigation for biological resource impacts shall be outlined per activity and then by temporary and permanent impact. Information regarding project-specific drainage and hydrology changes resulting from project implementation shall be provided, along with a description of stormwater treatment methods.

Minimization and avoidance measures shall be proposed, as appropriate, and may include preconstruction species surveys and reporting, protective fencing around avoided biological resources, worker environmental awareness training, seeding disturbed areas adjacent to open space areas with native seed, and installation of project-specific stormwater BMPs. Mitigation for impacts to 0.550-acre of arroyo willow scrub riparian vegetation may include restoration or enhancement of resources on- or off-site, or any other method acceptable to CDFW. Mitigation shall not result in a net loss of a Sensitive Natural Community.

If CDFW determines through the course of the CFGC Section 1600 notification process that the project does not require a Lake or Streambed Alteration Agreement (LSAA) to address potential impacts to arroyo willow scrub, further mitigation beyond the proposed mitigation included in the notice to CDFW regarding the aforementioned vegetation communities shall not be required. Written verification of the applicant’s compliance with the Section 1600 LSAA process shall be submitted to the City of Pacifica Planning Division prior to the start of any construction activities.

The fence will also double as a wildlife exclusion fence during construction. The fence shall consist of standard construction silt fence material with a height of 36 inches. The lower six inches of fence material shall either be folded toward the construction side of the fence and weighted down with soil or sandbags, or backfilled in a trench; with both methods, the purpose is to completely contact the surface so that water and sediment would not flow underneath, and wildlife would not enter the work area from the wetland. The barrier shall be maintained throughout the duration of the construction period. Evidence of compliance with this measure shall be submitted to the City of Pacifica Planning Division prior to the start of any construction activities.

4.1-4(c) A qualified biologist, or a designated representative who has been trained by a qualified biologist, shall inspect the area inside of the sediment and debris barrier for special-status species, including California red-legged frog, every day before construction activities commence. If any special-status species are found, the qualified biologist shall be immediately contacted (if the survey was conducted by the designated representative), construction activities shall not be allowed to start, and the USFWS and CDFW shall be consulted on an

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appropriate course of action. Such action could include leaving the animal alone to move away on its own or the relocation of the animal to an area outside of the construction area. The qualified biologist, in consultation with the CDFW and USFWS, shall make the ultimate determination of the action to be taken. Evidence of compliance with this measure shall be submitted to the City’s Planning Department prior to commencement of construction activities.

4.1-4(d) If required and prior to initiation of grading, excavation, or other construction activities, the project applicant shall submit to the San Francisco Bay RWQCB an application for CWA Section 401 Water Quality Certification and/or Waste Discharge Requirements for Projects Involving Discharge of Dredged and/or Fill Material to Waters of the State and obtain a permit or waiver. The project applicant shall be responsible for conducting all project activities in accordance with the permit provisions outlined in any applicable permit. A copy of the Water Quality Certification or waiver issued for the project shall be submitted to the City’s Planning Department prior to commencement of grading, excavation, or other construction activities.

4.1-5 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. Based on the analysis below, the impact is less than significant.

Environmental corridors are segments of land that provide a link between different habitats while also providing cover. Habitat loss, fragmentation, and degradation have the potential to alter the use and viability of wildlife movement corridors (i.e., linear habitats that naturally connect and provide passage between two or more otherwise distinct larger habitats or habitat fragments). The suitability of a habitat as a wildlife movement corridor is related to, among other factors, the habitat corridor’s dimensions (length and width), topography, vegetation, exposure to human influence, and the species in question.

With implementation of Mitigation Measure 4.1-4(b), a temporary sediment and debris barrier would be installed on the southern limit of the construction area that slopes toward the arroyo willow and emergent wetland habitat. The fence would act as a wildlife exclusion fence during construction. Therefore, water and sediment would not flow under the fence, and wildlife, including California red-legged frogs, would not enter the construction area from the wetland.

Furthermore, as the project site is bounded by the Pacifica Community Center and Pacifica Skatepark to the west, Ocean View Senior Apartments and commercial businesses to the north, across Crespi Drive, commercial businesses to the east, and single-family residences to the south, the potential for use of the site as a wildlife corridor or native wildlife nursery site is limited. Additionally, sufficient land in the greater vicinity, specifically in the eastern portions of the City limits and areas to the south of the City, offer land much more conducive to wildlife movement and native

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wildlife nursery sites, as such areas are devoid of development. Given the amount of suitable land in the greater vicinity of the project site that could accommodate wildlife movement, the proposed project would not substantially interfere with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors.

In addition, with respect to California red-legged frog, as discussed above, existing populations are separated from the project site by high ridges and other topographic barriers precluding line-of-sight migration, residential development and major roads, including SR 1. The on-site wetland does not exhibit a continuous surface water connection to navigable waters, because the wetland is interrupted by a drainage swale that did not exhibit flow during the wet winter of 2022-2023. Therefore, because a hydraulic connection to the project site does not exist, the species would not be anticipated to migrate to the project site. Nonetheless, as discussed above, Mitigation Measure 4.1-4(b) would require a temporary sediment and debris barrier on the southern limit of the construction area that slopes toward the arroyo willow and emergent wetland habitat, which would serve as a wildlife exclusion fence during construction.

Based on the above information, 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. Therefore, the proposed project would have a less-thansignificant impact.

Mitigation Measure(s)
None required.

4.1-6 Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Based on the analysis below and with
implementation of mitigation, the impact is less than
significant.

Several trees and shrubs are located on-site. Although the proposed project would include the removal of several on-site trees, the project would preserve trees along the project site frontage and within the off-site improvement area. As discussed above, one on-site Monterey pine is considered a heritage tree, and two on-site Monterey cypress trees are considered protected trees pursuant to Pacifica Municipal Code Section 4-12.02.

Any removal of a protected tree requires a Tree Removal Permit, and any relocation or transportation of a protected tree, application of fertilizers or chemicals, grading, clearing, excavating, adding fill soil, trenching, boring, compacting, or paving within 50 feet of a protected tree or City tree requires a Tree Encroachment Permit pursuant to Pacifica Municipal Code Sections 4-12.04 and 4-12.06, respectively. A Tree Protection and Preservation Plan must be submitted in conjunction with any development proposal which requires a discretionary permit or other land use approval, or a proposal to engage in regulated work within 50 feet of a protected tree. The plan must IL

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be prepared by a qualified arborist, horticulturist, landscape architect or other qualified person.

Based on the above, without preparation of a Tree Protection and Preservation Plan or obtainment of a Tree Removal Permit or Tree Encroachment Permit, the removal of or encroachment upon on-site heritage and protected trees could conflict with a local policy or ordinance protecting biological resources, such as a tree preservation policy or ordinance. Thus, a significant impact would occur.

Mitigation Measure(s)
Implementation of the following mitigation measure would reduce the above impact to a less-than-significant level.

4.1-6 Prior to issuance of any grading permit, the project applicant shall obtain a Tree Removal Permit for any protected trees to be removed and a Tree Encroachment Permit for any construction activities within 50 feet of a protected tree from the City of Pacifica Director of Public Works.

Prior to issuance of a certificate of occupancy, the project applicant shall complete planting of any replacement trees required as part of the Director of Public Works heritage tree removal authorization or other authorizations. In addition, the project applicant shall prepare and submit a Tree Protection and Preservation Plan prior to the protected tree removal or encroachment authorizations or other authorizations in accordance with the City Municipal Code, Sections 4-12.02 through 4-

12.11, and shall implement any tree protection measures identified to protect trees which will not be removed during construction prior to commencement of any construction activity.

Cumulative Impacts and Mitigation Measures
As defined in Section 15355 of the CEQA Guidelines, “cumulative impacts” refers to two or more individual effects which, when considered together, are considerable, compound, or increase other environmental impacts. The individual effects may be changes resulting from a single project or a number of separate projects. The cumulative impact from several projects is the change in the environment that results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.

The geographic scope for the cumulative biological resources analysis generally includes buildout of the proposed project in conjunction with the development of the City of Pacifica General Plan 2040 planning area. For more details regarding the cumulative setting, refer to Chapter 5, Statutorily Required Sections, of this EIR.

4.1-7 Cumulative impact on biological resources. Based on the analysis below, the cumulative impact is less than significant.

The General Plan Update EIR concluded that, with implementation of the City of Pacifica General Plan 2040 policies, impacts to biological resources would be less than significant. While the proposed project would require a General Plan Amendment, IL

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disturbance of the project site and associated impacts to biological resources were anticipated in the General Plan Update EIR.

As discussed above, the study area contains a variety of vegetation communities, including arroyo willow scrub, emergent marsh, seasonal wetland, non-native annual grassland, and disturbed and ornamental. In addition, the study area includes a total of 0.87-acre of jurisdictional wetlands. As discussed throughout this chapter, the project site provides limited habitat for special-status species, including San Francisco Bay spineflower and saltmarsh common yellowthroat. Mitigation measures have been set forth in this chapter to ensure that the proposed project complies with all applicable standards and regulations and minimizes potential adverse effects to special-status species.

It should be noted that while the proposed project would result in the loss of a portion of the existing on-site habitat, the southern portion of the project site would remain undeveloped in order to avoid environmentally sensitive wetland areas. Overall, with incorporation of the mitigation measures set forth herein, potential impacts to biological resources would be reduced to less-than-significant levels. As such, the proposed project would not result in substantial adverse effects to biological resources protected by CEQA.

As further discussed in Chapter 5 of this EIR, CEQA Guidelines Section 15064(h)(5), states, “[…] the mere existence of significant cumulative impacts caused by other projects alone shall not constitute substantial evidence that the proposed project’s incremental effects are cumulatively considerable.” Therefore, even where cumulative impacts are identified as significant, any level of incremental contribution is not necessarily deemed cumulatively considerable. In addition, the courts have explicitly rejected the notion that a finding of significance is required simply because a proposed project would result in a net loss of habitat. “[M]itigation need not account for every square foot of impacted habitat to be adequate. What matters is that the unmitigated impact is no longer significant,” (Save Panoche Valley v. San Benito County [2013] 217 Cal.App.4th 503, 528, quoting Banning Ranch Conservancy v. City of Newport Beach [2012] 211 Cal.App.4th 1209, 1233).

The above discussion provides substantial evidence that, while the combined effects on biological resources resulting from approved/planned development throughout the area could be considered significant, the proposed project’s incremental contribution to the significant cumulative effect would be reduced with implementation of the mitigation measures required in this EIR.

Based on the above, the proposed project’s cumulative impact would be less than significant.

Mitigation Measure(s)
None required.

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4.2 GREENHOUSE GAS EMISSIONS

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4.2.1 INTRODUCTION
The Greenhouse Gas Emissions chapter of the EIR describes the potential impacts of the proposed project related to greenhouse gas (GHG) emissions and climate change. The chapter includes a discussion of the existing GHG setting, construction-related GHG impacts resulting from grading and equipment emissions, direct and indirect emissions associated with operations of the project, the impacts of these emissions on both the local and regional scale, and mitigation measures warranted to reduce or eliminate any identified significant impacts. The chapter is primarily based on information and guidance within the Bay Area Air Quality Management District’s (BAAQMD’s) CEQA Air Quality Guidelines (Air Quality Guidelines),1 as well as the City of Pacifica General Plan 20402 and City of Pacifica General Plan Update EIR.3 Further information was also sourced from the City of Pacifica’s 2014 Climate Action Plan,4 as applicable. The results of the air quality modeling prepared for the project and presented in this chapter are included as Appendix E to this EIR.

4.2.2 EXISTING ENVIRONMENTAL SETTING
The following information provides an overview of the existing environmental setting in relation to GHG emissions within the proposed project area.

Background on GHG Emissions
GHGs are gases that absorb and emit radiation within the thermal infrared range, trapping heat in the earth’s atmosphere. Some GHGs occur naturally and are emitted into the atmosphere through both natural processes and human activities. Other GHGs are created and emitted solely through human activities. The principal GHGs that enter the atmosphere due to human activities are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and fluorinated carbons. Other common GHGs include water vapor, ozone, and aerosols. The increase in atmospheric concentrations of GHG due to human activities has resulted in more heat being held within the atmosphere, which is the accepted explanation for global climate change.5 The primary GHG emitted by human activities is CO2, with the next largest components being CH4 and N2O. A wide variety of human activities result in the emission of CO2. Some of the largest sources of CO2 include the burning of fossil fuels for transportation and electricity, industrial processes including fertilizer production, agricultural processing, and cement production. The primary sources of CH4 emissions include domestic livestock sources, decomposition of wastes in landfills, releases from natural gas systems, coal mine seepage, and manure management. 1 Bay Area Air Quality Management District. California Environmental Quality Act Air Quality Guidelines. April 2022. 2 City of Pacifica. City of Pacifica General Plan 2040. Adopted July 11, 2022. 3 City of Pacifica. City of Pacifica General Plan Update and Sharp Park Specific Plan Final Environmental Impact Report. Adopted May 25, 2022. 4 City of Pacifica. City of Pacifica Climate Action Plan. Adopted July 14, 2014. 5 U.S. Environmental Protection Agency. Climate Change Indicators: Atmospheric Concentrations of Greenhouse Gases. Available at: https://www.epa.gov/climate-indicators/climate-change-indicators-atmosphericconcentrations-greenhouse-gases. Accessed November 2024.

4.2 GREENHOUSE GAS EMISSIONS

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The main human activities producing N2O are agricultural soil management, fuel combustion in motor vehicles, nitric acid production, manure management, and stationary fuel combustion.

Emissions of GHG by economic sector indicate that energy-related activities account for the majority of U.S. emissions. Transportation is the largest single-source of GHG emissions, and energy generation is the second largest source, followed by industrial activities. The agricultural, commercial, and residential sectors account for the remainder of GHG emission sources.6

Emissions of GHG are partially offset by uptake of carbon and sequestration in trees, agricultural soils, landfilled yard trimmings and food scraps, and absorption of CO2 by the Earth’s oceans.

Additional emission reduction measures for GHG could include, but are not limited to, compliance with local, State, or federal plans or strategies for GHG reductions, on-site and off-site mitigation, and project design features. Attainment concentration standards for GHGs have not been established by the federal or State government.

Global Warming Potential
Global warming potential (GWP) is one type of simplified index (based upon radiative properties) that can be used to estimate the potential future impacts of emissions of various gases. According to the United States Environmental Protection Agency (USEPA), the GWP of a gas, or aerosol, to trap heat in the atmosphere is the “cumulative radiative forcing effects of a gas over a specified time horizon resulting from the emission of a unit mass of gas relative to a reference gas.” The reference gas for comparison is CO2. GWP is based on a number of factors, including the heatabsorbing ability of each gas relative to that of CO2, as well as the decay rate of each gas relative to that of CO2. The GWP of each gas is determined by comparing the radiative forcing associated with emissions of that gas versus the radiative forcing associated with emissions of the same mass of CO2, for which the GWP is set at one. Methane gas, for example, is estimated by the USEPA to have a comparative GWP 25 times greater than that of CO2, as shown in Table 4.2-1.

Table 4.2-1
GWPs and Atmospheric Lifetimes of Select GHGs
Gas
Atmospheric
Lifetime (years)
GWP
(100 year time horizon)
Carbon Dioxide (CO2)50-2001 1
Methane (CH4)12 25
Nitrous Oxide (N2O) 114 298
Hydrofluorocarbon (HFC)-23 270 14,800
HFC-134a 14 1,430
HFC-152a 1.4 124
PFC: Tetrafluoromethane (CF4) 50,000 7,390
PFC: Hexafluoroethane (C2F6) 10,000 12,200
Sulfur Hexafluoride (SF6) 3,200 22,800 1. For a given amount of CO2 emitted, some fraction of the atmospheric increase in concentration is quickly absorbed by the oceans and terrestrial vegetation, some fraction of the atmospheric increase will only slowly decrease over a number of years, and a small portion of the increase will remain for many centuries or more.

Source: USEPA. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019 [Table 1-2]. April 14, 2021.
6 U.S. Environmental Protection Agency. Sources of Greenhouse Gas Emissions. Available at:
https://www.epa.gov/ghgemissions/sources-greenhouse-gas-emissions. Accessed November 2024.

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As shown in the table, at the extreme end of the scale, sulfur hexafluoride is estimated to have a comparative GWP 22,800 times that of CO2. The atmospheric lifetimes of such GHGs are estimated by the USEPA to vary from 50 to 200 years for CO2, to 50,000 years for CF4. Longer atmospheric lifetimes allow GHG to buildup in the atmosphere; therefore, longer lifetimes correlate with the GWP of a gas. The common indicator for GHG is expressed in terms of metric tons of CO2 equivalents (MTCO2e), which is calculated based on the GWP for each pollutant.

Effects of Global Climate Change
Globally, climate change has the potential to affect numerous environmental resources through uncertain impacts related to future air temperatures and precipitation patterns. The Intergovernmental Panel on Climate Change’s (IPCC) Climate Change 2021: The Physical Science Basis report indicated that warming of the climate system is unequivocal, and since the 1950s, many of the observed changes are unprecedented over decades to millennia.7 Signs that global climate change has occurred include:
x Warming of the atmosphere and ocean;
x Diminished amounts of snow and ice;
x Rising sea levels; and
x Ocean acidification.

Although climate change is driven by global atmospheric conditions, climate change impacts are felt locally. A scientific consensus confirms that climate change is already affecting California. The Office of Environmental Health Hazard Assessment (OEHHA) identified various indicators of climate change in California, which are scientifically based measurements that track trends in various aspects of climate change. Many indicators reveal discernable evidence that climate change is occurring in California and is having significant, measurable impacts in the State.

Changes in the State’s climate have been observed, including:
x An increase in annual average air temperature with record warmth occurring in recent years;
x More frequent extreme heat events;
x More extreme drought;
x A decline in winter chill; and
x An increase in variability of statewide precipitation.

Warming temperatures and changing precipitation patterns have altered California’s physical systems—the ocean, lakes, rivers, and snowpack—upon which the State depends. Winter snowpack and spring snowmelt runoff from the Sierra Nevada and southern Cascade Mountains provide approximately one-third of the State’s annual water supply. Impacts of climate on physical systems have been observed, such as high variability of snow-water content (i.e., amount of water stored in snowpack), decrease in snowmelt runoff, glacier change (loss in area), rise in sea levels, increase in average lake water temperature and coastal ocean temperature, and a decrease in dissolved oxygen in coastal waters. Impacts of climate change on biological systems, including humans, wildlife, and vegetation, have also been observed, including climate change impacts on terrestrial, marine, and freshwater ecosystems.
7 Intergovernmental Panel on Climate Change. Climate Change 2021: The Physical Science Basis Summary for Policymakers. Available at: https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_SPM.pdf.

Accessed October 2024.

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According to the City’s Climate Action Plan (CAP), the City of Pacifica, specifically, is susceptible to coastal degradation and sea level rise as climate change increases the rate of erosion and storm surges, which could lead to adverse impacts on infrastructure and both public and private properties within the City. Additionally, the number of extreme heat days (i.e., a location specific threshold defined as the 98th percentile value of the historical daily maximum and minimum temperatures, which for the City of Pacifica, are days that exceed 84.2 F) could reach an average of 16 days per year, as compared to the three days per year that occur now. While California could not see the average annual precipitation changing significantly in the next 50 to 75 years, precipitation could likely be delivered in more intense storms and within a shorter wet season. For example, the 30-year average length of dry spell in the City is 97 days. By the end of the century, the average dry spell could be up to 105 days.8
Existing Project-Area GHGs
The project site is located in the western portion of the nine-county San Francisco Bay Area Air Basin (SFBAAB), and is within the jurisdictional boundaries of the BAAQMD. The SFBAAB consists of coastal mountain ranges, inland valleys, and bays.

As of 2024 the City of Pacifica is in the process of updating their CAP which includes their GHG Emissions Inventory. According to the City of Pacifica most recent 2005 GHG Emissions Inventory used within the 2014 CAP, the primary source of GHG emissions in the City is from transportation, which makes up approximately 50 percent of all GHG emissions in the City, followed by residential energy at 29 percent, solid waste at 7.8 percent, commercial energy at 4.8 percent, and City government operations at 3.6 percent. Off road equipment, direct access energy, and County/district operations, combined, make up the remaining 4.6 percent of the City of Pacifica’s GHG emissions. Overall, the City of Pacifica emits approximately 183,090 MTCO2e annually.9 The project site is currently undeveloped, and, therefore, does not contribute to the City’s annual GHG emissions.

4.2.3 REGULATORY CONTEXT
GHG emissions are monitored and regulated through the efforts of various international, federal, State, and local government agencies. Agencies work jointly and individually to reduce GHG emissions through legislation, regulations, planning, policy-making, education, and a variety of programs. The agencies responsible for monitoring or reducing GHG emissions are discussed below.

Federal Regulations
The following are the federal regulations relevant to GHG emissions.

Federal Vehicle Standards
In 2010, President Obama issued a memorandum directing the Department of Transportation, Department of Energy, USEPA, and National Highway Traffic Safety Administration (NHTSA) to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastructure. In response to this directive, the USEPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model years 2017 through 8 Cal-Adapt. Local Climate Change Snapshot for Pacifica, California. Available at: https://cal-adapt.org/tools/localclimate-change-snapshot/. Accessed November 2024. 9 City of Pacifica. City of Pacifica Climate Action Plan. Adopted July 14, 2014.

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2025 light-duty vehicles. The proposed standards were projected to achieve emission rates as low as 163 grams of CO2 per mile by model year 2025 on an average industry fleet-wide basis, which is equivalent to 54.5 miles per gallon if the foregoing emissions level was achieved solely through fuel efficiency. The final rule was adopted in 2012 for model years 2017 through 2021 (77 FR 62624–63200), and NHTSA intended to set standards for model years 2022 through 2025 in future rulemaking.

In August 2016, the USEPA and NHTSA announced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase two program would have applied to vehicles with model years 2018 through 2027 for certain trailers, and model years 2021 through 2027 for semi-trucks, large pickup trucks, vans, and all types of sizes of buses and work trucks. The final standards were expected to lower CO2 emissions by approximately 1.1 billion MT, and reduce oil consumption by up to two billion barrels over the lifetime of the vehicles sold under the program.

In August 2018, the USEPA and NHTSA proposed to amend certain fuel economy and GHG standards for passenger cars and light trucks and establish new, less-stringent standards for model years 2021 through 2026. Compared to maintaining the post-2020 standards that were previously in place, the 2018 proposal would increase U.S. fuel consumption by approximately

0.5 million barrels per day, and would impact the global climate by 3/1000th of one degree Celsius by 2100. California and other states stated their intent to challenge federal actions that would delay or eliminate GHG reduction measures, and committed to cooperating with other countries to implement global climate change initiatives.

On September 27, 2019, the USEPA and NHTSA published the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National Program (84 FR 51,310), which became effective November 26, 2019. The Part One Rule revokes California’s authority to set its own GHG emissions standards and set zero-emission-vehicle mandates in California. On March 31, 2020, the USEPA and NHTSA issued the Part Two Rule, which sets CO2 emissions standards and corporate average fuel economy standards for passenger vehicles and light-duty trucks for model years 2021 through 2026. On January 20, 2021, an Executive Order (EO) was issued on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis, which includes review of the Part One Rule by April 2021 and review of the Part Two Rule by July 2021. In response to the Part One Rule, in December 2021, the U.S. Department of Transportation withdrew its portions of the "SAFE I” rule. As a result, states are now allowed to issue their own GHG emissions standards and zero-emissions vehicle mandates.10 In addition, the Part Two Rule was adopted to revise the existing national GHG emission standards for passenger cars and light trucks through model year 2026. These standards are the strongest vehicle emissions standards ever established for the light-duty vehicle sector and will result in avoiding more than three billion tons of GHG emissions through 2050.11 10 National Highway Traffic Safety Administration. In Removing Major Roadblock to State Action on Emissions Standards, U.S. Department of Transportation Advances Biden-Harris Administration’s Climate and Jobs Goals.

Available at: https://www.nhtsa.gov/press-releases/cafe-preemption-final-rule. Accessed October 2024. 11 U.S. Environmental Protection Agency. Final Rule to Revise Existing National GHG Emissions Standards for Passenger Cars and Light Trucks Through Model Year 2026. Available at: https://www.epa.gov/regulationsemissions-vehicles-and-engines/final-rule-revise-existing-national-ghg-emissions. Accessed October 2024.

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State Regulations
The statewide GHG emissions regulatory framework is summarized below. The following text describes EOs, legislation, regulations, and other plans and policies that would directly or indirectly reduce GHG emissions and/or address climate change issues. The following discussion does not include an exhaustive list of applicable regulations; rather, only the most prominent and applicable California legislation related to GHG emissions and climate change is included below.

California Green Building Standards Code
In 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as CALGreen and establishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency, water conservation, material conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground-up, new construction of commercial, low-rise residential and State-owned buildings and schools and hospitals. The original CALGreen standards have been updated several times. The CALGreen 2022 standards, which are the current standards, improved upon the 2019 CALGreen standards, and went into effect on January 1, 2023. The 2022 CALGreen Code focuses on four key areas in newly constructed homes and businesses:12
x Encouraging electric heat pump technology for space and water heating, which consumes less energy and produces fewer emissions than gas-powered units. x Establishing electric-ready requirements for single-family homes to position owners to use cleaner electric heating, cooking and electric vehicle (EV) charging options whenever they choose to adopt those technologies.
x Expanding solar photovoltaic (PV) system and battery storage standards to make clean energy available onsite and complement the state’s progress toward a 100 percent clean electricity grid.
x Strengthening ventilation standards to improve indoor air quality.

The CALGreen standards also include voluntary efficiency measures that are provided at two tiers and implemented at the discretion of local agencies and applicants. According to Section A4.602 of Appendix A4 of the CALGreen Code, CALGreen’s Tier 1 standards call for a 15 percent improvement in energy requirements, stricter water conservation, 65 percent diversion of construction and demolition waste, 10 percent recycled content in building materials, 20 percent permeable paving, 20 percent cement reduction, and cool/solar-reflective roofs. CALGreen’s more rigorous Tier 2 standards call for a 30 percent improvement in energy requirements, stricter water conservation, 80 percent diversion of construction and demolition waste, 15 percent recycled content in building materials, 30 percent permeable paving, 25 percent cement reduction, and cool/solar-reflective roofs.

California Building Standards Code
Title 24 of the California Code of Regulations (CCR), which is known as the California Building Standards Code (CBSC), was established in 1978 and serves to enhance and regulate California’s building standards. While not initially promulgated to reduce GHG emissions, Part 6 12 California Energy Commission. Energy Commission Adopts Updated Building Standards to Improve Efficiency, Reduce Emissions From Homes and Businesses. Available at: https://www.energy.ca.gov/news/2021-08/energycommission-adopts-updated-building-standards-improve-efficiency-reduce-0. Accessed December 2024.

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of Title 24 specifically established Building Energy Efficiency Standards that are designed to ensure new and existing buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality. These energy efficiency standards are reviewed periodically, and revised if necessary, by the Building Standards Commission and CEC (PRC Section 25402[b][1]). The regulations receive input from members of industry, as well as the public, with the goal of “reducing of wasteful, uneconomic, inefficient, or unnecessary consumption of energy” (PRC Section 25402). The regulations are scrutinized and analyzed for technological and economic feasibility (PRC Section 25402[d]) and cost effectiveness (PRC Sections 25402[b][2] and [b][3]). As a result, the standards save energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power plants, and help preserve the environment.

The 2022 Title 24 standards are the currently applicable building energy efficiency standards and became effective on January 1, 2023. Compliance with the 2022 Title 24 Building Energy Efficiency Standards will reduce energy use and associated GHG emissions compared to structures built in compliance with the previous 2019 Title 24 standards.

State Climate Change Targets
California has taken a number of actions to address climate change, including EOs, legislation, and California Air Resources Board (CARB) plans and requirements, which are summarized below.

Executive Order S-3-05
EO S-3-05 (June 2005) established California’s GHG emissions reduction targets and laid out responsibilities among the State agencies for implementing the EO and for reporting on progress toward the targets. The EO established the following targets:
x By 2010, reduce GHG emissions to 2000 levels;
x By 2020, reduce GHG emissions to 1990 levels; and
x By 2050, reduce GHG emissions to 80 percent below 1990 levels.

EO S-3-05 also directed the California Environmental Protection Agency (CalEPA) to report biannually on progress made toward meeting the GHG targets and the impacts to California due to global warming, including impacts to water supply, public health, agriculture, the coastline, and forestry. The Climate Action Team was formed, which subsequently issues yearly GHG reduction report cards to track the progress of emission reduction strategies. Each report card documents the effectiveness of measures to reduce GHG in California, presents GHG emissions from State agencies’ operations, and shows reductions that have occurred in the two years prior to publication.

Assembly Bill 32
In furtherance of the goals established in EO S-3-05, the Legislature enacted Assembly Bill (AB) 32 (Núñez and Pavley). The bill is referred to as the California Global Warming Solutions Act of 2006 (September 27, 2006). AB 32 provided initial direction on creating a comprehensive, multiyear program to limit California’s GHG emissions at 1990 levels by 2020 and initiate the transformations required to achieve the State’s long-range climate objectives. AB 32 also required that the CARB prepare a “scoping plan” for achieving the maximum technologically feasible and cost-effective GHG emission reductions by 2020. The CARB’s Scoping Plan is described in further detail below.

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Executive Order B-30-15
EO B-30-15 (April 2015) identified an interim GHG reduction target in support of targets previously identified under EO S-3-05 and AB 32. EO B-30-15 set an interim target goal of reducing GHG emissions to 40 percent below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the long-term goal of reducing GHG emissions to 80 percent below 1990 levels by 2050 as set forth in EO S-3-05. To facilitate achieving this goal, EO B-30-15 called for an update to the CARB’s Scoping Plan to express the 2030 target in terms of million metric tons (MMT) CO2e. The CARB’s Scoping Plan is discussed in further detail below. The EO also called for State agencies to continue to develop and implement GHG emission reduction programs in support of the reduction targets.

Senate Bill 32 and AB 197
Senate Bill (SB) 32 and AB 197 (enacted in 2016) are companion bills. SB 32 codified the 2030 emissions reduction goal of EO B-30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40 percent below 1990 levels by 2030. AB 197 established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members of the Senate and three members of the Assembly, to provide ongoing oversight over implementation of the State’s climate policies. AB 197 also added two members of the Legislature to the Board as non-voting members; requires CARB to make available and update (at least annually via the CARB’s website) emissions data for GHGs, criteria air pollutants, and toxic air contaminants (TACs) from reporting facilities; and requires CARB to identify specific information for GHG emissions reduction measures when updating the Scoping Plan.

CARB’s Climate Change Scoping Plan
One specific requirement of AB 32 is for CARB to prepare a scoping plan for achieving the maximum technologically feasible and cost-effective GHG emission reductions by 2020 (Health and Safety Code Section 38561[a]), and to update the Scoping Plan at least once every five years.

In 2008, CARB approved the first Scoping Plan. The Scoping Plan included a mix of recommended strategies that combined direct regulations, market-based approaches, voluntary measures, policies, and other emission reduction programs calculated to meet the 2020 statewide GHG emission limit and initiate the transformations needed to achieve the State’s long-range climate objectives. The key elements of the Scoping Plan include the following:

1. Expanding and strengthening existing energy efficiency programs as well as building and appliance standards;

2. Achieving a statewide renewable energy mix of 33 percent;

3. Developing a California cap-and-trade program that links with other Western Climate Initiative partner programs to create a regional market system and caps sources contributing 85 percent of California’s GHG emissions;

4. Establishing targets for transportation-related GHG emissions for regions throughout California, and pursuing policies and incentives to achieve those targets;

5. Adopting and implementing measures pursuant to existing State laws and policies, including California’s clean car standards, goods movement measures, and the Low Carbon Fuel Standard (LCFS) (17 CCR, Section 95480 et seq.); and

6. Creating targeted fees, including a public goods charge on water use, fees on high GWP gases, and a fee to fund the administrative costs of the State’s long-term commitment to AB 32 implementation.

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The Scoping Plan also identified local governments as essential partners in achieving California’s goals to reduce GHG emissions because they have broad influence and, in some cases, exclusive authority over activities that contribute to significant direct and indirect GHG emissions through their planning and permitting processes, local ordinances, outreach and education efforts, and municipal operations. Specifically, the Scoping Plan encouraged local governments to adopt a reduction goal for municipal operations and for community emissions to reduce GHGs by approximately 15 percent from 2008 levels by 2020. Many local governments developed community-scale local GHG reduction plans based on this Scoping Plan recommendation.

In 2014, CARB approved the first update to the Scoping Plan. The First Update to the Climate Change Scoping Plan: Building on the Framework (First Update) defined the State’s GHG emission reduction priorities for the next five years and laid the groundwork to start the transition to the post-2020 goals set forth in EO S-3-05 and EO B-16-2012. The First Update concluded that California is on track to meet the 2020 target but recommended a 2030 mid-term GHG reduction target be established to ensure a continuation of action to reduce emissions. The First Update recommended a mix of technologies in key economic sectors to reduce emissions through 2050, including energy demand reduction through efficiency and activity changes; large-scale electrification of on-road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean energy technologies. As part of the First Update, CARB recalculated the State’s 1990 emissions level using more recent GWPs identified by the IPCC, from 427 MMT CO2e to 431 MMT CO2e.

In 2015, as directed by EO B-30-15, CARB began working on an update to the Scoping Plan to incorporate the 2030 target of 40 percent below 1990 levels by 2030 to keep California on a trajectory toward meeting or exceeding the long-term goal of reducing GHG emissions to 80 percent below 1990 levels by 2050, as set forth in EO S-3-05. In summer 2016, the Legislature affirmed the importance of addressing climate change through passage of SB 32 (Pavley, Chapter 249, Statutes of 2016).

In December 2017, the Scoping Plan was once again updated. The 2017 Scoping Plan built upon the successful framework established in the initial Scoping Plan and First Update, while identifying new, technologically feasible and cost-effective strategies that would serve as the framework to achieve the 2030 GHG target as established by SB 32 and define the State’s climate change priorities to 2030 and beyond. For local governments, the 2017 Scoping Plan replaced the initial Scoping Plan’s 15 percent reduction goal with a recommendation to aim for a communitywide goal of no more than six MTCO2e per capita by 2030, and no more than two MTCO2e per capita by 2050, which are consistent with the State’s long-term goals. The 2017 Scoping Plan recognized the benefits of local government GHG planning (e.g., through CAPs) and provided more information regarding tools to support those efforts. The 2017 Scoping Plan also recognized the CEQA streamlining provisions for project-level review where a legally adequate CAP exists.

When discussing project-level GHG emissions reduction actions and thresholds in the context of CEQA, the 2017 Scoping Plan stated that “achieving no net additional increase in GHG emissions, resulting in no contribution to GHG impacts, is an appropriate overall objective for new development” for project-level CEQA analysis, but also recognized that such a standard may not be appropriate or feasible for every development project. The 2017 Scoping Plan further provided that “the inability of a project to mitigate its GHG emissions to net zero does not imply the project results in a substantial contribution to the cumulatively significant environmental impact of climate change under CEQA.”

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The most recent update to the Scoping Plan, the 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan Update) was adopted by the CARB in December 2022.13 The 2022 Scoping Plan Update builds upon previous efforts to reduce GHG emissions and is designed to continue to shift the California economy away from dependence on fossil fuels. The 2022 Scoping Plan Update, the most comprehensive and far-reaching Scoping Plan developed to date, identifies a technologically feasible and cost-effective path to achieve carbon neutrality by 2045 while also assessing the progress California is making toward reducing its GHG emissions by at least 40 percent below 1990 levels by 2030, as called for in SB 32 and laid out in the 2017 Scoping Plan. The 2030 target is an interim but important stepping stone along the critical path to the broader goal of deep decarbonization by 2045. The relatively longer path assessed in the Scoping Plan incorporates, coordinates, and leverages many existing and ongoing efforts to reduce GHGs and air pollution, while identifying new clean technologies and energy. Given the focus on carbon neutrality, the Scoping Plan also includes discussion for the first time of the Natural and Working Lands (NWL) sectors as both sources of emissions and carbon sinks.

The 2022 Scoping Plan Update lays out a path to achieve targets for carbon neutrality and reduce GHG emissions by 85 percent below 1990 levels by 2045, as directed by AB 1279. The actions and outcomes in the plan will achieve significant reductions in fossil fuel combustion by deploying clean technologies and fuels, further reductions in short-lived climate pollutants (SLCP), support for sustainable development, increased action on natural and working lands to reduce emissions and sequester carbon, and the capture and storage of carbon.

CARB’s Regulations for the Mandatory Reporting of GHG Emissions CARB’s Regulation for the Mandatory Reporting of GHG Emissions (Title 17 California Code of Regulations [CCR] 95100–95157) incorporated by reference certain requirements that the USEPA promulgated in its Final Rule on Mandatory Reporting of GHGs (40 Code of Federal Regulations [CFR] Part 98). In general, entities subject to the Mandatory Reporting Regulation that emit more than 10,000 MTCO2e per year are required to report annual GHGs through the California Electronic GHG Reporting Tool. Certain sectors, such as refineries and cement plants, are required to report regardless of emission levels. Entities that emit more than the 25,000 MTCO2e per year threshold are required to have their GHG emission report verified by a CARBaccredited third party.

Senate Bill 1383
SB 1383 establishes specific targets for the reduction of short-lived climate pollutants (SLCPs) (40 percent below 2013 levels by 2030 for CH4 and hydrofluorocarbons (HFCs), and 50 percent below 2013 levels by 2030 for anthropogenic black carbon), and provides direction for reductions from dairy and livestock operations and landfills. Accordingly, CARB adopted its SLCP Reduction Strategy in March 2017. The SLCP Reduction Strategy establishes a framework for the statewide reduction of emissions of black carbon, CH4, and fluorinated gases.

Executive Order B-55-18/Assembly Bill 1279
EO B-55-18 (September 2018) establishes a statewide policy for California to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net-negative emissions thereafter. The goal is an addition to the existing statewide targets of reducing the State’s GHG emissions. CARB intends to work with relevant State agencies to ensure that future scoping plan updates identify and recommend measures to achieve the carbon neutrality goal. 13 California Air Resources Board. 2022 Scoping Plan for Achieving Carbon Neutrality. November 16, 2022.

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On September 16, 2022, AB 1279, also known as the California Climate Crisis Act, codified the carbon neutrality goal established by EO B-55-18.

Mobile Sources
The following regulations relate to the control of GHG emissions from mobile sources. Mobile sources include both on-road vehicles and off-road equipment.

Assembly Bill 1493
AB 1493 (Pavley) (July 2002) was enacted in response to the transportation sector accounting for more than half of California’s CO2 emissions. AB 1493 required CARB to set GHG emission standards for passenger vehicles, light-duty trucks, and other vehicles determined by the State board to be vehicles that are primarily used for non-commercial personal transportation in the State. The bill required that CARB set GHG emission standards for motor vehicles manufactured in 2009 and all subsequent model years. CARB adopted the standards in September 2004. When fully phased in, the near-term (2009-2012) standards would result in a reduction of approximately 22 percent of GHG emissions compared to the emissions from the 2002 fleet, and the mid-term (2013-2016) standards would result in a reduction of approximately 30 percent.

Senate Bill 375
SB 375 (Steinberg) (September 2008) addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. SB 375 requires CARB to adopt regional GHG reduction targets for the automobile and light-truck sector for 2020 and 2035, and to update those targets every eight years. SB 375 requires the State’s 18 regional metropolitan planning organizations to prepare a sustainable communities strategy as part of their Regional Transportation Plans that will achieve the GHG reduction targets set by CARB. If a metropolitan planning organization is unable to devise a sustainable communities strategy to achieve the GHG reduction target, the metropolitan planning organization must prepare an alternative planning strategy demonstrating how the GHG reduction target would be achieved through alternative development patterns, infrastructure, or additional transportation measures or policies.

Pursuant to California Government Code Section 65080(b)(2)(K), a sustainable communities strategy does not (1) regulate the use of land, (2) supersede the land use authority of cities and counties, or (3) require that a city’s or county’s land use policies and regulations, including those in a general plan, be consistent with the sustainable community strategy. Nonetheless, SB 375 makes regional and local planning agencies responsible for developing those strategies as part of the federally required metropolitan transportation planning process and the State-mandated housing element process.

Advanced Clean Cars Program and Zero-Emissions Vehicle Program The Advanced Clean Cars program (January 2012) is an emissions-control program for model years 2015 through 2025. The program combines the control of smog- and soot-causing pollutants and GHG emissions into a single coordinated package. The package includes elements to reduce smog-forming pollution, reduce GHG emissions, promote clean cars, and provide the fuels for clean cars. To improve air quality, CARB has implemented new emission standards to reduce smog-forming emissions beginning with 2015 model year vehicles. By 2025, implementation of the rule is anticipated to reduce emissions of smog-forming pollution from cars by 75 percent compared to the average new car sold in 2015. To reduce GHG emissions, CARB, in conjunction with the USEPA and NHTSA, adopted GHG standards for model year 2017 to 2025

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Pacifica City CouncilDecember 2, 2025

Pacifica City Council
December 2, 2025