Pacifica City Council
December 2, 2025

CITY OF PACIFICA

CITY COUNCIL AGENDA
Council Chambers
2212 Beach Blvd
Pacifica, CA 94044
Mayor Sue Beckmeyer
Vice Mayor Christine Boles
Councilmember Mary Bier
Councilmember Mayra Espinosa
Councilmember Greg Wright
City Council Special Meeting 1 December 02, 2025

SPECIAL MEETING
December 02, 2025 (TUESDAY) – 6:00 PM
www.cityofpacifica.org

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City Council Special Meeting 2 December 02, 2025
6:00 PM - OPEN SESSION
Call to Order
Roll Call
Reading of Land Acknowledgment
The City of Pacifica acknowledges that we occupy the unceded ancestral homeland of the Ramaytush Ohlone peoples, who are the original inhabitants of the San Francisco Peninsula. We honor the Ramaytush Ohlone peoples for their enduring commitment to Mother Earth. As the Indigenous protectors of this land and in accordance with their traditions, the Ramaytush Ohlone have never ceded, lost, nor forgotten their responsibilities as the caretakers of this place, as well as for all peoples who reside in their traditional territory. We affirm their sovereign rights as First Peoples and wish to pay our respects to the ancestors, elders, and relatives of the Ramaytush Ohlone peoples.

Salute to the Flag led by Councilmember Bier

PUBLIC HEARINGS

1. Consideration of the following with respect to a proposed mixed-use project at 570 Crespi Drive (APN 022-162-310) and the eastern 55 feet of 540 Crespi Drive (APN 022- 162-420) that includes construction of a 43,696 square-foot development consisting of three buildings with 19 residential units, including three Below Market Rate units and 3,165 square feet of commercial use (Project): 1) Adoption of a Resolution Certifying the Environmental Impact Report (EIR), and Adopting California Environmental Quality Act Findings, a Statement of Overriding Considerations and Mitigation and Monitoring and Reporting Program; 2) Adoption of a Resolution Approving General Plan Amendment to designate portions of the Project site C (Conservation); 3) Introduction, and waiver of first reading of an Ordinance Rezoning the Project site from the M-1 (Controlled Manufacturing) to the C-2 (Community Commercial) and OS (Open Space) zoning districts and amending the Zoning Code to allow residential in locations other than the same building as a commercial use above the ground floor (horizontal mixed use); 4) Introduction, and waiver of first reading of an Ordinance Approving a Development Agreement between the City and Breakwater Crespi, LLC; 5) Consideration of Councilmember Call-up and Adoption of a Resolution Approving Planning Commission’s decision, and approving Site Development Permit PSD-811-16, Use Permit UP-76-16, Tentative Subdivision Map SUB-233-16, Sign Permit S-129-19, Parking Exception PE183-19, and Tree Removal Permit TP-13-25; and 6) Adoption of a Resolution Approving a Purchase and Sale Agreement with Breakwater Crespi, LLC for the Sale of a Portion of the City’s Property at 540 Crespi Drive
PROPOSED ACTION:
(1) Adopt a resolution certifying the Environmental Impact Report, and adopting CEQA Findings, a Statement of Overriding Consideration, and a Mitigation Monitoring and Reporting Program; and
(2) Adopt a resolution approving General Plan Amendment GPA-96-19; and (3) Introduce, waive the first reading, and read by title only, an Ordinance entitled “An Ordinance of the City Council of the City of Pacifica approving Rezoning RZ-194-16 and Zoning Text Amendment TA-116-19 to rezone portions of the property to be developed as C-2 to allow residential uses and portions to remain undeveloped as Open Space, and allow horizontal mixed use as a conditional use in C-2 ); and City Council Special Meeting 3 December 02, 2025
(4) Introduce, waive the first reading, and read by title only, an Ordinance entitled “An Ordinance of the City Council of the City of Pacifica approving Development Agreement DA-4-21 to establish a development agreement between Crespi Breakwater LLC and City of Pacifica to provide certain public and private benefits in conjunction with a development project at 570 Crespi Drive (APN 022-162-310) and a portion of the City owned property at 540 Crespi Drive (APN 022-162-420); and (5) Adopt a Resolution approving the Planning Commission approval of, and approving Site Development Permit PSD-811-16, Use Permit UP-076-16, Subdivision Permit SUB-233- 16, Sign Permit S-129-19, Parking Exception PE-183-19, and Protected Tree Removal TP-13-25, subject to the conditions of approval; and
(6) Adopt a Resolution approving the Purchase and Sale Agreement with Breakwater Crespi, LLC for the Sale of a Portion of the City’s Property at 540 Crespi Drive.

ADJOURN
NOTICE: If you challenge a city's zoning, planning or other decision in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered to the City Council at, or prior to, the public hearing. Judicial review of any city administrative decision may be had only if a petition is filed with the court not later than the 90th day following the date upon which the decision becomes final. Judicial review of environmental determinations may be subject to a shorter time period for litigation, in certain cases 30 days following the date of the final decision The City of Pacifica will provide assistance for disabled citizens upon at least 24 hours advance notice to the City Manager’s Office (650) 738-7301, or send request via email to:
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The Pacifica Municipal Code is available online at the City’s website (www.cityofpacifica.org/municode);

HOW TO OBTAIN CITY COUNCIL AGENDAS
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Agendas are posted no later than Friday prior to the City Council meeting date, at the entrance to the City Hall location at 170 Santa Maria Avenue, Pacifica.

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Council meetings:

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HOW TO REACH YOUR GOVERNMENT OFFICIALS
• San Mateo County Supervisor Ray Mueller, District 3, 500 County Center, Redwood City CA 94063 (650) 363-4569
• Governor Gavin Newsom, State Capitol Building, Sacramento CA 95814 (916) 445-2841 • State Senator Josh Becker, 1528 So. El Camino Real, Suite 303, San Mateo CA 94402 (650) 212-3313 • Assembly Member Marc Berman, 721 Colorado Ave, Suite 101, Palo Alto CA 94303 (650) 324-0224 • Congressman Sam Liccardo, 1117 Longworth House Office Building, Washington DC 20515 (202) 225-8104
City Council Special Meeting 4 December 02, 2025
• Senator Alex Padilla, 331 Hart Senate Office Building, Washington DC 20510 (202) 224-3553 • Senator Adam Schiff, SD-B40B Dirksen Senate Office Building, Washington DC 20510 (202) 224-3841 • President Donald J. Trump, 1600 Pennsylvania Ave. NW, Washington DC 20500

CITY COUNCIL
• Mayor Sue Beckmeyer, [email protected]
• Vice Mayor Christine Boles, [email protected]
• Councilmember Mary Bier, [email protected]
• Councilmember Mayra Espinosa, [email protected]
• Councilmember Greg Wright, [email protected]

CITY OF PACIFICA

COUNCIL AGENDA SUMMARY REPORT
12/2/2025
1 SUBJECT:

Consideration of the following with respect to a proposed mixed-use project at 570 Crespi Drive (APN 022-162-310) and the eastern 55 feet of 540 Crespi Drive (APN 022-162-420) that includes construction of a 43,696 square-foot development consisting of three buildings with 19 residential units, including three Below Market Rate units and 3,165 square feet of commercial use (Project): 1) Adoption of a Resolution Certifying the Environmental Impact Report (EIR), and Adopting California Environmental Quality Act Findings, a Statement of Overriding Considerations and Mitigation and Monitoring and Reporting Program; 2) Adoption of a Resolution Approving General Plan Amendment to designate portions of the Project site C (Conservation); 3) Introduction, and waiver of first reading of an Ordinance Rezoning the Project site from the M-1 (Controlled Manufacturing) to the C-2 (Community Commercial) and OS (Open Space) zoning districts and amending the Zoning Code to allow residential in locations other than the same building as a commercial use above the ground floor (horizontal mixed use); 4) Introduction, and waiver of first reading of an Ordinance Approving a Development Agreement between the City and Breakwater Crespi, LLC; 5) Consideration of Councilmember Call-up and Adoption of a Resolution Approving Planning Commission’s decision, and approving Site Development Permit PSD-811-16, Use Permit UP-76-16, Tentative Subdivision Map SUB-233-16, Sign Permit S-129-19, Parking Exception PE-183-19, and Tree Removal Permit TP-13-25; and 6) Adoption of a Resolution Approving a Purchase and Sale Agreement with Breakwater Crespi, LLC for the Sale of a Portion of the City’s Property at 540 Crespi Drive
RECOMMENDED ACTION:
(1) Adopt a resolution certifying the Environmental Impact Report, and adopting CEQA Findings, a Statement of Overriding Consideration, and a Mitigation Monitoring and Reporting Program; and
(2) Adopt a resolution approving General Plan Amendment GPA-96-19; and (3) Introduce, waive the first reading, and read by title only, an Ordinance entitled “An Ordinance of the City Council of the City of Pacifica approving Rezoning RZ-194-16 and Zoning Text Amendment TA-116-19 to rezone portions of the property to be developed as C-2 to allow residential uses and portions to remain undeveloped as Open Space, and allow horizontal mixed use as a conditional use in C-2 ); and (4) Introduce, waive the first reading, and read by title only, an Ordinance entitled “An Ordinance of the City Council of the City of Pacifica approving Development Agreement DA-4-21 to establish a development agreement between Crespi Breakwater LLC and City of Pacifica to provide certain public and private benefits in conjunction with a development project at 570 Crespi Drive (APN 022-162-310) and a portion of the City owned property at 540 Crespi Drive (APN 022-162-420); and (5) Adopt a Resolution approving the Planning Commission approval of, and approving Site Development Permit PSD-811-16, Use Permit UP-076-16, Subdivision Permit SUB-233- 16, Sign Permit S-129-19, Parking Exception PE-183-19, and Protected Tree Removal TP-13-25, subject to the conditions of approval; and
(6) Adopt a Resolution approving the Purchase and Sale Agreement with Breakwater Crespi, LLC for the Sale of a Portion of the City’s Property at 540 Crespi Drive. 1 Packet Pg. 5
Pacifica City Council 2
December 02, 2025
STAFF CONTACT:

Jacob Garcia, Contract Planning Services
[email protected]
Samantha Updegrave, Community Development Director
[email protected]
***END OF PREVIEW***
For full report, please refer to “Attachment 00 – Full Staff Report 251202 – 570 Crepsi” ORIGINATED BY:

Community Development Department
ATTACHMENT LIST:

ATT 00_FULL STAFF REPORT-570 Crespi 251202-FINAL(PDF)
ATT A-Draft Resolution EIR+Exhibits-570 Crespi-251202 (PDF) ATT B_Draft General Plan Amendment Resolution (DOCX)
ATT C_Draft Rezoning+Text Amendment Ordinance (DOCX)
ATT D_Draft Crespi Development Agreement Ordinance+Exhibit (PDF) ATT E_Draft Dev Permit Approvals Resolution+COA+MMRP_570 Crespi Drive (1) (PDF) ATT F_Project Plans 2023-10-27 Architecture_251202 (PDF) ATT G_Landscape Plans_251202 (PDF)
ATT H_Vesting Tentative Map Civil_251202 (PDF)
ATT I_Arborist Report 20240803_251202 (PDF)
ATT J_General Plan Policies_1980+2040 General Plans (DOCX) ATT K_Draft Crespi Purchase and Sale Agreement Resolution+Agreement (PDF) ATT L_2025-11-12_EMAIL_Council Call Up_570 Crespi (PDF) ATT M_Public Comment Received From 2025-10-01 through 2025-11-26 (PDF) 1 Packet Pg. 6

CITY OF PACIFICA

COUNCIL AGENDA SUMMARY REPORT
4896-2782-9884 v1
DATE: December 2, 2025
AGENDA ITEM:

File No.: 2016-004
GPA-96-19
RZ-194-16
TA-116-19
DA-4-21
PSD-811-16
UP-076-16
SUB-233-16
S-129-19
PE-183-19
TP-13-25

SUBJECT
Consideration of the following with respect to a proposed mixed-use project at 570 Crespi Drive (APN 022-162-310) and the eastern 55 feet of 540 Crespi Drive (APN 022-162-420) that includes construction of a 43,696 square-foot development consisting of three buildings with 19 residential units, including three Below Market Rate units and 3,165 square feet of commercial use (Project):
1) Adoption of a Resolution Certifying the Environmental Impact Report (EIR), and Adopting California Environmental Quality Act Findings, a Statement of Overriding Considerations and Mitigation and Monitoring and Reporting Program;
2) Adoption of a Resolution Approving General Plan Amendment to designate portions of the Project site C (Conservation);
3) Introduction, and waiver of first reading of an Ordinance Rezoning the Project site from the M-1 (Controlled Manufacturing) to the C-2 (Community Commercial) and OS (Open Space) zoning districts and amending the Zoning Code to allow residential in locations other than the same building as a commercial use above the ground floor (horizontal mixed use); 4) Introduction, and waiver of first reading of an Ordinance Approving a Development Agreement between the City and Breakwater Crespi, LLC;
5) Consideration of Councilmember Call-up and Adoption of a Resolution Approving Planning Commission’s decision, and approving Site Development Permit PSD-811-16, Use Permit UP-76-16, Tentative Subdivision Map SUB-233-16, Sign Permit S-129-19, Parking Exception PE-183-19, and Tree Removal Permit TP-13-25; and
6) Adoption of a Resolution Approving a Purchase and Sale Agreement with Breakwater Crespi, LLC for the Sale of a Portion of the City’s Property at 540 Crespi Drive

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4896-2782-9884 v1
RECOMMENDED ACTION:
(1) Adopt a resolution certifying the Environmental Impact Report, and adopting CEQA Findings, a Statement of Overriding Consideration, and a Mitigation Monitoring and Reporting Program; and (2) Adopt a resolution approving General Plan Amendment GPA-96-19; and (3) Introduce, waive the first reading, and read by title only, an Ordinance entitled “An Ordinance of the City Council of the City of Pacifica approving Rezoning RZ-194-16 and Zoning Text Amendment TA-116-19 to rezone portions of the property to be developed as C-2 to allow residential uses and portions to remain undeveloped as Open Space, and allow horizontal mixed use as a conditional use in C-2 ); and
(4) Introduce, waive the first reading, and read by title only, an Ordinance entitled “An Ordinance of the City Council of the City of Pacifica approving Development Agreement DA-4-21 to establish a development agreement between Crespi Breakwater LLC and City of Pacifica to provide certain public and private benefits in conjunction with a development project at 570 Crepsi Drive (APN 022-162-310) and a portion of the City owned property at 540 Crespi Drive (APN 022-162-420); and
(5) Adopt a Resolution approving the Planning Commission approval of, and approving Site Development Permit PSD-811-16, Use Permit UP-076-16, Subdivision Permit SUB-233-16, Sign Permit S-129-19, Parking Exception PE-183-19, and Protected Tree Removal TP-13-25, subject to the conditions of approval; and
(6) Adopt a Resolution approving the Purchase and Sale Agreement with Breakwater Crespi, LLC for the Sale of a Portion of the City’s Property at 540 Crespi Drive.

STAFF CONTACT
Jacob Garcia, Contract Planning Services, [email protected] Samantha Updegrave, Community Development Director, [email protected] I. BACKGROUND/PROJECT OVERVIEW
This is the first housing development project to come before the Planning Commission and the City Council since the adoption of the revised Housing Element in March and the state’s certification of the Housing Element in September of this year. The project, if approved with 19 residential units, including three BMR homeownership units, would be among the three largest residential projects approved by the City of Pacifica in the last 11 years, and would include commercial space consistent with the intent of the current General Plan designation for this site. According to the City’s Annual Progress Report (APR) on implementation of the Housing Element, during the years 2015 through 2024, the largest projects approved by the City was a 24-unit condominium townhome project at 801 Fassler Avenue and a 70-unit workforce housing project at 930 Oddstad Boulevard.

PROJECT OVERVIEW
A. Project Background:

The applicant owns 570 Crespi Drive (APN 022-162-310) which consists of 42,763 square feet. The project also includes development on a portion of 540 Crespi Drive, which is owned by the City. The applicant has negotiated a Purchase and Sale Agreement with the City of Pacifica (“City”) to purchase an undeveloped portion of the City owned property at 540 Crespi Drive (APN 022-162-420, parcel 5), the location of the Pacifica Community Center. Parcel 5 of 540 Crespi Drive consists of

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4896-2782-9884 v1
30,221 sf and the total proposed project site would be 72,984 sf. The Purchase and Sale Agreement is being considered by the City Council as part of this agenda item.

The proposed project would construct a 43,696 square foot mixed-use residential and commercial development, with 3,165 square feet of ground-floor commercial uses abutting Crespi Drive, 19 residential units, including three Below Market Rate Units (BMR), and a total of 47 parking spaces.

B. Planning Commission Recommendations and Approval: At their meeting on November 3, 20251 the Planning Commission adopted the following with a 4-1 vote (Ayes: Devine, Ferguson, Godwin, and Redfield; Nos: Davis (Absent: Berman and Hauser):
• Resolution No. 2025-014 to certify the Final Environmental Impact Report (EIR) and adopt the Mitigation Monitoring and Reporting Program (MMRP) to satisfy the requirements of the California Environmental Quality Act (CEQA); and
• Resolution No. 2025-015 recommending City Council approval of the General Plan Amendment, Rezoning, Zoning Text Amendment, and Development Agreement; approving the following development permits for the project: Site Development Permit, Use Permit, Tentative Subdivision Map, Sign Permit, Parking Exception, and Tree Removal Permit; and making Government Code section 65402 findings for the transfer of real property.

C. Council Consideration of Legislative Actions: The City Council is the final decision-maker on the legislative actions under its purview, namely the proposed General Plan Amendment, Rezoning, Zoning Text Amendment, and Development Agreement. See Section IV. for detailed information on the legislative actions.

D. City Council Call-Up of Planning Commission Decision on Development Permits: While there was no formal appeal of the Planning Commission decision, on November 12, 2025, within the statutory 10-day appeal period, Vice Mayor Boles provided written notice to the City Clerk and initiated a callup of the Planning Commission decision, pursuant to the procedures outlined in Pacifica Municipal Code (PMC) Chapter 2-1.105, “Council call-up of decisions.” (Attachment L) Pursuant to PMC 2-

1.105(b), the review shall be heard in the same manner as an appeal. Further, pursuant to PMC 2-

1.105, the Council may either approve, disapprove, or modify the decision of the Planning Commission, allowing the City Council to revisit approval of the development permits (Site Development Permit, Use Permit, Tentative Subdivision Map, Sign Permit, Parking Exception, and Tree Removal Permit). See Section V. for discussion of the development permits E. Brief Project History: The project, which has always contained mixed use, has gone through multiple iterations. The original project application was submitted in 2016 and included development of nine units and some commercial on the privately owned site at 570 Crespi Drive. The application was revised in 2019 to include a portion of 540 Crespi Drive and again in 2020 to its current configuration with a total of 19 units. The project was heard by the Planning Commission and City Council in 2022, and was remanded to the Planning Commission in 2025 with direction to prepare an Environmental 1 November 03, 2025, Planning Commission Staff Report Link:
https://pacificacityca.iqm2.com/Citizens/Detail_Meeting.aspx?ID=1726

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4896-2782-9884 v1
Impact Report (EIR). An EIR was prepared and a Notice of Preparation was issued in October 2024. A more detailed CEQA history is set forth in Section VII below.

In addition, during the course of project review, changes to the California Surplus Lands Act (SLA) created new obligations before the City could dispose of land. In 2023, the City completed the required SLA procedures (Gov. Code Section 54220–54234). At their meeting on May 22, 2023, the City Council adopted Resolution No. 49-2023 declaring the 55-foot portion of the 540 Crespi Drive property that is part of this application as surplus property and authorized staff to proceed with disposition in compliance with the SLA. On June 27, 2023, the City issued a Notice of Availability to the State’s list of 190 registered and eligible entities, including numerous affordable housing developers, which initiated a 60-day period for eligible entities to express interest in acquiring the property for affordable housing or other public uses. No letters of interest were received. Therefore, the City can now transfer the property as recommended herein.

For a detailed description of the prior PC approval on March 7, 2022 and the subsequent appeal and remand by the City Council, please see the November 3, 2025 Planning Commission staff report.

Additionally, project submittals received after the appeal that occurred in March 2022 are provided at the following link for reference: https://cityofpacifica.egnyte.com/fl/3fbbVbVDt3xQ.

II. GENERAL PLAN, LOCAL COASTAL PLAN, ZONING, AND SURROUNDING USES:

SITE AND PROJECT CONTEXT
A. General Plan. The 1980 General Plan designated the subject site as “Commercial” (Attachment C). Since the Project application, including the application for a Tentative Vesting Subdivision Map, was deemed complete prior to the effective date of the 2040 General Plan, the project is being considered under the law in effect at the time of application, which includes the Commercial designation then in effect. The Commercial land use designation allows for mixed use residential when the dwelling units are located in the same building as a commercial use, above the ground floor, known as vertical mixed use. The maximum allowable density is 21.8 units per acre, calculated as one dwelling unit per 2,000 square feet of lot area, and there is no requirement for a minimum density. Based on the full site area, the proposed density would be 11.3 units per acre (3,841 square feet of lot area per unit), which does not exceed the maximum allowable density for the 1980 General Plan Commercial designation. While the Project includes some residential units located above commercial uses in Building A, residential-only Buildings B and C would be inconsistent with the Commercial designation, which at the time only allowed vertical mixed use.

As discussed throughout the forthcoming analysis and findings in this report, the proposed uses, density, and layout of the proposed project would substantially comply with the 1980 General Plan, as well as the current 2040 General Plan mixed use designations and policies, including providing housing at the density that is applicable to the site.

B. Local Coastal Plan. The subject site is not located in the coastal zone, therefore, the Local Coastal Plan is not applicable to this Project.

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4896-2782-9884 v1
C. Zoning District. The subject site is located within the Controlled Manufacturing (M-1) zoning district (Attachment C, Exhibit A). The M-1 zoning district is subject to the development standards and allowable uses in the Service Commercial (C-3) zoning district, which does not allow residential development of any type. The applicant is requesting a rezoning of the project site from the M-1 to the Community Commercial (C-2) zoning district, which allows residential development in the same building as a commercial use above the ground floor. Although Building A provides ground floor commercial, Buildings B and C would contain only residential uses and therefore would not be consistent with the C-2 zoning standards. The applicant has also requested a zoning text amendment that would add a conditional use to the C-2 zoning district to allow residential uses “in other locations attached to or detached from commercial uses on the same site (horizontal mixed use),” subject to approval of a conditional use permit. The density limitation of 1 dwelling per 2,000 square feet of lot area would also be removed from the C-2 zoning district, therefore removing an inconsistency between the current land use designation and zoning ordinance. This zoning text amendment would be consistent with the mixed-use land use designations in the 2040 General Plan.

The applicant is proposing a 43,696 square-foot mixed-use development consisting of three buildings with 19 residential townhouse units, including three below market rate units, and 3,165 square feet of commercial use on a 72,984 square foot lot. Additional project details, and related zoning standards, are summarized in Table 1 below and demonstrate compliance with the proposed C-2 zoning district, as amended to allow horizontal mixed-use.

Table 1: Zoning Standards Conformance, Existing (M-1/C-3) and Proposed C-2 Zoning Districts, and Residential Clustered Housing
Zoning
Standards
Existing Site
Conditions
Required
Existing M-1/C-3*
Required
Proposed C-2
Proposed
Project
Building Site
Area
72,984 sf 5,000 sf 5,000 sf 72,984 sf
Landscaping N/A 10% 10% 11%
Lot Width
(At Street)
135’-0” 50’-0” (min) 50’-0” (min) 135’-0”
Maximum
Allowable
Height
N/A 35’-0” 35’-0” 35’-0”
Setbacks (measured from the lot line to the face of building) Front
N/A None, unless required by site development
permit
10’-0”
Rear 235’-2”
Side 10’
Parking
One-Bedroom Units, 1.5/Unit2 → 1.5 x 3 units = 5 473
Two+ bedroom units, 2/Unit4 → 2 x 16 units = 32
2 At least one space must be covered
3 Fourteen parking spaces are proposed off-site for the Community Center as part of the Development Agreement, but do not serve the proposed development. See Section V of report for more information on the Development Agreement.
4 Both spaces must be covered

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Table 1: Zoning Standards Conformance, Existing (M-1/C-3) and Proposed C-2 Zoning Districts, and Residential Clustered Housing
Zoning
Standards
Existing Site
Conditions
Required
Existing M-1/C-3*
Required
Proposed C-2
Proposed
Project
Retail stores and service establishments, 1/300 sf → 3,165 sf / 300 sf = 11 Parking Guest Parking, 1/4 Units → 19 units/4 = 5 Exception
Total Spaces Required: 53
Bicycle parking spaces, 10% of total parking required → 10% x 53 = 5 spaces 5 spaces Open Space
Usable Open Space – Townhouses: 750 sf per unit;
All other forms of clustered housing: 450 sf per unit → (750 sf x 16 units) + (450 sf x 3 units) 15,936 sf
Total Open Space Required: 13,350
Private Open Space – 1 or less bedrooms: 130 sf per unit Range:
132 – 395 sf
Private Open Space – 2 or more bedrooms: 150 sf per unit Range:
242 – 444 sf
D. Surrounding Land Uses. The project site is east of Highway 1, on the south side of Crespi Drive, in the West Linda Mar neighborhood. It is surrounded by urban uses on all sides, as shown in Table 2.

The subject site is the only undeveloped site in the immediate area along Crepsi Drive. Figure 1 provides an aerial view of the site and surrounding uses and Figure 2 shows the subject site relative to the West Linda Mar neighborhood.

Table 2: Surrounding Uses
Location Existing Use Zoning
District General Plan Designation
Subject Property Vacant (single-family
demolished 2016) M-1 Commercial (1980 GP) Mixed Use Center (2040 GP) Surrounding
Properties
North
(across
Crespi)
Shopping Center; Senior
Housing; US Post Office;
Multi-family Apartments
P-D
R-3
C-1
C-2
Retail Commercial
Mixed Use Neighborhood
Public Facilities
South Single-Family residential R-1 Low-Density Residential East Self-Storage
Crespi Business Center C-3 Mixed Use Center
West City of Pacifica Community
Center M-1 Public/Semi-Public and Park

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Figure 1: Subject Site & Surrounding Uses Figure 2: West Linda Mar neighborhood III. PROPOSED DEVELOPMENT
A. Project Site. The subject site was previously developed with a single-family residence that was demolished in 2016. The site currently is undeveloped and primarily flat with an elevation that slopes downward to the rear (south). The elevation at the front of the site is approximately 14 feet above mean sea level (MSL) and elevation at the rear of the site is approximately 10 feet above MSL.

The site consists of two contiguous parcels with similar dimensions. Approximately 46 percent of the southern portion of the development site would remain undeveloped as it contains wetlands and other biological resources that are being retained. The subject site consists of a total of 72,984 sf lot area with a minimum lot width of 135 feet. It is comprised of 42,763 sf of the existing 570 Crespi Drive site plus an additional 30,221 sf lot area from a proposed merger with “Parcel 5” as shown on the vesting tentative subdivision map. Parcel 5 is a portion of the City-owned property located at 540 Crespi Drive (APN 022-162-420). The applicant would acquire Parcel 5 through a Purchase and Sale Agreement negotiated with the City Council. The applicant would also make certain off-site improvements to the property at 540 Crespi Drive that would remain in City ownership subject to the terms of the proposed Development Agreement which is further discussed in Section IV of this report.

B. Proposed Buildings and Design. Due to the site constraints noted above the development and site improvements are clustered on the front, northern portion of the lot. The project would merge the two parcels to create a single project site of 72,984 square feet in area, and the parcel merger is included as a condition of approval. The proposed development would be accessed from an entry1.a Packet Pg. 13
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only driveway, with the vehicular exit shared with the Community Center5. The project includes three buildings, totaling 43,696 sf in floor area, as shown in Figure 3. (Also see Project Plans Attachment F, Landscape Plans Attachment G, Vesting Tentative Subdivision Map Attachment H):
• Building A: Includes 3,165 sf of commercial floor area on the ground floor and three one-bedroom “flat” residential units on the second floor.
• Building B: Includes seven two-bedroom, three-story townhouses with attached two-car (tandem) garages.
• Building C: Includes nine two-bedroom, three-story townhouses with attached two-car (tandem) garages.

Figure 3: Proposed Site Plan
For all three buildings the proposed materials, colors, roofing, and other architectural features are described in Table 3.
5 Off-site driveway improvements are proposed as part of the Development Agreement, as well as an annual payment for the driveway lease.

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Table 3: Exterior Details
Exterior Architectural Features Proposed
Exterior Materials Stucco, metal, aluminum and fiber cement board Exterior Colors Cedar, white, and a range of greys and blacks Roofing Building A – Thermoplastic polyolefin and metal standing seam
Building B and Building C – Asphalt shingles and
metal standing seams
Window Glazing Bronze
Columns and Diagonal Bracing Steel sand blasted
As shown in the rendering in Figure 4, the front of Building A has three entrances with floor-to-ceiling windows, trimmed with black framing that highlight the front façade of the commercial spaces. Above the commercial space, corrugated metal balconies serve to create a distinct second level. Each of the three one-bedroom units would have a balcony facing Crespi Drive and would also share a public balcony facing south. The east and west units of Building A would also provide balconies facing south.

The center unit of Building A, Unit A2, would not have a secondary private balcony but would have access to a public balcony serving a circulation function from the staircase connecting the first and second floors of the building. Each unit has its own exterior entrance which is accessible through the public balcony on the second level.

Figure 4: Building A Rendering
Buildings B and C (Figure 5) feature tandem garages that open to the center of the site. Each unit would be accessible from a walk-through door adjacent to the garage doors which would first open to the main garage, then provide access to an interior, private staircase connected to the second floors

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of the residential units containing the main living area, with the bedrooms located on the third floor, and roof decks on top.

Figure 5: Buildings B and C Rendering
C. Trees. There are 13 trees inventoried within the proposed project area which include Monterey cypress, Hollywood Juniper and pine trees, all of which are considered protected trees. An arborist report was completed on December 18, 2021, and updated on August 3, 2024, to reflect up to date protected tree information, demonstrating consistency with the City’s adopted Tree Preservation Ordinance (PMC Chapter 12) (Attachment I). Table 4 provides an inventory of protected trees.

Table 4: Protected Tree Inventory
Tree # Species Condition Notes Retain
1 Monterey
cypress
Fair Unmaintained, multiple trunks, multiple
limb failure on south side of canopy.

Located in the middle of the lot located at
the front of the property. Proposed
removal.

NO
2 Monterey
pine
Dead Proposed removal. NO

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Table 4: Protected Tree Inventory
3 Monterey
cypress
Fair Unmaintained, tree has many broken
branches, and the canopy has been heavily
pruned on one side to accommodate PG
and E. This tree should be removed but it
has been requested to be retained and
protected during construction.

YES
4 Monterey
cypress
Poor Unmaintained, located on the adjacent
property. The tree is in poor health and
condition and is located very close to the
proposed construction. The tree may not
survive construction but all attempts to
work around the tree and keep it alive will
be made. Storm damage from recent
storms has partially removed one side of
the canopy of the tree.

Proposed to be retained.

YES
5 Monterey
cypress
Fair Has not been maintained for many years.

Storm damage from recent storms has
partially removed one side of the canopy
of the tree.

Proposed removal.

NO
6 Monterey
cypress
Fair Has not been maintained for many years.

Storm damage from recent storms has
partially removed one side of the canopy
of the tree.

Proposed for removal.

NO
Tree # Species Condition Notes Retain
7 Monterey
cypress
Fair Tree is very close to a utility vault and is
proposed removal.

NO
8 Monterey
cypress
Fair Protected tree that will be retained and
should be protected during construction.

YES
9 Monterey
cypress
Fair Protected tree that will be retained and
should be protected during construction.

YES
10 Monterey
cypress
Fair Protected tree that will be retained and
should be protected during construction.

YES
11 Monterey
cypress
Poor Protected tree that will be retained and
should be protected during construction.

YES
12 Hollywood
juniper
Good Protected tree that will be retained and
should be protected during construction.

YES
13 Monterey
cypress
Fair Protected tree that will be retained and
should be protected during construction.

YES

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Of the 13 protected trees five trees are proposed for removal (trees #1, 2, 5, 6, and 7) by the applicant so development may occur at the front of the site in order to maintain the rear of the property in a natural state. The applicant requests approval for the removal of the five protected trees as the tree locations would conflict with the proposed building locations and/or other on-site improvements necessary for the project, and tree # 2 is dead. While the project proposes to remove five protected trees, the applicant has submitted a proposed landscape plan that would add 15 trees for a net increase of 10 trees, as discussed in more detail in the Landscaping and Open Space Section below. This is consistent with the Planning Commission’s prior requirement in 2022 to provide replanting at a 3:1 ratio. As a condition of approval, prior to the issuance of a building permit the applicant is to prepare Tree Protection and Preservation Plan, consistent with PMC Sec. 4-12.11, and include replanting at a 3:1 ratio (Attachment B, Exhibit B, Condition #12).

D. Parking. The Project would provide 47 off-street parking spaces, comprised of 32 covered parking spaces (two garage spaces per townhouse unit in a tandem configuration) and 15 uncovered spaces in parking areas adjacent to Building A and at the rear of Buildings B and C. Fifty-three spaces are required under the current Zoning, and the applicant is requesting a Parking Exception; see Section V for analysis. As described in Table 2 and included as a condition of approval (Attachment E, Exhibit A, Condition # 11), the project is required to have a minimum of five bicycle parking spaces.

E. Landscape and Open Space. The Project proposes approximately 7,953 square feet of landscaping, which constitutes 11 percent of the lot size, where 10 percent is required. The proposed planting palette includes 19 different perennial, shrub, grass, groundcover, tree and vine species, many of which are native to the area or California. The Arroyo Willow, a large shrub which is native to California, is a dominant plant species existing on-site. The proposed Project draws upon this natural condition and plants 11 additional Arroyo Willows throughout the site. Shrubs, living walls, and perennials are used in planters to help provide visual breaks between the asphalt and pedestrian walkways. The project proposes to remove five protected trees and would add 15 trees for a net increase of 10 trees.

Overall, the project meets the development standards for providing private usable open space per unit in a residential clustered housing development pursuant to PMC Section 9-4.2402 by providing landscaping onsite, balconies for all units, and roof top decks for all of the townhouses. The project would provide 10,334 square feet in private open space and 5,603 square feet in landscape usable open space for a total of 15,936 square feet, exceeding the 12,000 square foot requirement.

Building A provides five private balconies ranging in size from 131 square feet to 197 square feet and also includes a shared balcony that’s 328 square feet. Building B provides roof decks of at least 442 square feet and Building C provides roof decks 249 square feet in size. Six of the seven units in Building B and eight of the nine units in Building C would have four balconies: two each on the second and third levels, facing east and west. The southernmost units in Building B and Building C lack a fourth balcony on the third level, but both of the units have a large balcony of at least 270 square feet. Each unit in Building B and Building C has a supplemental balcony on the third level facing the center of the site which is usable but does not count towards the total amount of usable open space due to being smaller than the required dimensions pursuant to PMC section 9-4.260.2.

This code section indicates usable open space must be a minimum of four feet by ten feet; these

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balconies are fourteen feet by three feet. Even without counting these balconies as usable open space, as noted earlier, the project exceeds the required amount of usable open space by over 2,500 square feet.

F. Wetlands. The project site contains wetlands across 46 percent of the site, and 33,372 square feet of the lot will remain undeveloped. The site also contains riparian vegetation, including Arroyo Willows (Figure 6). There is no construction proposed in the wetlands area. Approximately 784 square feet of Arroyo Willow would be relocated from the area between the rear of Buildings B and C to the rear of each building and along the west side of Building B. The new area of Arroyo Willow would be 1,170 square feet, a 27 percent increase in area.

Figure 6: Wetlands and Arroyo Willow
G. Signage. The project would include a variety of signage throughout the site. The signage would include a proposed single-sided freestanding sign that identifies the development and would be located east of the one-way entry driveway near Crespi Drive (Attachment F, Sheet A-0.51). It would be 7-feet, 4-inches tall by 12 feet wide, and the area of the copy would be a total of 56 square feet.

The sign would be primarily constructed of Corten steel plates with laser cut-out letters, frosted glass backing behind the letters, and internal LED illumination.

The project would also include tenant signs on the commercial building, examples of which can be seen on Sheets A3.5, A3.6, and A-7.2 of Attachment D. The various building numbers, parking, and directional signage are not specifically included in the project plans but will be required prior to issuance of building permits and reviewed/approved by the City Engineer, Fire Department, and Building Official.

PMC section 9-4.2907 requires multi-unit developments to have an approved master sign program (MSP). The proposed project includes a mixed-use residential and commercial multi-unit development and requires a master sign program. The PMC authorizes the Planning Director to approve an MSP as a condition of approval prior to building permit issuance. However, because the multi-unit development would include a freestanding sign, pursuant to PMC section 9-4.2906(b), the applicant is required to seek Planning Commission approval for the freestanding sign and the proposed MSP and because the Council has called up the November 3, 2025 Planning Commission decisions pursuant to PMC Sec 2-1.105, approval of the sign permit is part of the action to be considered by Council.

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IV. LEGISLATIVE ACTIONS: ANALYSIS AND FINDINGS
The proposed project requires Council approval of four legislative actions. The Planning Commission has recommended that Council approves the legislative actions. The proposed General Plan Amendment, Zoning Text Amendment and Rezoning, all shown in Table 5, and Development Agreement are consistent with policies found in both the 1980 General Plan and the 2040 General Plan.

Table 5: General Plan Land Use Designations and Zoning Districts Current Proposed
General Plan:

Mixed Use Center (MUC)
General Plan:

Mixed Use Center (MUC): developable area (no change)
Conservation (C) undeveloped area
Zoning:

Controlled Manufacturing (M-1)
Zoning:

Community Commercial (C-2) developable area
Open Space undeveloped area
A. General Plan Policies
The Project is consistent with the policies found throughout the 1980 General Plan6 and 2040 General Plan7
, including the prior and current Housing Elements8,9, as summarized below. For a complete list of applicable policies, please refer to Attachment J.

In summary, the project represents orderly growth that would enhance the character of lower Crespi Drive. The commercial space in the project would provide opportunities for new businesses and jobs in Pacifica and revenue-generating land uses to increase the fiscal benefits to the City. The project is well designed, meets the City’s adopted Design Guidelines, and, although not applicable to the project, it also meets the objective design standards recently adopted under the rezone program.

This infill mixed use housing development also activates and enhances this area, which is a designated activity center in the 2040 General Plan, and provides high-quality multi-family housing across income levels. A portion of the project site was previously developed and is fully located adjacent to already improved areas, and would be built outside of the wetland area, retaining 46 percent of the lot as undeveloped. The project would also add 19 residential units, including three BMRs, in a high resource area close to transit and shopping, and contribute to much-needed new housing within the City.

B. General Plan Amendment – GP-96-19. The proposed General Plan Amendment would reclassify the portions of the site to remain undeveloped to a Conservation (C) Land Use Designation and retain the Mixed Use Center (MUC) designation on the portions to be developed.

The Conservation designation “applies to publicly- and privately-owned open areas not intended for development,” which includes areas such as “land which is physically unsuited for development due to… wetlands… or other environmental constraints.” Redesignating the area over the portions to remain undeveloped would reflect the use of this area. Because the General Plan considers gross developable acres for calculating density, this change would not affect the overall density of the site 6 1980 General Plan: https://www.cityofpacifica.org/home/showpublisheddocument/2386/637838931942900000 7 2040 General Plan: https://cityofpacifica.egnyte.com/dl/vGfg0Mii2c 8 2015-2023 Housing Element: https://www.cityofpacifica.org/home/showpublisheddocument/2388/637838931948530000 9 2023-2031 Housing Element: https://cityofpacifica.egnyte.com/dl/fXv3YkHhqK4W

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since it is excluded from density calculations.

C. Zoning Text Amendment and Rezoning. Per PMC section 9-4.3501, the zoning ordinance and zoning districts may be amended whenever the public necessity and convenience and the general welfare require such amendments. The Planning Commission reviewed the Zoning Text Amendment and Rezoning and recommended that the City Council approve these legislative actions. The recommendation to approve the Zoning Text Amendment and Rezoning is based on the following considerations:
i. Zoning Text Amendment – TA-116-19. Residential uses located above the ground floor in the same building as commercial uses, or vertical mixed, are currently allowed by conditional use in the C-2. The proposed zoning text amendment would add a new subsection (12) to section 9-4.1101(b) of the PMC to add a new conditional use that incorporates the allowance of residential-only buildings as part of an integrated mixed-use development to the C-2 zoning district, as follows:

PMC section 9-4.1101(B) (12) Residential dwelling units as part of a mixed-use development, including: (a) Residential units located above the ground floor in the same building as a permitted commercial use (“vertical mixed use”); and (b) Residential units located in a separate building or buildings on the same site as a permitted commercial use, where the residential and commercial uses are planned as a single, integrated development project (“horizontal mixed use”).

The zoning text amendment would apply to all property in the City zoned as C-2 and would by reference also apply to properties zoned as O (Professional Office), which refers to the standards in C-2. The zoning text amendment would not alter the allowable uses or density in the C-1 (Neighborhood Commercial) zoning district where residential uses mixed with commercial uses on the same site would continue to be required within the same building as a commercial use, above the ground floor (vertical mixed-use), with a maximum density of one unit per 2,000 square feet of lot area. Residential uses would continue to be prohibited in the C-3 (Service Commercial) zoning district.

The Zoning Amendment would also address an inconsistency between the zoning ordinance and the 2040 General Plan for sites that are zoned C-2 or O and designated as Mixed Use Neighborhood (MUN) or Mixed Use Center (MUC). These Mixed Use Land Use Land Use designations (1) both allow vertical and horizontal mixed use, and (2) establish the density allowance based on units per acre. The current zoning ordinance is inconsistent because it only allows vertical mixed use and establishes a density of one unit per 2,000 square feet of lot area, which is less than what is allowed under the General Plan. Further, sites that are zoned C-2 or O but are not designated in the General Plan to allow residential uses would not be impacted by this change since residential is not allowed. ii. Rezoning – RZ-194-16. The project would rezone the northern developable portions of the subject site from the M-1 (Controlled Manufacturing) to the C-2 (Community Commercial) zoning district. The M-1 zoning district is subject to the allowable uses in the C-3 (Service Commercial) zoning district codified in PMC section 9-4.1201 which expressly prohibit

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residential uses. The proposed rezoning would allow the proposed project and proposed uses to be subject to the allowable uses in the C-2 zoning district codified in PMC section 9-

4.1101 which, upon approval of the proposed zoning text amendment, would allow mixeduse commercial and residential development on the project site.

The project would also rezone the southern portions to remain undeveloped to an Open Space Zoning District consistent with the recommended General Plan designation of Conservation. The purpose of the Open Space District is to provide for the protection, maintenance, and enhancement of such environmental resources while providing for reasonable and compatible uses of land, and extends “protections to, but not limited to… land which is unsuitable for development due to steep slopes, geotechnical hazards, or other reasons, land areas vital to water resources relating to the supply, recharge, and/or watersheds, and areas of scenic value or unique natural features” (PMC section 9-4.2051).

Open space as a reserve for seismic safety, water conservation erosion protection, view protection, or appropriate uses is a permitted use in the district.

The rezoning would also address an inconsistency between the site zoning designation and the 2040 General Plan MUC Land Use designation, which allows mixed use residential whereas the M-1 zoning prohibits residential. Both the rezoning to C-2 and zoning text amendment would create consistency between the current MUC designation, which allows horizontal mixed use, and the zoning by allowing residential uses on the site, eliminate the conflicting prohibition on residential uses on the site, density provisions (no minimum and lower maximum), and allowing horizontal mixed use at the site.

Attachment C includes the existing and proposed zoning designations.

D. Findings for General Plan Amendment, Rezoning and Zoning Text Amendment.

The findings to support the approval of the proposed General Plan amendment, rezoning, and zoning text amendment are summarized below, and as set forth in detail in the proposed General Plan resolution and zoning ordinance (Attachment B and Attachment C, respectively):

As set forth in the findings, the Project would provide 19 residential units, including three Below Market Rate (BMR) homeownership units (one in each building) to meet current inclusionary housing requirements. The site’s location and characteristics and the in-fill nature of the development make it suitable for the density, intensity, and type of development proposed. The General Plan Amendment and rezoning would be appropriately divided between the MUC Land Use designation and C-2 zoning on the northern developable portions of the parcel, and Conservation Land Use designation and Open Space zoning on the southern portions that are proposed to remain in a natural state. The zoning text amendment would allow flexibility in site design to utilize the developable portions at a scale and intensity appropriate for the area by clustering development in the appropriate part of the site, providing space for critical housing and viable commercial spaces along the street frontage. The Project aligns with current policies to promote infill development, encourage mixeduse development, especially in the lower Crespi Drive primary activity center, and preserve natural resources.

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The rezoning to C-2 and text amendment also address the current inconsistencies between the Mixed Use Center Land Use designation and the M-1 Zoning District by allowing residential uses, and inconsistencies with the C-2 district by allowing both vertical and horizontal mixed use as conditional uses, and removing inconsistent provisions that do not establish a minimum density and set a lower maximum based on lot area.

The Project also supports and furthers Housing Element polices and increases ownership opportunities in a high resource area of the City. Further, the proposed rezoning and zoning text amendment would facilitate a project that can safely develop without causing adverse neighborhood impacts, and the appropriate General Plan consistency and zoning compliance findings can be made for the development upon approval.

E. Development Agreement – DA-4-21. The City and the developer negotiated the terms of a development agreement to establish certain developer benefits and public benefits (Attachment D, Exhibit A). The developer would be granted vested rights to proceed with development under the City’s current land use regulations for the term of the development agreement, up to five years with an initial term of three years and a provision for a two-year extension. Public benefits include, but are not limited to:
• Affordable housing contribution in excess of the minimum requirements of the City’s below-market rate (BMR) inclusionary zoning requirements in the amount of $272,000; • Lease and associated payments to the City for use of the Community Center driveway at 540 Crespi Drive;
• Improvements to the Community Center property including construction of off-street parking spaces, a drop-off location at the front of the Community Center building, and landscaping improvements; and
• Wetlands interpretive signage at the rear of the project site.

All off-site improvements provided pursuant to the Development Agreement, including new parking spaces at the Community Center, would be required to obtain the applicable permits with the final layout and configuration approved to the satisfaction of the City Engineer (Condition of Approval #25), and be completed prior to the first Certificate of Occupancy.

The findings to approve the Development Agreement, pursuant to PMC section 9-4.5007, can be made, as summarized below ,and as set forth in detail in the proposed ordinance (Attachment D):

The project consists of an in-fill development with direct access to a public street and utilities within Crespi Drive. The proposed development would not result in any adverse impacts to public health, safety, or welfare as conditioned. In particular, the project would result in a project where building mass would be broken up into three buildings as opposed to a single building as would be required under current zoning standards.

Provisions in Article 5 of the development agreement would require the applicant to complete the Community Center and wetlands interpretive sign improvements prior to issuance of the first certificate of occupancy for the project, which would ensure their completion prior to the applicant

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receiving substantial benefits from development of the project. Article 5 of the development agreement would also require payment of an additional affordable housing contribution of $272,000 prior to issuance of a building permit.

New housing creates revenue for the City through sales and property taxes and supports local businesses. The commercial component of the project would have a positive impact on the City’s economy, and the residential component of the project would have a significant positive impact on meeting the City’s housing needs generally and affordable housing needs specifically, as well as generating additional revenue.

The project, on the whole, inclusive of the provisions of the proposed development agreement, would be positive for the City of Pacifica and would not adversely affect public health, safety, or welfare.

V. DEVELOPMENT PERMITS: ANALYSIS AND FINDINGS
The project also requires approval of the six discretionary permits listed and summarized below, which have been called-up for Council consideration. The effectiveness of any development permit approvals would not be valid until the effective date of the legislative approvals, and a condition of approval has been included. The Council may either approve, disapprove or modify the Planning Commission decision.

A. Site Development Permit – PSD-811-16 is required for new construction in a commercial zoning district pursuant to PMC section 9-4.3201(a) and for construction of a clustered housing development pursuant to PMC section 9-4.2403(a).

Section 9-4.3204(a) of the PMC states that a site development permit shall not be granted if the certain findings are made. As summarized below and set forth in detail in the proposed resolution (Attachment E), staff recommends that findings be made to support the fact that the findings for disapproval cannot be made. The Planning Commission agreed and approved the Site Development Permit.

Generally, the project will not create a hazardous traffic pattern and has well designed parking areas.

Further, the project would provide sufficient landscaped area and would exceed the landscape requirements for the site without including the area to remain undeveloped. The buildings range from two to three stories and comply with the maximum height limit. Forty-six percent of the lot would remain undeveloped and in a natural state, with all structures located outside of the wetland.

The project design complies with the City’s adopted Design Guidelines, including responsive site planning and building design. The project also complies with the recently adopted objective design standards even though these standards do not apply to the project.

The project is consistent with the General Plan, as detailed in the proposed resolution, and would also be consistent with the Inclusionary Housing requirements by providing three BMR units (15 percent of the total) equally distributed throughout the development with one in each building.

With the rezoning and text amendment, the project would be consistent with the C-2 zoning district, as well as the residential cluster development standards.

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B. Use Permit – UP-076-16 is required for the proposed residential uses pursuant to the proposed zoning text amendment to PMC section 9-4.1101(b), abutting an R district pursuant to PMC section 9-4.1102(i), and residential clustered housing development pursuant to PMC section 9-4.2403(a).

Section 9-4.3303(a) of the PMC states that a use permit shall be granted only if the certain findings are made, and PMC section 9-4.2403(c) also requires additional findings for approval of a residential clustered housing development. As summarized below and set forth in detail in the proposed resolution (Attachment E), staff recommend that the findings for approval can be made. The Planning Commission agreed and approved the Use Permit.

Generally, the use and building will not be detrimental to health, safety and welfare and are consistent with the General Plan and other City requirements, including the design guidelines. The privacy of nearby residences will not be reduced and the architectural features of proposed structures will be integrated harmoniously into the design character of the immediate neighborhood C. Parking Exception – PE-183-19 is required for an exception to off-street parking requirements pursuant to PMC section 9-4.2824(a).

Section 9-4.2824(a) of the PMC states that a parking exception shall be granted in the event of practical difficulties and unusual hardship upon making of a finding that the establishment, maintenance, and/or conducting of the off-street parking facilities as proposed are as nearly in compliance with the requirements as are reasonably possible. As summarized below and set forth in detail in the proposed resolution (Attachment E), staff recommend that the findings for approval be made. The Planning Commission agreed and approved the Parking Exception.

The primary constraint to the provision of off-street parking facilities on the subject site is suitable development area which presents practical difficulty and unusual hardship. The project and parking has been designed to protect the biological resources that exist on 46 percent of the site – roughly in the southern half of the lot. Off-street parking is provided where feasible while balancing the need for landscaping, zoning-compliant drive aisles, and other mandatory requirements for the project.

Providing the required number of off-street parking spaces would most likely require encroaching into the southern half of the site, which contains important biological resources, or else reducing the number of residential units proposed with the project, which would run at cross-purposes with General Plan policies to encourage in-fill and affordable housing development.

The tandem parking configuration within the garages of the two-bedroom townhouse units is a reasonable alternative to the standards side-by-side garage requirement. The uncovered parking is sited in practical locations while also complying with site development permit findings and Design Guidelines that direct off-street parking to be located where less visible from the street. The offstreet parking facilities as proposed would be as nearly in compliance with the standards as is reasonably possible.

D. Sign Permit – S-129-19 is required for the proposed freestanding sign as a part of a master sign program for its commercial tenants pursuant to PMC section 9-4.2907(b).

Section 9-4.2907 of the PMC states that a sign permit for a freestanding sign shall be granted only if

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certain findings are made. As summarized below and set forth in detail in the proposed resolution (Attachment E), staff recommend that the findings for approval be made. The Planning Commission agreed and approved the Sign Permit.

The proposed project is located along a substantially developed segment of Crespi Drive. The properties adjacent to the project site at 540 Crespi Drive and 580 Crespi Drive both have freestanding signs to identify those developments. A freestanding sign is necessary to distinguish the project site from the adjacent properties at 540 Crespi Drive and 580 Crespi Drive. Additionally, with much of the project located behind Building A at the rear of the project site, a freestanding sign that identifies the name of the development would provide a ready means for businesses, residents, and emergency services to direct visitors to the project site with a simple point of reference to the freestanding sign. Further, the sign is consistent with the purposes of the Sign Ordinance, and would not exceed size limitations, or interfere with vehicular access or pedestrian safety.

E. Vesting Tentative Subdivision Map – SUB-233-16 for condominium subdivision of five or more parcels pursuant to PMC section 10-1.302.

Section 10-1.407(d) of the PMC lists the findings that would require denial of a vesting tentative subdivision map. A map may be approved only if none of those findings can be made. As summarized below and set forth in detail in the proposed resolution (Attachment E), staff recommend that the findings for denial cannot be made. The Planning Commission agreed and approved the Vesting Tentative Subdivision Map.

The proposed subdivision, including its design and improvements, is consistent with the General Plan and zoning provisions, as detailed in the Site Development Permit findings. Because the project is primarily a condominium subdivision of airspace, many of the subdivision standards are not applicable to the proposed subdivision. However, the proposed subdivision would meet the lot design and standards related to the preservation of existing vegetation by preserving the southern portion of the project site. The proposed subdivision would also comply with the specific requirements applicable to a vesting tentative subdivision map which include, but are not limited to, concurrent application for all other required discretionary project.

The site is suitable for mixed use residential development, as identified in the 1980 General Plan Commercial designation that allowed vertical mixed use and the 2040 General Plan MUC designation that allows for both vertical and horizontal mixed use. Potential impacts and mitigation measures were analyzed in the Environmental Impact Report, and required mitigations would reduce potential impacts to biological resources to less than significant.

F. Tree Removal Permit – TP13-25 for removal of one or more Protected Trees pursuant to PMC section 4-12.04(a).

Section 4-12.04(c) of the PMC states that a tree removal permit shall be granted based on certain criteria. As summarized below and set forth in detail in the proposed resolution (Attachment E), staff recommend that the findings for approval be made. The Planning Commission agreed and approved the Tree Removal Permit.

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Five of the thirteen protected trees proposed for removal to accommodate development are clustered on the northern portion of lot, outside of the wetland. Given the limitations of the identified biological resources at the rear of the property, removal of the trees is necessary to preserve the natural portions of the property at the rear of the site while allowing for the economically viable use of the property.

VI. AGREEMENT FOR PURCHASE AND SALE
As noted above, the project includes a 55-foot portion of the City property located at 540 Crespi Drive, which the applicant has proposed to purchase from the City. The City and the developer negotiated the terms and conditions of the transfer, which are set forth in a proposed Agreement for Purchase and Sale attached hereto as Exhibit A to Attachment K (the “Agreement”). The terms include a purchase price of $750,000, which was based initially on an appraisal and then negotiated between the City and the developer.

In addition, the Agreement includes standard terms and conditions regarding escrow, closing requirements, warranties and representations, and due diligence and title review. In particular, the Agreement requires that escrow be opened within ten days of the effective date of the Agreement and that a Good Faith Deposit of $75,000 be deposited into escrow three business days thereafter. The Good Faith Deposit will become nonrefundable after the end of a 90-day due diligence period if the applicant determines to move forward after title and property review. In addition, the applicant would be purchasing the property in its as-is condition and releasing the City from claims regarding the condition of the property. The final closing is conditioned upon the applicant obtaining a building permit to construct the project to ensure the property is not transferred until the project is ready to move forward.

The outside closing date is December 31, 2026, subject to extension.

Before the disposition of any real property, the Planning Commission must find that the transfer conforms to the adopted 2040 General Plan to ensure that the location, purpose, and extent of the disposition are consistent with the City’s long-range planning goals and policies. The Planning Commission reviewed the real property transfer for General Plan consistency and made the required finding on November 3, 2025. In addition, as set forth above, the City has complied with all the required SLA requirements.

VII. CEQA RECOMMENDATION FOR CERTIFICATION OF EIR AND ADOPTION OF CEQA FINDINGS AND

STATEMENT OF OVERRIDING CONSIDERATIONS
In accordance with the California Environmental Quality Act (CEQA), the City prepared a Focused Environmental Impact Report (EIR) to evaluate the environmental impacts of the proposed project (State Clearinghouse #2021120126)10. The EIR analysis evaluated the following potential environmental impacts from the project: Biological Resources; Greenhouse Gas Emissions; and Transportation (Attachment A, Exhibit A). The Initial Study prepared for the project, and included as Appendix A of the Draft EIR, identifies potentially significant impacts related to the following: Cultural and Tribal Cultural Resources; Geology and Soils/Mineral Resources; Hazards and Hazardous Materials; Hydrology and Water Quality; and Noise. However, the City has concluded that implementation of 18 mitigation measures in the proposed Mitigation Monitoring and Reporting Program (MMRP) (Attachment A, 10 Environmental documents also available through State Clearinghouse: SCH# 2021120126

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Exhibit B) would reduce these potentially significant environmental impacts to a less than significant level. The MMRP identifies responsibilities related to implementation, timing, monitoring frequency, and responsible party for each mitigation measure. As identified, a Greenhouse Gas Emissions and a Transportation Impact was determined to be significant and unavoidable, thus a Statement of Overriding Consideration has been prepared.

In summary, the EIR for the 570 Crespi Drive Project identified significant and unavoidable impacts related to greenhouse gas emissions and vehicle miles traveled. Although mitigation measures have been incorporated, these impacts would remain significant. The City Council must therefore adopt a Statement of Overriding Considerations. In this case, the Project’s benefits—including new housing units to help meet RHNA obligations, new commercial space and jobs, economic and fiscal benefits to the City, site improvements to the Community Center, and preservation of open space and wetlands—outweigh the Project’s unavoidable environmental effects.

The City prepared and released the Draft EIR on April 11, 2025, for a 45-day public review period to present the proposed project to the public, answer questions about the proposed project, and receive public comments on the Draft EIR. The 45-day public review period was extended to June 20, 2025. The City received written comments on the Draft EIR during the 70-day public review period. Based on comments pertaining to the adequacy of the Draft EIR related to biological resources, the City determined that recirculation of Chapter 4.1 was required.

The Partially Recirculated Draft EIR was made available for public review and comment from August 1, 2025, through September 15, 2025 (5 PM). The City received one public comment and no agency comments on the Partially Recirculated Draft Review during the public review and comment period.

As it pertains to potential development of sites other than the project site as a result of the zoning text amendment, as indicated in the EIR (including the IS/MND) prepared for the project and above in this staff report, mixed-use commercial and residential development on the same lot or parcel would continue to be a conditional use subject to approval of a use permit, which is a discretionary permit. The use permit review and approval process requires a discretionary permit and would be subject to the requirements of CEQA. Consequently, development of new residential uses that may result from the zoning text amendment on sites other than the project site would be subject to site-specific environmental review and would not be allowed by-right by the proposed zoning text amendment.

As discussed above, after an appeal of the project approvals in 2022, the City Council directed preparation of an EIR. During preparation of the EIR, agency comments were received that further refined the prior biological analysis. The EIR process included:
• Conducting a formal wetland and jurisdictional delineation in coordination with the California Department of Fish and Wildlife (CDFW), Regional Water Quality Control Board (RWQCB), U.S.

Army Corps of Engineers (USACE) to confirm whether any Waters of the U.S. or State occur onsite. • Completing updated biological surveys and special-status species habitat assessments to verify the presence of absence of sensitive resources.
• Expanding the analysis to address habitat connectivity, potential barriers to wildlife movement, and the effects of project lighting.

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• Revising and strengthening mitigation measures, including wider buffer zones, enhanced tree protection and replacement ratios with monitoring and bonding requirements, detailed preconstruction survey protocols for nesting birds. • Responding to public agency comments in the recirculated Chapter 4.1, clarifying methodologies, thresholds, and implementation requirements for all mitigation measures.

These refinements resulted in a more robust analysis. The Final EIR concludes that all biological resource impacts can be mitigated to a less-than-significant level. The Partially Recirculated Chapter 4.1 received one additional public comment and no agency comments during the August 1 – September 15, 2025, comment period. No changes were required to the environmental documents based on review of the public comment.

VIII. STAFF RECOMMENDATION
The project is one of the three largest housing development projects proposed in the City in the last eleven years11 to come before the Planning Commission and City Council for entitlements. This is also the first project to be considered after the adoption and certification of Pacifica’s 2023-2031 Housing Element and is the only housing development project under consideration for entitlement this calendar year.

The project site, because of its proximity to residential, commercial, public facilities, and recreational opportunities, is an appropriate in-fill development site. In-fill development of mixed residential and commercial uses is consistent with the various policies in the City’s 1980 and 2040 General Plan. The project, as conditioned, would be consistent with applicable provisions of the PMC and required findings for approval of the required permits, or would receive appropriate exceptions therefrom.

The zoning text amendment, which would also be applicable to sites other than the project site, would enhance public health, safety, and welfare by providing greater flexibility in the design of mixed-use projects on sites affected by the amendments and better align with Land Use designations in the adopted 2040 General Plan. Greater flexibility in project design can improve neighborhood compatibility of projects and reduce the bulk of mixed-use buildings as discussed in the staff report. Such is the case with the project, where a rezoning to C-2 (Community Commercial) would appropriately allow mixed-use development and would allow the project to utilize the provisions that add horizontal mixed use to the already allowable mixed use contained in the zoning text amendment.

Due to the appropriateness of the project and its consistency with applicable development regulations, staff recommend the City Council certify the EIR and adopt the CEQA findings and a Statement of Overriding Consideration, approve the proposed development agreement, rezoning, and zoning text amendment, and approve the decision of the Planning Commission and approve the Development Permits.
11 801 Fassler Avenue: 24 units including four BMR; application 2014 and approval 2018; under construction/some units occupied; and
930 Oddstad Boulevard: 70 workforce units; application 2020 and approval 2023; building permit under review

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X. PUBLIC COMMENTS
Public comments received between October 1, 2025 through noon October 26, 2025, prior to the agenda packet publication, are included as Attachment M. *****
ALTERNATIVE ACTION:

The City Council could modify or deny the project, or continue the hearing to another date, provided that the PC decisions that were called up for review are brought back prior to Sunday, January 11, 2026, to comply with the 60-day timeline for acting on an appeal set forth in PMC Section 9-4.3603, which must be followed for Councilmember Call-Ups as well.

RELATION TO CITY COUNCIL GOALS AND WORKPLAN
The project, as a whole, relates to the following Strategic Plan12 goals:
• 01: Enhance organizational and fiscal stability
• 02: Improve and steward City infrastructure, streets and facilities • 03: Prioritize protection and development of affordable housing FISCAL IMPACT:

In addition to the fiscal benefits associated with new housing, the development agreement would have the following positive fiscal impacts for the City:
• Revenue from the sale of the property to the developer; • Property and sales taxes from the units;
• Affordable housing contribution of $272,000, beyond and in addition to the code required three on-site BMR units; and
• Annual payment for a driveway lease, which is adjusted annually; and • Construction of off-site improvements at the City-owned and operated community center 12 City of Pacifica Strategic Plan 2023 to 2030 (amended April 14, 2025):
https://www.cityofpacifica.org/government/city-council-strategic-plan

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ATTACHMENTS LIST
Attachment 00 – Staff Report (Full)
Attachment A - Draft EIR Resolution & Statement of Overriding Considerations • Exhibit A: Environmental Impact Report (FEIR, PR DEIR, DEIR) • Exhibit B: Mitigation Monitoring and Reporting Program (MMRP) (Section 3 of Final EIR) Attachment B – Draft General Plan Amendment
• Exhibit A: Land Use Diagram
Attachment C – Draft Rezone and Zoning Text Amendment Ordinance • Exhibit A: Zoning Diagram
Attachment D – Draft Development Agreement Ordinance
• Exhibit A: Draft Development Agreement
Attachment E – Draft Permit Approvals Resolution
• Exhibit A: Conditions of Approval
• Exhibit B: Mitigation Monitoring and Reporting Program (MMRP) Attachment F - Project Plans
Attachment G – Landscape Plans
Attachment H – Vesting Tentative Subdivision Map
Attachment I – Arborist Report
Attachment J – LU Policies
Attachment K – Draft Purchase and Sale Agreement Resolution Attachment L – Council Call Up, dated November 12, 2025 Attachment M – Public comment (10/1/25 – 11/26/25)

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ATTACHMENT A
RESOLUTION NO. xx-2025

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PACIFICA CERTIFYING THE ENVIRONMENTAL IMPACT REPORT FOR THE 570 CRESPI DRIVE PROJECT

AND ADOPTING CALIFORNIA ENVIRONMENTAL QUALITY ACT FINDINGS, A

STATEMENT OF OVERRIDING CONSIDERATIONS, AND A MITIGATION

MONITORING AND REPORTING PROGRAM
WHEREAS, an application has been submitted for construction of a 43,696-square foot (sf) mixed-use development including one two-story mixed-use building with three residential units and 3,165 sf of commercial space, two three-story residential buildings behind the street-facing mixed-use building consisting of 16 townhouse residential units; construction of a freestanding sign; merger of two parcels located at 540 and 570 Crespi Drive (APNs 022-162-420 and 022-162-310); removal of five protected trees; a condominium subdivision; construction of off-site parking, circulation and landscaping improvements at 540 Crespi Drive; construction of a wetlands interpretive sign; a development agreement with certain public and developer benefits; a general plan amendment to designate portions of the site as C (Conservation); a zoning text amendment to revise the list of conditional uses in the C-2 (Community Commercial) zoning district; and a rezoning to change the zoning classification to the C-2 and OS (Open Space) zoning district (“Project”).

WHEREAS, the Project site is located at 570 Crespi Drive and 540 Crespi Drive in the City of Pacifica, California and is bound by 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 1.68- acre project site currently consists of two parcels: Parcel 1, located at 570 Crespi Drive, is identified by APN 022-162-310, and Parcel 2, located at 540 Crespi Drive, is identified by APN 022-162-420.

WHEREAS, the Project applicant would purchase from the City of Pacifica a 0.70- acre portion of Parcel 2 and process a Lot Merger and/or 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 mixed-use building (Building A) and two three-story residential buildings (Buildings B and C). The Project would also include a condominium subdivision to create one commercial condominium and 19 residential condominiums. All three buildings would be constructed on the northernmost half of the site, while the southernmost half of the site would remain undisturbed. In addition, the project would require 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.

WHEREAS, the Project includes a general plan amendment, zoning text amendment, rezoning and Development Agreement, which require a recommendation from the Planning Commission and approval by the City Council (the “Legislative

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Actions”), and various discretionary permits, namely a Site Development Permit, Use Permit, Parking Exception, Sign Permit, Vesting Tentative Subdivision Map and Tree Removal Permit (“Development Permits”), which require approval by the Planning Commission.

WHEREAS, the Planning Commission of the City of Pacifica held a public hearing to consider the recommendation of the Legislative Actions, and certification of the EIR and approval of the Development Permits on November 3, 2025, at which time it considered all oral documentary evidence presented, and incorporated all testimony and documents into the record by reference; adopted Resolution No. 2025-014 certifying the EIR, adopting the Findings of Fact and Statement of Overriding Considerations, and Mitigation, Monitoring, and Reporting Program; and adopted Resolution No. 2025-015 recommended City Council approval of the Legislative Action and approving the Development Permits.

WHEREAS, the Planning Commission’s approvals were called up by a Councilmember on November 12, 2025, within the 10-day statutory period, pursuant to Pacifica Municipal Code (PMC) section 2-1.105.

WHEREAS, City, as lead agency under the California Environmental Quality Act (“CEQA”), has completed the Final Environmental Impact Report (“Final EIR” or “EIR”) for the Project.

WHEREAS, this document contains the City Council’s certification of the EIR and its CEQA findings supporting its adoption on the Legislative Actions and approval of the Development Permits, as considered in the EIR. The Final EIR has State Clearinghouse No. 2021120126.

WHEREAS, a Draft Environmental Impact Report (“Draft EIR”) was released for public and agency review on April 11, 2025. The Draft EIR assesses the potential environmental effects of implementation of the Project, identifies means to eliminate or reduce potential adverse impacts, and evaluates a reasonable range of alternatives to the Project.

WHEREAS, a Partially Recirculated Draft Environmental Impact Report (“Partially Recirculated Draft EIR”) was released for public and agency review on August 1, 2025.

Based on the comments received regarding the Draft EIR, the Partially Recirculated Draft EIR recirculated Chapter 4.1, Biological Resources, of the Draft EIR, in order to comply with CEQA Guidelines Section 15088.5.

WHEREAS, the Final EIR comprises the Draft EIR and Partially Recirculated Draft EIR together with one additional volume that includes the comments on the Draft EIR submitted by interested public agencies and written responses to the environmental issues raised in those comments. The Final EIR is hereby incorporated in this document by reference.

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NOW, THEREFORE, BE IT RESOLVED AND DETERMINED, as follows:

SECTION 1. CERTIFICATION OF THE FINAL EIR
The City Council of the City of Pacifica (the “City Council”) certifies that it has been presented with the Final EIR and that it has reviewed and considered the information contained in the Final EIR prior to making the following findings below.

Pursuant to CEQA Guidelines Section 15090 (Title 14 of the California Code of Regulations, Section 15090) the City Council certifies that the Final EIR has been completed in compliance with CEQA and the State CEQA Guidelines. The City Council certifies the Final EIR for the Project as described above.

The City Council further certifies that the Final EIR reflects its independent judgment and analysis.

SECTION 2. FINDINGS AND STATEMENT OF OVERRIDING CONSIDERATIONS Having received, reviewed, and considered the Final EIR and other information in the record of proceedings, the City Council hereby adopts the following findings in compliance with CEQA and the CEQA Guidelines:

Part A: Findings regarding the environmental review process and the contents of the Final EIR.

Part B: Findings regarding the significant environmental impacts of the Project and the mitigation measures for those impacts identified in the Final EIR and adopted as conditions of approval.

Part C: Findings regarding the reasonableness of the range of alternatives evaluated in the Final EIR.

Part D: Statement of Overriding Considerations
Due to the significant and unavoidable environmental effects identified in the Final EIR, CEQA requires the City Council to approve a Statement of Overriding Considerations prior to approving the Project.

The City Council certifies that these findings are based on full appraisal of all viewpoints, including all comments received up to the date of adoption of these findings, concerning the environmental issues identified and discussed in the Final EIR. The City Council adopts the findings and the statement in Parts A, B, C, and D for the Project.

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Part A. Environmental Review Process
Notice of Preparation and Scoping Meeting
On October 4, 2024, the City issued a Notice of Preparation announcing the intended preparation of the Draft EIR and describing its proposed scope. The public review period for the Notice of Preparation complied with the required 30-day requirement, extending from October 4 until November 4, 2024. The City held a public scoping meeting for the Draft EIR on October 22, 2024 for the purpose of informing the public and receiving comments on the scope of the environmental analysis to be prepared for the Project. The scoping meeting was held online, via Zoom.

The City received two comment letters during the comment period on the Notice of Preparation from State agencies, included as Appendix B to the Draft EIR. Verbal comments were not received during the public scoping meeting for the Draft EIR.

Preparation of the EIR
The City completed the Draft EIR for the Project and, beginning on April 11, 2025, the City made the Draft EIR available for review and comment. A Notice of Availability was published and the period for receipt of comments on the Draft EIR remained open for 70 days. Copies of the Draft EIR document were made available at the Pacifica Community Development Department, 1800 Francisco Boulevard, Pacifica, California 94044, and on the City’s website at:
https://www.cityofpacifica.org/home/showpublisheddocument/20135/638799864859170 000.

During the comment period on the Draft EIR, the City received two comment letters. The letters were authored by State agencies.

Based on the comments received regarding the Draft EIR, the City modified Chapter 4.1, Biological Resources, of the EIR and, beginning on August 1, 2025, the City made a Partially Recirculated Draft EIR available for review and comment. A Notice of Availability was published and the period for receipt of comments on the Partially Recirculated Draft EIR remained open for 45 days. Copies of the Partially Recirculated Draft EIR were made available at the Pacifica Community Development Department, 1800 Francisco Boulevard, Pacifica, California 94044, and on the City’s website at:
https://www.cityofpacifica.org/departments/community-development/planningdivision/environmental-documents. .

One public comment letter was received on the Partially Recirculated Draft EIR.

None of the comments received required any modifications to the Partially Recirculated Draft EIR.

The Final EIR was completed and available to commenting public agencies on or before September 26, 2025.

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The Final EIR contains all of the comments received during and immediately after the public comment period, together with written responses to significant environmental issues raised in those comments, which were prepared in accordance with CEQA and the CEQA Guidelines.

The City Council finds and determines that the Final EIR provides adequate, good faith, and reasoned responses to all comments raising significant environmental issues.

Absence of Significant New Information
CEQA Guidelines Section 15088.5 requires that a lead agency recirculate an EIR for further review and comment when significant new information is added to the EIR after public notice is given of the availability of a Draft EIR, but before certification of the Final EIR. New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect that the project proponent declines to implement. Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR. The Guidelines provide examples of significant new information under this standard, which include the following:

1. A new significant environmental impact that would result from the Project (or any alternative) or from a new mitigation measure proposed to be implemented.

2. A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.

3. A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the Project (or an alternative), but the Project's proponents decline to adopt it.

4. The Draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

Having reviewed all the information in the record, the City Council finds that no significant new information has been added to the Final EIR since public notice was given of the availability of the Partially Recirculated Draft EIR. No new or substantial changes to the Draft EIR beyond those included in the Partially Recirculated Draft EIR were proposed as a result of the public comment process. The Final EIR responds to comments and does not make any technical changes, clarifications, or additions to the Draft EIR.

Therefore, the City Council finds that recirculation of the EIR is not required.

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Differences of Opinion Regarding the Impacts of the Project In making its determination to certify the Final EIR and to approve the Project, the City Council recognizes that a range of technical and scientific opinion exists with respect to certain environmental issues. The City Council acknowledges that it has acquired an understanding of the range of this technical and scientific opinion by its review of the Draft EIR and Partially Recirculated Draft EIR, the comments received on the Draft EIR and the responses to those comments in the Final EIR, as well as testimony, letters, and reports regarding the Final EIR and its own experience and expertise in these environmental issues. The City Council acknowledges that it has reviewed and considered, as a whole, the evidence and analysis presented in the Draft EIR and Partially Recirculated Draft EIR, the evidence and analysis presented in the comments on the Draft EIR, the evidence and analysis presented in the Final EIR, the information submitted on the Final EIR, and the reports prepared by the experts who prepared the EIR, by the City’s consultants, and by staff, addressing those comments. The City Council acknowledges that it has gained a comprehensive and well-rounded understanding of the environmental issues presented by the Project. The City Council acknowledges that in turn, this understanding has enabled the City Council to make its decisions after weighing and considering the various viewpoints on these important issues. The City Council accordingly certifies that its findings are based on full appraisal of all of the evidence contained in the Final EIR, as well as the evidence and other information in the record addressing the Final EIR.

Part B. Impacts and Mitigation Measures
The City Council acknowledges that these findings provide the written analysis and conclusions of the City Council regarding the environmental impacts of the Project and the mitigation measures identified by the Final EIR and adopted by the City Council as conditions of approval for the Project.

The following significant environmental impacts of the Project are unavoidable and cannot be mitigated in a manner that would reduce the significant impact to a less-thansignificant level. Notwithstanding disclosure of these impacts, the City Council elects, due to overriding considerations as set forth below in Part D, to adopt the Statement of Overriding Considerations.

Greenhouse Gas (GHG) Emissions
Impact 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.

Mitigation Measures: The following mitigation measures have been adopted to address this impact to the extent feasible:

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4.2-1(a) Prior to the issuance of a building permit, the applicant shall implement the following measure:
• 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 14 community center spaces, consistent with the current CALGreen Tier 2 standards.

Project improvement plans shall be prepared by a licensed engineer indicating the required EV Capable parking spaces and shall be submitted for review and approval by the City’s Engineer prior to the issuance of a building permit. 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.

Finding: Implementation of Mitigation Measure 4.2-1(a) would ensure that the Project applicant shall install a total of four electric vehicle (EV) capable parking spaces throughout the 15 on-site uncovered parking spaces, and an additional four EV capable parking spaces throughout the 14 community center spaces. Mitigation Measure 4.2-1(a) would ensure project consistency with Transportation criterion d of the Bay Area Air District (BAAD) Buildings and Transportation criteria, in which the 2022 CALGreen Code Tier 2 Standards would require four EV capable spaces in both the on-site parking spaces and the community center parking spaces. Implementation of Mitigation Measure 4.2-1(b) references Mitigation Measure 4.3-3, which is further discussed below and would reduce Project vehicle miles traveled (VMT), but not to a level that would achieve 15 percent less than the regional average VMT. As such, even with the implementation of mitigation, the proposed project would conflict with BAAD’s Transportation criteria c. Thus, although Mitigation Measure 4.2-1(a) would ensure Project consistency with Transportation criteria d, and Mitigation Measure 4.2-1(b) would reduce the impact related to Transportation criteria c to the maximum extent feasible, the impact would not be reduced to a less-thansignificant level. Thus, the impact remains significant and unavoidable.

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

Mitigation Measure: The following mitigation measure has been adopted to address this impact to the extent feasible:

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

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approval by the City Engineer. The timing for the strategy is set forth below:

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.

Finding: Implementation of Mitigation Measure 4.3-3 would ensure that the Project applicant shall provide subsidized or discounted, or free transit passes for residents of the Project’s 19 dwelling units. Mitigation Measure 4.3-3 would reduce residential VMT per capita associated with the Project residential component by implementing California Air Pollution Control Officers Association (CAPCOA) reduction strategy T-9 to reduce external vehicle trips generated by Project residents and increase the total number of transit trips. According to CAPCOA, implementation of VMT reduction strategy T-9 would reduce Project-generated residential VMT per capita by 0.6 percent. Pursuant to the Governor’s Office of Land Use and Climate Innovation (LCI) screening criteria for VMT impacts, residential projects that generate average VMT per resident at 15 percent less than the regional baseline average may be considered to have a less-than-significant VMT impact. However, even with implementation of Mitigation Measure 4.3-3, the residential VMT per capita generated by the Project’s residential component would be

18.4 percent above baseline local VMT per capita average. Thus, although Mitigation Measure 4.3-3 would reduce the impact to the maximum extent feasible, the impact would not be reduced to a less-than-significant level. Thus, the impact remains significant and unavoidable.

The City Council acknowledges that in making these findings, the City Council has considered the opinions of other agencies and members of the public, including opinions that disagree with some of the analysis and significance thresholds used in the EIR. The City Council finds that the determination of significance thresholds is a judgment within the discretion of the City Council; the significance thresholds used in the EIR are supported by substantial evidence in the record, including the expert opinion of the EIR preparers and City staff; and the significance thresholds used in the EIR provide reasonable and appropriate means of assessing the significance of the adverse environmental effects of the Project.

In particular, the EIR relied on significance criteria for evaluating impacts that are tailored to this type of project. The criteria used in this EIR to determine whether an impact is or is not “significant” are based on (a) CEQA-stipulated “mandatory findings of significance” listed in CEQA Guidelines section 15065; (b) the relationship of the Project effect to the adopted policies, ordinances and standards of the City and of responsible

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agencies; and (c) commonly accepted practice and the professional judgment of the EIR authors and City staff.

A full explanation of the environmental findings and conclusions can be found in the Final EIR and these findings hereby incorporate by reference the discussion and analysis in the Final EIR supporting the Final EIR’s determinations regarding the Project’s impacts and mitigation measures designed to address those impacts. In making these findings, the City Council ratifies, adopts, and incorporates the analysis and explanation in the Final EIR, and ratifies, adopts, and incorporates in these findings the determinations and conclusions of the Final EIR relating to environmental impacts and mitigation measures, except to the extent any such determinations and conclusions are specifically and expressly modified by these findings.

The City Council adopts, and incorporates as conditions of approval of the Project, the mitigation measures set forth in the Mitigation Monitoring and Reporting Program attached to these findings as Exhibit A to reduce or avoid the potentially significant and significant impacts of the Project. The City Council acknowledges that in adopting these mitigation measures, the City Council intends to adopt each of the mitigation measures recommended for approval by the Final EIR. Accordingly, in the event a mitigation measure recommended in the Final EIR has inadvertently been omitted from Exhibit A, such mitigation measure is hereby adopted and incorporated in the findings below by reference. In addition, in the event the language describing a mitigation measure set forth in Exhibit A fails to accurately reflect the mitigation measures in the Final EIR due to a clerical error, the language of the mitigation measure as set forth in the Final EIR shall control, unless the language of the mitigation measure has been specifically and expressly modified by these findings.

The City Council hereby finds that the adopted mitigation measures are changes or alterations that have been required in, or incorporated into, the Project which mitigate or avoid significant effects on the environment.

Part C. Alternatives
Summary of Discussion of Alternatives in the Draft EIR
The Final EIR evaluates three potential alternatives to the Project. The EIR examines the environmental impacts of each alternative in comparison with the Project and the relative ability of each alternative to satisfy project objectives.

Findings Relating to Alternatives
In making these findings, the City Council certifies that it has independently reviewed and considered the information on alternatives provided in the Draft EIR, including the information provided in comments on the Draft EIR and the responses to those comments in the Final EIR. The Draft EIR’s discussion and analysis of these alternatives is not repeated in these findings, but the discussion and analysis of the alternatives in the Draft EIR is incorporated in these findings by reference.

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The Final EIR describes and evaluates in detail three alternatives to the Project.

CEQA requires the City Council to adopt findings rejecting alternatives to the Project and, as such, the City Council acknowledges that the reasons for City Council’s decision to approve the Project instead of the remaining alternatives are presented below. The City Council finds that the Project would satisfy the Project Objectives; two of the three alternatives would satisfy the Project objectives to the same degree as the Project, and the remaining alternative would be unable to satisfy any of the Project objectives. The City Council further finds that, while two of the three alternatives have environmental advantages over the Project, each alternative would be infeasible for economic reasons, as described further below. Accordingly, the City Council determines to approve the Project instead of approving one of the remaining alternatives.

Description of Project Objectives
The Project Objectives are the following:

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 Pacifica 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.

Discussion and Findings Relating to the Alternatives
Evaluated in the Draft EIR
Chapter 6 of the Draft EIR evaluates the following three alternatives, which are summarized below:
• No Project (No Build) Alternative;
• 100 Percent Affordable Housing Alternative; and
• Reduced Intensity Alternative.

No Project (No Build) Alternative.

Under CEQA, a “No Project (No Build) Alternative” compares the impacts of proceeding with a proposed project with the impacts of not proceeding with the proposed project. A No Project (No Build) Alternative describes the environmental conditions in existence at the time the Notice of Preparation, along with a discussion of what would be

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reasonably expected to occur at the site in the foreseeable future, based on current plans and consistent with available infrastructure and community services.

The No Project (No Build) Alternative is defined in the Draft EIR as the continuation of the existing conditions of the Project site. The Project site is currently undeveloped and covered in dense vegetation. Several trees and shrubs are located throughout the Project site. The western portion of the site is disturbed due to landscape improvements, while the southern portion is predominantly characterized by a seasonal drainage and wetland area. Because implementation of the No Project (No Build) Alternative would result in the site remaining under current conditions, physical environmental impacts would not occur, and none of the project objectives would be met.

On balance, the environmental benefits that might be achieved with this Alternative are outweighed by its failure to achieve any of the project objectives, and the City Council rejects this Alternative.

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100 Percent Affordable Housing Alternative.

The 100 Percent Affordable Housing Alternative would consist of similar buildout of the components of the Project, including a two-story mixed-use building (Building A), two three-story residential buildings (Buildings B and C), and the same off-site improvements as the Project north of the existing Pacifica Community Center. However, under the 100 Percent Affordable Housing Alternative, the 19 proposed units would be made affordable units, available to buyers with low to moderate incomes.

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. As discussed in Chapter 6, Alternatives Analysis, of the Draft EIR, impacts related to biological resources would remain similar under the Alternative as compared to the Project; the potential to impact special-status plant and animal species and to disturb water of the State, on-site trees, and riparian vegetation would still occur. However, as affordable housing is shown to generate less VMT than market-rate housing, the Alternative would result in fewer impacts related to GHG emissions and transportation, and the significant and unavoidable impacts identified for the Project would be eliminated.

As stated above, the Draft EIR determined that the 100 Percent Affordable Housing Alternative would achieve all of the Project objectives and would result in similar or fewer impacts to all resource areas as compared to the Project. However, the City finds that the 100 Percent Affordable Housing Alternative is not feasible. “Feasible” is defined as “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, technological, and legal factors.” (Public Resources Code Section 21061 and CEQA Guidelines Section 15364).

The City finds that the 100 Percent Affordable Housing Alternative is not feasible, as defined under CEQA, as the City cannot legally require the Project applicant to construct 100 percent affordable housing on the project site, as Section 9-4.4702 of the PMC only requires 15 percent of the total number of residential units be affordable.

On balance, the environmental benefits that might be achieved with the 100 Percent Affordable Housing Alternative are outweighed by its infeasibility, and the City Council rejects this Alternative.

Reduced Intensity Alternative.

The Reduced Intensity Alternative would eliminate four residences from the Project by reducing Building C by three units and Building B by one unit, for a total of 15 units.

The affordable units, which would be located within Building A, would remain as proposed. Buildings B and C would remove the units from the end closest to the existing wetlands, thereby increasing the buffer distance between the development and the wetlands. All other aspects of the Project would be similar under the Reduced Intensity Alternative, including the off-site improvements.

Because the Alternative would include development of the same uses as the Project, all of the project objectives would be met. Objective 5 could arguably be better

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met under the Alternative, as the removal of four units would preserve more open space at the rear of the site.

As discussed in Chapter 6, Alternatives Analysis, of the Draft EIR, impacts related to biological resources would remain similar under the Alternative as compared to the Project, as the potential to impact special-status plant and animal species and to disturb waters of the State, on-site trees, and riparian vegetation would still occur. However, as the reduction in residential units would lower the total daily trips under the Alternative, the Alternative would result in fewer impacts related to GHG emissions and transportation, and the significant and unavoidable impacts identified for the Project would be eliminated under the Reduced Intensity Alternative.

As stated above, the Draft EIR determined that the Reduced Intensity Alternative would achieve all of the Project’s objectives and would result in similar or fewer impacts to all resource areas. However, because fewer residential units would be developed under the Alternative, the economic benefit to the City through property and sales taxes and other project fees would be greatly reduced. Furthermore, the Reduced Intensity Alternative would provide approximately 21 percent less housing than the Project would create and, thus, would not provide the needed housing supply for the State and City to the same extent as the Project. Accordingly, the City has determined that the aforementioned considerations render the Reduced Intensity Alternative infeasible. (See CEQA Guidelines Section 15091, subdivision [a][3]).

On balance, the environmental benefits that might be achieved with the Reduced Intensity Alternative are outweighed by its infeasibility, and the City Council rejects this Alternative.

Findings Regarding Reasonable Range of Alternatives
The City Council finds that the range of alternatives evaluated in the EIR reflects a reasonable attempt to identify and evaluate various types of alternatives that would potentially be capable of reducing the Project’s environmental effects, while accomplishing the project objectives. The City Council finds that the alternatives analysis is sufficient to inform the City Council and the public regarding the tradeoffs between the degree to which alternatives to the Project could reduce environmental impacts and the corresponding degree to which the alternatives would hinder the City’s ability to achieve the project objectives and/or result in economic infeasibility.

Part D. Statement of Overriding Considerations
Pursuant to CEQA Guidelines Section 15092, the City Council finds that in approving the Project it has eliminated or substantially reduced all significant and potentially significant effects of the Project on the environment where feasible, as shown in the EIR and described in these findings.

In the City Council’s judgment, the Project and its benefits outweigh its unavoidable significant effects. The following Statement of Overriding Considerations identifies the

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reasons why, in the City Council’s judgment, the benefits of the Project, as approved, outweigh its unavoidable significant effects.

Any one of the stated reasons is sufficient to justify approval of the Project. Thus, even if a court were to conclude that not every reason set forth in this Statement is supported by substantial evidence, the City Council finds that any individual reason is separately sufficient. This Statement is supported by the substantial evidence set forth in the Draft EIR, Partially Recirculated Draft EIR, Final EIR, and the findings set forth above, and in the documents incorporated by reference above.

The following considerations support approval of the Project:

1. The Project would provide citywide and regional economic benefits through tax revenues and project fees.

2. Considering the nature and size of the Project, a substantial amount of construction workers would likely be needed in construction of the proposed residential uses and other proposed improvements, thereby creating jobs for local residents. Additionally, building materials would likely be purchased in the area, stimulating the local economy and businesses.

3. The Project would provide additional housing opportunities in the City of Pacifica. Based on the City’s 2023-2031 Housing Element Update, the Regional Housing Needs Allocation (RHNA) for the years 2023-2031 would require 1,892 residences. The Project would contribute an additional 19 residential units to increase the City’s housing supply, which would help the City satisfy its RHNA goals, as well as the goals of the California Housing Crisis Act of 2019 (Senate Bill No. 330).

4. The Project would include the preservation of open space to the south of development area, providing wetland and open space preservation within the City.

5. The Project would provide improvements to the City-owned property, including the construction of 14 uncovered parking spaces, a drop-off area, and a new trash containment area intended for use by the Pacifica Community Center.

6. The Project would include the development of 3,165-sf of commercial space, providing for job creation and economic benefits to the local economy.

SECTION 3. Record of Proceedings
Various documents and other materials constitute the record upon which the City Council bases these findings and the approvals contained herein. The location of these

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documents and materials is: City of Pacifica Community Development Department, 1800 Francisco Boulevard, Pacifica, California 94044.

SECTION 4. Mitigation Monitoring and Reporting Program
In accordance with CEQA and the CEQA Guidelines, the City Council must adopt a mitigation monitoring and reporting program to ensure that the mitigation measures adopted herein are implemented. The City Council hereby adopts the Mitigation Monitoring and Reporting Program for the Project attached to these findings as Exhibit B. * * * * * * * *

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PASSED AND ADOPTED at a special meeting of the City Council of the City of Pacifica, California, held on the 2nd of December.

AYES, Council Members:

NOES, Council Members:

ABSENT, Council Members:

ABSTAIN, Council Members:
_____________________________
Sue Beckmeyer Mayor
ATTEST: APPROVED AS TO FORM:
______________________________ _____________________________ Sarah Coffey, Michelle Kenyon, City Attorney
City Clerk

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EXHIBIT A
“570 CRESPI RESPONSES TO COMMENTS SUPPLEMENTAL,” DATED
NOVEMBER 2025, “570 CRESPI DRIVE PROJECT FINAL ENVIRONMENTAL IMPACT REPORT,” DATED SEPTEMBER 2025, “570 CRESPI DRIVE PROJECT PARTIALLY RECIRCUALTED DRAFT EIR,’ DATED AUGUST 205, AND “570 CRESPI DRIVE PROJECT DRAFT EIR,” DATED APRIL 2025; CEQA STATE CLEARINGHOUSE NO. 2021120126.

EXHIBIT B
FINAL EIR SECTION 3: MITIGATION MONITORING AND REPORTING

PROGRAM

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570 Crespi Project
November 2025
1 INTRODUCTION
This Responses to Comments document contains comments received during the public review period.

BACKGROUND
The City of Pacifica solicited public input on the Recirculated Draft EIR on August 1, 2025.

LIST OF COMMENTERS
The City of Pacifica received one comment letter during the open comment period on the Recirculated Draft EIR for the proposed project. The comment letter was authored by the following interested persons.

Letter 1 ........................................................................... Alexandra Medoza, Green Foothils

RESPONSES TO COMMENTS
The Responses to Comments below includes a general response to each of the comments submitted.

LETTER 1
Raney Planning & Management, Inc. has reviewed the comments and none of them require any modifications to the CEQA document.

The Commenter mentioned wetland impacts citing City policy related to filling, dredge, or otherwise having activity within a wetland. The proposed project does not include any dredge of fill of the wetland area. In addition, the proposed project would not change the hydrology contributing to the wetland feature. The Commenter also mentioned potential impacts to specialstatus species, including red legged frog. Red legged frog is address in the partially recirculated chapter as well as any potentially occurring special-status species. Mitigation measures are included accordingly. Finally, they acknowledge the industry standard approach to assessing potential impacts to wildlife migration that was used in the EIR, but they request additional consideration of fragmented habitats. Because the site is already limited in the ability to support wildlife migration (Crespi Road, development on all sides of the parcels, etc.), the EIR adequately addresses this issue pursuant to CEQA requirements and changes to the analysis and conclusions are not warranted.

RESPONSES TO COMMENTS

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Brianne Harkousha, Community Development Deputy Director City of Pacifica Planning Division
1800 Francisco Boulevard, Pacifica, CA 94044
Email: [email protected]
Re: 570 Crespi Dr Project
Dear Ms. Harkousha,
Green Foothills submits the following comments for the partially recirculated Biological Resources section of the Draft Environmental Impact Report (DEIR). Green Foothills is a local nonprofit organization that works to protect local nature and farmland in San Mateo County, Santa Clara, and San Benito Counties, including the San Mateo coast since 1962.

The proposed project at 570 Crespi Dr in Pacifica plans to build one commercial condominium and 19 residential condominiums, on a newly merged 1.68 acre parcel. As described in the partially recirculated DEIR, the southern portion of the parcel has been deemed a wetland while the northern portion does not qualify. The following are comments that Green Foothills has on the biological resource section of the DEIR, but do not represent a comprehensive list:

The project conflicts with implementation and guiding policies in Pacifica's General Plan 2040.

CO-I-4: “Wetland Preservation: Prohibit new development in existing wetlands except as allowed under the federal Clean Water Act and California Coastal Act.” CO-1-5: “Limitations on Diking, Filling or Dredging: Only permit the diking, filling, or dredging of…wetlands…where there is no feasible, less environmentally damaging alternative and where feasible mitigation measures have been provided to minimize adverse environmental effects.” CO-I-7: “Maintain Functional Capacity of Wetlands: Ensure that any diking, filling, or dredging in existing wetlands maintains or enhances their functional capacity.” The above policies are just some of the guidelines in Pacifica’s General Plan that encourage wetland conservation and restoration. The project at 570 Crespi Dr directly contradicts these goals. The size and location of the buildings on the parcel would directly impact the adjacent habitat, ignoring the well known fact that promoting healthy landscapes also requires that surrounding land encourage habitat health. The city has a unique opportunity to restore a portion of the historic Lake Mathilde and provide important species habitat, for both special status species such as the California red-legged frog as well as non special status species. Additionally, as we continue to face climate change, preserving these sensitive habitats to help promote resilient cities becomes increasingly more urgent.

There should be implementation of buffer zones between the wetlands and buildings.

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Attachment: ATT A-Draft Resolution EIR+Exhibits-570 Crespi-251202 (6098 : Crespi Drive Mixed Use Project Considerations) 2 The 19 condominiums and one commercial condominium are all planned to be built on the northern portion of the site (as seen in Figure 3-3 in the Project Description chapter of the DEIR), leaving the southern portion “undisturbed.” The construction appears to lead directly up to the boundary of the emergent wetland with a wood deck and concrete pathway brushing the border. Pacifica’s LCLUP, recently approved by the California Coastal Commission in April of 2025, sets up an implementation guideline of a 100-foot buffer around environmentally sensitive habitats and wetlands, which is not to be reduced to less than 50 feet. While this location sits outside of the coastal zone, as a document that is meant to guide decisions the LCLUP gives the city a good set of baseline policies to follow throughout Pacifica.

Figure 3-13 from the Project Description provides a closeup depiction of what the boundaries will look like between the construction in the northern portion versus the wetlands in the southern part. The figure clearly depicts the wetland delineation line overlapping with Building C, and fails to incorporate an appropriate buffer in other locations of the project design. This would go against general practice that other cities take around their wetlands, and Pacifica’s own LCLUP. Buffer zones help mitigate issues around flooding that can be common when building around wetlands, something that infrastructure surrounding 570 Crespi Dr have already experienced.

Despite being isolated, this parcel presents an opportunity to provide a “stepping stone” in wildlife movement in an urbanized area.

The recirculated DEIR claims that the project would have a less than significant impact to wildlife movement since it is fragmented and isolated from other similar landscapes, also emphasizing that there are other plots around the city more conducive to being a wildlife corridor. While the definition and baseline that the DEIR uses is commonly used, this definition lacks the necessary flexibility and approach needed in more urban settings. Many times in urbanized cities it is hard or impossible to be able to physically connect two pieces of land due to various constraints, such as ownership or jurisdictional boundaries. Therefore, it is important to expand the definition of what determines a parcel’s importance in aiding wildlife movement, looking instead at a site's ability to provide an important stepping stone between fragments and helping prevent isolation of larger areas. Surrounding parks, backyards, and green spaces realistically play a key role in species movement in urbanized settings. The DEIR fails to acknowledge this nuanced definition of wildlife corridors in urban cities like Pacifica, therefore it improperly determines this impact as less than significant.

Green Foothills thanks you for taking the time to read and consider our comments.

Respectfully,
Alexandra Mendoza
Environmental Associate
Green Foothills

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Project
SCH# 2021120126
Final Environmental Impact
Report
Prepared for
City of Pacifica
September 2025
Prepared by
1501 Sports Drive, Suite A, Sacramento, CA 95834
SCH# 2021120126
Fi l E i t l I t
RANEY

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Final Environmental Impact Report
SCH# 2021120126
Lead Agency
City of Pacifica
Planning Division
1800 Francisco Boulevard
Pacifica, CA 94044
(650) 738-7341
Samantha Updegrave
Community Development Director
Brianne Harkousha
Deputy Director of Community Development
Prepared By
Raney Planning and Management, Inc.
1501 Sports Drive, Suite A
Sacramento, CA 95834
(916) 372-6100
Contact:

Rod Stinson
Vice President
Lead Agency
Prepared By
Final Environmental Impact Report

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TABLE OF

CONTENTS

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570 Crespi Drive Project
September 2025
Table of Contents
Page i

CHAPTER PAGE

1. Introduction and List of Commenters.................................... 1-1

1.1 Introduction .................................................................................................1-1

1.2 Background.................................................................................................1-1

1.3 Purpose of the Final EIR .............................................................................1-2

1.4 List of Commenters.....................................................................................1-2

1.5 Organization of the Final EIR ......................................................................1-3

2. Responses to Comments ....................................................... 2-1

2.1 Introduction .................................................................................................2-1

2.2 Responses to Comments ............................................................................2-1

3. Mitigation Monitoring and Reporting Program....................... 3-1

3.1 Introduction .................................................................................................3-1

3.2 Compliance Checklist..................................................................................3-1

3.3 Mitigation Monitoring and Reporting Program .............................................3-2

TABLE OF CONTENTS
IL

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1. INTRODUCTION AND LIST OF

COMMENTERS

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September 2025
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Chapter 1 – Introduction and List of Commenters

1.1 INTRODUCTION
This Final Environmental Impact Report (EIR) contains comments received during the public review period of the 570 Crespi Drive Project (proposed project) Draft EIR and Partially Recirculated Draft EIR. This document has been prepared by the City of Pacifica, as Lead Agency, in accordance with the California Environmental Quality Act (CEQA) and the CEQA Guidelines, Section 15132. The Introduction and List of Commenters chapter of the Final EIR discusses the background of the Draft EIR and Partially Recirculated Draft EIR, purpose of the Final EIR, identifies the comment letters received on the Draft EIR and Partially Recirculated Draft EIR, and provides an overview of the organization of the Final EIR.

1.2 BACKGROUND
The Draft EIR identified the proposed project’s potential impacts and the mitigation measures that would be required to be implemented. The proposed project Draft EIR includes the following environmental analysis chapters: Biological Resources; Greenhouse Gas Emissions; and Transportation.

In accordance with CEQA, the City of Pacifica used the following methods to solicit public input on the Draft EIR:
x A Notice of Preparation (NOP) for the Draft EIR was released for a 30-day public review period from October 4, 2024 to November 4, 2024. The NOP comment letters are included as Appendix B to the Draft EIR.
x A public scoping meeting was held via Zoom on October 22, 2024 to solicit comments regarding the scope of the Draft EIR.
x On April 11, 2025, the Draft EIR was submitted to the State Clearinghouse for distribution to State agencies, resulting in a 70-day public review period from April 11, 2025 to June 20, 2025.
x On April 11, 2025, a Notice of Availability (NOA) of the Draft EIR was posted to the City’s website.
x The Draft EIR was made available for review on the City website at https://www.cityofpacifica.org/departments/community-development/planningdivision/environmental-documents.

All public comments received on the Draft EIR are listed in this chapter, and written responses to comments are included in Chapter 2, Response to Comments, as discussed in more detail in Section 1.4 of this chapter.

Based on comments received regarding the Draft EIR, the City determined that revisions to Chapter 4.1, Biological Resources, of the Draft EIR, were necessary and that recirculation was required to comply with CEQA Guidelines Section 15088.5. Revisions to Chapter 4.1 included a change to conclusions and the addition of new mitigation measures, and, thus, met the criteria for CEQA Guidelines Section 15088.5. A Notice of Availability (NOA) of the Partially Recirculated

1. INTRODUCTION AND LIST OF

COMMENTERS

1. F
IL

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Chapter 1 – Introduction and List of Commenters

Draft EIR was distributed and the Partially Recirculated Draft EIR was sent to the State Clearinghouse for distribution on August 1, 2025 for a 45-day review period, consistent with the time periods set forth in the CEQA Guidelines.

This Final EIR acknowledges and incorporates the revisions made as part of the Partially Recirculated Draft EIR. No public comments were received during the 45-day review period for the Partially Recirculated Draft EIR. Where applicable, the Responses to Comments presented in this Final EIR refer the reader to revisions made as part of the Partially Recirculated Draft EIR.

1.3 PURPOSE OF THE FINAL EIR
Pursuant to CEQA Guidelines Section 15132, this Final EIR consists of the following:

1. A list of public agencies commenting on the Draft EIR and Partially Recirculated Draft EIR (included as Section 1.4 of this chapter);

2. Comments received on the Draft EIR and Partially Recirculated Draft EIR (Chapter 2 of this Final EIR);

3. Mitigation Monitoring and Reporting Program (Chapter 3 of this Final EIR); and

4. Any other information added by the Lead Agency.

As required by CEQA Guidelines, Section 15090(a)(1)-(3), a Lead Agency must make the following three determinations in certifying a Final EIR:

1. The Final EIR has been completed in compliance with CEQA.

2. The Final EIR was presented to the decision-making body of the Lead Agency, and the decision-making body reviewed and considered the information in the Final EIR prior to approving the project.

3. The Final EIR reflects the Lead Agency’s independent judgment and analysis.

Under CEQA Guidelines Section 15091, a public agency shall not approve or carry out a project for which an EIR has been certified that identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings (Findings of Fact) for each of those significant effects. Findings of Fact must be accompanied by a brief explanation of the rationale for each finding supported by substantial evidence in the record. The Findings of Fact are included in a separate document that will be considered for adoption by the City’s decision-makers.

Pursuant to CEQA Guidelines, Section 15093(b), when a Lead Agency approves a project that would result in significant and unavoidable impacts, the agency must state in writing the reasons supporting the action (Statement of Overriding Considerations). The Statement of Overriding Considerations shall be supported by substantial evidence, and are subject to adoption by the City’s decision-makers along with the Findings of Fact. The proposed project would result in a significant and unavoidable impact with respect to a conflict or inconsistency with CEQA Guidelines Section 15064.3, subdivision (b) (Impact 4.3-3) related to vehicle miles traveled (VMT). Thus, a Statement of Overriding Considerations must be adopted if the project is approved, which would be included in a separate document that will be considered for adoption by the City’s decision-makers.

1.4 LIST OF COMMENTERS
The City of Pacifica received two comment letters during the public comment period on the Draft EIR for the proposed project. Additional comment letters were not received during the public IL

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comment period on the Partially Recirculated Draft EIR. The comment letters were authored by the following agencies.

Agencies
Letter 1...............................................California Department of Fish and Wildlife – Erin Chappell Letter 2................................................ California Department of Transportation – Yunsheng Luo

1.5 ORGANIZATION OF THE FINAL EIR
The Final EIR is organized into the following three chapters:

1. Introduction and List of Commenters
Chapter 1 provides an introduction and overview of the document, describing the background and organization of the Final EIR. Chapter 1 also provides a list of commenters who submitted letters in response to the Draft EIR.

2. Responses to Comments
Chapter 2 presents the comment letters received and responses to each comment. Each comment letter received has been numbered at the top and bracketed to indicate how the letter has been divided into individual comments. Each comment is given a number with the letter number appearing first, followed by the comment number. For example, the first comment in Letter 1 would have the following format: 1-1.

3. Mitigation Monitoring and Reporting Program
CEQA Guidelines, Section 15097, requires lead agencies to adopt a program for monitoring the mitigation measures required to avoid the significant environmental impacts of a project. The intent of the Mitigation Monitoring and Reporting Program is to ensure implementation of the mitigation measures identified within the EIR for the proposed project.

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2. RESPONSES TO COMMENTS

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2.1 INTRODUCTION
The Responses to Comments chapter contains responses to the comment letters submitted by agencies and interested persons regarding 570 Crespi Drive Project (proposed project) Draft EIR during the public review period (April 11, 2025, to June 20, 2025). The EIR was revised and partially recirculated from August 1, 2025, to September 15, 2025 in response to one of the comment letters (Partially Recirculated Draft EIR). No additional comments were received.

2.2 RESPONSES TO COMMENTS
The following two letters were received by the City during the Draft EIR public comment period.

Additional comment letters were not received during the Partially Recirculated Draft EIR public review period. Each bracketed comment letter is followed by numbered responses to each bracketed comment. The responses amplify or clarify information provided in the Draft EIR and/or refer the reader to the appropriate place in the document where the requested information can be found. Comments that are not directly related to environmental issues (e.g., opinions on the merits of the project that are unrelated to its environmental impacts) are noted for the record, as appropriate.

In accordance with CEQA Guidelines, Section 15088.5, additional recirculation of the EIR is not required. Each letter has been considered by the City and addressed, according to CEQA Guidelines Section 15088, prior to approval of this Final EIR.

2. RESPONSES TO COMMENTS
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Letter 1
1-1
Docusign Envelope ID: 9A40181 E-D902-40C8-B479-0A376A99FB05 IL
State of California - Natural Resources Agency

DEPARTMENT OF FISH AND WILDLIFE
Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www w ildlife. ca. gov
May 20, 2025
GAVIN NEWSOM. Governor
CHARLTON H. BONHAM, Director
Brianne Harkousha, Community Development Deputy Director City of Pacifica
1800 Francisco Boulevard
Pacifica, CA, 94044
BHa [email protected]
Subject: 570 Crespi Drive Project, Draft Environmental Impact Report, SCH No. 2021120126, City of Pacifica, San Mateo County
Dear Brianne Harkousha:

The California Department of Fish and Wildlife (CDFVV) received a Notice of Availability of a Draft Environmental Impact Report (EIR) from the City of Pacifica (City) for the 570 Crespi Drive Project (Project) pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.1 CDFW previously submitted comments in response to the Notice of Preparation of the draft El R.

Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife.

Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW ROLE
CDFW is California's Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State. (Fish & G. Code , §§ 711 . 7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines§ 15386, subd. (a).) CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species. (Id., § 1802.) Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA. (Pub.

Resources Code, § 21069; CEQA Guidelines, § 15381.) CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code. As 1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The "CEQA Guidelines" are found in Title 14 of the California Code of Regulations, commencing with section 15000.

Conserving Ca[ifornia's Wiul[ife Since 1870

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Docusign Envelope ID: 9A40181 E-D902-40C8-B479-0A376A99FB05 IL
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May 20, 2025

proposed, for example, the Project may be subject to CDFW's Lake and Streambed Alteration (LSA) regulatory authority. (Fish & G. Code,§ 1600 et seq.) Likewise, to the extent implementation of the Project as proposed may result in "take" as defined by State law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code,§ 2050 et seq .), the project proponent may seek related take authorization as provided by the Fish and Game Code .

California Endangered Species Act and Native Plant Protection Act Please be advised that a CESA Incidental Take Permit (ITP) must be obtained if the Project has the potential to result in "take" of plants or animals listed under CESA or Native Plant Protection Act (NPPA), either during construction or over the life of the Project. Under CESA, take is defined as "to hunt, pursue, catch , capture, or kill , or attempt to hunt, pursue , catch, capture or kill." Issuance of an ITP is subject to CEQA documentation. If the Project will impact CESA or NPPA listed species, early consultation with CDFW is encouraged, as significant modification to the Project and mitigation measures may be required to obtain an ITP. Issuance of an ITP is subject to CEQA documentation; the CEQA document must specify impacts, mitigation measures, and a mitigation monitoring and reporting program . Fully protected species may not be taken or possessed at any time (Fish and Game Code, §§ 3511, 4700, 5050, and 5515).

CEQA requires a Mandatory Finding of Significance if a Project is likely to substantially impact threatened or endangered species (Pub. Resources Code, §§ 21001 (c), 21083, and CEQA Guidelines§§ 15380, 15064, 15065). Impacts must be avoided or mitigated to less-than-significant levels unless the CEQA Lead Agency makes and supports Findings of Overriding Consideration (FOC). The CEQA Lead Agency's FOC does not eliminate the Project proponent's obligation to comply with Fish and Game Code, § 2080 et. seq .

Lake and Streambed Alteration
CDFW requires an LSA Notification, pursuant to Fish and Game Code section 1600 et seq ., for project activities affecting lakes or streams and associated riparian habitat.

Notification is required for any activity that may substantially divert or obstruct the natural flow; change or use material from the bed, channel, or bank (including associated riparian or wetland resources); or deposit or dispose of material where it may pass into a river, lake, or stream. Work within ephemeral streams, drainage ditches, washes, watercourses with a subsurface flow, and floodplains are generally subject to notification requirements. In addition, infrastructure installed beneath such aquatic features, such as through hydraulic directional drilling , is also generally subject to notification requirements. Any impacts to the mainstems, tributaries and floodplains or associated riparian habitat would likely require an LSA Notification. CDFW, as a

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responsible agency under CEQA, will consider the EIR for the Project. CDFW may not execute a final LSA Agreement until it has complied with CEQA as the responsible agency.

Raptors and Other Nesting Birds
CDFW has authority over actions that may result in the disturbance or destruction of active nest sites or the unauthorized take of birds. Fish and Game Code sections protecting birds, their eggs, and nests include§§ 3503 (regarding unlawful take , possession or needless destruction of the nests or eggs of any bird), 3503.5 (regarding the take , possession or destruction of any birds-of-prey or their nests or eggs), and 3513 (regarding unlawful take of any migratory nongame bird). Migratory birds are also protected under the federal Migratory Bird Treaty Act (MBTA).

Fully Protected Species
Fully protected species, such as San Francisco garter snake (Thamnophis sirtalis tetrataenia) may not be taken or possessed at any time and no licenses or permits may be issued for their take except as follows:
• Take is for necessary scientific research ;
• Efforts to recover a fully protected, endangered, or threatened species, live capture and relocation of a bird species for the protection of livestock; or • They are a covered species whose conservation and management is provided for in a Natural Community Conservation Plan (Fish & G. Code, §§ 3511, 4700, 5050, & 5515).

Specified types of infrastructure projects may be eligible for an ITP for unavoidable impacts to fully protected species if certain conditions are met (Fish & G. Code , §2081 .15). Project proponents should consult with CDFW early in the Project planning process.

PROJECT DESCRIPTION SUMMARY
Proponent: City of Pacifica
Objective: The objective of the Project is to develop one two-story mixed-use building and two three-story residential buildings on the parcel at 570 Crespi Drive . The Project would include a condominium subdivision to create one commercial condominium and 19 residential condominiums. In addition , the Project would involve off-site activities, including removal of two trees, and construction of a new driveway and associated parking spaces within the northern portion of the existing Pacifica Community Center.

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1-2
Docusign Envelope ID: 9A40181 E-D902-40C8-B479-0A376A99FB05 IL
Brianne Harkousha
City of Pacifica
May 20, 2025

Location: 570 Crespi Drive, Pacifica , CA, 94044; San Mateo County; Latitude

37.598391 , Longitude -122.498785.

Timeframe: To be determined

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the Project's significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.

I. Project Description and Related Impact Shortcoming
Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by CDFW or U.S. Fish and Wildlife (USFWS)? COMMENT 1: Riparian Setbacks
Section 4.1-4
Issue: The Biological Constraints Analysis (in Appendix C of the draft EIR) prepared by Wood Biological Consulting in 2020 for the Project identifies the vegetative communities present in the Project area, and states that "willow scrub, dominated by arroyo willow (Salix lasiolepis), covers the majority of the southern portion of the study area on both parcels. It also occurs in smaller stands along the western and eastern parcel boundaries.". The draft EIR states that "the proposed project would remove or prune an estimated 784 square feet of arroyo willow scrub to meet parking and walkway requirements at the southern edge of the proposed Building B ," and that, additionally, "the proposed project could potentially disturb and , possibly, fill, up to 0.87-acre of jurisdictional wetlands and/or remove potential riparian vegetation."
CDFW is unable to determine the extent of potentially significant Project impacts to riparian and associated wetlands within and adjacent to the Project area because it is unclear if riparian vegetation will be pruned or if it must be removed and if wetland will be temporarily disturbed or permanently filled. Further, Mitigation Measure 4.1- 4(a) is proposed to offset potentially significant impacts to riparian habitat and other sensitive natural communities due to Project activities, and development of specific mitigation actions is contingent on the Project notifying CDFW pursuant to Fish and Game Code section 1600.

Mitigation Measure 4.1-4(a) of the draft EIR effectively defers formulation of mitigation measures that would offset potentially significant temporary and

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permanent impacts to riparian habitat until "some future time" (when the project applicant notifies CDFW pursuant to Fish and G. Code section 1600). Given that the Project EIR describes the riparian and wetland is not associated with any river, lake or stream, Project activities may not be subject to Fish and Game Code section 1600. CEQA Guidelines section 15126.4(a)(1 )(B) identifies compliance with a regulatory permit or other similar process may be identified as mitigation if compliance would result in implementation of measures that would be reasonably expected, based on substantial evidence in the record , to reduce the significant impact to the specified performance standards. However, the development of a complete set of mitigation measures sufficient to reduce potentially significant impacts on riparian and/or wetland habitat to less-than-significant levels, under proposed Mitigation Measure 4.1-4(a), would be deferred to a future time that may or may not occur, and may not be subject to CDFW review and comment.

Specific impact, why impact would occur, and evidence impact would be significant: Arroyo willow is part of the Red Willow Riparian Woodland and Forest Alliance , a natural community with a State Ranking of S3- Vulnerable . Red Willow Riparian Woodland and Forest Alliance, with a State Ranking of S3, is a Sensitive Natural Community "at moderate risk of extinction or collapse due to a fairly restricted range , relatively few populations or occurrences, recent and widespread declines, threats, or other factors" (CDFW Sensitive Natural Communities, https://wi Id life .ca .gov /Data/Veg CAMP /Natura ICo mm unities#natura I%20commu n ities%20Iists). Continued loss of this riparian habitat from Project encroachment is damaging to the watershed's biotic and abiotic integrity.

Riparian vegetation, and associated floodplains, provide many essential benefits to stream and aquatic species habitat (Moyle 2002, CDFW 2007). Development within or adjacent to riparian zones can result in fragmentation of riparian habitat and decreases in native species abundance and biodiversity (Davies et al. 2001, CDFW 2007). Riparian buffers help keep pollutants from entering adjacent waters, benefiting species who rely on those waters for habitat and drinking water. Narrow riparian buffers are considerably less effective in minimizing the effects of adjacent development than wider buffers (Caste lie et al. 1992, Brosofske et al. 1997, Dong et al. 1998, Kiffney et al. 2003, Moore et al. 2005).

Riparian habitats also contribute to bank stability and provide flood protection.

Development can modify natural streamflow patterns by increasing the magnitude and frequency of high flow events and storm flows. Riparian habitat and adjacent wetlands and floodplains are critical to lessening these impacts because they store and meter floodwaters, recharge groundwater aquifers, trap sediment, filter pollution, help minimize erosion, lessen peak flow velocities, and protect against storm surges.

In doing so, they protect adjacent upland, down-stream, and coastal properties from

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loss and damage during flooding and help maintain surface and groundwater during summer months.

Recommendation 1: CDFW recommends the Project avoid, to the greatest extent feasible, all temporary and permanent impacts to arroyo willow, Red Willow Riparian Woodland and associated wetlands or forest and establish protective riparian and wetland buffer zones to limit development and vegetation clearing to outside of and away from riparian and wetland areas. Where impacts to riparian and wetland habitat cannot be avoided, the draft EIR should provide sufficient information to demonstrate if impacts to riparian and/or wetlands will be significant. Supporting details should be included showing which impacts will be temporary or permanent, the extent of Project pruning and/or tree removal , and further explain disturbances and/or filling to riparian and wetland habitats.

To address Project activities that cannot avoid impacts to riparian vegetation and wetlands, CDFW recommends that the draft El R include a plan detailing any proposed on- and/or off-site mitigation needs necessary to compensate for net-loss of riparian and/or wetland resources. Examples of permanent impacts include but are not limited to loss of riparian vegetation and mature trees and expansion of infrastructure footprints. CDFW recommends the proposed mitigation plan include details such as mitigation location(s), proposed actions, monitoring, success criteria, and any corrective actions. Further, CDFW recommends the Project not rely on "enhancement" mitigation alone for permanent impacts to riparian and/or wetland habitat. Alternative options may include compensatory mitigation in the form of permanent protection of riparian resources and/or creation of riparian habitat along streams such as streamside riparian revegetation and pavement removal.

COMMENT 2: Nesting Birds
Issue: Nesting birds, including saltmarsh common yellowthroat (Geothlypis trichas sinuosa), a State special-status species, have the potential to nest on the ground, in trees, on structures, or in vegetation within and immediately adjacent to the Project site . The avoidance, minimization and mitigation measures included in the draft EIR to protect special-status and nesting birds are not sufficient to reduce potential impacts to less-than-significant levels. Specifically, Mitigation Measure 4.1-2 incorrectly identifies the nesting bird period for owl and raptor species and does not implement sufficiently sized nest buffers.

Specific impact, why the impact would occur, and evidence the impact would be significant: The federal MBTA and Fish and Game Code protect migratory and nesting birds, including special-status species with potential to occur in the Project area (e.g., San Francisco common yellow throat). The nesting seasons for passerines, owls, and raptors range from February 15- August 30, January 15-

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D Letter 1 cont. ocusign Envelope ID: 9A40181 E-D902-40C8-B479-0A376A99FB05 IL
Brianne Harkousha
City of Pacifica
May 20, 2025

September 15, and February 15- September 15, respectively. The nesting season described in the draft EIR is not inclusive of early-season owl breeding or lateseason raptor breeding.

No-disturbance buffers for any bird nests identified in pre-construction surveys should be of sufficient, species-specific size to protect young birds until they have fledged and are foraging independently. Buffers for passerines, accipiters, and buteos should be a minimum of 250 feet, 500 feet, and 1,000 feet, respectively. The no-disturbance buffers proposed in the draft El R nesting bird measure are not adequately sized to protect passerines or raptors, which require larger nodisturbance buffers than proposed .

If construction commences during the nesting season without sufficiently sized nest buffers in place, or if construction activities occur without a qualified biologist having performed appropriately timed breeding bird surveys, nesting birds may be impacted directly through the removal of nest structures, or indirectly through localized disturbance sufficient to cause nest abandonment, a potentially significant impact under CEQA.

Recommendation 2: CDFW recommends incorporating the mitigation measure below to reduce potential impacts to nesting birds to less-than-significant levels:

Recommended Nesting Bird Mitigation Measure: If project grading or construction is scheduled to take place between January 15 - September 15, a preconstruction survey of the project vicinity for nesting birds shall be conducted by a qualified biologist experienced with the nesting behavior of bird species of the region . The survey shall determine if active nests are present within the planned area of disturbance or within 250 feet for passerines, 500 feet for accipiters and 1,000 feet for buteos. The survey shall be performed no more than 7 days prior to the commencement of construction activities, and a second focused survey shall be conducted within 48 hours prior to construction activities that would occur during the nesting/breeding season. If ground disturbance activities are delayed following a survey , then an additional preconstruction survey shall be conducted such that no more than two weeks will have elapsed between the last survey and the commencement of ground disturbance activities.

If a lapse of Project-related activities of seven days or longer occurs, another focused survey will be conducted before Project activities can be reinitiated.

If an active bird nest is found within the survey radii, species-specific measures shall be prepared by a qualified biologist and implemented to prevent abandonment of the active nest. A protective buffer distance shall be established by a qualified biologist based on the site conditions such as whether the nest is in a line of sight of the construction and the sensitivity of the birds nesting . Typical

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D Letter 1 cont. ocusign Envelope ID: 9A40181 E-D902-40C8-B479-0A376A99FB05 IL
Brianne Harkousha
City of Pacifica
May 20, 2025

protective buffers are as follows: 1) 250 feet for passerines, 2) 500 feet for accipiters, and 3) 1,000 feet for buteos. No Project personnel or equipment shall be allowed to enter the protective buffer until the qualified biologist determines that the young have fully fledged and will no longer be adversely affected by the Project.

The qualified biologist shall observe any identified active nests prior to the start of any construction-related activities to establish a behavioral baseline of the adults and any nestlings, and the nest site(s) shall be monitored by the biologist periodically to see if the birds are stressed by the construction activities and if the protective buffer needs to be increased. The perimeter of the nest setback zone shall be fenced or adequately demarcated with stakes and flagging at 20-foot intervals, and construction personnel and activities restricted from the area . A survey report by the qualified biologist verifying that no active nests are present, or that the young have fledged, shall be submitted prior to initiation of grading in the nest-setback zone. The qualified biologist shall serve as a biological monitor during those periods when construction activities occur near active nest areas to ensure that no inadvertent impacts on these nests occur. All buffers shall be shown on all sets of construction drawings.

COMMENT 3: Bats
Issue: The Biological Constraints Analysis (Appendix C) prepared by Wood Biological Consulting in 2020 for the Project identified populations of big free-tailed bat (Nyctinomops macrotis), fringed myotis (Myotis thysanodes), hoary bat (Lasiurus cinereus), and Townsend 's big-eared bat (Corynorhinus townsendi1) within five miles of the Project area . Project activities could directly or indirectly impact roosting bats during vegetation removal, ground disturbance, or other noise generating activities, a potentially significant impact under CEQA. The draft EIR does not include measures to avoid, minimize, and mitigate impacts to roosting bats.

Specific impact, why the impact would occur, and evidence the impact would be significant: The big free-tailed bat, fringed myotis, hoary bat and Townsend 's big-eared bat are California Species of Special Concern.

Bats play an important role in Bay Area ecosystems, through pest control, pollination and seed dispersal. Recent studies estimate that bat consumption of insect pests results in more than $3 billion in agricultural production savings per year in the U.S. (USFWS 2025). Bats are known to roost under bridges, in caves and mines, on buildings, in cliff crevices, in tree foliage, bark, and hollows, and in riprap, with habitat use varying temporally and seasonally. Suitability of bat roosting habitat is dependent on temperature, protection from predators and inclement weather, and proximity to foraging sites. Habitat reduction and disruption of hibernation and

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Docusign Envelope ID: 9A40181 E-D902-40C8-B479-0A376A99FB05 Brianne Harkousha
City of Pacifica
May 20, 2025

maternity roosts due to human development and activity have contributed to steep population declines in California and across the globe. Many bat species are long lived , with most females birthing only one to two young per year. Due to low reproductive rates and sensitivity of breeding females to disruption, maternity colonies affected by human activities that temporarily reduce fecundity, or mortality may require multiple years to recover following disturbance events (Caltrans 2019). ----
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Recommendation 3: CDFW recommends including the following mitigation measure to reduce potentially significant impacts on bats to a less-than-significant level:

Recommended Bat Mitigation Measure: Pre-construction surveys for specialstatus and non-listed bat species shall be performed by a qualified biologist if any trees are to be removed or underutilized or vacant buildings are to be demolished , or if any suitable habitat including buildings, trees, rock outcrops, bridges, or culverts are present within 100 feet of proposed construction. If any active maternity or hibernation roosts are identified within 100 feet of areas proposed for development, an agency-approved qualified biologist shall establish site-specific protective buffers around roosts, sized with consideration for the species that are present and the time of year bats are roosting , as well as levels of construction noise and light emission from Project activities.

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly, please report any special-status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB).The CNDDB field survey form can be filled out and submitted online at the following link: https://wildlife .ca.gov/Data/CNDDB/Submitting-Data . The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

ENVIRONMENTAL DOCUMENT FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying project approval to be operative, vested , and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.)

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CONCLUSION
CDFW appreciates the opportunity to comment on the draft EIR to assist the City in identifying and mitigating Project impacts on biological resources.

Questions regarding this letter or further coordination should be directed to Shannon Husband, Environmental Scientist, at (707) 337-1364 or Shannon.Husband@wildlife .ca.gov; or Wesley Stokes, Senior Environmental Scientist (Supervisory), at [email protected] .qov.

Sincerely,
re::;;~
~w~~'p'pin
Regional Manager
Bay Delta Region
ec: Office of Planning and Research, State Clearinghouse, Sacramento Craig Weightman, CDFW Bay Delta Region - [email protected]

REFERENCES
Brosofske, K.D. , J. Chen, R.J. Naiman, and J.F. Franklin. 1997. Harvesting effects on microclimatic gradients from small streams to uplands in western Washington.

Ecological Applications 7:1188-1200.

California Department of Transportation. 2019. Caltrans Bat Mitigation: A Guide to Developing Feasible and Effective Solutions.

Castelle , A.J ., C. Conolly, M. Emers, E.D. Metz, S. Meyer, M. Witter, S. Mauermann , T.

Erickson , and S.S. Cooke . 1992. Wetlands buffers use and effectiveness.

Adolfson Associates, Inc., Shorelands and Coastal Zone Management Program, Washington Department of Ecology, Olympia, WA. Pub. No. 92-10.

CDFW. 2007. California wildlife: conservation challenges. California Department of Fish and Game , Sacramento, CA.

Davies, K.F., C. Gascon, and C.R. Margules. 2001 . Habitat fragmentation :
consequences, management, and future research priorities. Pages 81-97 in:

M.E. Soule and G. H. Orians, (eds.) Conservation Biology: Research Priorities for the Next Decade. Island Press, Washington, DC.

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LETTER 1: ERIN CHAPPELL, CALIFORNIA DEPARTMENT OF FISH AND

WILDLIFE
Response to Comment 1-1
The comment presents background information on the role of the California Department of Fish and Wildlife (CDFW) and the project components, and does not address the adequacy of the EIR.

The comment has been noted for the record and will be forwarded to the decision-makers for their consideration.

Response to Comment 1-2
As shown in Chapter 4.1, Biological Resources, of the Partially Recirculated Draft EIR, Mitigation Measure 4.1-4(a) establishes specific timing and standards related to riparian and wetland habitat. If, at the time that project construction occurs, the project is not subject to California Fish and Game Code (CFGC) Section 1600, “further mitigation beyond the proposed mitigation included in the notice to CDFW regarding the aforementioned vegetation communities shall not be required.” Mitigation Measure 4.1-4(a) allows for the specific details requested in the comment to be included in the project’s notification to CDFW, which is required to occur prior to the commencement of ground-disturbing activities. Such timing is intended to accommodate and account for any potential delays in the project and/or changes in on-site riparian conditions.

Response to Comment 1-3
The comments and recommendations related to nesting birds have been addressed within Chapter 4.1, Biological Resources, of the Partially Recirculated Draft EIR.

Response to Comment 1-4
The information provided in the comment was incorporated into Impact 4.1-3 within Chapter 4.1, Biological Resources, of the Partially Recirculated Draft EIR.

Response to Comment 1-5
The recommendation included in the comment was incorporated into Mitigation Measure 4.1-3(b) within Chapter 4.1, Biological Resources, of the Partially Recirculated Draft EIR.

Response to Comment 1-6
The comment presents background information on CDFW’s processes related to environmental documents and does not address the adequacy of the EIR. The comment has been noted for the record and will be forwarded to the decision-makers for their consideration, as well as the project applicant and City staff.

Response to Comment 1-7
The comment is conclusionary and does not address the adequacy of the EIR. The comment has been noted for the record and will be forwarded to the decision-makers for their consideration.

IL

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Letter 2
2-1
2-2
IL

CALIFORNIA STATE TRANSPORTATION AGENCY
California Department of Transportation
DISTRICT 4

OFFICE OF REGIONAL AND COMMUNITY PLANNING
P.O . BOX 23660, MS-1 OD I OAKLAND, CA 94623-0660
www.dot.ca.gov
May 22, 2025
Brianne Harkousha, Community Development Director
City of Pacifica
1800 Fro ncisco Blvd
Pacifica, CA 94044

GAVIN NEWSOM, GOVERNOR
SCH#: 2021120126
GTS #: 04-SM-2021-00672
GTS ID: 24973
Co/Rt/Pm: SM/1 /41.25
Re: 570 Crespi Drive Project - Draft Environmental Impact Report (DEIR) Dear Brianne Harkousha:

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the 570 Crespi Drive Project. The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities. The following comments are based on our review of the April 2025 DEIR.

Please note this correspondence does not indicate an official position or approval by Caltrans on this project and is for informational purposes only.

Project Understanding
The proposed project would develop one two-story mixed-use building and two threestory residential buildings to construct one commercial condominium and 19 residential condominiums on a 1.68-acre parcel. Proposed off-site improvements for the project include tree removal and construction of a new driveway and associated parking spaces at the northern portion of the existing adjacent Pacific Community Center, directly adjacent to a state-owned parking lot that is within Caltrans right-ofway (ROW). Some of the proposed modifications for the off-site improvements will require a Caltrans-issued encroachment permit. The project site itself is also within 500 feet of State Route (SR) 1.

Travel Demand Analysis
The project vehicle miles traveled (VMT) analysis and significance determination were undertaken in a manner consistent with the Office of Land Use and Climate Innovation's (LCI) Technical Advisory. The commercial and residential components of "Provide a safe and reliable transportation network that serves all people and respects the environment."

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Letter 2 cont.
2-2 cont.
2-3
2-4
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Brianne Harkousha, Community Development Director
May 22, 2025

the proposed project were evaluated separately. Per the DEIR, VMT impacts for the commercial component of the proposed project was determined to be less than significant while VMT impacts for the residential component were found to be significant and unavoidable. Proposed mitigation measures include the integration of affordable and below market rate housing, implementation of a subsidized or discounted transit program, and providing improvements to the pedestrian network.

The proposed mitigation measures should be documented with annual monitoring reports to demonstrate effectiveness.

Please also consider the following measures to further mitigate the project' s residential VMT impact:
• Provide secure bike parking,
• Provide traffic calming measures,
• Implement a shared vehicle program (car/bike/E-bike/scooter) .

Please additionally note that the City/County Association of Governments of San Mateo County (C/CAG) recently published its Final Report for the VMT /Greenhouse Gas (GHG) Model Mitigation Program (link) . The VMT/GHG Model Mitigation Program was awarded through Caltrans' Sustainable Transportation Planning Grant Program and intends to assist project sponsors and developers in identifying feasible options for mitigating VMT and GHG emission impacts of land use and VMT-inducing transportation projects in the County. The City is encouraged to collaborate with Caltrans and C/CAG to explore more citywide or regional VMT mitigation options w here feasible.

Hydrology
Please ensure that any increase in storm water runoff to State Drainage Systems or Facilities be treated, contained on project site, and metered to preconstruction levels.

Any floodplain impacts must be documented and mitigated.

The off-site improvements adjacent to the Pacifica Community Center will convert the existing landscaped area into a paved parking lot. The increased runoff from this paved area is expected to flow into the state-owned parking lot. During the Encroachment Permit application stage, please provide drainage plan and hydrologic calculations showing pre-and post-construction conditions for the off-site improvements.

Climate Change/Sea Level Rise
The proposed project is located near a high-priority segment of SR 1 identified in the 2020 Caltrans District 4 Adaptation Priorities Report (link) . Please ensure that Caltrans remains informed about the various climate stressors affecting the project location, and the ongoing development and implementation of adaptation and resilience "Provide a safe and re liable transportati on network tha t serves all people and respects the environment."

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Letter 2 cont.
2-4 cont.

IL
Brianne Harkousha, Community Development Director
May 22, 2025

initiatives. Caltrans is particularly interested in the efforts to enhance coastal resilience along its shoreline. The image below illustrates how a combination of storm surge and l .75 meter of sea level rise (SLR) will affect SR l at the intersection with Crespi Drive.

Given the proximity of the project location to vulnerable sections of SR l, please consider climate impacts such as SLR and storm surge that will affect the project and its surrounding location.

All Layers ~ x
► 0 Storm Surge plus 0.5 m (1.64 ft) SH-level Rise •••
► 0 Storm Surge plus 1 m (3.28 ft) Sea-Level Rise •••
•r.l StormSurgeplus1.75m(5.75ft)Sea-levelR1se •••
► 0 2025 Wildfire - Exposed Roadway
► 0 Level of Conatrn for Wildfires - 2025
► 0 2055 Wildfire - Exposed Roadway
► 0 level of Concern for Wildfires - 2055
► 0 2085 Wildfire - Exposed Roaidway
► 0 level of Concern for Wildfires - 2085
► 0 Average Mm1mum Temperature• 2025
► 0 Averilge Mirnmum Tempel'ilture . 2055
' ► 0 Average Minimum Temperature - 2085
l ► 0 Average 7-day Maximum Temperature • 2025
Source : Caltrans Cirnate Cha nge Vu nera bility Assessment Ma p Rising groundwater levels could be a concern, as coastal groundwater may increase in response to rising sea levels. Shallow groundwater can float on the underlying seawater, exacerbating this issue.

Given these considerations, please keep Caltrans District 4 updated on any ongoing construction efforts, especially those related to drainage improvements. For inquiries or concerns within District 4's geographical boundaries, please contact the Caltrans Bay Area Climate Change Planning Coordinator at [email protected].

Construction-Related Impacts
Project work that requires movement of oversized or excessive load vehicles on State roadways requires a transportation permit that is issued by Caltrans. To apply, please visit Caltrans Transportation Permits (link).
"Provide a safe and re liable transpo rtati on network that serves all people and respects the environment."

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Letter 2 cont.
2-4 cont.
2-5
2-6
IL
Brianne Harkousha, Community Development Director
May 22, 2025

Prior to construction, coordination may be required with Caltrans to develop a Transportation Management Plan (TMP) to reduce construction traffic impacts to the State Transportation Network (STN).

Lead Agency
As the Lead Agency, the County is responsible for all project mitigation, including any needed improvements to the STN. The project's fair share contribution, financing, scheduling, implementation responsibilities and lead agency monitoring should be fully discussed for all proposed mitigation measures.

Equitable Access
A reminder that if any Caltrans facilities are impacted by the project, those facilities must meet Americans with Disabilities Act (ADA) Standards after project completion.

As well, the project must maintain bicycle and pedestrian access during construction.

These access considerations support Caltrans' equity mission to provide a safe, sustainable, and equitable transportation network for all users.

Encroachment Permit
Please be advised that any temporary or permanent work including traffic control that encroaches in, under, or over any portion of the State highway ROW requires a Caltrans-issued encroachment permit.

The Office of Encroachment Permits requires l 00% complete design plans and supporting documents to review and circulate the permit application package. The review and approval of encroachment projects is managed through the Encroachment Permits Office Process (EPOP) or the Project Delivery Quality Management Assessment Process (QMAP), depending on project scope, complexity, and completeness of the application. Please use the following resources to determine the appropriate review process:
- TR-0416 Applicant's Checklist (link)
- Caltrans Encroachment Projects Processes - Information Video (link) - Flowchart, Figure 1.2 in Section l 08, Overview of the Encroachment Review Process, of Chapter l 00- The Permit Function, Caltrans Encroachment Permit Manual (link)
The permit approval typically takes less than 60 days, but may take longer depending on the project scope, size, complexity, completeness, compliance with applicable laws, standards, policies, and quality of the permit package submitted. Projects requiring exceptions to design standards, exceptions to encroachment policies, or external agency approvals may need more time to process. "Provide a safe and re liable transportati on network that serves all people and respects the environment."

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2-6 cont.
2-7
Letter 2 cont.

IL
Brianne Harkousha, Community Development Director
May 22, 2025

To obtain more information and download the permit application, please visit Caltrans Encroachment Permits (link) .

Thank you again for including Caltrans in the environmental review process. Should you have any questions regarding this letter, please contact Luana Chen, Transportation Planner, via [email protected]. For future early coordination opportunities or project referrals, please visit Caltrans LOR website (link) or contact LDR[email protected].

Sincerely,

YUNSHENG LUO
Branch Chief, Local Development Review
Office of Regional and Community Planning
c: State Clearinghouse
"Provide a sole and re liable transportation network that serves all people and respects the environment."

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LETTER 2: YUNSHEN LUO, CALIFORNIA DEPARTMENT OF

TRANSPORTATION
Response to Comment 2-1
The comment is introductory and does not address the adequacy of the EIR. The comment has been noted for the record and will be forwarded to the decision-makers for their consideration.

Response to Comment 2-2
The comment reiterates the conclusions of the Draft EIR and does not address the adequacy of the EIR. The commenter’s recommendations have been noted for the record. The comment will be forwarded to the decision-makers for their consideration.

Response to Comment 2-3
Issues related to hydrology and stormwater drainage were addressed in the Initial Study (IS) prepared for the proposed project in October 2024. As discussed within Section X, Hydrology and Water Quality, under question ‘c.i-iii,’ the proposed project would not create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems, and a less-than-significant impact would occur.

Response to Comment 2-4
The comment does not address the adequacy of the EIR and has been noted for the record. The comment will be forwarded to the decision-makers for their consideration, and the City will continue to notify and coordinate with the California Department of Transportation (Caltrans) regarding any potential impacts to Caltrans facilities.

Response to Comment 2-5
Contrary to the comment, the lead agency for the proposed project is the City of Pacifica, not the County of San Mateo. The comment does not address the adequacy of the EIR and has been noted for the record. The comment will be forwarded to the decision-makers for their consideration. All mitigation measures provided in the Draft EIR for the proposed project include timing and monitoring specifications, as well as funding concerns where appropriate.

Response to Comment 2-6
The comment provides background information on Caltrans requirements and does not address the adequacy of the EIR. The comment has been noted for the record and will be forwarded to the decision-makers for their consideration.

Response to Comment 2-7
The comment is conclusionary and does not address the adequacy of the EIR. The comment has been noted for the record and will be forwarded to the decision-makers for their consideration.

IL

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3. MITIGATION MONITORING AND

REPORTING PROGRAM

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3.1 INTRODUCTION
Section 15097 of the California Environmental Quality Act (CEQA) requires all State and local agencies to establish monitoring or reporting programs for projects approved by a public agency whenever approval involves the adoption of either a “mitigated negative declaration” or specified environmental findings related to environmental impact reports.

The following is the Mitigation Monitoring and Reporting Program (MMRP) for the 570 Crespi Drive Project (proposed project). The intent of the MMRP is to ensure implementation of the mitigation measures identified within the Environmental Impact Report (EIR) for the proposed project. Unless otherwise noted, the cost of implementing the mitigation measures as prescribed by this MMRP shall be funded by the applicant.

3.2 COMPLIANCE CHECKLIST
The MMRP contained herein is intended to satisfy the requirements of CEQA as they relate to the EIR prepared for the proposed project. This MMRP is intended to be used by City of Pacifica staff and mitigation monitoring personnel to ensure compliance with mitigation measures during project implementation. Mitigation measures identified in this MMRP were developed in the EIR.

The EIR presents a detailed set of mitigation measures that will be implemented throughout the lifetime of the project. Mitigation is defined by CEQA Guidelines, Section 15370, as a measure that:
x Avoids the impact altogether by not taking a certain action or parts of an action; x Minimizes impacts by limiting the degree or magnitude of the action and its implementation;
x Rectifies the impact by repairing, rehabilitating, or restoring the impacted environment; x Reduces or eliminates the impact over time by preservation and maintenance operations during the life of the project; or
x Compensates for the impact by replacing or providing substitute resources or environments.

The intent of the MMRP is to ensure the implementation of adopted mitigation measures. The MMRP will provide for monitoring of reclamation activities as necessary and in-the-field identification and resolution of environmental concerns.

Monitoring and documenting the implementation of mitigation measures will be coordinated by the City of Pacifica. The table attached to this report identifies the mitigation measures, the monitoring action for each mitigation measure, the responsible party for the monitoring action, and timing of the monitoring action. The applicant will be responsible for fully understanding and effectively implementing the mitigation measures contained within the MMRP. The City will be responsible for monitoring compliance.

3. MITIGATION MONITORING

AND REPORTING PROGRAM
3 A

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3.3 MITIGATION MONITORING AND REPORTING PROGRAM
The following table indicates the mitigation measure number, the impact the measure is designed to address, the measure text, the monitoring agency, implementation schedule, and an area for sign-off indicating compliance.

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Chapter 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 specialstatus species.

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 specialstatus 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 City of PacificaPlanning DivisionCity of PacificaPlanning DivisionUSFWSCDFW Prior to issuance of any grading or building permits and prior to any ground disturbing activities After survey results and prior to the commencement of construction activities, if San Francisco Bay spineflower are identified on-site L

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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 reestablished at a minimum of a one-toone 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 ofre-established populations and performance standards for further replanting for any re-established During construction activitiesAnnually for a minimum of five years after reestablishment of plants L

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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 selfsustaining levels, threaten to eliminate an animal community) or through habitat modifications, on migratory birds and raptors protected under the MBTA.

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 15 through January 15), pre-construction surveys or other mitigation measures are not necessary.

2. If construction activities are
scheduled to occur during the breeding season (i.e., January 15 through September 15), a
preconstruction nesting bird survey shall be conducted on the identified work area and a buffer zone (see #3, below).

City of PacificaPlanning Division
Prior to the issuance of grading or building permits and at least seven days prior to start of construction (if in nesting season) L

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The survey shall be performed by a qualified biologist experienced with nesting behavior of birds of the region no more than seven days prior to the initiation of work. A second focused survey shall be conducted within 48 hours prior to construction activities that would occur during the nesting/breeding season. If ground disturbance activities are delayed following a survey, then an additional preconstruction survey shall be conducted such that no more than two weeks will have elapsed between the last survey and the commencement of ground disturbance activities. If a lapse of project-related activities of seven days or longer occurs, another focused survey shall be conducted before project activities can be reinitiated. 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, Immediately prior to and during initial grading/construction L

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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 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 humanactivity. For raptors, the project biologist shall contact CDFW and/or the USFWS Division of Migratory Bird Management for Throughout construction near active nests
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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 and project personnel or equipment shall not be allowed to enter the protective buffer until the project biologist determines that the nest is unoccupied and the young have fully fledged.

4. If the project contractor, 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. The qualified biologist shall observe any identified active nests prior to the start of any constructionrelated activities to establish a behavioral baseline of the adults and any nestlings, and the nest site(s) shall be monitored by the biologist After fledging or nest inactivity is confirmed
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periodically to see if the birds are stressed by the construction activities and if the protective buffer needs to be increased. The perimeter of the nest setback zone shall be fenced or adequately demarcated with stakes and flagging at 20-foot intervals, and construction personnel and activities restricted from the area. A survey report by the qualified biologist verifying that no active nests are present, or that the young have fledged, shall be submitted prior to initiation of grading in the nestsetback zone. The qualified biologist shall serve as a biological monitor during those periods when construction activities occur near active nest areas to ensure that no inadvertent impacts on these nests occur. All buffers shall be shown on all sets of construction drawings. 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 L

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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 selfsustaining levels, threaten to eliminate an animal community) or through habitat modifications, on any wildlife species identified as a candidate, sensitive, or special-status species.

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

4.1-3(b) Pre-construction surveys for specialstatus and non-listed bat species shall be performed by a qualified biologist prior to removal of the on-site trees and commencement of construction activities. If any active maternity or hibernation roosts are identified within 100 feet of areas proposed for development, a CDFW-approved qualified biologist shall establish sitespecific protective buffers around roosts, sized with consideration for the species that are present and the time of year bats are roosting, as well as levels of construction noise and light emission from project activities.

See Mitigation Measures 4.1-4(b) and 4.1-4(c)City of Pacifica Planning DivisionCDFW See Mitigation Measures 4.1-4(b) and 4.1-4(c)Prior to removal of the on-site trees and commencement of construction activities

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,

4.1-4(a) Prior to the commencement of grounddisturbing 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 City of PacificaPlanning Division CDFW
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filling, hydrological interruption, or other means.
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 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.

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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.

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 City of Pacifica Planning Division
Prior to the start of any construction activities
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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 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 City of Pacifica Planning Division
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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.

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

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 City of PacificaDirector of Public Works
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to protect trees which will not be removed during construction prior to commencement of any construction activity.

Chapter 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.

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 onsite 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.

City of Pacifica Planning DivisionSee Mitigation Measure 4.3-3 Prior to the approval of project improvement plansSee Mitigation Measure 4.3-3 Chapter 4.3 – Transportation

4.3-1 Conflict with a program,
plan, ordinance, or policy addressing the

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

4.3-3 Conflict or be
inconsistent with CEQA

4.3-3 The project applicant shall implement
the following CAPCOA VMT reduction strategy T-9 to reduce the number of City Engineer Prior to issuance of
final occupancy of the residential units
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Guidelines section 15064.3, subdivision (b).
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:

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.

4.3-4 Implement Initial Study Mitigation
Measure IX-3.

See Mitigation Measure IX-3
See Mitigation Measure IX-3
Initial Study
a-c. Cause a substantial
adverse change in the significance of a historical resource pursuant to Section 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 City of Pacifica Planning Division
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15064.5; cause a substantial adverse change in the significance of a unique archaeological resource pursuant to Section 15064.5; or disturb any human remains, including those interred outside of dedicated cemeteries? 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 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 City of Pacifica Planning Division County Coroner
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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, 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 NAHC
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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. a,c. Directly or indirectly
cause potential substantial adverse effects, including the risk of loss, injury, or death involving: seismic-related ground failure, including liquefaction, or landslides; or 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 off-site landslide, lateral spreading,
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 Director of Public Works/City EngineerChief Building Official Qualified Geotechnical Engineer Prior to the issuance of a grading or buildingpermit
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subsidence, liquefaction or collapse?
properly incorporated and utilized in the project design. 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? VII-2. Implement Mitigation Measure VII-1 See Mitigation Measure VII-1
See Mitigation Measure VII-1
f. Directly or indirectly
destroy a unique paleontological resource or site or unique geologic feature? 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 toevaluate the discovery for the purpose of recording, 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 City of Pacifica Planning Division
In the event that paleontological resources, including individual fossils or assemblages of fossils, are encountered during construction activities b. Create a significant
hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the likely release of 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 City of Pacifica Planning Division
Prior to initiation of grading, excavation,
or other grounddisturbing activities on the northern portion of the project site .

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hazardous materials into the environment?
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 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? IX-2. Implement Mitigation Measure IX-1. See Mitigation Measure IX-1
See Mitigation Measure IX-1
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f. Impair implementation of
or physically interfere with an adopted emergency response plan or emergency evacuation plan? 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.

NCFA Prior to the
issuance of a building permit
a,e. Violate any water quality
standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality; or conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? 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 employed to control erosion from disturbedareas; x Inactive construction areas
(previously graded areas inactive for 10 days or more) that could contribute sediment City Engineer Prior to the
issuance of a grading, excavation, or building permit
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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.

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City Engineer prior to issuance of a grading, excavation, or building permit.

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 theproposed project. Evidence of such shall be submitted to the City Engineer for review and approval.

City EngineerCity Attorney’s OfficeCity Engineer
Prior to issuance of a certificate of occupancy for any component of the proposed projectPrior to issuance of a certificate of occupancy for any component of the proposed project b. Generation of excessive
groundborne vibration or groundborne noise levels?
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.

City of Pacifica Planning Division
During constructionof the proposed project
a,b. Listed or eligible for
listing in the California Register of Historical Resources, or in a local XVIII-1. Implement Mitigation Measures V-1
and V-2.

See Mitigation Measures V-1
and V-2
See Mitigation Measures V-1 and
V-2
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register of historical resources as defined in Public Resources Code section 5020.1(k); or aresource 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.

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Project
SCH# 2021120126
Partially Recirculated Draft
Environmental Impact Report
Prepared for
City of Pacifica
August 2025
Prepared by
1501 Sports Drive, Suite A, Sacramento, CA 95834
RANEY --PLANNlNG & MANAGEMENT, lNC. fjRflM

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Partially Recirculated Draft
Environmental Impact Report
SCH# 2021120126
Lead Agency
City of Pacifica
Planning Division
1800 Francisco Boulevard
Pacifica, CA 94044
Brianne Harkousha
Deputy Director of Community Development
(650) 738-7341
Prepared By
Raney Planning and Management, Inc.
1501 Sports Drive, Suite A
Sacramento, CA 95834
(916) 372-6100
Contact:

Rod Stinson
Vice President
Lead Agency
Prepared By
Environmental Impact Report

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TABLE OF

CONTENTS

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Table of Contents
Page i

CHAPTER PAGE

1. Introduction to the Partially Recirculated Draft EIR.............. 1-1

4.1. Recirculated Biological Resources Chapter......................... 4.1-1

4.1.1 Introduction ..............................................................................................4.1-1

4.1.2 Existing Environmental Setting.................................................................4.1-1

4.1.3 Regulatory Context ................................................................................4.1-13

4.1.4 Impacts and Mitigation Measures...........................................................4.1-19 Appendices
Appendix C Biological Constraints Analysis
Appendix D Delineation of Potentially Jurisdictional Aquatic Resources and Effects Analysis

TABLE OF CONTENTS

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1. INTRODUCTION TO THE PARTIALLY

RECIRCULATED DRAFT EIR

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1.1 INTRODUCTION
This Partially Recirculated Draft Environmental Impact Report (EIR) is prepared to provide further environmental impact review for the proposed 570 Crespi Drive Project (proposed project). As discussed in the “Background” section below, an EIR was previously circulated for this project.

Based on comments received regarding the Draft EIR, the City determined that recirculation of Chapter 4.1 of the Draft EIR, pertaining to Biological Resources, was necessary to comply with CEQA Guidelines Section 15088.5. Revisions to the Biological Resources chapter include a change to conclusions and the addition of new mitigation measures and, thus, meet the criteria for CEQA Guidelines Section 15088.5.

1.2 PROJECT DESCRIPTION
The project description for the proposed project is unchanged from the 2025 Draft EIR (see Draft EIR Chapter 3 – Project Description).

1.3 BACKGROUND
The EIR process began with the decision by the lead agency in 2021 to prepare an Initial Study/Mitigated Negative Declaration for the proposed project, which was released for public review. Extensive comments were received by the City, requesting further analysis in an EIR. The City determined that an EIR should be prepared and, thus, a subsequent Initial Study was prepared to focus the EIR, which was released with the Notice of Preparation (NOP) on October 4, 2024 for a 30-day review. During the NOP review period, 2 written comments were received regarding the scope of the EIR. In addition, a public scoping meeting was held on October 22, 2024 to receive verbal comments.

The City prepared and released the Draft EIR on April 11, 2025 for a 45-day public review period to present the proposed project to the public, answer questions about the proposed project, and to receive public comments on the Draft EIR. The 45-day public review period was extended to end on June 20, 2025. As required by CEQA Guidelines Section 15087, a Notice of Availability (NOA) of the Draft EIR was distributed on April 11, 2025 to the applicable public agencies and interested individuals, and the Draft EIR was made available for public review. Copies of the document were made available at the City of Pacifica Community Development Department located at 1800 Francisco Boulevard in Pacifica, California, the Sharp Park Library Library located at 104 Hilton Way in Pacifica, the Sanchez Library at 1111 Terra Nova Boulevard, and on the City’s website at https://www.cityofpacifica.org/.

The Draft EIR contained the following technical chapters:

1. INTRODUCTION TO THE

PARTIALLY RECIRCULATED DRAFT
EIR
ARTI
E
RAFT

1. p

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x Chapter 4.1, Biological Resources;
x Chapter 4.2, GHG Emissions; and
x Chapter 4.3, Transportation
The Draft EIR also addressed alternatives to the proposed project.

The City received written comments on the Draft EIR during the 70-day public review period.

Based on comments pertaining to the adequacy of the Draft EIR related to biological resources, the City determined that recirculation of Chapter 4.1 was required.

1.4 PURPOSE OF THIS PARTIALLY RECIRCULATED EIR
This Partially Recirculated Draft EIR was prepared to comply with CEQA guidelines. Pursuant to CEQA Guidelines Section 15088.5, the City determined that recirculation of the EIR is necessary based on comments received; however, only the Biological Resources chapter will be recirculated per CEQA Guidelines Section 15088.5(c). This Partially Recirculated DEIR is being circulated for a 45-day review period, consistent with the time periods set forth in the CEQA Guidelines. The 2025 Draft EIR is available online at the City’s website (https://www.cityofpacifica.org/) and in hard copy at the City of Pacifica Community Development Department, the Sharp Park Library, and the Sanchez Library for background reference.

Upon completion of the 45-day public review period, the City will consider all comments received on the Partially Recirculated Draft EIR, respond to those comments, and identify any associated text changes that should be made in response to those comments. A Final EIR, including responses to comments on the 2025 Draft EIR and this Partially Recirculated Draft EIR, will then be prepared.

A Planning Commission hearing will then be held to consider whether to recommend the City Council certify and approve the entire EIR (including the recirculated portion) for the proposed project. The Planning Commission recommendations will be presented to the City Council to aid in the Council’s decision. The EIR for the consideration of the proposed project will consist of the previously circulated EIR, plus the Partially Recirculated Draft EIR and the Final EIR.

1.5 SCOPE OF THE PARTIALLY RECIRCULATED EIR AND SCOPE OF

COMMENTS
CEQA permits a lead agency to recirculate all or a portion of an EIR: “If the revision is limited to a few chapters or portions of the EIR, the lead agency need only recirculate the chapters or portions that have been modified” (CEQA Guidelines Section 15088.5[c]). Based on the comments received on the Draft EIR, which related to the Biological Resources Chapter of the EIR, the City of Pacifica has exercised its discretion as lead agency to recirculate only the Biological Resources chapter for public review and comments.

Recirculation of an EIR, or a portion of an EIR as is the case here, requires public notice and a public review period pursuant to CEQA Guidelines Section 15087, and consultation with other agencies pursuant to Section 15086 (CEQA Guidelines Section 15088.5[d]).

The CEQA Guidelines specify that, when a portion of an EIR is being recirculated, the lead agency may request that reviewers limit their comments to the revised parts of the EIR that have been recirculated. Also, the CEQA Guidelines specify that the lead agency is not required to respond

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to comments on the recirculated EIR that do not relate to the portions of the EIR that have been revised and recirculated. CEQA Guidelines Section 15088.5(f)(2), provides:

When the EIR is revised only in part and the lead agency is re-circulating only the revised chapters or portions of the EIR, the lead agency may request that reviewers limit their comments to the revised chapters or portions of the re-circulated EIR. The lead agency need only respond to (i) comments received during the initial circulation period that relate to chapters or portions of the document that were not revised and re-circulated, and (ii) comments received during the recirculation period that relate to the chapters or portions of the earlier EIR that were revised and re-circulated. The lead agency's request that reviewers limit the scope of their comments shall be included either within the text of the revised EIR or by an attachment to the revised EIR.

Pursuant to this provision, the City of Pacifica requests that public comments be limited to the newly-circulated information contained in this document related to Biological Resources.

CEQA does not require the City to respond to any new comments that are directed to the portions of the Draft EIR that were not revised and are not being recirculated in this document. The Final EIR for the proposed project will contain detailed responses to the comments on the 2025 Draft EIR, as well as all comments made on this Partially Recirculated Draft EIR that are properly limited to the appropriate subjects within the Recirculated Biological Resources chapter. It should be noted that all comments related to the previous Biological Resources chapter are addressed in the Recirculated chapter. Therefore, pursuant to CEQA Guidelines Section 15088.5(f)(2)(ii), the City will respond to comments received during the recirculation period that relate to the Recirculated Biological Resources Chapter.

1.6 ORGANIZATION OF THE PARTIALLY RECIRCULATED DRAFT EIR This Partially Recirculated Draft EIR is organized as follows:

Chapter 1 – Introduction to the Partially Recirculated Draft EIR Provides an introduction, background, and describes the layout and intended use of the Partially Recirculated Draft EIR and the review process.

Chapter 4.1 – Recirculated Biological Resources Chapter Contains a revised project-level and cumulative analysis of Biological Resources issue areas associated with the proposed project. The chapter contains Introduction, Existing Environmental Setting, Regulatory Context, and Impacts and Mitigation Measures sections. Revisions are presented as new text double underlined and deleted text as struck through. Where an entire Figure or Table has been revised, the Figure or Table title will be shown as double underlined.

Where only portions of a figure or table have been revised, new text will be shown as double underlined and deleted text as struck through.

Appendices
It should be noted that the appendix lettering is kept consistent with the Draft EIR. Appendix C includes the Biological Constraints Analysis produced by Wood Biological Consulting. Appendix D includes the Delineation of Potentially Jurisdictional Aquatic Resources and Effects Analysis produced by Wood Biological Consulting.

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4.1. RECIRCULATED BIOLOGICAL

RESOURCES CHAPTER

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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 1 Wood Biological Consulting. Biological Constraints Analysis – Updated. August 17, 2020. Wood Biological Consulting. Biological Constraints Analysis – 2023 Update. August 21, 2023. 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
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Chapter 4.1 – Biological Resources

Pacifica is 64 degrees Fahrenheit, and the annual average low temperature is 49 degrees 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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Chapter 4.1 – Biological Resources

Figure 4.1-1
Vegetation Communities
N --·- Parcel Line Boundary Distu rbed/Ornarnental 0.45 A c:J Study Area
-Freshwater Emergent Marsh AWS-3 0.02
AWS-NON-JD 0.08
Ve getation Non-native Grassland
0 50 100 NNG-1 0.39
Arroyo Willow Scrub Seasonal Wetland SW-1 0.06
Feet - FEM-1 0.24
Arroyo Willow Scrub (non-JD) D0 -1 0.50
00-3 0.42 D0-2 0.01
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Chapter 4.1 – Biological Resources

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. Although rainfall in 2022-2023 was substantially above normal, the location of vegetation boundaries appeared relatively unchanged since 2020.

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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Chapter 4.1 – Biological Resources

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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Chapter 4.1 – Biological Resources

Figure 4.1-2
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Chapter 4.1 – Biological Resources

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 31 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 30 of the 29 31 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.

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Chapter 4.1 – Biological Resources

Figure 4.1-3
Special-Status Plant Species Within Five Miles of Study Area Source: Wood Biological Consulting, 2024 2023.

Unlabeled Species:

Agrostis blasdalei
Chorizanthe cuspidate var. cuspidata
Eriophyllum latilobum
Hosackia gracilis
Hypogymnia schizidiata
Leptosiphon croceus
Leptosiphon latisectus
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 char, sianus var. c.

SISC - Silene scouleri ss . scouleri
SIVE - Silene verecunda ssp. verecunda
RFL - Triphysaria flori unda
D
N
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COMU
CIAN
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Chapter 4.1 – Biological Resources

Figure 4.1-4
Special-Status Wildlife Species Within Five Miles of Study Area Source: Wood Biological Consulting, 2024 2023..

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 (occs.
protected throughout region)
SH - steelhead
SMCY - saltmarsh common yellowthroat
TBB - Townsend's big-eared bat
0 0
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. ,
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Furthermore, while big free-tailed bat (Nyctinomops macrotis), fringed myotis (Myotis thysanodes), hoary bat (Lasiurus cinereus), and Townsend’s big-eared bat (Corynorhinus townsendii) were not observed as part of the reconnaissance-level survey conducted as part of the Biological Constraints Analysis, potential roosting habitat exists in the vicinity of the study area. Salt marsh common yellowthroat (Geothlypis trichas sinuosa), birds protected by the MBTA, and California red-legged frog, and roosting bat species are discussed in detail, below.

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 21 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 IL

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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.

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., while unusually large precipitation events or seasonal cumulative totals can cause ponding to persist for several 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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months, as occurred following the greater than normal precipitation total for the winter of 2022 to 2023.

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 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.

Roosting Bat Species
Big free-tailed bat, fringed myotis, hoary bat, and Townsend’s big-eared bat are CDFW Species of Special Concern. Bats play an important role in Bay Area ecosystems, through pest control, pollination and seed dispersal. Recent studies estimate that bat consumption of insect pests results in more than $3 billion in agricultural production savings per year in the U.S. Bats are known to roost under bridges, in caves and mines, on buildings, in cliff crevices, in tree foliage, bark, and hollows, and in riprap, with habitat use varying temporally and seasonally. Suitability of bat roosting habitat is dependent on temperature, protection from predators and inclement weather, and proximity to foraging sites. Habitat reduction and disruption of hibernation and maternity roosts due to human development and activity have contributed to steep population declines in California and across the globe. Many bat species are long lived, with most females birthing only one to two young per year. Due to low reproductive rates and sensitivity of breeding females to disruption, maternity colonies affected by human activities that temporarily reduce fecundity, or mortality may require multiple years to recover following disturbance events.

Known records of the aforementioned bat species (CNNDB Occurrences #431, #120, #44, and #20) are all located within four miles of the study area. Large cypress trees in the study area provide marginally suitable day roosting habitat, but not maternal roosting habitat. However, according to the CDFW, the potential exists for trees or rocky habitat in the vicinity of the study area to provide roosting habitat.

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. 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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