The proposed project is inconsistent with the Special Area land use classification of the site, as it proposes residential only development, with no commercial, city hall and/or marina uses, which are required by this land use classification.
2. Coastal Plan Beach Access designates the project site within Area 11, “Rockaway Quarry – Calera Creek (pg C-81)” and sets forth the Land Use as “Rock quarrying. Proposed use is for a planned development, including visitor commercial, neighborhood commercial offices and high density residential. A marina and civic center are also possibilities for this large acreage, depending upon off-shore feasibility studies and fiscal constraints. If a marina were to be built, beach access would be cut off.” The proposed project is inconsistent with this Coastal Plan Beach Access designation, as it proposes residential only development, and does not include any visitor serving commercial or neighborhood commercial offices(or marina or civic center if appropriate based on studies and analyses) as required by this designation.
3. Coastal Act Policy 1 states, “Maximum access shall be conspicuously posted and recreational opportunities shall be provided for all the people consistent with public safety needs and the need to protect public rights, rights of property owners, and natural resource areas from overuse (O, SS, CN, OS).” Although the applicant’s project description purports to provide public open space, the application materials submitted are not clear on how the project will be providing public open space and trail improvements. With respect to trail improvements, although the project plans include notes regarding a “proposed new trail”, the provision of this trail remains unclear. With respect to the proposed Indigenous Memorial Park, there is no detail on specifications of this proposed new area, nor detail on how it is proposed (or not) to interact and integrate with the existing and proposed public trails, open space, or otherwise. Sheet SI 3.0 indicates 3 locations with a “PS - Public Space ID/Regulations” note; two within the western parcel and one within the eastern parcel with the corresponding details on Sheet SI 3.0 for Sign PS includes a sign stating,
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“public park”, but it is unclear how members of the public would access and use such spaces. This issue is discussed in greater detail within Item B.4. in the Initial Inconsistencies Letter. From the limited details provided in the plan set, it is not clear how the project provides maximum access and recreational opportunities. Thus, the proposal is inconsistent with this policy.
4. Coastal Act Policy 3 states, “Public access from the nearest public roadway to the shoreline and along the coast shall be provided in review development projects except where: (a) It is inconsistent with public safety, military security needs, or the protection of fragile coastal resources; (b) Adequate access exists nearby; or (c) Agriculture would be adversely affected.
Dedicated accessway shall not be required to be opened to public use until a public agency or private association agrees to accept responsibility for maintenance and liability of the accessway. (SS, LU).“ There are two parking lots proposed along the eastern property line across from the eastern development area, as well as a small parking lot proposed across from the INDIGENOUS LAND RESERVATION, TO BE DETERMINED (NOT IN SCOPE) on Sheet G1.02 but none are noted to specify whetherthey are proposed as private parking, public parking or both. Should these parking areas, or portions of, be made available to the public, there is no associated detail on the proposed connectivity of how the public would subsequently obtain access to the shoreline and along the coast. Identification of roads and paths as public or private, and delineation of existing and proposed improvements is not Included in the materials submitted. This issue is discussed in more detail in Item B.4. in the Initial Inconsistencies Letter. Asthe submittal materialslack details, and is internally inconsistent regarding the project’s proposed public access component and provides limited details provided in the plan set, the proposed project is inconsistent with this policy requiring public access.
5. Coastal Act Policy 4 states, “Wherever appropriate and feasible, public facilities including parking areas or facilities shall be distributed throughout an area so as to mitigate against the impacts, social and otherwise, of overcrowding or overuse by the public of any single area. (CN, CF, LU)” There are two parking lots proposed along the eastern property line across from the eastern development area, as well as a small parking lot proposed across from the INDIGENOUS LAND RESERVATION, TO BE DETERMINED (NOT IN SCOPE) on Sheet G1.02 but none are noted to specify whether they are proposed as private parking, public parking or both. Should these parking areas, or portions of, be made available to the public, there is no associated detail on the proposed connectivity of how the public would subsequently obtain access to the shoreline and along the coast, if proposed. Identification of roads and paths as public or private, and delineation of existing and proposed improvements is not included in the materials submitted. Without these details and specifications, and from the limited details provided in the plan set, the proposed project is inconsistent with this policy.
6. Coastal Act Policy 7 states, “Oceanfront land suitable for recreational use shall be protected for recreational use and development unless present and foreseeable future demand for public or commercial recreational activities that could be accommodated on the property is already adequately provided for in the area. (LU)” The proposed residential only development is not consistent with the policy’s intent to protect such land for recreational uses and is thus inconsistent with this policy.
7. Coastal Act Policy 8 states, “The use of private lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, general industrial, or general commercial development, but not
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over agriculture or coastal dependent industry.(H, LU) ” The proposed project is inconsistent with this policy, as it proposes residential only development, with no visitor-serving commercial recreational facilities, which is required to be prioritized over private residential development.
8. Coastal Act Policy 9 states, “Upland areas necessary to support coastal recreational uses shall be reserved for such uses, where feasible. (LU)” The project proposes residential only development, including residential development within the site’s upland areas. As discussed in Item B.4. in the Initial Inconsistencies Letter, from the limited details provided in the plan set, it is not clear how the project provides coastal recreational opportunities. Thus, the proposal is inconsistent with this policy.
9. Coastal Act Policy 12 states, “The biological productivity and the quality of coastal waters, streams, wetlands, estuaries, and lakes appropriate to maintain optimum populations of marine organisms and for the protection of human health shall be maintained and, where feasible, restored through, among other means, minimizing adverse effects of waste water discharge and entrainment, controlling runoff, preventing depletion of ground water supplies and substantial· interference with surface water flow, encouraging waste water reclamation, maintaining natural vegetation buffer areas that protect riparian habitats, and minimizing alteration of natural streams. (CN, CF, LU)” Although the application’s project description purports to provide “Environmental Stewardship,” the submittal materials do not include specific details as to how the project proposes to fully implement these environmental stewardship actions related to productivity and quality of the Calera Creek, on-site wetlands, protection of riparian habitats, minimization of natural stream alteration. Details on wetland restoration areas, 100-year floodplain and a 35-foot creek setback from top of bank are not included in the materials submitted. Demonstration of approval of outside agencies to work in the creek will also be required. A Sewer Capacity Study and Preliminary Sewer Plan will be required. The Geotechnical Report does not include a plan to describe infiltration testing and detention basin locations after grading is completed and does not confirm if there are any known nearby sources of soil contamination that would prohibit the use of infiltration on site. Various environmental and other technicalstudies, including biologicalstudies, will be required asthe City continuesto processthis application and will provide more detail. As there is not enough information to determine if the project will maintain biological productivity and natural vegetation buffers and riparian habitats, the quality of coastal waters, the Calera Creek and on-site wetlands, minimize effects of waste water discharge and entrainment, control runoff, prevent depletion of ground water supplies, interfere with surface water flow resources the project is potentially inconsistent with this policy.
10. Coastal Act Policy 14(a)(3) states, “The diking, filling, or dredging of open coastal waters, wetlands, estuaries, and lakes shall be permitted in accordance with other applicable provisions of this policy, where there is no feasible less environmentally damaging alternative and where feasible mitigation measures have been provided to minimize adverse environmental effects, and shall be limited to the following: (3) In wetland areas only, entrance channels for new or expanded boating facilities; and in a degraded wet land, identified by the Department of Fish and Game for boating facilities if, in conjunction with such boating facilities, a substantial portion of degraded wetland is restored and maintained as a biologically productive wetland; provided, however that in no event shall the size of the wetland area used for such boating facility, including berthing space, turning basins, necessary navigation channels, and any necessary support service facilities, be greater than 25 percent of the total wetland area to be restored.” The application purports on
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Sheet G0.01 that project will “undertake the ecological restoration of wetlands and Calera Creek” however, from the materials submitted, the 100-year floodplain and a creek setback from top of bank are not included and it is not clear how restoration will be accomplished. Lastly, various studies, will be required as the City continues to process this application and will assist in determining whether the project is consistent with the aspects of this policy related to the least environmentally damaging alternative and noted limitations of activities. As there is not enough information at this time, the project is potentially inconsistent with this policy.
11. Coastal Act Policy 14(c) states, “In addition to the other provisions of this section, diking, filling, or dredging in existing estuaries and wetlands shall maintain or enhance the functional capacity of the wetland or estuary. Any alteration of coastal ,wetlandsidentified by the Department of· Fish and Game shall be limited to very minor incidental public facilities, restorative measures and nature study. (CN, CF, OS, LU)” Details on wetland restoration areas are not included in application materials and as such, the project may be inconsistent with this policy. In addition, various environmentalstudies, will be required asthe City continuesto processthis application to analyze wetland impacts. As there is not enough information to determine if the project will maintain or enhance the functional capacity of wetlands, the project is potentially inconsistent with this policy.
12. Coastal Act Policy 18 states, “Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values, and only uses dependent on such resources shall be allowed within such areas. Development in areas adjacent to environmentally sensitive habitat areas and parks and recreation areas shall be sited and designed to prevent impacts which would significantly degrade such areas, and shall be compatible with the continuance of such habitat areas. (CN, OS, CO, LU)” Various environmental studies, including biological studies and verification of any environmentally sensitive habitat areas, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding the protection of environmentally sensitive habitats,the project is potentially inconsistent with this policy.
13. Coastal Act Policy 22 states, “Where development would adversely impact archeological or paleontological resources as identified by the State Historic Preservation Officer, reasonable mitigation measuresshall be required. (OS, HS).” Various environmentalstudies, including cultural resource, historic and archaeologicalstudies, will be required as the City continues to processthis application. As there is not enough information to determine if the project meets this policy regarding archaeological and paleontologicalresource impact mitigation, the project is potentially inconsistent with this policy.
14. Coastal Act Policy 24 states, “The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance. Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural landforms, to be visually compatible with the character of surrounding areas, and, where feasible; to restore and enhance visual quality in visually degraded areas.” Development on the Western Parcel is situated on the project site hillside and ridgeline as depicted on Sheets G0.04 – G0.06 and the proposed buildings would be visually prominent from the western, eastern, southern, and northern vantage points. The residential buildings are proposed with heights varying between approximately 20 – 91 feet on the project site ridgelines.
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The proposed new residential buildingsimpact views and appearto not protect viewsto and along the ocean and scenic coastal areas. As such, the proposal is inconsistent with this policy.
15. Coastal Act Policy 25 states, “The location and amount of new development should maintain and enhance public access to the coast by: (a) Facilitating the provision or extension of transit service; (b) Providing commercial facilities within or adjoining residential development, or in other areas that will minimize the use of coastal access roads; (c) Providing non-automobile circulation within the development; (d} Providing adequate parking facilities or providing substitute means of serving the development with public transportation; (e) Assuring the potential for public transit for high intensity uses such as high-rise office buildings; and (f) Assuring that the recreational needs of new residents will not overload nearby coastal recreation areas by correlating the amount of development with local park acquisition and development plans with, the provision of on-site recreational facilities to serve the new development. (C, LU)” As discussed in Item B.4. and B.16 in the Initial Inconsistencies Letter, from the limited details provided in the plan set, it is not clear how the project provides maintains and/or enhances public access to the coast, nor the intent and dedication of proposed parking areas. The application proposes only residential uses, with no commercial facilities within or adjoining such residential uses. The proposed trail improvements are not clearly delineated throughout the plan and although an area noted as the “proposed new trail” is denoted on several sheets throughout the plan set, the plans do not include detail on how “the proposed new trail” would connect to existing public trails and the extent and users of the trail. In addition, the plans regarding paths, delineation of existing and proposed improvements and easements to trails and/or multi-use paths are not clear. Thus, the proposal is found to be inconsistent with this policy requiring maintenance and enhancement of public access.
16. Coastal Act Policy 26 states, “New development shall: (a) Minimize risks to life and property· in areas of high geologic, flood and fire hazard. (b) Assure stability and structural integrity and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding area; or in any way require the construction of protective devices that would substantially alter natural landforms along bluffs and cliffs. (c) Be consistent ·with requirements imposed by an air pollution control district or the State Air Resources Control Board as to each particular development. (d) Minimize energy consumption and vehicle miles traveled. (e) Where appropriate, protect special communities and neighborhoods which, because of their unique characteristics, are popular visitor destination points for recreational uses. (C, SS, CN, CO, LU)” The materials submitted did not include the 100-year floodplain, creek setbacks from top of bank, or a Vegetation Management Plan. The Geotechnical Report does not include a plan to describe infiltration testing and detention basin locations after grading is completed and does not confirm if there are any known nearby sources of soil contamination that would prohibit the use of infiltration on site. A Sewer Capacity Study and Preliminary Sewer Plan, and potentially a Hydrology/Hydraulics, Floodplain/Flood Hazard Analysis, Water Quality and/or a Water Supply Assessment, will be required as the City continues to process this application. Lastly, various studies, including transportation, air quality and greenhouse gas studies, will also be required, all of which will assist in determining whether the project is consistent with the aspects of this policy related to geologic, flood and fire hazards, geologic stability air quality, and energy consumption.
As there is not enough information at this time, the project is potentially inconsistent with those aspects of the policy.
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B. Project Inconsistency with Pacifica Municipal Code Title 9, Chapter 4 Zoning The project is inconsistent with the following standards and regulations set forth in the Pacifica Municipal Code (PMC) Title 9 Planning and Zoning, Chapter 4 Zoning.
1. PMC Sec. 9-4.1200: Service Commercial District (C-3) Zoning District – The project site is zoned Service Commercial District (C-3). Pursuant to PMC Section 9-4.1201, residential uses are not a permitted or conditional use within the C-3 District. Further, the zoning map labels the project site with the symbol “X” to indicate that it requires a public vote for residential development. In addition, as noted above and in the Initial Inconsistencies Letter, we have determined that Ordinance No. 391, which requires a public vote to authorize residential use at the site, applies to your project application. Your proposed project is inconsistent with this requirement.
2. Article 6- R-3 Multiple-Family Residential District – While your project is inconsistent with the underlying zoning district, as noted above, staff has also analyzed consistency with the medium density residential districts, R-3, as you have invoked the Builder’s Remedy. Government Code Section 65589.5(f)(6)(A), regarding Builder’s Remedy projects, providesthat the City may “require the project to comply with the objective, quantifiable, written development standards, conditions, and policies that would have applied to the project had it been proposed on a site with a general plan designation and zoning classification that allow the density and unit type proposed by the applicant.” In this case, the closest development standards to accommodate the development at the density permitted on the site and proposed by the development are the R-3 standards, as they are the most similar to the proposed uses. Further, these standards are assumed to be the zoning district proposed by the applicant, as R-3 is noted within the plan set on Sheet G0.01.
a. PMC Sec. 9-4.602(b) establishes a minimum lot area per dwelling unit of 2,075 sf. The City calculates the minimum sf per unit utilizing the gross lot area, which includes the wetland area. On the East parcel, 833 units on a 1,702,760 sf lot (39.09 acres) is approximately 2,044 sf per unit. This does not meet the minimum lot area per dwelling unit of 2,075 sf per unit.
Thus, the project is inconsistent with PMC Sec. 9-4.602. b. PMC Sec. 9-4.602(d) states that minimum setbacks are the same as R-1 standards. Minimum setbacksin the R-1 district are: (1)minimum frontsetback of 15 feet, exceptthat the minimum front setback to a garage entrance and street side of a corner lot is 20 feet; (2) minimum side setback of 5 feet; and (3) minimum rear setback of 20 feet (PMC Sec. 9-4.402(d)-(f).) The project plans do not provide enough detail to determine consistency with these setback requirements. Based on site plan sheet A1.01, plans do not distinguish lot lines by front, side and rear (as defined in PMC Sec. 9-4.254 through Sec. 9-4.256), nor do they demonstrate minimum required setbacks. Therefore, the project is potentially inconsistent with these setback requirements.
c. PMC Sec. 9-4.602 (e) states that maximum heights are the same as R-1 standards. Maximum heights in the R-1 district are 35 feet for residential buildings, and 12 feet for a detached accessory building (PMC Sec. 9-4.402(j)). As proposed and set forth on architectural elevations on plan sheets A3.01-A3.10, each of the individual residential buildings exceeds the 35-foot height limit, and the proposed private community buildings exceed the 12-foot height limit
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for detached accessory buildings or do not have the height labeled. Thus, the project is inconsistent with the height requirements in PMC Sec. 9-4.602(e). d. PMC Sec. 9-4.602(f) establishes a maximum lot coverage of 60 percent for all structures on each parcel. The plans do not provide enough detail to determine maximum lot coverage on each parcel. Plans provide a landscape area diagram on sheet L0.07 and a table to summarize the proposed, disturbed and undisturbed areas including area calculations for building footprints, structure areas, circulation and road areas, hardscape paved areas, landscape planting areas, recreation facilities, and active recreation areas which can be utilized by all residents of the development, stormwater mitigation areas, wetland mitigation areas, water infrastructure areas on West Parcel and East Parcel; however the table and diagram areas do not directly correspond with one another and do not distinguish what areas are being counted toward lot coverage. Therefore, staff is unable to determine if they are consistent. Further, proposed building coverage per each parcel is not calculated as a percentage within the plan set. Therefore, the project is potentially inconsistent with the coverage requirement in PMC Sec. 9-4.602(f).
e. PMC Sec. 9-4.602(g) requires a minimum landscaped area of 20 percent on each parcel.
However, landscape coverage for the project is not calculated on each parcel. Plans include a landscape area diagram sheet on L0.07., and table to summarize the proposed, disturbed and undisturbed areas including area calculations for building footprints, structure areas, circulation and road areas, hardscape paved areas, landscape planting areas, stormwater mitigation areas, wetland mitigation areas, waterinfrastructure areas on West Parcel and East Parcel; however the table and diagram do not directly correspond with another and do not distinguish what areas are being counted toward the required landscape area, therefore staff is unable to determine if they are consistent. Further, proposed landscape coverage per each parcel is not calculated as a percentage within the plan set, and it is unclear if the proposed landscape area coverage is consistent with the PMC Sec. 9-4.602(g). The project is potentially inconsistent with the minimum landscape area requirement. f. PMC Sec. 9-4.602(h) establishes a minimum usable open space 400 sf per unit. PMC Sec. 9-
4.260.2 defines "Usable open space" as “common or private outdoor living, recreation, domestic use, orlandscaping. Such area may be on the ground or on a roof, porch, deck, court, or balcony. Off-street parking areas or driveway and/or exit corridors shall not be included as usable open space. Any separate area to qualify under this definition shall be a minimum of 4 feet by 10 feet. Usable open space shall not have a slope of more than ten (10%) percent.” Project plans provide an open space diagram, Sheet G0.16, legend and table which shows proposed open space, and excluded open space. However, plans do not clearly show what areas are being counted toward the open space requirements and do not clearly depict that the counted area meets the definition of “Usable Open Space”. The plan also shows areas that are hashed in a pattern and color not shown on the legend. It is unclear if areas marked on the diagram have a slope less than 10 percent. Further, if there is usable open space on a roof, porch, deck, court, or balcony, it is not shown on the open space diagram and is not called out on the table and not calculated into the overall proposed useable open space. Given the lack of clarity on the plans, the amount of usable open space cannot be determined.
Therefore, the project is potentially inconsistent with this requirement.
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3. Article 22 – Planned Development District (P-D)
a. Per PMC Sec. 9-4.2256, “Applicants of any development proposal within the Hillside Preservation District shall pursue the procedures and standards set forth for the P-D District, specifically Sections 9-4.2204 through 9-4.2211 of Article 22 of this chapter, as now enacted or hereafter amended.” Pacifica Municipal Code (PMC) Sec. 9-4.2204(b) establishes that “[r]egulations for area, coverage, density, yards, parking, height, and open ground area for PD District users shall be guided by the regulations of the residential, commercial, or industrial zoning districts most similar in nature and function to the proposed P-D District uses as determined by the Commission and the Council”. The current application does not include a Planned Development rezoning request or the materials necessary to establish consistency with the Planned Development requirements applicable to development within the Hillside Preservation District. Accordingly, the project is inconsistent with PMC Section 9-4.2256 and the Planned Development provisions of Article 22.
4. Article 22.5 – Hillside Preservation District (HPD)
a. PMC Sec. 9-4.2257 establishes the maximum allowable site coverage based on a formula provided in PMC Sec. 9-4.2257. This requirement applies within the HPD overlay zoning district, which the project is located in. As calculated by the applicant on sheet C4.01, Allowable Land Coverage Exhibit, the maximum allowable site coverage calculated for the project as a whole is 22.9%. Plan sheet C4.01 provides a separate calculation for the allowed site coverage area excluding the “bluff area.” However, the allowable site coverage is to be calculated by individual parcels, and include the gross lot area including any bluff or wetland areas. Further, plans include a landscape area diagram on sheet L0.07 which provides a diagram, and table to summarize the proposed, disturbed and undisturbed areas including area calculations for building footprints, structure areas, circulation and road areas, hardscape paved areas, landscape planting areas, recreation facilities, and active recreation areas which can be utilized by all residents of the development, stormwater mitigation areas, wetland mitigation areas, water infrastructure areas on West Parcel and East Parcel; however the table and diagram do not directly correspond with one another and do not distinguish what areas are being counted toward allowable land coverage, therefore staff is unable to determine if they are consistent. Further, proposed site coverage is not calculated as a percentage per each parcel within the plan set. Therefore, the project is inconsistent with the proposed allowable site coverage requirements in PMC Sec. 9-4.2257. b. PMC Sec. 9-4.2257 establishes a minimum usable recreational open space of 200 sf per unit.
Plans provide plan sheet G0.16, open space diagram, legend and table which shows proposed open space, and excluded open space. However, plans do not clearly show what areas are being counted toward “recreational open space requirements”. Therefore, the project may be inconsistent with this recreational open space requirement. c. PMC Sec. 9-4.2258 requires minimum street standards in the HPD, see standards diagram excerpt from zoning code pasted below. The plans for the proposed streets do not include information on the proposed street dimensions and standards. Identification of roads as public or private, and delineation of existing and proposed improvements and easements was not provided. As there is not enough information to determine if the project meet the City’s street standards, the project is potentially inconsistent with this policy.
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d. PMC Sec. 9-4.2259 establishes parking requirementsfor each dwelling unit based on unit type and number of bedrooms. The required number of parking spaces, as well as whether spaces must be covered or uncovered and their proximity to the unit, varies depending on these factors. The project cover sheet includes a table summarizing parking requirements for the Hillside Preservation District; however, it does not distinguish between building types or the number of bedrooms per unit, nor does it clarify whether the proposed parking spaces are covered or uncovered. In addition, no corresponding parking plan or diagram has been provided to verify the information presented in the table. Therefore, the project may be inconsistent with this parking requirement.
e. PMC Sec. 9-4.2259(d) requires a minimum of “one guest parking space for every ten (10) dwelling units, or fraction thereof.” Based on the submitted plan set, it is unclear whether the project complies with the required guest parking standard for multifamily development in the Hillside Preservation District. While the cover sheet includes tabular data summarizing parking, no corresponding parking plan or diagram has been provided to demonstrate that the required guest spaces are adequately located and provided. Therefore, the project may be inconsistent with this parking requirement.
5. Article 23 – General provision and Exceptions
a. PMC Sec. 9-4.2313 “Minimum Dwelling Unit Sizes” states, “Two-family and multiple-family dwelling units and condominiums shall contain the following minimum gross floor area:
i. Bachelor or studio units, 450 square feet;
ii. One bedroom units, 600 square feet;
iii. Two (2) bedroom units, 800 square feet;
iv. Three (3) bedroom units, 850 square feet; and
v. Each additional bedroom in excess of three (3), 100 additional square feet.
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Bachelor or studio units shall be those units which have one room for the purposes of eating and sleeping.” While the plan set includes floor plans on Sheets A2.01 – A2.08, none of these sheets, nor elsewhere in the plan set include detailspecifying the proposed square footage forthe 1,225 dwelling unit mix specified on Sheet GO1.01. Further, neither the Project Data information provided for each building on Sheets G0.20 – G0.24, nor the floors plans and data listed on Sheet A2.01 – A2.08 provided a breakdown on the proposed square footage per dwelling unit type. As there is not enough information to determine consistency with these minimum unitsize regulations, the projectis potentially inconsistent with PMC Section 9-4.2313.
6. Article 25 – Height Limits
a. PMC Sec. 9-4.2502(a) establishes that “no fence, hedge, wall, or screen planting of any kind shall be constructed or grown to exceed six (6) feet in height within any required side to the rear of the required front yard of any dwelling or within any required rear yard; nor exceed three (3’) in height within the required front yard of any dwelling, or for corner lots, within twenty-five (25′) feet of a street corner measured at the property line. Civil, landscape and architectural plans do not call out the height of the onsite fences, walls, or hedges. Landscape plans show structures that are not labeled in the civil and architectural plans. Structures should be consistent between the landscape, architectural and civil plans, and include labeled heights. As there is not enough information to determine whether the plans comply with Article 25 of the Zoning Code pertaining to height limit, the project is potentially inconsistent with this requirement.
7. Article 27 – Projections into Yard. Article 27 pertains to allowed projections into yards, for cornices, eaves, canopies, and similar architectural features; porches, landings and outside stairways; and accessory buildings. As noted in Comment B.2.b of this letter, the plans do not distinguish between front, side, and rear lot lines, nor do they identify the associated front side or rear yard and corresponding setback requirements. As there is not enough information to determine if there are projections to the required yards and if they comply with Article 27 of the Zoning Code pertaining to projections into the yard, the project is potentially inconsistent with this requirement.
8. Article 28 – Off Street Parking and Loading
a. Per PMC Sec. 9-4.2811, “Off-street parking facilities for different buildings, structures, or uses may be provided collectively provided the total number of spaces so located together shall not be less than the sum of the separate requirement for each use and provided, further, that the right for the continued use of such parking facilities is established to the satisfaction of the City Attorney.” While the cover sheet includes tabular data summarizing parking, no corresponding parking plan or diagram has been provided to demonstrate where the parking is located for each building, or if any of the parking is to be shared between buildings structures or uses. Thus, the project is potentially inconsistent with this requirement. b. Per PMC Sec. 9-4.2813(b), “for multiple-family projects, street access to all parking spaces shall be limited to 50 percent of the total lot frontage, but in no event shall such access be greater than fifty feet.” No driveway dimensions have been provided and as stated in Comment B.2.b, no lot line designations have been identified. In addition, the plans do not show percentage of each lot frontage occupied by driveway curb cuts to demonstrate
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compliance with this standard. As there is not enough information to determine if the project complies with PMC Sec. 9-4.2813, the project is potentially inconsistent with this requirement.
c. Per PMC Sec. 9-4.2813(c) states: “Residential driveways and access roadways shall provide a permanent, unobstructed passageway constructed to the following standards:...(3)Driveways serving two or more units shall be a minimum of ten (10′) feet in width for one-way traffic and twenty (20′) feet in width for two-way traffic…(4)Except as otherwise provided in this section, the maximum width for residential driveways shall be twelve (12′) feet for single driveways and twenty (20′) feet for double driveways.” No driveway, or drive aisle dimensions have been provided. As there is not enough information to determine if the project complies with this regulation, the project is potentially inconsistent with PMC Sec. 9-4.2813(c). d. Per PMC Sec. 9-4.2813(f), “residential driveways for lots with forty (40′) feet of lot frontage or more shall be designed to provide at least one on-street parking space. For lots with less than forty (40′) feet of lot frontage, driveways shall be designed to provide at least one on-street parking space whenever feasible. Off-street parking in the form of parking bays may be substituted in lieu of such on-street requirements.” No driveway dimensions have been provided and asstated in Comment B.2.b, no lot line designations have been identified. While the cover sheet includes tabular data summarizing parking, no corresponding parking plan or diagram has been provided to demonstrate where the parking is located for each building, or if any of the parking is to be shared between buildings structures or uses and no reference to location and number of parking spaces located on-street. As there is not enough information to determine if the project is consistent with these requirements, the project is potentially inconsistent with PMC Sec. 9-4.2813(f).
e. Per PMC Sec. 9-4.2815, “All open automobile parking areas for more than ten (10) parking spacesshall be effectively screened on each side adjoining or fronting on any property situated in a residential district by a wall, fence, or densely-planted, compact hedge not less than three (3′) feet nor more than six (6′) feet in height which shall be maintained in good condition.” While the proposed Planting plan on sheet L3.0 shows some existing landscape screening along parking areas parallel to Highway 1, it is unclear if there are any gaps that should be filled to adequately screen parking areas from off site, including where parking lot that is located out by the North Wetland and the parking lot by the Road crossing over Calera Creek.
Thus, the project is potentially inconsistent with this requirement. f. Per PMC Sec. 9-4.2810: (a) All required covered off-street parking spaces shall have a minimum usable area of not less than 171 square feet, exclusive of access drives or aisles, and shall be of usable shape, location, and condition. The minimum dimensions of covered parking spaces shall be nine (9′) feet in width by nineteen (19′) feet in length. The vertical clearance shall be not less than seven (7′) feet over the entire area. (b) In any parking area with fifty (50) or less required off-street parking spaces, twenty (20%) percent of the total required spaces may be compact spaces. In any parking area with over fifty (50) required off-street parking spaces, thirty (30%) percent of the total required spaces may be compact spaces. All required covered spaces shall be full size. (c) refers to a table for the standards for the design of uncovered off-street parking areas and drive aisles. (d) Wheel stops or other barriers acceptable to the City Engineer shall be provided for all uncovered off-street parking spaces and may be included within the required minimum parking dimensions of such spaces. Wheel
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stops or other such barriers shall be located to allow a minimum overhang of three (3′) feet. (e)Automobiles may overhang plantings in areas where the median between parking stalls is a minimum ofsix (6′) feet in width and a six (6″) inch curb is provided. The parking space length may be reduced two (2′) feet, and no wheel stop need be provided in such cases. Plantings shall be designed to not be damaged by the overhang of parked automobiles. (f)Where posts, columns, or other architectural appenditures, other than wheel stops, are located within parking areas, such posts, columns, or other appenditures shall not be permitted to be calculated within the required minimum parking dimensions of spaces, or driveways serving such spaces, as required by the standards set forth in subsection (c) of this section. Further, such posts, columns, or other appenditures shall not be so located as to obstruct the facilitation of vehicular movement and the parking or the opening of vehicular doors.
Proposed plans do not dimension parking spaces and drive aisles, nor do they identify percentage of compact spaces. Parking spaces do not identify wheel stops or other barriers, areas of automobile hang over, or post columns or other architectural appenditures. Thus, the project is potentially inconsistent with these requirement. g. PMC Sec. 9-4.2818, sets forth the number of parking spaces required by use, and for residential projects within the Hillside Preservation District…spaces shall be provided as required by 9-4.2258 of Article 22.5 of this chapter. See comments B.4.d and B.4.e. of this letterregarding consistency with the Hillside Preservation district parking requirements. Thus, the project is potentially inconsistent with this requirement.
9. Article 29 – Signs
a. PMC Sec. 9-4.2904(f) refers to exempt signage and states that on-site directional signs shall require the approval of the Planning Administrator and shall be limited to four (4)square feet.
Free-standing on-site directionalsignsshall be limited to four(4′) feet high. On-site directional signs attached to a wall shall be located no higher than (8′) feet above the ground level. Plan Sheet S10.0 provides a table of titled “Exempt Project Site Signage”, and lists three freestanding signs including signs for Public Space ID and Trail Signs which are both are up to 5 five feet in height and a Street Wayfinding sign which is 8 feet above the ground. These three signs do not qualify as exempt free standing signs and would instead be considered along with other signs in the Master Sign Program. Thus, the project is inconsistent with the City’s signage requirements.
b. PMC Sec. 9-4.2906(a)(3) requires, the total permitted sign area for any building shall not exceed seventy-five hundredths (.75 or ¾) square foot of signage per one foot of lineal street frontage, except that an additional five-tenths (.5 or ½) square foot of permanent window sign area per one foot of lineal street frontage shall be permitted. Plan Sheet S10.0 provides a table which calculatesthe allowed signage area per building but does notstate the proposed signage area within the table or on the typical building elevations provided on sheet S12.0. As there is not enough information to determine sign area, the project is potentially inconsistent with this requirement.
c. PMC Sec. 9-4.2906(a)(5) requires there shall be no limit to the number of signs allowed provided the size limitation set forth in subsection (3) of this subsection is not exceeded; however, there shall be no more than one freestanding sign for each premises. A freestanding sign is defined buy PMC. Sec. 9-4.2902(q), A sign erected to a freestanding frame or support mast or pole and not attached to any building. And PMC Sec.9-4.2907(d) states that, no more
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than one freestanding sign shall be allowed for each multi-unit development, unless the Commission finds that more than one freestanding sign is necessary for reasonable identification. The proposed Master Sign Program proposes more than one freestanding sign as defined by PMC Sec, 9-4.2902(q). Further, plans do not clearly and consistently distinguish between free standing signs, wall signs, and directional signs throughout Sheet S10.0-S13.0 and building wall signs. Thus, the project is potentially inconsistent with this requirement.
10. Article 44 – Coastal Development Regulations
a. PMC Sec. 9-4.4403, Habitat Preservation. Pursuant to this section, development within or adjacent to environmentally sensitive habitat areas, including wetlands and habitat associated with special-status species, may require a habitat survey prepared by a qualified biologist to identify environmentally sensitive habitat areas, delineate wetlands and habitat buffers, evaluate direct and indirect impacts, and recommend mitigation measures necessary to protect the long-term viability of the habitat. The project site contains and is adjacent to wetlands, restored habitat areas, open space lands, and other potentially environmentally sensitive resources. In addition, the proposed development includes extensive grading, roadways, parking areas, utilities, stormwater facilities, residential development, and recreational improvements in close proximity to these resources. However, the current submittal does not clearly identify all environmentally sensitive habitat areas subject to protection under PMC Section 9-4.4403, delineate the boundaries of wetlands and required habitat buffer areas, or demonstrate that all proposed development is located outside protected habitat areas. Furthermore, the submittal does not adequately evaluate potential direct and indirect impacts associated with grading, runoff, sedimentation, lighting, noise, increased human activity, domestic pets, long-term maintenance activities, and other disturbances that may affect adjacent habitat areas. The plans also do not clearly demonstrate how habitat buffer areas will be protected, maintained, and permanently preserved, or how project design has been modified to maximize contiguous open space adjacent to sensitive habitat areas as required by PMC Section 9-4.4403. Because the application materials do not provide sufficient information to identify environmentally sensitive habitat areas, evaluate potential impacts, establish appropriate habitat buffers, or demonstrate compliance with the development standards applicable to wetlands and habitat buffer areas, the project is potentially inconsistent with PMC Section 9-4.4403. b. PMC Sec. 9-4.4404, Geotechnical Suitability. The purpose of this section is to ensure that development is designed and located in a manner that minimizes risks to life, property, and the natural environment through a comprehensive evaluation of geologic, geotechnical, and erosion hazards. While the applicant has submitted geotechnical information, the materials provided do not contain sufficient analysis to demonstrate that all geotechnical constraints and potential hazards associated with the proposed development have been fully evaluated.
The submitted Geotechnical Report does not include a plan describing proposed infiltration testing following completion of grading activities, does not identify the final locations and feasibility of proposed detention and infiltration facilities, and does not confirm whether nearby sources ofsoil or groundwater contamination could affectthe suitability of infiltrationbased stormwater management measures. As a result, the City cannot determine whether the site's geologic and subsurface conditions can safely accommodate the proposed drainage and stormwater infrastructure. In addition, the submitted materials do not adequately
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demonstrate that all potential geotechnical impacts associated with grading, slope modification, erosion, stormwater infiltration, roadway construction, and long-term site development have been evaluated and mitigated to acceptable levels. The application also does not clearly establish whether additional geotechnical investigations, infiltration testing, slope stability analyses, erosion assessments, or other technical studies may be necessary to verify the suitability of the proposed development and infrastructure. Furthermore, the technical materials submitted include references to older studies and mapping, including a 2017 FEMA Flood Insurance Rate Map and a 1996 Reclamation Plan. The current record does not clearly demonstrate that all relevant geologic, hydrologic, coastal hazard, erosion, bluff stability, and sea level rise conditions affecting the site have been evaluated using current information. Additional technical studies may be necessary to determine the extent to which existing and future geologic and coastal hazards could affect the proposed development and to identify any corresponding mitigation measures. Because the application materials do not provide sufficient information to fully evaluate geologic hazards, erosion potential, infiltration feasibility, stormwater management suitability, and other geotechnical constraints affecting the site, the project is potentially inconsistent with PMC Section 9-4.4404. c. PMC Sec. 9-4.4405, Grading and Drainage. The purpose of this section is to minimize alteration of natural topography and major landforms, foster resource preservation, and reduce hazards associated with grading, erosion, sedimentation, and stormwater runoff. The proposed project includes substantial grading, roadway construction, utility installation, drainage improvements, retaining structures, and residential development across a large site containing steep slopes, wetlands, habitat areas, and other environmentally sensitive resources. However, the current application materials do not provide sufficient information to demonstrate that grading has been minimized to the maximum extentfeasible,that natural drainage patterns and landforms have been preserved where feasible, or that potential grading and drainage impacts have been mitigated. In addition, the submitted Grading and Drainage Plans do not adequately demonstrate compliance with the construction and longterm drainage management standards contained in PMC Section 9-4.4405(c). The plans do not clearly identify all areas of permanent landform disturbance, erosion control measures, revegetation treatments, sediment control facilities, drainage improvements, stormwater management facilities, or other mitigation measures necessary to verify compliance with the requirements of this section. The submittal also does not clearly demonstrate that proposed grading and drainage improvements will avoid adverse impacts to adjacent wetlands, environmentally sensitive habitat areas, drainage courses, and other natural resources located on and around the project site. Furthermore, additional environmental studies, engineering analyses, and technical review may be required to evaluate potential impacts associated with grading, erosion, sedimentation, stormwater runoff, drainage infrastructure, slope stability, habitat protection, and long-term site management. As the City continues processing the application, peer review of technical studies and supporting analyses may also be necessary to verify the assumptions, methodologies, and conclusions relied upon by the project design team. Because sufficient information has not been provided to demonstrate compliance with the grading and drainage standards of PMC Section 9-4.4405, the project is potentially inconsistent with PMC Section 9-4.4405.
d. PMC Sec. 9-4.4406, Shoreline Protection. The purpose of this section is to minimize erosion and stabilize shoreline areas where ocean wave action, tidal forces, coastal bluff retreat, and
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other coastal processes may create hazardous or damaging conditions. The proposed project includes development in proximity to coastal bluffs, shoreline areas, drainage features, and other areas potentially subject to erosion, bluff retreat, flooding, slope instability, storm impacts, sea level rise, and related coastal hazards. Pursuant to PMC Section 9-4.4406(b), development proposed on coastal bluffs is required to be supported by a site stability survey prepared by a qualified soils engineer or engineering geologist. While technical studies have been submitted, the application materials do not adequately demonstrate that all shoreline hazards and long-term bluff stability considerations have been evaluated consistent with the requirements of this section. As noted in the Initial Inconsistencies Letter, portions of the project site appear to be located within the Local Coastal Program's mapped Coastal Vulnerability Zone. However, the application materials do not include site-specific coastal hazard mapping, vulnerability assessments, bluff retreat analyses, sea level rise evaluations, or other studies necessary to determine the extent to which existing and future coastal hazards may affect the proposed development. In addition, the plans do not clearly identify the limits of any 100-year floodplain, applicable flood hazard areas, or required creek setbacks, including the extent of the required 35-footsetback measured from the top of bank.
Without this information, the City cannot determine whether the proposed development has been appropriately sited and designed to avoid existing and future coastal hazards.
Furthermore, the current submittal does not clearly demonstrate that the proposed development can be safely maintained throughout its anticipated lifespan without the future construction of shoreline protection devices, seawalls, revetments, or other shoreline armoring measures. PMC Section 9-4.4406(c)(2) prohibits development that requiresseawalls as a mitigation measure or that would eventually require seawalls for the protection of structures unless the property would otherwise be rendered undevelopable for any economically viable use. The application materials do not adequately evaluate future shoreline retreat, erosion rates, sea level rise impacts, flooding hazards, storm events, bluff stability conditions, or other coastal processes necessary to determine whether the proposed development may ultimately require shoreline armoring. Additional site-specific coastal hazard assessments, floodplain analyses, geotechnical investigations, coastal engineering studies, environmental review, and technical peer review may be required as the City continues processing the application. Because sufficient information has not been provided to verify long-term shoreline stability, evaluate coastal hazard exposure, identify applicable floodplain and creek setback constraints, determine whether the proposed development can avoid reliance on future shoreline armoring, or demonstrate compliance with the shoreline protection standards of PMC Section 9-4.4406, the project is potentially inconsistent with this section.
e. PMC Sec. 9-4.4407, Public Shoreline Access. The purpose of this section is to maximize public access to and along the shoreline while protecting environmentally sensitive resources and the rights, privacy, and security of adjacent property owners. The proposed project includes public trails, bluff-top access areas, open space amenities, habitat areas, and other improvements that may function as components of the shoreline access system. However, the application materials do not clearly identify all required public shoreline access easements, lateral access easements, vertical access easements, trail corridors, access improvements, and associated public access facilities necessary to evaluate compliance with the standards of this section. The current submittal does not clearly demonstrate that all
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proposed shoreline access facilities comply with the minimum setback requirements from existing and proposed residential development, nor does it demonstrate that required lateral and vertical access easements satisfy the minimum width requirements established by PMC Section 9-4.4407. The plans also do not adequately identify where shoreline access facilities may traverse or be located adjacent to environmentally sensitive habitat areas, wetlands, coastal bluffs, or other protected resources, or demonstrate compliance with the habitat protection requirements referenced in PMC Section 9-4.4407(b)(2). Furthermore, the application materials do not provide sufficient information to determine whether proposed trails, viewing areas, parking facilities, signage, ramps, stairways, and other shoreline access improvements have been designed to be accessible to persons with limited mobility to the maximum extent feasible, or whether such improvements have been designed to be compatible with the natural character of the shoreline as required by PMC Section 9-
4.4407(b)(3) and (4). The submittal also lacks sufficient detail regarding the design, location, appearance, and content of proposed shoreline accesssignage necessary to verify compliance with the standards of this section. In addition, the plans do not adequately demonstrate how future coastal bluff retreat and shoreline change have been incorporated into the design and long-term location of proposed bluff-top access facilities and easements, including whether required trail adjustments can occur while maintaining required setbacksfrom residences and continued public access opportunities. Additional shoreline access plans, easement exhibits, trail design details, accessibility analyses, habitat impact assessments, and technical review may be required as the City continues processing the application. Because sufficient information has not been provided to verify compliance with the shoreline access standards of PMC Section 9-4.4407, including access easement dimensions, trail setbacks, habitat protection measures, accessibility requirements, and bluff-top access provisions, the project is potentially inconsistent with PMC Section 9-4.4407.
f. PMC Section 9-4.4408, Coastal View Corridors. The purpose of thissection isto protect public views toward and along the ocean and scenic areas, ensure visual compatibility with the surrounding character, and restore and enhance visual quality within designated coastal view corridors. The project site is located within a designated coastal view corridor and proposes substantial residential development, grading, roadways, retaining structures, parking areas, and associated infrastructure throughout a highly visible coastal landscape. Pursuant to PMC Section 9-4.4408, development within coastal view corridors must be sited and designed to minimize alteration of natural topography and landforms, minimize tree removal and grading, locate structures on the least visible portions of the site where feasible, consolidate development within the natural topography, provide landscape screening and restoration, and protect public coastal views. The project submittal does not adequately demonstrate consistency with these requirements. Based on the renderings provided on Sheets G0.04 through G0.06, the proposed development appears visually prominent within the surrounding coastal landscape. The siting of residential buildings along the hillside and ridgeline areas, with proposed building heightsranging from approximately 20 feet to 91 feet, appears likely to result in highly visible development from multiple public vantage points, including views from the west, east, north, and south. The application materials do not adequately demonstrate that structures have been located on the least visible portions of the property or that development has been consolidated and clustered within the natural topography to minimize visual impacts as required by PMC Section 9-4.4408(b)(2) and (4). In
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addition, the current submittal does not demonstrate that grading and landform alteration have been minimized to the extent necessary to accommodate development. The plans indicate substantial modification of existing hillside landforms and extensive grading associated with building pads, roadways, retaining walls, and site improvements. However, the applicant has not provided sufficient visual analysis to demonstrate that these alterations have been minimized consistent with the requirements of PMC Section 9-4.4408(b)(1). The application materials also do not adequately demonstrate that landscape screening and restoration measures will be sufficient to minimize the visual prominence of the proposed development. While landscape plans have been submitted, the current record does not include sufficient information to determine whether proposed vegetation will effectively screen buildings, parking areas, retaining structures, and othersite improvementsfrom public viewpoints over time, particularly during the establishment period and in the context of longrange coastal views. Furthermore, constraints associated with floodplain areas, creek setbacks, environmentally sensitive habitat areas, coastal hazards, and other site limitations may influence the ultimate location and design of development. However, the submittal does not demonstrate how these constraints have been integrated into a site design that simultaneously protects public coastal views and avoidslocating development in highly visible portions of the site. The current submittal does not include sufficient visual simulations, view corridor studies, line-of-sight analyses, cross-sections, ridgeline visibility analyses, or other visual resource documentation necessary to evaluate consistency with the Coastal View Corridor standards of PMC Section 9-4.4408. Additional visual impact analyses, simulations from key public viewpoints, and technical review will be required as the City continues processing the application. Because sufficient information has not been provided to demonstrate that the project protects public coastal views, minimizes grading and landform alteration, locates development on the least visible portions of the site, provides adequate landscape screening, and otherwise complies with the Coastal View Corridor standards of PMC Section 9-4.4408, the project is potentially inconsistent with these requirements.
11. Article 47 – City of Pacifica Below Market Rate (Inclusionary) Program. a. PMC Sec. 9-4.4711 establishes that residential developments located within the HPD that provide below market rate (BMR) units shall be subject to all regulations and standards of the HPD district. As the project does not meet all the standards in the HPD district, as set forth above, the project is inconsistent with PMC Sec. 9-4.4711.
C. Inconsistency with Other Provisions of the Pacifica Municipal Code
1. PMC Chapter 12 – Sec. 4-12.11(a) requires that a tree protection and preservation plan must be submitted in conjunction with any development proposal which requires a discretionary permit or other land use approval as set forth in Title 9 of this Code, or a proposal to engage in regulated work within fifty (50') feet of a protected tree. There appears to be work within 50 feet of protected trees and thus a tree preservation plan may be required. There is vegetation along the west parcel northern line, near the proposed Townhome development, that resembles a tree or group of trees that are not included in the arborist report, but appear to be located within 50 feet of the proposed scope of work, including grading and construction staging. Additionally, there appears to be a tree or group of trees along the entrance road/parking area, located off-site, that may fall within fifty (50) feet of the proposed work area. A 50-foot radius from the scope of work and/or from any trees not currently identified in the arborist report should be clearly delineated
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to determine whether a tree encroachment permit, tree protection measures, and/or a tree removal permit are required pursuant to Pacifica Municipal Code Section 4-12.11(a). Therefore, the project may be inconsistent with this requirement.
D. Pacifica Design Guidelines
1. Guideline I.A.1. states “Site improvements should be designed to work with site features, not against them. Lot grading should be minimized and disruption of natural features such as trees, ground forms, rocks, and water courses should be avoided”. The proposed project proposes extensive grading, and is therefore inconsistent with the policy to minimize grading. Further, the project proposestree removal and istherefore inconsistent with the policy to minimize disruption to trees. Lastly, the project does not clearly delineate setbacks from the top of bank of the creek, and therefore additional information is needed to determine if the project will impact water courses. Thus, the project is inconsistent with this design guideline.
2. Guideline I.A.2. states that “buildings should be sited to consider shadows, changing climatic conditions, the potential for passive or active solar energy, safety, and privacy of adjacent outdoor spaces. Building placementshould take into impacts on adjacent property. Existing views, privacy, and solar access of surrounding properties should be preserved wherever possible. In multi-unit developments, buildings should be located so as to avoid crowding and to allow for a functional use of the space between buildings. Based on the renderings provided on Sheets G0.04 – G0.06, the proposed development appears visually prominent and the siting, massing, and design of the buildings would not avoid or minimize obstruction of public coastal views. The renderings do not appear to adequately screen or visually subordinate the proposed structures within the landscape context. As noted in Item B.76 through B.79. in the Initial Inconsistencies Letter, the siting of residential buildings along the hillside and ridgelines, with proposed heights ranging from approximately 20 to 91 feet, would result in visually prominent development when viewed from multiple public vantage points, including from the west, east, south, and north. The current submittal does not include sufficient visual analysis, simulations, or line-of-sight studies to demonstrate that coastal views would be preserved or that visual impacts would be minimized consistent with LCP requirements. Additionally, as discussed in Item B.97 in the Initial Inconsistencies Letter, constraints related to floodplain areas and creek setbacks may influence building placement and grading; however, the submittal does not demonstrate how these constraints have been integrated into a site design that protects visual resources or avoids placing structures in highly visible or sensitive locations. Based on the information provided, the project is inconsistent with this Design Guidelines policy related to site improvements and building location.
3. Guideline I.A.3. states, “exterior lighting should be subdued, and should enhance building design as well as provide for safety and security. Lighting which creates glare for occupants or neighbors should not be used. In general, large areas should be illuminated with a few low shielded fixtures.
Tall fixtures which illuminate large areas should be avoided”. The project Sheet L2.00 includes a lighting plan with the following note: “Note: See HLB’ DRAWING FOR LIGHTING ENLARGEMENT PLANS AND LIGHT FIXTURE SELECTION”; however the noted drawing is not found in the materials submitted. Without these specific lighting details, the project is potentially inconsistent with this policy.
4. Guideline I.A.4. states, “exterior trash and storage areas, service yards, landing docks and ramps, electrical utility boxes, etc., should be screened from view of all nearby streets and adjacent
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structures in a manner that is compatible with building and site design. Such facilities should be conveniently located, but must not interfere with circulation or parking on the site”. The project plans do not identify the location or appearance of exterior trash and storage areas, service yards landing docks and ramps, electrical utility boxes, etc. Therefore, due to the lack of information, the project is potentially inconsistent with this design guideline.
5. Guideline I.A.5. states, “the visual impact of parking areas should be minimized when appropriate to the site by locating parking areas to the rear or side of the property, rather than along street frontages. Ample landscaping should be used to help screen parking areas from both exterior and interior views.” As proposed, multiple parking areas are located in visually prominent portions of the site, including along the eastern property boundary and adjacent to hillside development areas, and may be visible from surrounding public and private vantage points. The submitted plans do not clearly demonstrate that parking areas have been sufficiently integrated into the site design to minimize visual impacts within the coastal hillside context. In addition, the current submittal does not adequately demonstrate that ample landscaping, berming, or screening treatments have been incorporated to soften and screen the proposed parking areas from exterior and interior views. Further, inconsistencies remain between the landscape, irrigation, and civil plans, including overlap between proposed wetland planting areas and parking improvements, resulting in uncertainty regarding the final configuration and screening of parking facilities. Therefore, the current project submittal is not consistent with this Design Guideline.
6. Guideline I.A.6. states, “consideration should be given to security and safety concerns in the location and design of parking areas”. The project proposes multiple parking areas that appear physically separated from the primary development areas, including the parking lot located along the entry road nearthe intersection of Reina del Mar Avenue and Highway 1, as well asthe parking area along the eastern edge of the East Parcel adjacent to the wetlands. Based on the materials submitted, it is unclear how these parking areas are intended to function with respect to pedestrian and vehicular safety. The plans do not clearly identify whether traffic-calming measures, pedestrian crossings, speed-reduction features, lighting, wayfinding, or other safety and security improvements are proposed to address potential conflicts between vehicles and pedestrians accessing the parking areas and project site. As a result, there is insufficient information to determine whether the project is consistent with this Design Guideline and the project is potentially inconsistent.
7. Guideline I.A.6. states, “in projects which feature phased construction, each phase of the design should be completed in its functional, traffic, visual, drainage, and landscaping aspects to the maximum extent possible”. The submitted phasing plans do not clearly identify or depictsufficient information regarding how each phase of construction would function independently with respect to circulation, drainage, landscaping, and overall site operations. As proposed, the phasing plans do not clearly demonstrate the extent of interim improvements, temporary conditions, or how unfinished portions of the site would be managed during each construction phase. Therefore, due to the lack of information provided within the phasing plans, the project is potentially inconsistent with this Design Guideline.
8. Guideline I.A.7. states, “in projects which feature phased construction, each phase of the design should be completed in its functional, traffic, visual, drainage, and landscaping aspects to the maximum extent possible. The submitted phasing plans do not clearly identify how grading, circulation, drainage, landscaping, retaining features, parking areas, and othersite improvements
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would function independently during each phase of construction. In addition, the current submittal does not adequately demonstrate the extent of interim grading conditions, temporary erosion control measures, drainage infrastructure, or visualscreening that would be implemented throughout phased development of the site. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline.
9. Guideline I.A.8. states that “Where significant amounts of grading are required, contours should be graded to blend with those of adjacent properties. Contours should be rounded on both cut and fill slopes, horizontally and vertically”. The project submittal does not adequately demonstrate that the proposed grading has been designed to integrate with the existing natural topography and surrounding hillside conditions. As proposed, the project includes substantial grading associated with hillside development, building pads, retaining walls, access improvements, and related site infrastructure, which may significantly alter the existing landform characteristics of the site. The plans and supporting materials do not clearly demonstrate how the proposed cut and fill areas have been designed to visually blend with adjacent properties and existing contours, nor do they adequately illustrate whetherslope transitions have been rounded and softened both horizontally and vertically to reduce the appearance of manufactured grading. Additionally, the submittal does not provide sufficient visual analysis, grading detail, or cross-sectional information to evaluate whether the proposed grading would preserve the natural hillside character or minimize visual scarring when viewed from adjacent properties, public roadways, or surrounding open space areas. Therefore, based on the information provided, there is insufficient evidence to determine consistency with this Design Guideline, and the project is potentially inconsistent with this Design Guideline.
10. Guideline I.B.1. states, “[t]he style and design of new buildings should be in character with that of the surrounding neighborhood. This does not mean that new buildings should be identical to existing buildings on neighboring lots, but that new buildings should complement, enhance, and reinforce the positive characteristics of surrounding development. This can be accomplished by incorporating the dominate architectural features of an area into the design of new development.
Such features may include bay windows, chimneys, balconies, porches, roof shapes, and other architectural details and materials...” The proposed building design does not clearly reflect or incorporate the prevailing architectural character and established design patterns of the surrounding neighborhood. The project introduces building forms, massing, and architectural elements that may be inconsistent with the scale, articulation, and visual character of nearby development and may not sufficiently incorporate complementary neighborhood features that would help reinforce the existing characteristics of the surrounding development. As proposed, the project could appear visually distinct from the surrounding residential context without additional design modifications or architectural detailing to better integrate with the character of the neighborhood. Therefore, the project is potentially inconsistent with this design guideline.
11. Guideline I.B.2. states, “an important aspect of design compatibility is scale. Scale is the measure of the relationship of the relative overall size of one structure with one or more other structures.
Scale is also used to refer to a group of buildings, a neighborhood, or an entire city. A development can be "out of scale" with its surroundings due to its relative height, bulk, mass, or density. A structure which is out of scale with its site and neighborhood threatens the integrity of the overall streetscape, and residential projects, particularly single-family dwellings, which are much larger than neighboring structures are therefore discouraged. The City's height limitation is a maximum
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only, and the maximum height may often be inappropriate when considered in the context of surrounding development and topography. The "carrying capacity" of a given site is also an important factor in determining appropriate scale and lot coverage. As with the height limitation, the City's lot coverage limitation is a maximum only.” As depicted in the renderings on Sheets G0.04 – G0.06, the proposed residential buildings appear visually prominent along the hillside and ridgeline and do not demonstrate that the siting, massing, and design of the structures would minimize visual impacts or be visually subordinate to the surrounding landscape context. As discussed in Items B.76 through B.79 of the Initial Inconsistencies Letter, the proposed buildings, ranging in height from approximately 20 to 91 feet, may appear out of scale with the surrounding neighborhood, natural landforms, and existing development pattern when viewed from multiple public vantage points. In addition, the current submittal does not include sufficient visual analysis or studies to demonstrate that visual impacts and obstruction of public coastal views would be minimized consistent with applicable Design Guidelines and LCP requirements. Therefore, the project is inconsistent with this design guideline.
12. Guideline I.B.3. states, “Use architectural features and details to help create a sense of human scale. Wall insets, balconies, window projections, etc. Are examples of building elements which may help reduce the scale of larger buildings”. The project submittal does not adequately demonstrate that the proposed architectural design incorporates sufficient detailing or articulation to reduce the perceived scale and massing of the proposed structures. As depicted in the submitted elevations and renderings, portions of the buildings appear to include large uninterrupted wall planes and visually prominent building forms that may not sufficiently incorporate architectural features or modulation to create a sense of human scale or compatibility with the surrounding neighborhood context. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline.
13. Guideline I.B.5. states, “Building color should be compatible with the neighborhood and should reinforce and complement the visual character of the building's environment. Multiple colors applied to a single building should relate to changes of material or form.” The project submittal does not adequately demonstrate that the proposed building colors and material palette would be compatible with the surrounding neighborhood or visually integrated with the existing landscape and hillside environment. In addition, the current submittal does not provide sufficient information regarding final color treatments, material transitions, or how the proposed color palette would reduce visual prominence and complement the surrounding setting. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline.
14. Guideline I.B.7. states, “all exposed mechanical and electrical equipment must be screened from public view. The design of such screening should be an integral part of the building design”. The project submittal does not adequately demonstrate that all proposed mechanical and electrical equipment would be fully screened from public view or integrated into the overall architectural design of the project. The current plans and renderings do not clearly identify the location, extent, or screening treatment for all rooftop, exterior, or utility-related equipment. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline.
15. Guideline I.B.8. states, “[t]here should be architectural consistency among all building elevations.
All elevations need not be identical, but a sense of overall design continuity must occur. Window treatment and trim, for example, should be carried out around the entire building, not just on the
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most visible sides”. The project submittal does not adequately demonstrate architectural consistency and continuity across all building elevations. The current submittal does not include sufficient detail regarding final colors, materials, trim treatments, or architectural finishes to demonstrate a cohesive and integrated building design. In addition, the proposed fenestration patterns, window sizes, and architectural articulation appear to vary between elevations and do not clearly demonstrate consistent architectural treatment throughout the project. As proposed, portions of the buildings may contain reduced detailing or inconsistent façade treatment when compared across elevations. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline.
16. The Design Guidelines establish guidelines for Landscaping related to site design, visual integration,screening, plantselection, parking area landscaping,retention of existing landscape features, and long-term landscape functionality. The current project submittal does not provide sufficient information to evaluate consistency with the Landscaping Design Guidelines. The submittal does not include sufficient detail regarding final landscape design, planting plans, irrigation systems, screening treatments, tree protection measures, or long-term maintenance provisions. Specifically, the proposed wetland areas do not include sufficient planting details or plant palette information to evaluate compatibility with wetland restoration and landscape objectives. Turf areas are not clearly quantified by area, and the submittal does not adequately demonstrate compliance with applicable water conservation landscape requirements. In addition, required tree staking details are not provided consistent with the Design Guidelines. The bioretention plans reference associated civil plans for implementation details; however, the civil plans indicate that portions of the work are to be completed by others, resulting in unclear or incomplete coordination between plan sets. Further inconsistencies appear within the irrigation and landscape plans, including wetland areas overlapping with proposed parking areas and wetland planting areas overlapping with existing trees that do not appear to be wetland species.
Additionally, the current submittal does not adequately demonstrate how landscaping would be integrated to reduce visual impacts associated with the proposed hillside development, grading, parking areas, retaining features, and visually prominent building massing. The submittal also does not clearly demonstrate retention and integration of existing landscape features or how landscape treatments would complement the scale and visual character of the surrounding environment. Therefore, based on the information provided, the project is potentially inconsistent with the applicable Landscaping Design Guidelines.
17. The Design Guidelines establish Planning Design guidelines related to water conservation, turf limitations, plant selection, irrigation efficiency, and landscape functionality. The current project submittal does not provide enough information to evaluate consistency with the applicable water conservation, turf limitations, plantselection, irrigation efficiency, and landscape functionality guidelines. While the landscape plans quantify proposed turf areas, the submittal does not clearly identify the overall percentage of turf and water-intensive landscape areas relative to the total landscaped area to demonstrate compliance with the maximum allowable turf limitations. In addition, the submittal does not adequately demonstrate that proposed plant species and turf areas have been selected and organized to minimize water use consistent with the coastal climate and water conservation objectives of the Design Guidelines. Further, the landscape and irrigation plans do not clearly demonstrate differentiated watering zones, coordinated irrigation design, or how landscape areas have been planned to address the functional, environmental, and aesthetic conditionsspecific to the site. Additional inconsistencies
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remain within the landscape and irrigation plans, including wetland planting areas overlapping with parking areas and existing non-wetland tree species. Therefore, based on the information provided, the project is potentially inconsistent with the applicable Planning Design Guidelines related to water conservation, landscape planning, and irrigation design
18. The Design Guidelines establish Irrigation guidelines related to water conservation, irrigation efficiency, runoff prevention, irrigation zoning, and long-term landscape maintenance. The current project submittal does not provide enough information to evaluate consistency with the applicable Irrigation Design Guidelines. The submitted irrigation plans do not clearly demonstrate that the proposed irrigation system has been designed to minimize water use, prevent runoff, and provide appropriate irrigation rates and watering zones based on plant type and site conditions.
In addition, the submittal does not include sufficient information regarding irrigation scheduling, precipitation rates, application rates, soil testing, or irrigation controller operations to evaluate consistency with the Design Guidelines. Further, the irrigation plans do not clearly demonstrate separation of turf and non-turf irrigation zones or how irrigation design has been coordinated with proposed wetland, bioretention, and landscape areas. Inconsistencies remain within the irrigation and landscape plans, including wetland areas overlapping with parking areas and existing non-wetland tree species, which raises questions regarding irrigation coordination and planting functionality. Additionally, the plans do not adequately demonstrate how overspray onto paved areas would be avoided or how the irrigation system would be integrated with the proposed grading and drainage design. Therefore, based on the information provided, the project is potentially inconsistent with the applicable Irrigation Design Guidelines.
19. The Design Guidelines establish guidelines related to soils, decorative use of water, maintenance, and miscellaneous landscape treatments intended to support water conservation, infiltration, long-term landscape health, and functional site design. The current project submittal does not provide enough information to evaluate consistency with the applicable Design Guidelines. The submittal does not include sufficient information regarding soil testing, soil amendments, mulch application, or soil preparation methods to evaluate whether the proposed landscape and irrigation design would adequately support water retention, infiltration, and long-term plant health consistent with the Design Guidelines. Therefore, based on the information provided, the project is potentially inconsistent with the applicable guidelines related to soils, decorative use of water, maintenance, and miscellaneous landscape treatments intended to support water conservation, infiltration, long-term landscape health, and functional site design. In addition, the current plans do not clearly demonstrate how long-term maintenance of the irrigation system, landscaped areas, wetland planting areas, and bioretention features would be implemented and coordinated. The submitted plans also do not adequately demonstrate how porous paving materials, infiltration strategies, or other water-conserving site treatments have been incorporated into the project design to minimize runoff and improve groundwater infiltration where appropriate. Further inconsistencies remain between the landscape, irrigation, and civil plans, including overlapping wetland planting areas, parking improvements, and existing non-wetland tree species, resulting in uncertainty regarding the longterm functionality and coordination of the proposed landscape and drainage systems. Therefore, based on the information provided, the project is potentially inconsistent with the applicable Design Guidelines related to soils, maintenance, and water-conserving site design.
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20. Guideline II.2.A.1 states, “[m]any of the hillside show areasshow signs of instability through creep and slippage. Drainage and erosion potential are also problems associated with hillside development. (a) Obtain input from a geologist or soils engineer early in the design process. A geotechnical report may be required. (See Administrative Policy Nos. 29 and 34.) (b) Avoid construction near geologically fragile or unstable areas. (c) Use engineering techniques, such as drainage swales and channels, catch basins, and French drains to direct runoff. (See Engineering Standards 300 series.) (d) Use landscaping techniques such as netting, hydro seeding, and selection of plants which have root systems which aid in stabilizing the soil.” The current project submittal does not adequately demonstrate consistency with this Design Guideline. As proposed, the project includes substantial hillside and ridgeline development, grading, retaining features, roadway improvements, and site disturbance within areas potentially subject to slope instability, erosion, and drainage constraints. While a Geotechnical Report has been provided, the current submittal does not adequately demonstrate that all proposed development areas avoid geologically fragile or unstable areas to the maximum extent feasible, nor does it sufficiently demonstrate how drainage facilities, erosion control measures, and slope stabilization techniques have been integrated into the project design. In addition, the Geotechnical Report does not include a plan describing infiltration testing and detention basin locations following grading activities, and does not confirm whether there are known nearby sources of soil contamination that may affect infiltration feasibility. Further, the current submittal does not include sufficient information regarding revegetation, hydroseeding, netting, erosion control planting, or other landscaping measures intended to stabilize disturbed slopes and reduce erosion potential.
Various environmental and technical studies will be required as review of the application continues to evaluate slope stability, drainage, stormwater management, and erosion impacts.
Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline related to slope instability and erosion.
21. Guideline II.2.A.2 states, “Large amounts of cut and/or fill are unattractive on hillsides, and can have a detrimental impact on the immediate and surrounding environment.(a) Structures should relate to and follow site topography to work with the slope, not against it. (b) Whenever feasible, buildings and roads should be sited to align with existing contours of the land. (c) Retaining walls should be avoided or, if necessary, their height should be reduced to the minimum feasible. (d) Avoid one-level solutions which would result in excessive lot coverage and more disruption of the site. Multi-levelstructures which step down the slope can help minimize cut and fill.” As proposed, the project appears to require substantial grading, excavation, retaining features, and alteration of the existing hillside topography to accommodate the proposed building pads, access improvements, and site development. The submittal does not clearly demonstrate that the proposed structures, roads, and site improvements have been designed to align with existing contours or minimize cut and fill to the maximum extent feasible. In addition, the current plans do not adequately demonstrate that retaining walls and other structural hillside interventions have been minimized or integrated into the site design to reduce visual and environmental impacts, nor do the plans clearly specify the proposed retaining wall heights throughout the site.
Further, the submittal does not clearly identify or quantify the amount of lot coverage associated with the proposed hillside development or demonstrate how the project avoids excessive site disruption and grading consistent with the intent of the Design Guidelines. Based on the information provided, portions of the development appear visually prominent and may reflect development patterns that work against, rather than with, the existing slope and natural
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landforms. Therefore, based on the information provided, the project is inconsistent with this Design Guideline.
22. Guideline II.2.A.3 states, “Development on hillsides and ridges is often visible to neighbors and other residents in the vicinity, as we 11 as those at a distance, such as motorists traveling on Highway 1. Hillside development also has the potential to block or impair established. views from existing development. (a) Locate development below ridges and hill tops so that ridgelines are left open. Avoid linear arrangements of buildings. (b) Building forms, particularly roof forms, should complement the contours and slopes of the hillside to increase structure and site integration. (c) Buildings should be designed with low profiles. In some cases, low-pitched roofs and hip ends may be desirable. (d) Massive roof overhangs and building cantilevers on downhill faces should be avoided where site conditions allow. Terracing into the hillside will help reduce the impact of the bulk of the structure. Long pole supports on downhill faces are to be avoided. (e) Multi-level designs which conform to the hillside are encouraged, but careful planning is required to avoid excessive height. Although generally discouraged, very low pitched or flat roofs may be considered if no other solution is feasible. The horizontal potential of a site should be fully exploited before increasing building height. (f) Landscaping should be used as necessary to help soften building appearance. Place larger trees and shrubs at lower levels of a site to screen views from below, while allowing views from buildings above. Locate fast-growing material near blank walls. (g) Where feasible, locate new buildings to minimize view blockage from primary viewing areas, (i.e., living and dining rooms, decks) of existing development. As a tool to minimize view blockage, emphasize the quality of the view (i.e., framed view corridors) from new development, instead of the quantity of the view (i.e., sweeping panorama).” As depicted on Sheets G0.04 – G0.06, development on the Western Parcel situates the proposed residential buildings along the hillside and ridgeline in a manner that appears visually prominent from western, eastern, southern, and northern vantage points, including from Highway 1 and Sharp Park. As noted in the Initial Inconsistencies Letter, the residential buildings are sited on the hillside and ridgelines with proposed heights varying from approximately 20 to 91 feet, resulting in visually prominent development that does not clearly demonstrate preservation of ridgelines, minimization of view impacts, or integration with the natural landforms of the site. The submitted renderings also do not appear to demonstrate sufficient landscaping or screening to visually soften or integrate the proposed buildings into the surrounding hillside context. Further, the current submittal does not include sufficient visual analysis, view corridor studies, cross-sections, or other supporting information to demonstrate that visual and view impacts from surrounding public and private vantage points have been minimized. Therefore, based on the information provided, the project is inconsistent with this Design Guideline due to the visual prominence of the proposed hillside development and insufficient information demonstrating minimization of visual and view impacts.
23. Guideline II.2.A.4 states, “Vehicular access and circulation in hillside development can often be unsafe or dangerous due to excessive slope and lack of adequate sight distance. (a) Driveways and access roads should follow the contours of the hillside rather than cut through them. (b) Wherever possible, roads and drivewaysshould be designed with lessthan the maximum slope allowed by City standards. (See Engineering Standard 102A.) (c) While safe ingress and egress must be provided, circulation should depend on a minimum number of roadways. (d) Onstreet parking turnouts should be provided where appropriate. (See Engineering Standard 111.) (e) Driveway lengthsto accommodate a parked vehicle are encouraged.” As proposed, the project
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introduces hillside roads, driveways, and circulation improvements that appear to require substantial grading and hillside alteration to accommodate vehicular access. The current submittal does not clearly demonstrate that proposed driveways and access roads follow the natural contours of the hillside or minimize excessive slope conditions to the maximum extent feasible. In addition, labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, and delineation of existing and proposed street improvements have not been adequately provided. The plans also do not include sufficient grading analysis, roadway profiles, or sight distance information to demonstrate that safe vehicular circulation and ingress/egress can be achieved consistent with the intent of the Design Guidelines and applicable City engineering standards. Further, various technical studies, including a Transportation Study, will be required as review of the application continues. As there is insufficient information to determine whether the project complies with applicable block size, street spacing, roadway design, and circulation requirements, the project is potentially inconsistent with this Design Guideline.
24. Guideline II.2.D.1 states, “One of the primary concerns in the Coastal Act is the preservation of ocean views for the public. (a) New development within the coastal view shed should not impair views to the sea from public roads, trails, and vista points. This can be achieved by limiting the height of structures to below the sight line, clustering structures to protect view corridors, careful placement of landscaping to shield structures while leaving the view unobstructed, using naturalappearing materials and colors, limiting outdoor lighting, and undergrounding utilities. (b) Development should be subordinate to coastal topography. The height and mass of the structures should be limited, and clustering of structures is encouraged in order to achieve development which is unobtrusive and visually compatible with landforms.” As depicted on Sheets G0.04 – G0.06, the proposed residential development on the Western Parcel issited along the hillside and ridgeline in a manner that appears visually prominent from multiple public vantage points, including Highway 1 and Sharp Park. The proposed structures, with heights ranging from approximately 20 to 91 feet, do not clearly demonstrate that development has been clustered, lowered below primary sight lines, or otherwise designed to preserve and minimize impacts to public coastal views and view corridors. In addition, the submitted renderings and plans do not adequately demonstrate that the proposed building massing, roof forms, landscaping, materials, grading, and retaining features would be visually subordinate to the surrounding coastal topography or sufficiently integrated into the natural landforms of the site. Further, the current submittal does not include sufficient visual analysis, view corridor studies, landscaping details, lighting analysis, or utility undergrounding information to demonstrate that visual impacts to the coastal viewshed have been minimized consistent with the intent of the Design Guidelines.
Therefore, based on the information provided, the project is inconsistent with this Design Guideline due to the visual prominence of the proposed hillside development and insufficient information demonstrating preservation of public coastal views and compatibility with the surrounding coastal landscape.
25. Guideline II.2.D.2 states, “There are relatively few public accessways to the beach within the City. (a) Public access from the nearest roadway to the shore to the shoreline and along the coast should be provided in new development except as otherwise specified in the City's adopted, Local Coastal Program Land Use Plan. New development should plan for such access early in the design process”. As discussed underItem B.4. in the Initial Inconsistencies Letter,the submittedmaterials lack sufficient detail and contain internal inconsistencies regarding the project’s proposed Public
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Open Space and Recreation components. The plans identify multiple parking areas along the eastern property line and adjacent to the area labeled “INDIGENOUS LAND RESERVATION, TO BE DETERMINED (NOT IN SCOPE)” on Sheet G1.02; however, the submittal does not specify whether these parking areas are intended for public use, private use, or both. In addition, the plans do not adequately identify roads, paths, accessways, or circulation routes as public or private, nor do they demonstrate how public access to the shoreline or along the coast would be provided or connected to the proposed development. Further, the current submittal does not include sufficient access analysis, circulation details, easement information, or delineation of existing and proposed improvements to evaluate consistency with the intent of the Design Guidelines and applicable Local Coastal Program requirements. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline.
26. Guideline II.2.D.3 states, “Existing vegetation the coastal area is often fragile and has little resistance to human trampling. New landscaping requires special attention because of the limited plant palette of the coastal environment. (a) Trails and beach accesses across native coastal vegetation should be designed to protect the vegetation from trampling and scarring. (b) Vegetation cover on steep slopes should be left undisturbed. (c) Areas remaining undeveloped should be revegetated with native coastal vegetation. (d) Where necessary, new development should incorporate means to prohibit motorized vehicles from areas covered with native coastal vegetation.” As proposed, the project includes substantial hillside development, grading, circulation improvements, and landscape alterations within coastal hillside areas containing existing vegetation and steep slopes. The proposed project does not clearly demonstrate that vegetation on steep slopes would remain undisturbed to the maximum extent feasible or that trails, accessways, and circulation improvements have been designed to minimize impacts to native coastal vegetation. In addition, the submitted plans do not adequately identify existing native vegetation proposed for retention, revegetation areas, or long-term restoration and protection measures for undeveloped portions of the site. Further, inconsistencies remain between the landscape, irrigation, grading, and civil plans, including wetland planting areas overlapping with parking improvements and existing non-wetland tree species, resulting in uncertainty regarding the long-term viability and coordination of the proposed landscape and habitat areas. The current submittal also does not clearly demonstrate what measures, if any, are proposed to restrict unauthorized vehicular access into sensitive vegetated or undeveloped coastal areas. Additionally, future biological studies will be required to determine whether the proposed replanting plan on Sheet L3.00 adequately protects and restores native coastal vegetation consistent with the intent of this policy. Therefore, the proposal is inconsistent with this Design Guideline.
27. Guideline II.2.D.4 states, “The coastal climate can be severe and must be considered in the site planning and design of coastal development. Wind blown sand can compound weather-related problems. (a) Corrosive resistant materials should be used, with good quality roofing. Use of 25- year asphalt shingles is encouraged. Non-protected metals exposed to elements should be avoided. Tight fitting doors and windows are essential. Use of more than the. minimum amount of required insulation is encouraged. (b) Entryways should be located away from direct exposure to wind, or should be protected with screening and overhangs. (c) If built-in planters are part of the design, they should be well secured and located above grade to protect against wind and sand.” The submitted plans and architectural materials do not clearly identify the proposed exterior material specifications, corrosion-resistant treatments, roofing materials, insulation
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measures, or weather protection features necessary to evaluate the project’s responsiveness to the coastal environment. In addition, the submittal does not adequately demonstrate that entryways, building orientations, overhangs, screening features, or other architectural elements have been designed to minimize direct exposure to coastal wind and weather conditions. Further, the current plans do not clearly identify whether built-in planters or similar landscape features would be secured and designed to withstand coastal wind and sand conditions. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline due to insufficient information demonstrating that the proposed development has been adequately designed to respond to the coastal climate and environmental conditions.
28. Guideline II.2.D.5 states, “The shoreline is subject to erosion, landslides, and other geotechnical problems of varying intensity. To conserve soil and protect people and property from such hazards, special design considerations are necessary. (a) A geotechnical reportshall be prepared for all new coastal development on bluff-tops or steep parcels. (See Administrative Policy Nos. 29 and 34.) (b) Buildings shall be set back an adequate distance from bluff edges to ensure the safety of the structures during their design life. (See Pacifica General Plan Seismic Safety Element and Geotechnical Standards.) (c) Proper drainage controls shall be incorporated into site design to minimize the potential for runoff and erosion. (d) Excessive grading should be avoided. Structures should be designed to work with the natural slope of the site. (e) Choice of plant materials should give consideration to the need for erosion control and bluff stability.” As proposed, the project includes substantial hillside and ridgeline development, grading, retaining features, and site disturbance within steep coastal terrain potentially subject to erosion, slope instability, flooding, and geotechnical constraints. The proposed project does not clearly demonstrate that proposed structures, roads, retaining walls, drainage facilities, and site improvements have been adequately designed to minimize excessive grading, erosion, runoff, or instability hazards, or to work with the natural slope of the site. In addition, the plans do not adequately identify retaining wall heights, bluff setback relationships, infiltration testing locations, post-grading detention basin locations, or whether site conditions or potential soil contamination may limit infiltration feasibility. Further, the proposed project may be potentially inconsistent with Coastal Zone Combining District and Hillside Preservation District regulations restricting development within hazardous areas. The technical reports submitted, including the Geotechnical Report, 2017 FEMA Flood Insurance Map, and 1996 Reclamation Plan, do not include sufficiently recent or comprehensive analysis regarding sea level rise, coastal hazards, bluff stability, stormwater management, drainage, erosion control, or coastal resource impacts. Various environmental and technical studies will be required as review of the application continues, and additional inconsistencies may be identified through future analysis. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline and associated General Plan and Municipal Code requirements related to coastal hazards, drainage, and geotechnical safety.
29. Guideline II.2.E.1 states, “[t]he arrangement and orientation of buildings within a multi-unit development has an important impact on the overall design effect in terms of massing and bulk, and also affects privacy and energy consumption. (a) Building orientation should be varied to provide usable exterior spaces between structures and to avoid instances where living spaces of one structure face living spaces of another and reduce privacy. (b) Private outdoor space should be located on the southern building exposure to gain the maximum amount of sunlight wherever feasible. (c) Buildings should be oriented to maximize southern exposure to window areas to
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encourage passive solar heating in winter months. (d) Buildings should be oriented to create courtyards and open space areas. (e) Linear arrangement of buildings should be avoided and setbacks should be varied. This can be accomplished through the staggering of buildings or clustering in groups of varied numbers”. As proposed, the arrangement and orientation of the residential buildings appear to create visually prominent and linear development patterns along portions of the hillside and ridgeline. The current submittal does not clearly demonstrate that building siting and orientation have been designed to maximize functional open space and courtyard areas or vary setbacks and building placement to reduce perceived bulk and massing.
In addition, the submitted plans do not sufficiently demonstrate how building orientation would maximize southern exposure, passive solar opportunities, or usable exterior spaces consistent with the intent of the Design Guidelines. Further, the current submittal does not include sufficient site planning analysis, cross-sections, or supporting studies to demonstrate that building clustering, staggering, and open space design have been integrated to minimize visual and massing impacts within the hillside context. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline.
30. Guideline II.2.E.2 states “variety is a key ingredient in the appearance of multi-unit developments.
Developments which feature a series of identical structures are visually monotonous and are not acceptable. (a) Building design should incorporate variety in the type of materials, colors, and heights while maintaining a cohesive style. (b) Building design should take into account the existing character of a neighborhood and incorporate its positive elements. (c) Building height should be varied by including one and two-story units in the development, by using a variety of complementary roof pitches and angles, or by varying grade. (d) Avoid locating buildings with similar facades close together. (e) In row-type townhouse or single-family dwelling developments, units should be varied in setback and height to provide visual relief”. As proposed, the residential development appears to include repetitive building forms and similar massing patterns across portions of the hillside and ridgeline development area. As discussed in prioritemsrelated to scale and visual impact, the proposed residential buildings range in height from approximately 20 to 91 feet and appear visually prominent from multiple public and private vantage points. The current submittal does not clearly demonstrate sufficient variation in building setbacks, heights, roof forms, façade articulation, colors, or materials to provide visual relief, reduce perceived bulk and massing, or minimize the appearance of repetitive development patterns. In addition, the submitted plans do not adequately demonstrate how the proposed building design incorporates or responds to the existing character and positive design elements of the surrounding neighborhood and coastal hillside context. Further, the current submittal does not include sufficient detail regarding final materials, color palettes, architectural treatments, or visual analysis to demonstrate that the project would achieve cohesive yet varied multi-unit design consistent with the intent of the Design Guidelines. Therefore, based on the information provided, the project is inconsistent with this Design Guideline.
31. Guideline II.2.E.3 states, “Multi-unit developments can result in a significant traffic increase in a given area, placing an additional burden on the capacity of existing streets to handle through traffic and on-street parking. Such developments all so often require a large number of on-site parking spaces. (a) Access should be planned to have the (b) least impact on existing residential streets. Requirements of the City's Fire Services Division regarding and turnaroundsshould be early in the design process driveways considered (c) Parking areas should be screened with fencing, planting, or berming. Planting islands should be provided in parking areas to provide visual relief
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and shade. (d) Parking spaces should be provided as close to their associated units as possible”.
As proposed, the project introduces substantial hillside circulation improvements, parking areas, and access roads that may increase traffic and circulation impacts within the surrounding area.
The current submittal does not clearly demonstrate that vehicular access and circulation have been designed to minimize impacts on existing residential streets or that roadway, driveway, and turnaround configurations have been fully coordinated with applicable Fire Services and engineering requirements. In addition, labeling of streets, roads, paths, and parking areas as public or private, as well as delineation of existing and proposed roadway improvements, has not been adequately provided within the submitted plans. Further, the current submittal does not adequately demonstrate that proposed parking areas would be sufficiently screened with landscaping, berming, or fencing to minimize visual impacts within the hillside and coastal context. The plans also do not clearly demonstrate provision of planting islands, shade elements, or integrated landscape screening within parking areas. Additional technical studies, including a Transportation Study, will be required as review of the application continues. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline.
32. Guideline II.2.E.4 states “Because multi-unit developments are larger than other types of development, landscaping requirements are more demanding. Although the "Landscaping" section of these guidelines applies to multi-unit developments, the following guidelines are of particular importance to such developments. (a) Landscaping for multi-unit developments should be chosen not only for aesthetic reasons, but also for the functional aspects of providing screening, appropriate shading, and defining recreation areas. (b.) A variety of plant sizes should be used, including many trees and more than the minimum size 24-inch or 36-inch box trees). (c.) Landscape maintenance is crucial in shrubs (i.e.,. large projects, and a bond or similar guarantee may be required to ensure the continued health of landscaping. (d.) Where appropriate,street treesshould be provided”. The proposed plans do not clearly demonstrate that the landscaping has been designed to adequately screen parking areas, retaining features, circulation improvements, and visually prominent hillside development. In addition, the current submittal does not adequately identify the use of varied plant sizes, large-scale tree planting, or enhanced landscape treatments necessary to soften the appearance of the proposed multi-unit development within the coastal hillside context. Required tree staking details and sufficient information regarding long-term landscape maintenance and guarantees have also not been adequately provided. Further, inconsistencies remain between the landscape, irrigation, grading, and civil plans, including wetland planting areas overlapping with parking improvements and existing non-wetland tree species, resulting in uncertainty regarding the long-term functionality and coordination of the proposed landscape design. The currentsubmittal also does not clearly demonstrate where street trees are proposed or how landscaping would define recreation and open space areas consistent with the intent of the Design Guidelines. Therefore, based on the information provided, the project is potentially inconsistent with this Design Guideline.
E. Pacifica Master Bicycle and Pedestrian Plan (Bike Ped Master Plan)
1. The Development Policies on page 19 of the Bike Ped Master Plan state, “...Pacifica currently requires new developments that affect public right-of-way to incorporate complete streets concepts at each stage of the development process. Right-of-way creation and modifications are reviewed against Metropolitan Transportation Commission (MTC) Complete Street directives.” The plans do not include labeling of streets on plan sets, exhibits, and details, identification of
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roads and paths as public or private. Delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, and easements) was not included. Various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine if the project proposes right-of-way creations and/or modifications and subsequently incorporates complete street concepts consistent with the MTC Complete Streets directives, the project is potentially inconsistent with this policy.
2. The Bike Ped Master Plan identifies a shared use path adjacent to Highway 1 along the project site. See excerpt from Figure ES-1: Priority Bicycle and Pedestrian Projects below. From the plans submitted, there is no proposed shared use path included; thus the project is inconsistent with this pathway identification.
3. Table 8: Pedestrian Recommendations – Vallemar/Fairway Park PPA identifies the location of Reina Del Mar/Highway 1 with the recommendation of, “Enhance pedestrian crossings, Calera Creek Trail access, and SamTrans access with crosswalk improvements, pedestrian refuge islands, and widened sidewalks.” From the plans submitted, there are no proposed details related to enhanced Calera Creek trail access; thus the project is inconsistent with this identified recommendation.
F. Rockaway Beach Specific Plan
1. Policy 2.1.1 Land Use Developmentstates, “Provide for visitorserving commercial activities which upgrade the physical character of the area.” The proposed residential only development does not provide any visitor serving commercial activities to upgrade the physical character of the neighborhood and is thus is inconsistent with this policy.
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2. Policy 2.1.7 Land Use Developmentstates, “Provide for cultural,social and recreational amenities and activities which enhance future vitality of the area”. Although the applicant’s project description purports to provide public open space, the application materials submitted are not clear on how the project will be providing recreational amenities, such as public open space, trail improvements, and cultural facilities (or not). As discussed in greater detail within Item B.4. in the Initial Inconsistencies Letter, recreational opportunities and the “Indigenous Memorial Park”, from the limited details provided in the plan set, it is not clear how the project provides recreational opportunities. Thus, the proposal is found to be inconsistent with this policy.
3. Policy 2.1.8 Land Use Development states, “Encourage public access and recreation activities for visitors consistent with the adopted Coastal Land Use Plan.” As detailed in thisletter and the Initial Inconsistencies Letter, the project is not consistent with the adopted Local Coastal Land Use Plan in multiple ways. Thus, the proposal is found to be inconsistent with this policy.
4. Policy 2.2.2 Circulation and Parking states, “All required parking within the Quarry Sub-Area shall be provided in well landscaped off-street facilities.” As discussed in greater detail in Item D.5 above, the current projectsubmittal does not adequately demonstrate that the proposed parking facilities have been designed and integrated as well-landscaped off-street facilities. Multiple parking areas are located in visually prominent portions of the site, including along the eastern property boundary and adjacent to hillside development areas, and the current plans do not clearly demonstrate sufficient landscaping, berming, or screening treatments to minimize visual impacts or soften views of parking areas from surrounding public and private vantage points. In addition, inconsistencies between the landscape, irrigation, and civil plans, including overlap between proposed wetland planting areas and parking improvements, create uncertainty regarding the final configuration and landscape screening of the parking facilities. Thus, the proposal is inconsistent with this policy.
5. Policy 2.2.3 Circulation and Parking states, “Achieve automobile and pedestrian connections between the Rockaway Beach community and future development on the quarry site.” The proposed trail improvements, and parking area dedications (private, public, or otherwise) do not provide clear extent and users of the trails, nor do the plans provide delineation or connectivity details between the Rockaway Beach community and the proposed development. As discussed in greater detail within Item B.4. and B.16 in the Initial Inconsistencies Letter, the application materials submitted are not clear on how the project will be providing trail connections or shoreline/coast access. Thus, the project is inconsistent with this policy.
6. Policy 2.2.4 Circulation and Parking states, “Provide for internal automobile circulation which enhances rather than detracts from the future vitality of the area.” The plans do not include labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, or delineations of existing and proposed street improvements. Various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine if the project enhances, rather than detracts from the future vitality of the area, the project is potentially inconsistent with this policy.
7. Policy 2.2.5 Circulation and Parking states, “Encourage an internal network of walkways and small scale pedestrian spaces including informal park-like areas, small plazas and beachfront recreation areas.” The plans do not include labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, or delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, and easements). In
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addition, various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine if the project is providing additional pedestrian facilities on this large site, the project is potentially inconsistent with this policy.
8. Policy 2.2.6 Circulation and Parking states, “Provide for a continuous bikeway and walkway system which will connect this area with adjacent coastal areas.” See Item G.5. about lack of plan details on connectivity to the coast area. The plans do not include labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, or delineations of existing and proposed street improvements. Various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine if the project is bike lanes to these design specifications, the project is potentially inconsistent with this policy.
9. Policy 2.3.1 Physical Appearance states, “Encourage high quality design in both public and private developments including buildings, landscaping, signing and street lighting.” See Item D.3. regarding lighting and D.13 regarding design related comments for the proposed building and landscaping. While Sheets SI.10 and SI-30 include some signage location renderings, they do not provide specific signage details orspecifications. Thus, the project is inconsistent with this policy.
10. Policy 2.3.3 Physical Appearance states, “Achieve relief from inclement weather in the design of public and semi-public improvements.” The plans do not include the labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, or delineations of existing and proposed street improvements(including but not limited to curbs and sidewalks, and easements. As there is not enough information to determine if (any) public and semi-public improvements were designed to achieve relief from inclement weather, the project is potentially inconsistent with this policy.
11. Figure 7, “Land Use Boundaries and Parking Locations” designates the site as “Visitor Commercial”, “Business Commercial” and “Open Space Recreation/Parking”. See Figure 7 excerpt below.
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Related, Section 3.1.1 “Relationship to General Plan and Coastal Land Use Plan” speaks directly to the project site as follows, “The Quarry is designated "Special Area" to promote integrated, planned and well-designed use of the site. Visitor se1ving commercial uses are encouraged, however, offices and neighborhood serving commercial activities are also permitted to add balance and to attract off-season users. It is recognized that a site the size of the Quarry property must include a mix of commercial uses, including those serving visitors and the local community as well as employment opportunities....”. Section 3.1.1 goes on further to state, “ The abovedescribed marina and residential uses are suggested in the LUP, but not required. The proposed mix of visitor-serving uses and business commercial uses will be refined following completion of a market study in conjunction with a review of a development plan for the Quarry. A mix of business commercial and visitor commercial usesis necessary to ensure success of the Development....” and “.... The Plan Conclusions state that visitor-serving commercial uses be given priority in the coastal areas. The proposed location of visitor-serving commercial uses in the Quarry gives such priority through the proposed beachfront location. The proposed project is inconsistent with these land use classifications and descriptions for the project site as it proposes residential only development, with no visitor, nor business commercial uses included as part of the proposal, as required by these land use classifications.
12. Figure 8, “Circulation Policy Diagram” denotes new roads, coastal pedestrian trails, beach parking, and a restroom on the project site. See Figure 8 excerpt below.
The plans submitted do not include a proposed beach parking area, restroom at the southern end of the project site, a new coastal trail along the western side of the project site, as required by this Diagram. As discussed in Item B.4. in the Initial Inconsistencies letter, , the plans do not include detail on how “the proposed new trail” would connect to existing public trails and the extent and users of the trail. In addition, the plans regarding paths, delineation of existing and
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proposed improvements and easements to trails and/or multi-use paths are not clear. As discussed in Item B.16 in the Initial Inconsistencies letter related to roadways, the plans as proposed do not indicate if proposed parking areas are public or private, or both. The plans do not include the labeling of streets on plan sets, exhibits, and details, ior delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, and easements. Variousstudies, including a transportation study will be required asthe City continues to process this application. Without these details and specifications, and from the limited details provided in the plan set, the proposed project is inconsistent with this Diagram.
13. Policy 3.3.1 Development Standards includes specific polices with which the project is inconsistent as set forth below:
a. Grading. Blend any proposed grading with the contours and contour round all proposed cut and fill slopes both horizontally and vertically. The project submittal does not adequately demonstrate that the proposed grading has been designed to blend with the existing natural landforms and adjacent properties and does not clearly demonstrate that cut and fill slopes have been designed to appear rounded or visually integrated with the surrounding terrain.
See discussion in Item D.9 above for more detail. Therefore, based on the information provided, the project may be potentially inconsistent with this Design Guidelines.
Landscaping. Size landscaping so that a mature appearance will be attained within a short period of time. The size of some of the trees may be required to exceed the usual minimum standards. Provide landscaping adjacent to Highway 1 in order to · provide an intense greenway that does not block coastal views from motorists. The City has established a tree planting and maintenance trust to provide larger trees. A coordinated landscape treatment shall be provided for the streets in Rockaway Beach. Sheet L3.00 includes details on the proposed trees and other landscaping to be planted, included a noted height. No growth information was provided to specify how long such tree/landscaping would take to grow to such noted height, thus not enough information to determine if a mature appearance will be attained within a short period of time. Sheet L3.00 indicates the series of existing trees/landscaping along the property's boundary to Highway 1, however no new additional landscaping appears to be proposed to provide an intense greenway that does not block motor vehicles. No coordinated street tree plan for Rockaway Beach was included. Therefore, the proposed project is inconsistent with this policy.
b. Intensity. The amount of grossfloor area allowable on each site shall not exceed the standards specified in the section dealing with development potential (page 16). It is also noted on page 16, relative to the project site: “As indicated in Figure 5, Existing Zoning, both the quarry property and the Headlands property have an overlay zoning designation of Hillside Preservation District (HPD). Pursuant to the City's Growth Control Ordinance, the HPD overlay cannot be deleted or revised during the life of the Growth Control Ordinance. The effect of the HPD is to limit land coverage and grading based on the average slope of a parcel and to stipulate a development process. The City's regulations for the Hillside Preservation District are herein incorporated by reference. Itshould also be noted that the property owner will likely request a Variance to exceed the maximum coverage permitted by the HPD regulations. Such Variances have been approved in the past for properties previously disturbed by quarry operations or severe grading activities. The quarry property is anticipated to be a prime area for commercial development because of its size, location, topography and coastal views”. As
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provided in above comment B.4.a proposed allowable site coverage is required to be calculated by parcel. Since the required site coverage and proposed site coverage have not been provided by parcel, in accordance with the HPD site coverage requirements the project is potentially inconsistent with this standard.
c. Parking. Quarry and Headlands: One (1) parking space for each 50 gross square feet of customer area, plus one (1) space for each 200 gross square feet of all other floor area. Sheet G0.01 notes a total grossfloor area of 1,214,100, thus 6,071 parking spaces would be required per this policy. As only 1,259 parking spaces are proposed, the project is inconsistent with this policy.
d. Building Design. Coordinate all facades of each building's exterior design with regard to color, materials, architectural form and detailing to achieve design harmony and continuity. All vents, gutters, downspouts, flashings, electrical conduits, etc., are to be painted to match the color of adjacent surfaces. See Item D.10 and D.11 above related to inconsistency with building scale and continuity with surrounding neighborhoods and the project’s overall building forms, Item D.12 related to inconsistency with architectural details, D.13 related to inconsistency with exterior colors and materials, and D.15 related to inconsistency with overall harmonious, consistent design throughout the development. Therefore, based on the information provided, the project is inconsistent with this component of the policy. e. Roofs. Gable or hip roofs are strongly encouraged on all buildings within the West Rockaway Beach subarea. This will give the area a special identity and minimize a bleak appearance as seen from the highway. Exposed mechanical systems should be screened so as to be unobtrusive. Coordinate roof shape, color, and texture with the treatment of the perimeter walls. From the elevation drawings submitted, several buildings have shed and/or flat roof parapet type designs and do not consistently propose a gable or hip roofline as encouraged by this policy. The project submittal does not adequately demonstrate that all proposed mechanical and electrical equipment would be fully screened from public view or integrated into the overall architectural design of the project. See Item D.20, D.23, D.25, D.28, and D.31 regarding design guidelines for roof form, shape, and materials and guidelines for how they should account for natural conditions and existing nearby uses. See Item D.14 for more detail regarding screening of rooftop mechanical equipment. Therefore, based on the information provided, the project is inconsistent with this component of the policy. f. Exterior Lighting. Shall be architecturally integrated with the building style, materials and colors. The project Sheet L2.00 includes a lighting plan with the “Note: See HLB’ DRAWING FOR LIGHTING ENLARGEMENT PLANS AND LIGHT FIXTURE SELECTION” however this drawing is not found in the materials submitted. Without these specific lighting details the project is potentially inconsistent with this policy.
g. Screening. Exterior trash and storage areas, service yards and utility boxes shall be screened from view of nearby streets and pedestrian areas. The project plans do not identify the location or appearance of exterior trash and storage areas, service yards landing docks and ramps, electrical utility boxes, etc. Therefore, due to the lack of information, the project may be inconsistent with this policy.
h. Signs. Maximum of 1 square foot of sign face for each 2 feet of street frontage. No roof signs will be permitted. No sign or lighting will move. Signs are encouraged to be placed on
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buildings; however, monument signs may be approved, if appropriate. While Sheets SI.10 and SI-30 include some signage location renderings, they do not provide specific signage details or specifications. Thus, the project is potentially inconsistent with this policy. See also above item B.9. regarding items of inconsistency pertaining to sign requirements.
14. Policy 3.3.2 Development Potential states, “The Quarry Sub-Area is characterized by steeply sloping areas, a seminatural creekway and highly sensitive oceanfront bluffs. This area is intended to have both destination visitor commercial activities and employment uses spread throughout the site but also being clustered so as to minimize impacts on natural amenities. The future development areas should be heavily landscaped to create a park-like setting. A maximum floor area to lot area ratio of 65% is deemed appropriate for the flatter portions of the site to achieve the above objectives. Increases to this maximum shall be considered if adequate parking is provided.” The proposed residential only development does not include any destination visitor commercial activities, nor employment uses. Overall floor area ratio is proposed at 32.3%. As such, the proposal is inconsistent with this policy.
15. Policy 3.3.3 Development Processing Procedures states, “All development in the Quarry and Headlands subareas is subject to the Hillside Preservation District (HPD) process, including City review and Specific Plan.” See Item B.3 and B.4 above, regarding comments related to the HPD and Development Plan processing requirements. As such, the proposal is inconsistent with this policy. Table 1 Summary of Development Potential notesthe projectsite to have a maximum total gross square footage (SF) of 2,125,000, with 850,000 SF for visitor commercial uses and 1,275,000 SF for business commercial uses. As the project proposes only residential uses, with no visitor or business commercial uses, it is inconsistent with this Table.
G. Complete Street Policy
1. Roadway Network Policy Serve All Users states,” Plan, design, build, and operate all transportation improvementsto supportsafe and convenient accessfor all users. Increase mobility for walking, bicycling and transit use wherever possible while promoting safe and accessible operations for all users.” Labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, and easements, was not included. Various studies, including a Transportation Study, will be required as the City continues to process this application. As noted in the Initial Inconsistencies Letter Item B.4., the application materials lack specificity and are inconsistent regarding the details of how the proposed trail improvements will be implemented. Further, the delineation of proposed pathway improvements and public access easements to trails and/or multi-use paths is not clear. As there is not enough information to determine if the project has designed transportation improvements to support safe and convenient access for all users, the project is potentially inconsistent with this policy.
2. Roadway Network Policy Context Sensitivity states “Plan and design transportation improvements so that they respect the surrounding environment. Transportation improvements should be undertaken in consultation with local residents and businesses, and should seek to maintain a sense of place.” The plans do not include labeling of streets on plan sets, exhibits, and details, identification ofroads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, right-of-way and utility impacts, and easements. Various studies, including a Transportation Study, will be required asthe City continues to process this application. As there is not enough information to determine how
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the project is fully detailing and designing transportation improvements, the project is potentially inconsistent with this policy
3. Roadway Network Policy Connective Street Network states, “The transportation system should provide a connected network of streets and paths for accommodating all modes of travel. New streets created as part of new development should continue existing street patterns, and must provide stub access points to adjacent undeveloped areas. The City will look for opportunities to repurpose existing rights-of way to enhance connectivity for cyclists, pedestrians and transit users.” The plans do not include labeling ofstreets on plan sets, exhibits, and details, identification ofroads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, right-of-way and utility impacts, and easements.
Variousstudies, including a Transportation Study, will be required asthe City continues to process this application. As there is not enough information to determine how the proposed network of streets and paths will accommodate all modes of travel and provide connectivity, the project is potentially inconsistent with this policy.
4. Roadway Network Policy Consideration of All Modes of Travel states, “When reviewing development proposals, consider the needs of all travel modes. In conditions of approval or environmental impact mitigations that are required, consider impacts on levels of service for pedestrians, bicyclists and transit, in addition to impacts on vehicular circulation, and mitigation measures including but not limited to bicycle parking, sidewalks, and landscaping.” Various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine any level of service impacts for various modes of travel, the project is potentially inconsistent with this policy.
5. Roadway Network Policy Complete Streets Design Approach states, “Include "Complete Streets" considerations in the design of all circulation improvement projects. These design considerations include, but are not limited to, the following:
• Maximized connections with the existing circulation network; • Minimized ingress and egress points, consolidated entries; • Public transit facilities and improvements;
• Bicycle and pedestrian facilities;
• Safety criteria such as lighting and traffic calming devices for residential streets; • Signage, including commercial signs, street signs, entry signs, directional signs); • Street furniture;
• On and off-street parking management.
The plans do not include labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, right-of-way and utility impacts, and easements. Various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine how the
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proposed on-site circulation plan includes Complete Streets considerations, or not, the project is potentially inconsistent with this policy.
6. Pedestrian and Bicycle Network Policy Additional Pedestrian Facilities on Large Sites states, “Enhance the pedestrian network with an interconnected system of walkways, continuous sidewalks on both sides of the street, and pedestrian crossings as part of higher-intensity redevelopment at the Rockaway Quarry site or the sites of existing shopping centers.” The plans do not include labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to sidewalks). As noted in the Initial Inconsistencies Letter, item B.4., the application materials lack specificity and are inconsistent regarding the details of how the proposed trail improvements will be implemented. Further, the delineation of proposed pathway improvements and public access easements to trails and/or multi-use paths is not clear. Various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine if the project has designed the pedestrian and bicycle network as an interconnected system, the project is potentially inconsistent with this policy.
7. Pedestrian and Bicycle Network Policy Universal Design states, “Provide pedestrian facilities that are accessible to persons with disabilities to ensure that roadway improvement projects address accessibility and universal design concepts.” The plans do not include labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements(including but not limited to curbs and sidewalks, and easements). Various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine if the project is providing universal design, the project is potentially inconsistent with this policy.
8. Pedestrian and Bicycle Network Policy Block Size and Maximum Street Spacing states, “For new development at the Quarry site or Park Mall site, streets should be designed to maximize connectivity for automobiles, cyclists, and pedestrians, with blocks between 200 and 600 feet in length. Mid-block pedestrian connections are encouraged.” For reference PMC Sec. 9-4.210 defines a block is defined as, “...shall mean that property abutting one side of a street and lying between the two (2) nearest intersecting streets or between the nearest intersecting street and railroad right-of-way, unsubdivided acreage, or a watercourse.” Proposed block lengths are not delineated in the proposed plans. See Item G.6 above, related to lack of plan detail on the proposed on-site bicycle and pedestrian network. As there is not enough information to determine if the project is maximizing connectivity for automobiles, cyclists, and pedestrians, the project is potentially inconsistent with this policy.
9. Parking, Parking Lot Design Policy states, “Design parking lots to have minimal environmental impact and to limit disruption of the urban fabric.” The application is not clear on whether the project parking is private or public. While there are two parking lots proposed along the eastern property line across from the eastern development area, as well as a small parking lot proposed across from the INDIGENOUS LAND RESERVATION, TO BE DETERMINED (NOT IN SCOPE) on Sheet G1.02, none are noted to specify whether they are proposed as private parking, public parking or both. Lastly, various environmental studies will be required as the City continues to process this
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application to analyze environmental impacts. As there is not enough information to determine what impacts the proposed parking lots may have on the environment, the project may be inconsistent with this policy.
Next Steps
Please note that as the City continues processing your application, we will identify additional information that is necessary to clarify, amplify, correct, or supplement your application. We look forward to your addressing the inconsistencies described above.
Appealable Issues
In addition, as stated above, this Final Inconsistency Letter constitutes a decision that your project application is subject to both Ordinance No. 391-C.S. and the City’s 2025 Local Coastal Land Use Plan, which are appealable decisions pursuant to Section 9-4.3804 of the Pacifica Municipal Code.
If you have any questions, please feel free to email me at [email protected].
Sincerely,
Samantha Updegrave
Community Development Director
City of Pacifica
Attachments
1. Initial Inconsistency Letter, dated April 28, 2026
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CITY OF PACIFICA
Community Development Department
170 Santa Maria Avenue • Pacifica, California 94044-2506 www.cityofpacifica.org
Scenic Pacifica
Incorporated Nov. 22, 1957
April 28, 2026
Paul Heule
231 Fulton St. W
Grand Rapids, MI 49503
Matt Larson
M Larson Incorporated
San Francisco, CA 94124
Sent via email: [email protected]
[email protected]
Subject: File No. 2025-036 – Initial Inconsistencies under the Housing Accountability Act, California Environmental Quality Act (“CEQA”) Compliance and Next Steps for Coastal Development Permit (CDP477-25), Development Plan (DP-92-25), Specific Plan (SP-192-25), Tree Permit (TP-14-25), and Sign Permit (S-138-25) for Development of 1,225 rental dwelling units in 20 apartment buildings and 26 townhomes (7 apartment buildings on the East Parcel (APN 018-150-150), and 3 apartment buildings and the townhome units on the West Parcel (018-150-110, 018-150-120)), and 1259 parking spaces on approximately 86.39 acre Vacant Parcels (APN 018-150-110, -120, -150) known as Coastal Crest Residences.
Dear Paul Heule & Matt Larson,
This letter provides initial project inconsistencies pursuant to the Housing Accountability Act (“HAA”), Government Code Section 65589.5(j)(2)(A), describes compliance with CEQA, and outlines next steps.
As background, you submitted a valid Preliminary Application for the Coastal Crest Residences project (“project”) pursuantto Government Code section 65941.1 on March 7, 2025. You subsequently submitted your regular application for a Coastal Development Permit (CDP-477-25), Development Plan (DP-92-25), Specific Plan (SP-192-25), Tree Permit (TP-14-25), and Sign Permit (S-138-25) for the project, on October 6, 2025. The application was deemed incomplete on November 5, 2025. You resubmitted your regular application on February 2, 2026, which was deemed incomplete on February 27, 2026. Your third resubmittal of March 25, 2026, was deemed complete on April 7, 2026.
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Inconsistency Analysis
California Government Code 65589.5(j)(2)(A) requires a city to provide notice to developers of a proposed housing development’s inconsistency with “an applicable plan, program, policy, ordinance, standard, requirement, or other similar provision …“ within 60 days of the date that the application is determined to be complete, if the project contains more than 150 units. As your proposed project proposes 1,225 rental dwelling units, the inconsistency analysis is due 60 days after the application for the project was deemed complete (See Gov. Code Section 65589.5(j)(2)(A)(ii)). As your application was deemed complete on April 7, 2026, the City’s inconsistency analysis is due by June 6, 2026. However, we have begun our inconsistency analysis and are providing you with fundamental project inconsistencies related to Ordinance No. 391, the current Local Coastal Land Use Plan, the General Plan, and Municipal Code, including inconsistencies that affect whether this project is allowable under State law notwithstanding the fact that you have invoked the Builder’s Remedy provisions in the HAA.
Pursuant to Government Code section 65589.5(o)(1), City staff are reviewing your application for consistency under the law in effect, on May 7, 2025, the date your preliminary application was deemed submitted. As noted above, we are aware that you have invoked the “Builder’s Remedy” with regard to your application. However, as discussed below, we do not believe that the Builder’s Remedy circumvents voter initiatives adopted by the electorate nor does it circumvent the obligation to comply with the Coastal Act. Thus, the inconsistencies noted below with respect to Ordinance No. 391-C.S. (the City’s voter initiative requiring a vote of the people to develop housing on the project site) and the City’s 2025 Local Coastal Land Use Plan must be rectified in order to proceed with your development as proposed.
A. Project Inconsistency with Ordinance No. 391-C.S.
Ordinance No. 391-C.S. is a voter initiative that requires a vote of the electorate to allow residential development at the projectsite (“VoterInitiative”). Ordinance No. 391-C.S. was adopted by Pacifica voters in 1983 and designated the quarry site as C-3 Service Commercial. No residential uses are listed as permitted or conditional usesin C-3 Service Commercial. (Pacifica Municipal Code (“PMC”) Sec. 9-4.1201.) C-3 Service Commercial explicitly provides that no residential uses are authorized. (PMC Sec. 9-
4.1201(b)(8).) Of critical importance, the Voter Initiative reserves in the electorate the exclusive power to authorize any residential uses at the site and states as follows:
“The following parcels of land: A.P. #018-150-050 & -070, commonly known as the quarry, are hereby rezoned from A/B-5 and M-1 to C-3 with the provision that no further public vote be required for any future rezonings except that any residential development of the property, including residential development permitted under the C-3 designation, shall require a vote of the people. This rezoning does not remove the HPD overlay.” Contrary to your claim that the project is subject to the Builder’s Remedy, State law does not allow development in contravention of voter initiatives. Courts will preserve the electorate’s initiative power in the absence of clearlegislative intent from the Legislature to abrogate it. (See Associated Home Builders etc., Inc. v. City of Livermore (1976) 18 Cal.3d 582, 591). Here, neither the HAA, nor its Builder’s Remedy provision, contain express language indicating that the Legislature intended to weaken the electorate’s initiative power. (See Aids Healthcare Foundation v. Bonta (2024) 101 Cal.App.5th 73.) Therefore, the
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Voter Initiative requirement for a vote of the electorate to develop residential uses on the project site continues to be enforceable, and residential development on the site will require a vote of the people irrespective of the invocation of the Builder’s Remedy.
B. Project Inconsistency with 2025 Local Coastal Land Use Plan (LCLUP) The LCLUP was adopted on May 8, 2025 (“2025 LCLUP” or “LCLUP”) and is applicable to this project under the Coastal Act. While you have asserted that the 1980 LCLUP applies because your preliminary application (deemed submitted on May 7, 2025) “locked in” the 1980 LCLUP regulations rather than the 2025 LCLUP adopted on May 8, 2025, the 2025 LCLUP applies because the Housing Crisis Act does not vest Local Coastal Land Use Plans. (Government Code sections 65589.5(o)(1), (4).).
Contrary to your claims, the City can continue to hold the applicant to the requirements of the Coastal Act, including consistency with the City’s 2025 LCLUP. The list ofregulationsthat become vested as a result of a preliminary application is defined in the Housing Crisis Act, and only includes a general plan, specific plan, zoning, design review and subdivision standards, and impact fees, and does not list a Local Coastal Plan as one of the eligible regulations. (Government Code §65589.5(o)(4).) In addition, the Coastal Act mandates that a Coastal Development Permit (CDP) can only be issued if the project is consistent with the adopted LCLUP. (Pub. Res. Code § 30604(b).) The City was not in a position to consider or approve a CDP until the City’s receipt of an application for a CDP, which occurred when the 2025 LCLUP was in effect.
Case law also supports this conclusion that housing-related laws, including the HAA, cannot be construed to relieve local agencies from complying with the Coastal Act, which means that the 2025 LCLUP applies. (See e.g., Kalnel Gardens, LLC v. City of Los Angeles (2016) 3 Cal.App.5th 927; [see also New Commune DTLA LLC v. City of Redondo Beach, Los Angeles County Superior Court Case No. 23STCP00426 [same].) Moreover, the Coastal Commission confirmed its agreement with this interpretation in a letter dated February 18, 2026 (see attached). In that letter, the Coastal Commission confirmed that the 2025 LCLUP applies even though the 1980 LCLUP was in effect on the date the preliminary application was deemed submitted.
As the City must apply the policies contained in the 2025 LCLUP, we have analyzed project inconsistencies as to the LCLUP adopted in 2025.1
Please note that a number of the LCLUP policies cited below are identical to policies in the 2040 General Plan and when that occurs, this letter identifies the identical General Plan policy as being inconsistent for the same reasons. For those policies, the section below also refers to the identical General Plan policy.
The project is inconsistent with the following LCLUP policies as set forth below:
1. The LCLUP designatesthe project site with the land use classifications of Conservation and Visitor Serving Commercial, as depicted in Figure 2-3 of the Land Use Diagram, as well as Figure 2-5:
Pacifica Coastal Zone, Central. LCLUP policy LD-I-1 further states that the Visitor Serving 1 This initial letter only addresses inconsistencies with the 2025 LCLUP given that we believe that the 2025 LCLUP applies. However, as we understand that you believe the 1980 LCLUP applies, we will be addressing inconsistencies with the 1980 LCLUP in our inconsistency letter due by June 6, 2026.
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Commercial designation is, “..intended to foster and protect areas that attract and cater to visitors, including hotels or a visitor attraction,such as an interpretive center or conference center, restaurants, retail and services, commercial recreation, or other compatible uses. Larger sites, with developable areas of two acres or larger, shall require a hotel, lower-cost overnight accommodation, or visitor attraction as part of new development. The maximum FAR is 3.0.
Buildout is calculated with an FAR of 0.35.”
With respect to the Conservation designation, as noted on page 2-11 of the LCLUP provides that the designation “…takes the place of the Greenbelt district from the previous General Plan. It applies to publicly- or privately-owned open areas not intended for development. Non-structural development, such as trails and viewing areas, is allowed. These areas may include:
• Watershed lands
• Sandy beach areas, including propertiesthat are fully on beaches or coastal dunes or bluffs • Land which is physically unsuitable for development due to geotechnical hazards, excessive steepness, wetlands, Environmentally Sensitive Habitat Area (ESHA), or other environmental constraints, or lies within stream channels; • Areas to remain undeveloped as a result of density transfer or clustered development, or covered by open space, recreational or scenic easements; • Open areas providing a physical and visual buffer between developed or open areas; and • Open space required as mitigation for environmental impacts.” The proposed project is inconsistent with the land use classifications of the site, Visitor-Serving Commercial and Conservation, as it proposes residential only development, which is not an allowable use in Visitor-Serving Commercial or Conservation. Further, the project does not include a hotel, lower-cost overnight accommodation, or visitor attraction within the portion of the site designated as Visitor Serving Commercial, as required. In addition, residential development is proposed within the portion of the site designated Conservation. As such, the proposal is found inconsistent with Figure 2-3, Figure 2-5, and policy LD-I-1, and would require an amendment to the adopted LCLUP.
2. The proposed development site is designated as a “Specific Site-Rockaway Beach, Quarry and Headlands” in Figure 2-4. Page 2-23 of the LCLUP sets forth the following description of “Specific Site-Rockaway Beach, Quarry and Headlands”:
• “...with trail improvements connecting Mori Point with Rockaway Beach. The Flats and the Pad overlooking Rockaway Beach are designated for Visitor-Serving Commercial development, supporting such potential uses as a resort hotel, boutique hotels, visitor attractions, and retail uses integrated with the Rockaway Beach district.”
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• “While housing may be proposed as part of a plan for the site, Ordinance No. 391 provides that rezoning to allow residential uses may occur only if approved by a vote of the electorate.”
The proposed project is inconsistent with the above policy regarding the project site. First, as noted above under Item A, Project Inconsistency with Ordinance No. 391, residential development, as proposed, must be approved by the voters, and voter approval is not proposed as part of the project. Further, the proposed trail improvements are not clearly delineated. Although an area noted as the “proposed new trail” is denoted on several sheets throughout the plan set, the plans do not include detail on how “the proposed new trail” connects Mori Point with Rockaway Beach and the extent and users of the trail, as well as its delineation, are not clear. In addition, there is no visitor-service commercial development component proposed.
3. Section 2.4 “COASTAL DEVELOPMENT PRIORITIES – Coastal-Dependent, Visitor Serving and Recreational Development” states, “Section 30255 of the Coastal Act states that “coastaldependent developments shall have priority over other developments on or near the shoreline.” Lower-cost visitor and recreation facilities (Section 30213); recreational uses and development (Section 30221); and coastal-dependent industry (Section 30260) are specifically called out.
Section 30222 provides that “the use of private lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, general industrial, or general commercial development.” The proposed residential only development is not consistent with priorities to develop coastaldependent development, such as lower-cost visitor and recreation facilities, recreational uses and development and coastal-dependent industry, and is thus inconsistent with this policy.
4. Figure 2-4 designates the project site within the “Rockaway Beach, Quarry, Headlands” Subarea (may be referred as neighborhoods), as well as a Specific Site subject to site specific land use policies and Figure 2-6 includesthe projectsite as part of the “Central Pacifica Coastal Zone”. The land use description for this Specific site states, “This area will remain open space, with trail improvements connecting Mori Point with Rockaway Beach. The Flats and the Pad overlooking Rockaway Beach are designated for Visitor-Serving Commercial development, supporting such potential uses as a resort hotel, boutique hotels, visitor attractions, and retail usesintegrated with the Rockaway Beach district. Redevelopment of the Quarry site could expand this visitor-oriented area. Any development of the Quarry site will require detailed evaluation of biological resources to ensure that sensitive habitat and wetlands are protected; and should be sited and designed to minimize coastal hazard risks in accordance with policies in Chapter 5 and 6 of the LUP. The likely footprint of development could be much smaller than the area designated. While housing may be proposed as part of a plan for the site, Ordinance No. 391 provides that rezoning to allow
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residential uses may occur only if approved by a vote of the electorate. …. Development in the Quarry Flats should include new public open space.”
This policy requires compliance with Ordinance No. 391, public open space and trail connections, and protection of biological resources and minimization of coastal hazard risks. As noted above under Item A, Project Inconsistency with Ordinance No. 391, the project is not consistent with Ordinance No. 391.
In addition, the proposed project is inconsistent with the requirement for new public open space, as set forth in detail below. Although the applicant’s project description purports to provide public open space, the application materials submitted are not clear on how the project will be providing public open space and trail improvements connecting Mori Point with Rockaway Beach.
With respect to trail improvements, although the project plans include notes regarding a “proposed new trail”, the provision of this trail remains unclear. A number of sheets throughout the plan set includes a textual note stating “propose new trail” (Sheets G0.16, G1.01, C1.01, C1.02, L0.03 – labeled “trail access”, L1.01, L2.00, L3.00, L4.00, A1.01, EL0.00, SI.1.0) that appears as either a solid or dashed line beginning towards the bottom of the Western development parcel, runs parallel to edge of the proposed new roadway providing access up to the northern most development area on the Western parcel (the “Summit” area as described in the project narrative), and appears to terminate at the edge of a proposed townhome on some sheets, or at the terminus of the proposed new roadway on other sheets. However, there is no further detail provided in the plan set, or othersubmitted application materials beyond this one dashed orsolid line appearing to be the only new trail proposed. Sheet G1.02 includes a solid green line denoting “public trail access” (assumed to mean existing trails), and also includestextstating “propose new trail” as previously referenced, and denotes this “propose new trail” as a solid blue line. However, numerous additional areas are also denoted by a solid blue line, but with no corresponding text if those are also proposed new trails or not. The corresponding legend on Sheet G1.02 liststhe solid blue line as “pedestrian circulation” but it is unclear if that means a new proposed pathway intended for project residents or new proposed trail, as there is no corresponding text or narrative. Further, there are no clear trail details connecting Mori Point with Rockaway Beach. In addition, the plans regarding paths, delineation of existing and proposed improvements and easements to trails and/or multi-use paths are not clear.
With respect to the Indigenous Memorial Park, there is no detail on specifications of this proposed new area, nor detail on how it is proposed (or not) to interact and integrate with the existing and proposed public trails, open space, or otherwise. The 10-5-25 submitted written narrative states under Community Amenities an “opportunity for one-acre indigenous memorial park honoring the area’s cultural heritage” but does not provide any description, nor is it noted in Project Description 6. on Sheet G0.01 6. PUBLIC OPEN SPACE AND RECREATION. On Sheet G0.16, within the northeast lower property extent of the East Parcel, appears to indicate the proposed general location of such possible “park”, with the text and “INDIGENOUS LAND RESERVATION, TO BE DETERMINED(NOT IN SCOPE)” (Sheets G0.16, G1.101, G1.02, L0.06, L1.01, L2.00, L3.00, L4.00, A1.01, EL0.00, EL1.101) which infers that it is not part of the overall proposal. It is also noted as “Indigenous People Node, Size and Location TBD” (Sheet L0.03) and “Native American Heritage Memorial” on Sheet SI1.10. This Indigenous Peoples area is unclear in its title, uses, users, access
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and intent, as no specific detail is provided in narrative on the plan, nor elsewhere in the submittal materials.
With respect to the provision for Outdoor Space, Sheet SI 3.0 indicates 3 locations with a “PS - Public Space ID/Regulations” note; two within the western parcel and one within the eastern parcel with the corresponding details on Sheet SI 3.0 for Sign PS includes a sign stating, “public park”, but it is unclear how members of the public would access and use such spaces. Further Sheet L0.03 includes text delineated to one specific area in the Western Parcel as “Open Program Area” and text delineated to one specific area in the Eastern Parcel as “Program/Recreational Spine” but there are no details elsewhere in the application materials describing the specifics of these areas in their intended purposes, intent and use. Without corresponding details and specifications of the public space, it is not clear that public open space is being provided as required.
Lastly, there is not enough information in the application materialsto determine consistency with the requirement to protect biological resources and minimize coastal hazard risks. Although the application’s project description purports to provide “Environmental Stewardship,” the submittal materials do not include specific details as to how the project proposes to fully implement these environmental stewardship actions related to protection and restoration of native habitats, wetlands, and coastal ecosystem, and ecological restoration of wetlands and Calera Creek to enhance biodiversity and habitat health. In addition, biological studies will be required as the City continues to process this application and will provide more detail on whether the project will protect biological resources. As there is not enough information to determine if the project will protect biological resources and minimize coastal hazard risks, the project is potentially inconsistent with this policy.
5. LD-G-3 and LD G-7 state (respectively) as follows regarding any residential development in the Coastal Zone, “Future Residential Development. Limit development to sites that are not critical for open space connections or habitat preservation, and which will be in harmony with the surrounding natural setting.” and “Open Space Conservation and Habitat Protection. Protect beaches, oceanfront bluffs, wetlands, riparian corridors, ESHA, ridgelines, hillside areas adjacent to existing open space, and areas that support critical wildlife habitat and special status species.” Significant portions of the project site have a land use designation of Conservation, but are proposed with residential uses, and thusthe project isinconsistent with LD-G-3. Further, as noted in Item B.4. above, there is a lack of specific details as to how the project proposes to implement its Environmental Stewardship actions and the project is thus potentially inconsistent with LD-G7, which requires open space conservation and habitat protection. No biological study, or mapped areas identifying any ESHA’s or critical wildlife habitat or special status species were included as part of the application of submittal materials.
These policies are also found in General Plan policy LU-G-3 and LU-G-7, and thus the project is also potentially inconsistent with those General Plan policies.
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6. LD-G-4 states, “Higher-Density Housing. Locate higher-density housing outside of Coastal Vulnerability Zones and in accessible places close to community shopping areas and transportation.”
The proposed residential housing project isinconsistent with this policy asit is proposing to locate housing within a Coastal Vulnerability Zone, although the exact extent is unclear from the application materials. Appendix B-4, Coastal Vulnerability Map Rockaway Beach, Quarry and Headlands, of the LCLUP appears to denote portions of the proposed development site within the mapped Coastal Vulnerabilities of “wave run-up”, “storm flood area”, “flood prone area” and “coastal erosion”. From the materials submitted, staff is unable to confirm the exact extent of the specific areas of the development site, and notably, what, if any associated proposed development improvements, may be situated specifically within these various mapped extents of these four different Coastal Vulnerabilities. A screenshot of Appendix B-4 showing the project site is included for reference below.
This policy is also found in General Plan policy LU-G-4, and thus the project is also inconsistent with General Plan policy LU-G-4.
7. LD-G-8 states, “Changes in Density or Intensity of Land Use in Coastal Vulnerability Zones. Do not increase the density or intensity of land use designations beyond those indicated in the LCLUP for sites located within Coastal Vulnerability Zones.” The proposed residential housing project is inconsistent with this policy as it is proposing an intensified land use of residential on a site currently designated by the LCLUP for Visitor Serving Commercial and Conservation uses within a Coastal Vulnerability zone (see Item B.6 above).
This policy is also found in General Plan policy LU-G-8, and thus the project is also inconsistent with General Plan policy LU-G-8.
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8. LD-I-8 states, “Development Priority for Visitor-Serving and Recreational Uses. Allow visitororiented uses as-of-right in all areas designated for Visitor-Serving Commercial or Low-Intensity Visitor Serving Commercial, and all commercial or mixed-use districts within the Coastal Zone.
Development on Visitor-Serving Commercial sites with developable areas of two acres or larger must include a visitor attraction, hotel, conference center, or similar use, and may also include a range of retail and service uses. Smaller sites may have any visitor- or pedestrian-oriented retail or service use.”
The project is inconsistent with this policy because the project site is over 2 acres and is proposed as 100 percent residential without any visitor serving commercial uses included.
This policy is also found in General Plan policy LU-I-9, and thus the project is also inconsistent with General Plan policy LU-I-9.
9. LD-I-17 states, “Rockaway Quarry Site. Enable the responsible development and environmental conservation of the Quarry Site, considering the potential coastal hazard constraints (including but not limited to bluff erosion, slope stability, and flooding), as well as the biological constraints (specific to sensitive species, environmentally sensitive habitat areas, and wetlands) and coastal resource protection more broadly. Preparation of a specific plan for the Quarry site could achieve the desired development outcomes. Allowable development should provide community benefits, including substantial public open space, and commercial uses and public spaces attractive to both visitors and local residents. Uses may include an inn or hotel; shops and restaurants; performance or conference spaces; and public uses. Ordinance No. 391 provides that residential uses are only authorized after a vote of the electorate. Development should be integrated with the Rockaway Beach district, to create an expanded visitor-oriented area in a memorable natural setting.” The project is inconsistent with this policy for a number of reasons.
First, as noted above under Item A, Project Inconsistency with Ordinance No. 391, the project is inconsistent with Ordinance No. 391. In addition, as the project proposes residential uses, with no commercial uses, no identified community benefits, and no proposed plan on how it would be integrated with the Rockaway Beach District to expand this visitor-oriented area, it is inconsistent with the development direction of this policy. Further, the project is inconsistent with the direction to prepare a specific plan to achieve the desired development outcomes, as no specific plan is proposed. Additionally, as noted in Item B.4 above, the project is potentially inconsistent with the policy’s direction on public open space and public spaces. From the materials submitted, the 100-year floodplain and a creek setbacks from top of bank are not included and the site may be subject to flooding. Lastly, various studies, including a biological resources study, will be required as the City continues to process this application and will assist in determining whether the project is consistent with the aspects of this policy related to coastal hazard constraints, biological constraints, and coastal resource protection. As there is not
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enough information at this time, the project is potentially inconsistent with those aspects of the policy.
This policy is also found in General Plan policy LU-I-25, and thus the project is also potentially inconsistent with General Plan policy LU-I-25.
10. LD-I-18 states, “Rockaway Beach. Facilitate continued improvements in the Rockaway Beach district and promote infill development emphasizing active ground-floor and visitor-oriented uses and links to the Quarry site.” See Item B.4 above regarding lack of project details demonstrating how the proposed site would be linked to Rockaway Beach; as such the proposal is found inconsistent with this policy.
This policy is also found in General Plan policy LU-I-26, and thus the project is also inconsistent with General Plan policy LU-I-26.
11. LD-I-27 states, “Enhanced Visitor Node. Taking all site constraints into account, create a visitororiented commercial and hospitality node at Rockaway Beach and on developable portions of the Rockaway Quarry site. A key component of this strategy would be to pursue a boutique or high end/resort-oriented hotel and supporting tourist-oriented shopping and dining opportunities.” As the project proposes only residential uses, and no visitor-oriented commercial and/or hospitality uses, it is inconsistent with this policy.
12. Table 2-3 provides development capacity for Non-Residential Development under the Plan’s land use designations and identifies the Rockaway Quarry Site at a total of 448,400 square feet of new non-residential square feet at buildout. As the project proposes approximately 1,214,100 square feet of residential development, and 0 square feet of non-residential development, it is inconsistent with this Table.
13. LD-I-34 (states, “Waste Water Treatment Capacity. Continue to monitor wastewater generation ratesso decision-makers are aware of the impacts on the treatment plant from new development, and plan for additional capacity in advance of projected need.” A Sewer Capacity Study, Preliminary Sewer Plan and modeling will be required as the City continues to process this application. As there is not enough information to determine if there is adequate wastewater treatment capacity, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-23, and thus the project is also potentially inconsistent with General Plan policy CO-I-23.
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14. LD-I-38 states, “Public Services for Development. Development shall only be approved if it can be shown that it can be accommodated by adequate and sustainable public services (including in terms of water, sewer, and circulation) without any significant impacts to coastal resources.” Various studies, including a Sewer Capacity study, Preliminary Sewer Plan, and a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine if the project can be accommodated by adequate and sustainable public services without any significant impacts to coastal resources, the project is potentially inconsistent with this policy.
15. PR-G-1 states, “Coastal Access and Recreational Opportunities. Provide maximum coastal access and recreational opportunities for all people consistent with public safety needs and the need to protect public rights, rights of property owners, and natural resource areas from overuse, including access at each point identified on Figure 3-1. As discussed in Item B.4, regarding comments related to coastal access and recreation, from the limited details provided in the plan set, it is not clear how the project provides coastal access and recreational opportunities. Thus, the proposal is found to be inconsistent with this policy. This policy is also found in General Plan policy OC-G-8, and thus the project is also inconsistent with General Plan policy OC-G-8.
16. PR-I-2 states, “New Development and Coastal Access. Require that new development along the coastline provide public access from the nearest public roadway to the shoreline and along the coast, and be designed to minimize impacts to public coastal access and recreation. Ensure that impacts are mitigated through the dedication of access or trail easements or the provision of improvements to other public access points. The City may grant exceptions to this requirement where public access would pose a safety risk or threat to fragile resources, or where adequate access exists nearby.” As discussed above under Item B.4., the submittal materials lack details and are internally inconsistent regarding the project’s proposed Public Open Space and Recreation plan component. There are two parking lots proposed along the eastern property line across from the eastern development area, as well as a small parking lot proposed across from the INDIGENOUS LAND RESERVATION, TO BE DETERMINED (NOT IN SCOPE) on Sheet G1.02 but none are noted to specify whether they are proposed as private parking, public parking or both. Should these parking areas, or portions of, be made available to the public, there is no associated detail on the proposed connectivity of how the public would subsequently obtain access to the shoreline and along the coast. Identification of roads and paths as public or private, and delineation of existing and proposed improvements is not included in the materials submitted. Without these details and specifications, and from the limited details provided in the plan set, the proposed project is inconsistent with this policy.
This policy is also found in General Plan policy OC-I-38, and thus the project is also inconsistent with General Plan policy OC-I-38.
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17. PR-I-4 states, “Maintenance of Public Coastal Access. Require a public or private entity to be responsible for required public access ways. Until such an entity agrees to be responsible for liability and maintenance of such access ways, they are not required to be open for public use.
Dedicated public access ways should be designed to provide views as well as access connections to or along the shore.” As discussed above under Item B.4., the submittal material lack details and are internally inconsistent regarding the project’s proposed Public Open Space and Recreation plan components, including trails. In addition, as noted above under Item B.16, the intent and dedication of proposed parking areas is not clear. Without these details and specifications, and the limited details provided in the plan set, it is not clear how public coastal access will be provided. Therefore, the proposal is inconsistent with this policy. This policy is also found in General Plan policy OC-I-40, and thus the project is also inconsistent with General Plan policy OC-I-40.
18. PR-I-19 states, “Rockaway Quarry. If a safe public route can be developed on the Quarry uplands, create coastal access along a new trail connecting Rockaway Beach with Mori Point, as part of a conservation proposal or new development.” As noted above under Items B.4, B.16 and B.17, the project plans are not clear regarding trails and coastal access. Without these details and specifications, and from the limited details provided in the plan set, the proposal is inconsistent with this policy. This policy is also found in General Plan policy OC-I-53, and thus the project is also inconsistent with General Plan policy OC-I-53.
19. PR-G-6 states, “Development of City Parks. Create and enhance neighborhood and pocket parks and plazas to provide access to local recreational space to all Pacifica residents.” As discussed above under Item B.4., the submittal material lack details and are internally inconsistent regarding the project’s proposed Public Open Space and Recreation plan component, including the proposed “Indigenous People Node, Size and Location TBD”. Without these details and specifications, and from the limited details provided in the plan set, the proposal is inconsistent with this policy. This policy is also found in General Plan policy OC-G-1, and thus the project is also inconsistent with General Plan policy OC-G-1.
20. PR-G-10 states, “Open Space Preservation. Preserve open space that protects natural resources, visual amenities, and public health and safety. The top priority areas for conservation are beaches, oceanfront bluffs, ridgelines, hillsides areas adjacent to existing open space, and areas thatsupport critical wildlife habitat and endangered species.” Asthe project proposesresidential uses within areas of the project site designated as Conservation, as discussed in Items B.1 and B.2 above, it is inconsistent with this policy to preserve open space. Furhter, as discussed above under Item B.4., the submittal materials lack details and are internally inconsistent regarding the project’s proposed Public Open Space and Recreation plan component. Without these details and specifications, and from the limited details provided in the plan set, the proposal is inconsistent
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with this policy. This policy is also found in General Plan policy OC-G-5, and thus the project is also inconsistent with General Plan policy OC-G-5.
21. PR-1-31 states, “Parks as Part of Future Development. Create future public spaces, accessible to the community, as part of the redevelopment of publicly-owned sites and of larger privatelyowned sites, including the Rockaway Quarry site, the undeveloped San Pedro Avenue site, and the Milagra Canyon site.” As noted above under Item B.4., the application materials lack specificity on the details of how the project proposes to specifically implement the project plan statements of “PUBLIC OPEN SPACE AND RECREATION” and provide public space and trails. Without these details and specifications and from the limited details provided in the plan set, it is not clear how the project intends to create future public space. Thus, the proposal is inconsistent with this policy.
22. PR-I-27 states, “Fees and Time Restrictions. Ensure that public beaches and parks in the Coastal Zone are free to access or maintain lower-cost user fees and parking fees, and minimize parking lot and beach curfews to the extent feasible in order to maximize public access and recreation opportunities.” As noted above under Item B.4., the application materials lack specificity on the details of how the project proposes to specifically implement the project plan statements of “PUBLIC OPEN SPACE AND RECREATION” and provide public space and trails. Identification of roads and paths as public or private is not provided. Without these details and specifications, and from the limited details provided in the plan set, the proposal is inconsistent with this policy.
23. PR-I-28 states, “Park Land Dedication or In-Lieu Fees. For new land divisions and residential development, continue to require the dedication of land or payment of in-lieu feesto provide park land at a ratio of five acres per 1,000 residents.” As noted above under Item B.4., the application materials lack specificity on the details of how the project proposes to specifically implement the project plan statements of “PUBLIC OPEN SPACE AND RECREATION” and provide public space and trails. In addition, identification of roads and paths as public or private is not provided.
Without these details and specifications, and the limited details provided in the plan set, the proposal is inconsistent with this policy. This policy is also found in General Plan policy OC-I-1, and thus the project is also inconsistent with General Plan policy OC-I-1.
24. PR-I-29 states, “Park Development to Meet Park Standards. Develop new parksin a timely manner using in-lieu fees or land dedicated as part of new development, to ensure that Citywide park and recreation space is available to the community at a ratio of 6.3 acres per 1,000 residents by 2040.” As noted above under Item B.4., the application materials lack specificity on the details of how the project proposes to specifically implement the project plan statements of “PUBLIC OPEN SPACE AND RECREATION” and provide public space and trails. Identification of roads and paths as public or private is not provided. Without these details and specifications, and from the limited
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details provided in the plan set, the proposal may be inconsistent with this policy.
This policy is also found in General Plan policy OC-I-2, and thus the project may be inconsistent with General Plan policy OC-I-2.
25. PR-I-31 states, “Parks as Part of Future Development. Create future public spaces, accessible to the community, as part of the redevelopment of publicly-owned sites and of larger privatelyowned sites, including the Rockaway Quarry site, the undeveloped San Pedro Avenue site, and the Milagra Canyon site.” As noted above under Item B.4., the application materials lack specificity on the details of how the project proposes to specifically implement the project plan statements of “PUBLIC OPEN SPACE AND RECREATION” and provide public space and trails. Further, it is not clear which roads are public or private and what public access will be provided.. Without these details and specifications, and from the limited details provided in the plan set, the proposal may be inconsistent with this policy. This policy is also found in General Plan policy OC-I-9, and thus the project may be inconsistent with General Plan policy OC-I-9.
26. PR-G-11 states, “Trail System Expansion. Expand the trail system in Pacifica to create a connected trail network with communitywide links to open space and recreation facilities, as shown on Figure 3-3, and to enhance and augment California Coastal Trail connections and connectivity”.
Figure 3-3: Trail System denotes a proposed trail or trail improvements within the project site that extends from the site’s southern property boundary to its northern property boundary with proposed connection to the existing trail in Mori Point (GGNRA) at the project’s site northern boundary. However, as noted above under Item B.4., the application materials lack specificity and are inconsistent regarding the details of how the proposed trail improvements will be implemented. Further, the delineation of proposed pathway improvements and public access easements to trails and/or multi-use paths is not clear. As the plans do not include sufficient detail or clarity showing how the propose new trail or trail improvements, connect with the existing Mori Point trail, the proposal is inconsistent with this policy. This policy is also found in General Plan policy OC-G-7, and thus the project is also inconsistent with General Plan policy OCG-7.
27. PR-I-33 states, “New Segments of California Coastal Trail in Pacifica. Create new trail segments through Rockaway Quarry uplands and the Headlands as part of development or as separate Coastal Trail initiatives.” However, as noted above under Item B.4., the application materialslack specificity and are inconsistent regarding the details of how the proposed trail improvements will be implemented. Further, the delineation of proposed pathway improvements and public access easements to trails and/or multi-use paths is not clear. Without these details and specifications, and from the limited details provided in the plan set, the proposal is found inconsistent with this
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policy. This policy is also found in General Plan policy OC-I-24, and thus the project is also inconsistent with General Plan policy OC-I-24.
28. PR-I-43 states, “Signage and Wayfinding. Develop the overall image and accessibility of Pacifica’s natural assets, through a program of consistent and attractive signage for the trail system. • Provide wayfinding signage along all on-street portions of the trail system; at junctions of off-street trails; and at trailheads.
• Provide interpretive signage to identify landforms visible from viewpoints; provide information about the natural environment and sensitive species; information about historical and cultural points of interest; information about unique features of Pacifica; and other subjects.
Each trail should have an identity as part of the Pacifica trail system (e.g., Trail 1— Coastal Trail). Where routes are shared with the California Coastal Trail or the Bay Area Ridge Trail, these should also be identified.
While Sheets SI.10 and SI-30 include some signage location renderings, there does not appear to be signage proposed along the portions of what is noted in text as a “propose new trail”. Further, as noted above under Item B.4., the application materials lack specificity and are inconsistent regarding the details of how the proposed trail improvements will be implemented. Further, the delineation of proposed pathway improvements and public access easements to trails and/or multi-use paths is not clear.
Without these signage or wayfinding details and specifications, and from the limited details provided in the plan set, the proposal is inconsistent with this policy. This policy is also found in General Plan policy OC-I-25, and thus the project is also inconsistent with General Plan policy OCI-25.
29. PR-G-12 states, “Bicycle and Pedestrian Routes. Establish trails, bike routes and pedestrian amenities connecting neighborhoods to major shopping and public facility destinations, and fill in gaps in the existing network.” As noted above under Item B.4., the application materials lack specificity and are inconsistent regarding the details of how the proposed trail improvements will be implemented. Further, the delineation of proposed pathway improvements and public access easements to trails and/or multi-use paths is not clear. Without these details and specifications, and from the limited details provided in the plan set, the proposal is inconsistent with this policy.
This policy is also found in General Plan policy CI-G-11, and thus the project is also inconsistent with General Plan policy CI-G-11.
30. PR-G-13 states, “Recreational Access. Provide recreational access to coastal resources and public open space in keeping with Pacifica’s natural environment, with linksto regional trails and bicycle corridors.” As noted above under Item B.4., the application materials lack specificity and are
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inconsistent regarding the details of how the proposed trail improvements will be implemented.
Further, the delineation of proposed pathway improvements and public access easements to trails and/or multi-use paths is not clear.
Without these details and specifications and from the limited details provided in the plan set, the proposal is inconsistent with this policy. This policy is also found in General Plan policy CI-G-13, and thus the project is also inconsistent with General Plan policy CI-G-13.
31. PR-G-14 “Mobility for All Users. Create a safe and attractive walking environment accessible for all users, particularly persons with disabilities, seniors, and younger residents and visitors.” As noted above under Item B.4., the application materials lack specificity and are inconsistent regarding the details of how the proposed trail improvements will be implemented. Further, the delineation of proposed pathway improvements and public access easements to trails and/or multi-use paths is not clear. Location and dimensions of all existing and proposed street improvements, including sidewalks, was not included. Without these details and specifications and from the limited details provided in the plan set, the proposal may be inconsistent with this policy.
This policy is also found in General Plan policy CI-G-14, and thus the project is also inconsistent with General Plan policy CI-G-14.
32. PR-I-45 states, “Pedestrian-Oriented Street Improvements. Implement Bicycle and Pedestrian Master Plan recommendations to improve pedestrian-oriented safety and comfort. Priority locations for pedestrian-oriented design improvements include:
• Pedestrian Priority Areas (including Manor, Sharp Park, Vallemar/Fairway Park, and Linda Mar PPAs,) which include mixed use and higher-intensity areas • Streets that are part of Pacifica’s proposed trail system improvements; • Streets adjacent to schools; and
• Locations where pedestrian-automobile collisions have occurred.
Labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, and easements, was not included. Various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine if the project is providing pedestrian-oriented street improvements implementing the Bicycle and Pedestrian Master Plan, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CI-I-26, and thus the project is also potentially inconsistent with General Plan policy CI-I-26.
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33. PR-I-50 states, “Bicycle Parking Requirements for New Development. Continue to require bicycle parking facilities in new high density residential, mixed use, and non-residential development.” Sheets A2.01 and A2.02 include areas noted as “bike room” on the proposed floor plan and within the enclosed garage areas, but no further detail isincluded such as how many spaces are provided and if such spaces are intended for short- or long-term use. No exterior bicycle parking spaces are included in the materials submitted. In addition, various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine how the project is providing bicycle parking requirements, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CI-I-40, and thus the project is potentially inconsistent with General Plan policy CI-I-40.
34. PR-G-18 states, “Serve All Users. Plan, design, build, and maintain transportation improvements to support safe and convenient access for all users with priority for “complete streets” projects that facilitate walking, bicycling and transit use wherever possible.” Labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, and easements, was not included. In addition, various studies, including a Transportation Study, will be required asthe City continuesto processthis application. As noted above under Item B.4., the plans regarding paths, delineation of existing and proposed improvements and easements to trails and/or multi-use paths are not clear. Asthere is not enough information to determine if the project is serving all users pursuant to this policy, the project is potentially inconsistent.
35. PR-G-19 states, “Plan, design, and build transportation improvements so that they respect the surrounding environment.” Labeling ofstreets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, and easements, was not included. In addition, variousstudies, including a Transportation Study, will be required asthe City continuesto process this application to study the transportation improvements. As there is not enough information to determine if the transportation improvements will respect the surrounding environment, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CI-G-6, and thus the project is also potentially inconsistent with General Plan policy CI-G-6.
36. PR-I-56 states, “Complete Streets in the Project Development Process. Incorporate complete streets concepts at each stage of the development processfor projects affecting the right-of-way, including the following:
• As part of design review, both at Phase I and Phase II, require documentation of how the “routine accommodation” of bicyclists and pedestrians has been satisfied in planning and design.;
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• During project review and approval, ensure that the objectives and purpose are consistent with MTC directives on Complete Streets and Routine Accommodation; • For projects subject to MTC’s Resolution 3765, as amended, work with MTC to secure approval of the Complete Streets checklist and submittal to MTC of all required documents. Integrating Complete Streets considerations should require only minor additions to normal design, acquisitions, and approval guidelines.
Labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, and easements, was not included. In addition, various studies, including a Transportation Study, will be required as the City continues to process this application, to analyze the street and transportation improvements. . As there is not enough information to determine if the project is meeting Complete Street standards, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CI-I-3, and thus the project is also potentially inconsistent with General Plan policy CI-I-3.
37. PR-I-59 states, “Block Size and Maximum Street Spacing. For new development at the Quarry site, require streetsto be designed to maximize connectivity for automobiles, cyclists, and pedestrians, with blocks between 200 and 600 feet in length. Provide mid-block pedestrian connections where blocks exceed 500 feet in length. The intent of these standards is to prevent development of introverted neighborhoods, provide flexibility in circulation, and promote access for bicyclists and pedestrians.”
Labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements, was not included. In addition, various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine if the project is meeting block size and maximum street spacing, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CI-I-6, and thusthe project is also potentially inconsistent with General Plan policy CI-I-6.
38. PR-I-63 states, “Additional Pedestrian Facilities on Large Sites. Enhance the pedestrian network with an interconnected system of walkways, continuous sidewalks on both sides of the street, and pedestrian crossings as part of higher-intensity redevelopment of large sites.” Labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, and easements, was not included. Identification of roads and paths as public or private, and delineation of existing and proposed improvements and easements was also not provided. In addition, various studies, including a Transportation Study, will be required as the City continues to process this application. As there is not enough information to determine if the
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project is providing additional pedestrian facilities on this large site, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CI-I-28, and thus the project is also potentially inconsistent with General Plan policy CI-I-28.
39. PR-I-64 states, “Universal Design. Require all pedestrian facilities to be ADA compliant and accessible to persons with disabilities.” Labeling of streets on plan sets, exhibits, and details, identification of roads and paths as public or private, delineations of existing and proposed street improvements (including but not limited to curbs and sidewalks, and easements, was also not included. Identification of roads and paths as public or private, and delineation of existing and proposed improvements and easements was not provided. In addition. variousstudies, including a Transportation Study, will be required asthe City continuesto processthis application. Asthere is not enough information to determine if the project is providing universal design, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CI-I-30, and thus the project is also potentially inconsistent with General Plan policy CI-I-30.
40. The LCP “Level of Service Standards”, on page 3-35 states, “In Pacifica’s Coastal Zone, the most critical congestion occurs on SR 1, where certain intersections and roadway segments currently operate at LOS E or F during peak periods. The City’s policy is to limit further deterioration of traffic conditions by evaluating the significance of impacts of new development on highway congestion, and requiring mitigation to maintain, if possible, LOS D for City streets and the LOS standards set by the City/County Association of Governments (C/CAG) for roadway segments included in the San Mateo County Congestion Management Program (CMP).” The development site is located within the City’s Coastal Zone, thus subject to this policy. The submitted Trip Generation Estimate, prepared by W-Trans, dated July 11, 2025, does not include an LOS Analysis.
A transportation study will be required to determine whether the project is consistent with this policy. As there is not enough information to determine if the project meets the LOS standards in this policy, the project is potentially inconsistent.
41. Regarding Transportation Demand Management (TDM), PR-G-25 states, “Support TDM strategies to reduce congestion and single-occupant vehicle travel” and PR-I-74 states, “Transportation Demand Management Measures. Require transportation demand management (TDM) consistent with the Congestion Management Program (CMP) and monitoring plans to ensure trip reduction targets are met or exceeded as conditions of approval for development projects that exceed the CMP threshold for impacts to the transportation network. Require TDM measures for development projects below the CMP threshold whenever feasible, but do not require a monitoring plan for these smaller projects.” The submitted “Trip Generation Estimate for the Coastal Coast Residences Project in Pacifica” estimates a daily total of 6,981 daily trips. The City/County Association of Governments San Mateo County (C/CAG), Transportation Demand Management (TDM) policy requires that any new development anticipated to generate at least 100 average daily trips (ADT) is subject to the TDM Policy and must therefore complete a TDM Checklist and implement associated measures to mitigate traffic impacts. No TDM program or plan was submitted as part of the application materials but will be required as the City continues
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to process the application. As there is not enough information to determine if the project is consistent with the TDM policy, the project is potentially inconsistent with this policy. These policies are also found in General Plan policies CI-G-18 and CI-I-50, and thus the project is also potentially inconsistent with General Plan policies CI-G-18 and CI-I-50.
42. PR-G-26 states, “Private Parking. Ensure adequate off-street parking in all new development.” The application is not clear on whether the project parking is private or public. While there are two parking lots proposed along the eastern property line across from the eastern development area, as well as a small parking lot proposed across from the INDIGENOUS LAND RESERVATION, TO BE DETERMINED (NOT IN SCOPE) on Sheet G1.02, none are noted to specify whether they are proposed as private parking, public parking or both. As there is not enough information to determine what private parking is being provided, the project may be inconsistent with this policy. This policy is also found in General Plan policy CI-G-20, and thus the project is also inconsistent with General Plan policy CI-G-20.
43. PR-G-27 states, “Public and Visitor Parking. Facilitate beach and recreational use by providing safe and well-located public parking. When appropriate and feasible, distribute parking areas throughout the Coastal Zone to mitigate against the impacts of overcrowding or overuse by the public of any single area.” The application is not clear on whether the project parking is private or public. While there are two parking lots proposed along the eastern property line across from the eastern development area, as well as a small parking lot proposed across from the INDIGENOUS LAND RESERVATION, TO BE DETERMINED (NOT IN SCOPE) on Sheet G1.02, none are noted to specify whether they are proposed as private parking, public parking or both. As there is not enough information to determine what public parking is being provided, the project may be inconsistent with this policy. This policy is also found in General Plan policy CI-G-21, and thus the project is also inconsistent with General Plan policy CI-G-21.
44. ER-G-1 states, “Water Quality. Support the improvement of Pacifica’s water quality, including both surface water and groundwater, through Best Management Practices (BMPs) for stormwater management,stream restoration, and riparian habitat restoration.” The Stormwater Management Plan (SWMP) does not identify, nor discuss opportunitiesto reduce imperviousness and incorporate stormwater controls into the site and landscape design, nor does it use the 4 percent method to design bioretention areas, nor details on wetland restoration areas.
Demonstration of approval of outside agenciesto work in the creek will also be required. Asthere is not enough information at this time to determine if the project meets this policy regarding water quality, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-G-1, and thusthe project is also potentially inconsistent with General Plan policy CO-G-1.
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45. ER-G-2 states, “Maintain Creeks as a Resource. Ensure both access to and ecological functionality of the creeks in Pacifica.“ As work is proposed in Calera Creek, additional review by outside agencies will be required. In addition, various environmentalstudies, including biologicalstudies, will be required as the City continues to process this application. As there is not enough information at thistime to determine if the project will maintain creeks as a resource, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-G3, and thus the project is also potentially inconsistent with General Plan policy CO-G-3.
46. ER-G-4 states, “Enable natural processes to occur on developed sites, and utilize these processes to enhance the built environment and users’ experiences of it.” The Stormwater Management Plan (SWMP) does not identify, nor discuss opportunities to reduce imperviousness and incorporate stormwater controls into the site and landscape design, nor does it use the 4 percent method to design bioretention areas, nor details on wetland restoration areas. Further, demonstration of approval of outside agencies to work in the creek will be required. Lastly, various environmental studies will be required as the City continues to process this application to analyze environmental impacts. Asthere is not enough information to determine if the project will enable natural processes to occur, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-G-4, and thus the project is also potentially inconsistent with General Plan policy CO-G-4.
47. ER-I-I states, “Creek Protection and Restoration. Maintain, protect, and restore Pacifica’s creeks, including San Pedro, Rockaway, Calera, Sanchez, and Milagra creeks, as environmental and aesthetic resources. Actions will include, but are not limited to: • Continuing restoration efforts along San Pedro Creek to improve conditions for steelhead by removing obstacles to fish passage, placing rock weirsto facilitate fish passage, and by monitoring the effectiveness of these projects; • Partnering with local organizations, such as the San Pedro Creek Watershed Coalition, Go Native, the Pacifica Land Trust, and others, on restoration efforts; • Exploring opportunities to collaborate with other agencies and organizations on stream restoration and riparian habitat restoration along Sanchez and Calera creeks; • Enforcing restrictions on the planting of invasive species near creek areas; • Identifying and working with property owners to take advantage of unique opportunities where human active use (e.g., through trail development) would enhance creek appreciation without disrupting ecological function; • Requiring a minimum of 100 feet buffers from the top of creek banks, or from the outer edge of riparian vegetation, where it exists, whichever is further, for development proposed adjacent to creeks, in keeping with City regulations and Best Management Practices. The 100-foot buffer may be reduced by the minimum necessary to avoid a taking (for private development), provided that any unavoidable impacts are commensurately mitigated. The 100 foot buffer may also be reduced to provide required incidental public services (for public development, such as burying cables and pipes or inspection of piers, maintenance of existing intake and outfall lines, and emergency repairs),
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provided that any unavoidable impacts are commensurately mitigated, that the buffer is as close to 100 feet as possible, and no less than 50 feet in any case, and provided that creek resource impacts are avoided as much as possible, and unavoidable impacts commensurately mitigated, all as conclusively demonstrated by a qualified biologist to the satisfaction of the City and applicable resource agencies, except that the 50-foot minimum shall not apply to low intensity public access and recreation maintenance and improvement services. • Permitted uses within buffer zones are limited to uses dependent on the resources within these areas and their buffer zones (i.e., habitat management and restoration, scientific research and educational activities, and low-intensity public access and recreation), Temporary disruption (e.g. less than six months), as determined by a qualified biologist in consideration of on-site specific biological resources, for the construction, alteration, repair, and maintenance of existing or newly permitted facilities or structures is allowed if there are no feasible alternatives, the disruption area is restored to its predisruption state or better within one yearfrom the initial point of impact and there is no significant ground disturbance.” As work is proposed in Calera Creek, additional review by outside agencies will be required. Details on wetland restoration areas, 100-year floodplain and a 35-foot creek setback from top of bank are not included in the materials submitted. In addition, various environmental studies, including biological studies, will be required as the City continues to process this application. As there is not enough information at this time to determine if the project will comply with creek protection and restoration requirements, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-1, and thus the project is also potentially inconsistent with General Plan policy CO-I-1.
48. ER-I-4 states, “Wetlands Preservation. Prohibit new development in existing wetlands except as allowed under the federal Clean Water Act and the California Coastal Act. Continue to require formal delineations of wetlands subject to State or federal regulations prior to any proposed development project where potential wetlands have been identified. If impacts on wetlands are unavoidable, compensation measure should be in line with the State’s no-net-loss goal regarding wetlands.” Details on wetland restoration areas not included in application materials submitted.
Various environmental studies, including biological studies, will be required as the City continues to processthis application and will analyze wetlandsimpacts. Asthere is not enough information to determine if the project addresses this policy regarding wetland preservation, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-4, and thus the project is also potentially inconsistent with General Plan policy CO-I-4.
49. ER-I-7 states, “Maintain Functional Capacity of Wetlands. Ensure that any diking, filling, or dredging in existing wetlands maintains or enhances their functional capacity. Any alteration of coastal wetlands identified by the Department of Fish and Wildlife or as defined by the Coastal Commission shall be limited to very minor incidental public facilities, restorative measures, or nature study.” Details on wetland restoration areas not included in application materials and as
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such, the project may be inconsistent with this policy. In addition various environmental studies, including biological studies, will be required as the City continues to process this application to analyze wetland impacts. As there is not enough information to determine if the project will maintain the functional capacity of wetlands, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-7, and thus the project is also potentially inconsistent with General Plan policy CO-I-7.
50. ER-I-10 (and General Plan policy CO-I-10) states, “Stormwater Discharge. Ensure compliance with the Municipal Regional Permit, the Construction General Permit and the Construction Dewatering Permit, which regulate stormwater discharge from new and existing development. These permits are established by the National Pollutant Discharge Elimination System (NPDES) and administered by the Regional Water Quality Control Board. They require that new development incorporate Best Management Practices (BMPs) and Green Infrastructure Plan requirements in site design, construction, and management to minimize storm water runoff rates and volumes, control water pollution, and maximize infiltration.” The Stormwater Management Plan (SWMP) does not identify, nor discuss opportunities to reduce imperviousness and incorporate stormwater controls into the site and landscape design, nor does it use the 4 percent method to design bioretention areas, nor details on wetland restoration areas. Demonstration of approval of outside agenciesto work in the creek will be required. Various additionalstudies will be required asthe City continuesto processthis application. Asthere is not enough information to determine if the project meets this policy regarding stormwater discharge the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-10, and thus the project is also potentially inconsistent with General Plan policy CO-I-10.
51. ER-1-12 states, “Infrastructure and Water Quality. Ensure that the design and construction of new infrastructure elements does not contribute to stream bank or hillside erosion or creek or wetland siltation, and incorporates site design and source control BMPs, construction phase BMPs, and treatment control BMPs to minimize impacts to water quality, in compliance with the NPDES Permit.” A Sewer Capacity Study and Preliminary Sewer Plan, and potentially a Hydrology/Hydraulics, Floodplain/Flood Hazard Analysis, Water Quality and/or a Water Supply Assessment, will be required as the City continues to process this application. As there is not enough information to determine the project’s impact on infrastructure and water quality at this time, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-12, and thus the project is also potentially inconsistent with General Plan policy CO-I-12.
52. ER-1-13 states, “Green Infrastructure. Require that new development projects incorporate inclusion of low impact development drainage design into storm drain infrastructure on public
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and private lands, including streets, roads, storm drains, parking lots, building roofs, and other storm drain infrastructure elements.” The Stormwater Management Plan (SWMP) does not identify, nor discuss opportunities to reduce imperviousness and incorporate stormwater controls into the site and landscape design, nor does it use the 4 percent method to design bioretention areas, nor details on wetland restoration areas. The materials submitted do not include details on existing and proposed utilities and how the proposed project connects so the existing systems. Various studies will be required as the City continues to processthis application to analyze potential environmental impacts. As there is not enough information to determine if the project meets the City’s Green Infrastructure requirements, the project is potentially inconsistent with this policy.
53. ER-I-13 states, “Erosion Control. Manage erosion in the Planning Area, particularly in watershed areas, through on-site erosion control. Construction projects will be required to use appropriate erosion prevention techniques, sediment control measures, and best management practices in accordance with City Specifications and General Conditions of Approval and the San Mateo Countywide Water Pollution Prevention Program.” The Geotechnical Report does not include a plan to describe infiltration testing and detention basin locations after grading is completed, and does not confirm if there are any known nearby sources ofsoil contamination that would prohibit the use of infiltration on site. Additional studies will be required as the City continues to process this application. Asthere is not enough information to determine if the project meetsthe erosion control measures, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-13, and thus the project is potentially inconsistent with this policy with General Plan policy CO-I-13.
54. ER-I-15 states, “Minimize Site Disturbance. Require use of best practices during development design and construction to preserve natural resources, such as soil, trees, native plants, and permeable surfaces.” The Geotechnical Report does not include a plan to describer infiltration testing and detention basin locations after grading is completed, and does not confirm if there are any known nearby sources ofsoil contamination that would prohibit the use of infiltration on site. The submitted project materials do not acknowledge the tree protection standards in Section 4-12.11 of the PMC, nor do they include plans for protecting individual and groups of protected trees by installing a five (5) or six (6) high chain link fencing. In addition, various environmental studies, including biological studies, will be required as the City continues to process this application to analyze impacts to natural resources. As there is not enough information to determine if the project will minimize site disturbance, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-14, and thus the project is also potentially inconsistent with General Plan policy CO-I-14.
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55. ER-I-16 states, “Reduce Impervious Surfaces. Enable natural drainage by reducing the amount of impervious surfaces on a development site, whenever feasible. Techniques that help accomplish this objective: • Designing development projectsto share driveways; • Placing parking lots under buildings, whenever feasible; and • Using permeable paving materials on walkways and driveways, whenever feasible.” The Stormwater Management Plan (SWMP) does not identify, nor discuss opportunities to reduce imperviousness and incorporate stormwater controls into the site and landscape design. Asthere is not enough information to determine if the project reduces impervious surfaces, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-15, and thus the project is also potentially inconsistent with General Plan policy CO-I-15.
56. ER-I-17 states, “On-site Stormwater Management. Continue to require all small projects and detached single-family home projects, as defined under the NPDES Permit, to incorporate site design measures that facilitate groundwater recharge and natural hydrological processes, allowing stormwater to infiltrate the ground on-site and/or be collected for reuse in landscaping and designated to on-site stormwater detention facilities. Techniques for on-site stormwater management include use of: • “Rain gardens” or bioretention areas in yards, parks, and parking lots; • Landscaped drainage swales along roadways; • Green roofs; • Permeable pavers for walkways and parking areas; • Rain barrels for harvesting runoff from rooftops; • Tree box filters for on-street filtration; • Parking areas that direct stormwater flow into vegetated areas; • Grading that lengthens flow paths and increases runoff travel time to reduce the peak flow rate; and • Cisterns or sub-surface retention facilities that capture rainwater for use in irrigation and non-potable uses.” The Stormwater Management Plan (SWMP) does not identify, nor discuss opportunities to reduce imperviousness and incorporate stormwater controls into the site and landscape design. Various additional studies will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding onsite stormwater management, the project is potentially inconsistent with this policy.
This policy is also found in General Plan policy CO-I-16, and thus the project is also potentially inconsistent with General Plan policy CO-I-16.
57. ER-I-18 states, “Prevent Contaminated Runoff. Ensure that new parking lots and commercial development incorporate BMPs designed to prevent or minimize runoff of oil, grease, solvents, battery acid, coolant, gasoline, sediments, trash, and other pollutants from the site. Runoff from areasserving vehicle traffic, structures, landscaping, loading areas, repair and maintenance bays, fueling areas, vehicle/equipment wash areas, outdoor material storage areas, and waste storage areas should be prevented or minimized.” The Stormwater Management Plan (SWMP) does not identify, nor discuss opportunities to reduce imperviousness and incorporate stormwater controls into the site and landscape design. The Geotechnical Report does not include a plan to describe infiltration testing and detention basin locations after grading is completed, and does
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not confirm if there are any known nearby sources of soil contamination that would prohibit the use of infiltration on site. Additional studies will be required as the City continues to process this application to analyze these project impacts. As there is not enough information to determine if the project will prevent contaminated runoff, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-17, and thus the project is also potentially inconsistent with General Plan policy CO-I-17.
58. ER-I-20 states, “Sanitary Sewer Discharge. Ensure that discharges of treated wastewater from the Calera Creek Wastewater Recycling Plant continue to comply with the Sanitary Sewer System Permit. The City will manage the release of treated wastewater as part of habitat restoration along Calera Creek, and pursue the use of recycled water for irrigation and other uses.” A Sewer Capacity Study, Preliminary Sewer Plan and additional studies will be required as the City continues to process this application. Demonstration of approval of outside agencies to work in the creek will also be required. As there is not enough information to determine if the project meets this policy regarding sanitary sewer discharge, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-25, and thus the project is also potentially inconsistent with General Plan policy CO-I-25.
59. ER-G-5 states, “Wildlife and Critical Habitat. Conserve and protect indigenous threatened, endangered, and other special status species by preserving critical habitat. Habitat can be protected by allowing very limited or no development, by identifying habitat areas astop priorities for permanent conservation, and by managing public land to ensure species protection. Critical Habitat in the Coastal Zone is considered Environmentally Sensitive Habitat Area (ESHA).” Various environmental studies, including biological studies and verification of ESHA, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding wildlife and critical habitat, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-G-7, and thus the project is also potentially inconsistent with General Plan policy CO-G-7.
60. ER-G-6 states, “Coastal Environment and Special Status Communities. Conserve and protect beaches, sand dunes, coastal bluffs, and special status communities, particularly the Coastal bluff scrub on the northern bluffs. Prohibit development in coastal dunes to preserve dune formations, vegetation, and wildlife habitats. Prevent overuse in dune areas by mechanismssuch asrestricting parking and directing pedestrian traffic through signage and sand fencing to areas capable of sustaining such use. Prohibit motor vehicles in dune areas except for emergency purposes, and prohibit motor vehiclesin non-dune beach areas except for emergency and essential maintenance purposes and where previously coastal permitted. Special status communities in the Coastal Zone are considered Environmentally Sensitive Habitat Area (ESHA).” Various environmental studies, including biological studies and verification of ESHA, will be required as the City continues to
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process this application. As there is not enough information to determine if the project meets this policy regarding coastal environment and special status communities, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-G-8, and thus the project is also potentially inconsistent with General Plan policy CO-G-8.
61. ER-G-7 states, “Creeks and Riparian Areas as Habitat. Protect year-round and intermittent creeks and their riparian habitats”. Various environmental studies, including biological studies, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding creeks and riparian habitat, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-G-9, and thus the project is also potentially inconsistent with General Plan policy CO-G-9.
62. ER-G-8 states, “Other Environmentally Sensitive Areas. Protect other potential Environmentally Sensitive Habitat Areas (ESHAs), High Value or High Habitat Value areas, and Wildlife Movement Corridors from development that would significantly disrupt habitat values.” Various environmental studies, including biological studies and verification of ESHA, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding other environmentally sensitive areas, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-G-11, and thus the project is also potentially inconsistent with General Plan policy CO-G-11.
63. ER-G-9 states, “Open Space Conservation and Habitat Protection. Protect beaches, oceanfront bluffs, ridgelines, hillside areas adjacent to existing open space, and areas that support critical wildlife habitat and special status species.” Various environmental studies, including biological studies, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding open space conservation and habitat protection, the project is potentially inconsistent with this policy.
64. ER-I-21 states, “Protection of Biological Resources with New Development. Protect sensitive habitat areas and special-status species through implementation of the following measures: 1) The City should discourage development and/or buildout in critical habitat of special status species during the development review process in a manner that is consistent with LD-I-5 to avoid takings. 2) Pre-construction plant and wildlife surveys: Project applicants shall engage a qualified biologist to conduct presence/absence biological surveys for sensitive plant and wildlife species prior to construction adjacent to or within identified special status communities and other sensitive areas identified in Figure 7-3 of the proposed General Plan. If special status species are identified, the qualified biologist shall consult with the California Department of Fish and Wildlife (CDFW) and establish no-disturbance buffers around avian nests, bat roosts, and sensitive plants to avoid disturbance and direct impactsto these resources during construction. If no specialstatus
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species are detected during surveys, then construction-related activities may proceed. Nesting birds, in particular, are protected by two means; they receive protection under the Migratory Bird Treaty Act, and nesting raptors (in the order Falconiformes or Strigiformes) are protected under the State Fish and Game Code, §3503.5. 3) Require biological resource assessments be conducted prior to approval for any development within 300 feet of creeks, wetlands, or other sensitive habitat areas shown on Figure 7-3 of the proposed General Plan. 4) Require on-site monitoring of biological resources by a qualified biologist throughout the duration of construction activity. 5) Require compensatory mitigation by means of habitat preservation, restoration, and enhancement; for the loss of any critical habitat and/or special status communities. Various environmental studies, including biological studies and verification of ESHA, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding protection of biological species with new development, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-26, and thus the project is also potentially inconsistent with General Plan policy CO-I26.
65. ER-I-22 states “Protection of Environmentally Sensitive Habitat Area (ESHA). Protect all sensitive species with defined or potential habitat by establishing specific habitat survey requirements, development limitations, and other requirements to mitigate potential impacts.” Various environmental studies, including biological studies and verification of ESHA, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding protection of ESHA, the project is potentially inconsistent with this policy.
66. ER-I-24 states, “Management of ESHA and Wetlands. If the area qualifies as an ESHA or wetlands under the California Coastal Act, the following regulations apply: • No new development shall be allowed within ESHA with the exception of resource dependent uses (i.e. habitat management and restoration, scientific research and educational activities, and low-intensity public access and recreation) that can be demonstrated to have no significant disruption of habitat values. • Buffer areas shall be established around all ESHA and wetlands, providing a minimum of 100 feet, and may be expanded as needed to account for feeding, breeding, nesting, and other habitat requirements. However, the 100-foot buffer may be reduced by the minimum distance necessary to avoid a taking (for private development), provided that any unavoidable impacts are commensurately mitigated. The 100-foot buffer may also be reduced by the minimum distance necessary, but no less than 50 feet, to provide required incidental public services (for public development), such as burying cables and pipes or inspection of piers, maintenance of existing intake and outfall lines, maintenance of trails and property adjacent to rights of way, and emergency repairs), provided that that the buffer is as close to 100 feet as possible, and provided that ESHA or wetland resource impacts are avoided as much as possible, and unavoidable impacts
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commensurately mitigated, as conclusively demonstrated by a qualified biologist to the satisfaction of the City and applicable resource agencies, except that the 50-foot minimum shall not apply to low intensity public access and recreation maintenance and improvement services. • Development shall be sited and designed to prevent impacts that would degrade adjacent habitat areas, taking into account drainage, vegetation, topography, and other considerations. • Alteration of landforms, removal of vegetation, impervious surfaces, noise, light, and glare shall be minimized as much as possible.” Various environmental studies, including biological studies and verification of ESHA, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding management of ESHA and wetlands, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-24, and thus the project is also potentially inconsistent with General Plan policy CO-I-24.
67. ER-I-25 states, “Fencing. Any fencing or barrierslocated within riparian ESHAs or wildlife corridors shall permit the free passage of wildlife.” Since no biological study, or mapped ESHAs have been submitted, it is unknown at this time if the proposed retaining walls on Sheet L1.01 is located within an ESHA or wildlife corridor, and assuch, the proposal may be inconsistent with this policy.
Various environmental studies, including biological studies and verification of ESHA, will be required as the City continues to process this application. As there is not enough information to determine if the project meetsthis policy regarding fencing, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-29, and thus the project is also potentially inconsistent with General Plan policy CO-I-29.
68. ER-I-26 states, “Ensure that new development is sited and designed to minimize the need for fuel modification and vegetation clearance in order to avoid or minimize the disturbance or destruction of habitat and existing hydrology while still providing for fire safety as necessitated by the North County Fire Authority’s Vegetation Management Program. Prohibit new development that would require fuel modification within ESHAs”. Various environmental studies, including biological studies and verification of ESHAs, will be required as the City continues to process this application. In addition, a Vegetation Management Plan will be required. As there is not enough information to determine if the project meets this policy regarding fuel modification and vegetation clearance, the project is potentially inconsistent with this policy.
This policy is also found in General Plan policy CO-I-30, and thus the project is also potentially inconsistent with General Plan policy CO-I-30.
69. ER-I-27 states, “Monitoring Requirements. Require a Restoration and Monitoring Proposal for any proposed habitat restoration or mitigation. The Proposal should describe the methods and practices to be employed, and include: • A clear statement of the goals of the restoration or
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mitigation for all habitat types; • Sampling of reference habitat, with reporting of resultant data; • Designation of a qualified biologist as the Restoration or Mitigation Manager responsible for all phases of the restoration; • A specific grading plan, if the topography must be altered; • A specific erosion control plan, if soil or other substrate will be disturbed during restoration; • A weed eradication plan designed to eradicate existing weeds and control future invasion by exotic species; • A planting plan based on the natural habitat type; • An irrigation plan that describes the method and timing of watering and ensures removal of watering infrastructure by the end of the monitoring period; • An interim monitoring plan with performance goals, assessment methods, and a schedule; and • A final monitoring plan to determine whether the restoration has been successful.” Various environmental studies, including biological studies, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding monitoring requirements, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-32, and thus the project is also potentially inconsistent with General Plan policy CO-I-32.
70. ER-I-31 states, “Invasive Plant Species. Prohibit the use of invasive plant species (i.e., any California Invasive Plant Council (Cal-IPC)-listed species with a status of high or moderate, or identified as locally-threatening under the limited, alert, or watch status).” The Tree Planting Plan on Sheet L3.00 does not specify if any of the proposed trees or understory schedule are invasive species or not, and as such, the proposal may be inconsistent with this policy. In addition, various environmental studies, including biological studies, will be required as the City continues to process this application and will analyze project consistency with this policy. This policy is also found in General Plan policy CO-I-36, and thus the project is also potentially inconsistent with General Plan policy CO-I-36.
71. ER-G-11 states, “Trees. Conserve trees and encourage native forestation and planting of appropriate trees and vegetation.” The submitted project materials do not acknowledge the tree protection standards in Section 4-12.11 of the PMC, nor do they include plans for protecting individual and groups of protected trees by installing a five (5) or six (6) high chain link fencing. In addition, various environmental studies, including biological studies, will be required as the City continues to process this application and will analyze impacts to trees. As there is not enough information to determine if the project will conserve trees and encourage native forestation and appropriate plantings, the project is potentially inconsistent with this policy.
72. ER-I-42 states, “Resource Impact Mitigation. Ensure that new development analyzes and avoids potential impacts to historic, archaeological, and paleontological resources by: • Requiring a records review for development proposed in areas that are considered archaeologically or paleontologically sensitive; • Requiring pre-construction surveys and monitoring during any
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ground disturbance for all development in areas of historic or archaeological sensitivity; and • Implementing appropriate measures as a condition of project approval—such as avoidance, preservation in place, and excavation,—to reduce or avoid impacts. In the event that historical, archaeological, or paleontological resources are accidentally discovered during construction, grading activity in the immediate area shall cease and materials and their surroundings shall not be altered or collected. A qualified archaeologist or paleontologist must make an immediate evaluation and avoidance measures or appropriate mitigation should be completed, according to CEQA Guidelines. The State Office of Historic Preservation has issued recommendations for the preparation of Archaeological Resource Management Reports that may be used as guidelines.” Various environmental studies, including cultural resource, historic and archaeological studies, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding resource impact mitigation, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-68, and thus the project is also potentially inconsistent with General Plan policy CO-I68.
73. ER-I-43 states, “Native American Sites. Work with local Native American tribesto protectrecorded and unrecorded cultural and sacred sites, and educate developers and the community-at-large about the connections between Native American history and the environmental features that characterize the local landscape.” Various environmental studies, including cultural resource, historic and archaeological studies, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding Native American sites,the project is potentially inconsistent with this policy. This policy is also found in General Plan policy CO-I-70, and thus the project is also potentially inconsistent with General Plan policy CO-I-70.
74. ER-G-16 states, “Viewsfrom Scenic Routes. Ensure that viewshedsfrom Highway 1 and Sharp Park Road are preserved and enhanced. These views are an essential part of Pacifica’s identity.” Development on the Western Parcelsituated on the project site hillside and ridgeline as depicted on Sheets G0.04 – G0.06 situates the proposed buildings to be visually prominent from the western, eastern,southern, and northern vantage points. The proposed new residential buildings impact view and do not preserve or enhance viewshed from Highway 1 and Sharp Park. Thus the proposal is inconsistent with this policy. This policy is also found in General Plan policy CD-G-7, and thus the project is also inconsistent with General Plan policy CD-G-7.
75. ER-I-44 states, “Minimize Visual Impacts of Hillside Development. Require new development to employ innovative site planning, engineering and design techniques that:
• Seek first to avoid impacts to scenic resources through site planning and design; • Minimize grading and conform with natural landforms to the greatest extent possible;
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• Design structures so that they follow contours and limit their downslope exposure; and • Use landscaping to screen and integrate buildings with the natural environment.
As noted in Item B.75 above, buildings are sited on the hillside. The renderings on Sheets G0.04 – G0.06 do not appear to visual screen the proposed new buildings. As such, the proposal is inconsistent with this policy. This policy is also found in General Plan policy CD-I11, and thus the project is also inconsistent with General Plan policy CD-I-11.
76. ER-I-45 states, “Protection of Ridgelines. Protect visually prominent ridgelines from residential and commercial development. Local accessroads and trails may be allowed on visually prominent ridgelines provided they follow contours, minimize grading, and are unobtrusive in their design.” As noted in Items B.75. above, the residential buildings are all sited on the hillside and visually prominent. Additionally, residential uses are proposed with heights varying between approximately 20 – 91 feet on the project site ridgelines. Thus, the proposal is inconsistent with this policy. This policy is also found in General Plan policy CD-I-12, and thus the project is also inconsistent with General Plan policy CD-I-12.
77. ER-I-48 states, “Minimize Impacts of Coastal Development on Landforms. Ensure that negative visual impacts resulting from new development in the Coastal Zone are minimized. In areas characterized by bluffs and landforms. Strategies to implement this policy include:
• Prohibiting development on slopes in excess of 35 percent and highly visible tops of prominent landforms.
• Requiring blufftop development to minimize impacts on the view from the ocean and beach below by implementing a setback from the bluff edge. • Requiring that development be clustered and contoured into the existing slope; and • Requiring that new development be scaled and designed to be subordinate to landforms in the Coastal Zone.
As discussed under Item B.75, the residential units are sited on the hillsides and visibility on the top of the bluff from the western, eastern, southern and northern vantage points. Therefore, the proposed project is inconsistent with this policy. This policy is also found in General Plan policy CD-I-15, and thus the project is also inconsistent with General Plan policy CD-I-15.
78. ER-I-49 states, “Minimize Impacts of Coastal Development on Vegetation. Continue to require that disturbance to vegetation be minimized in new development and that graded areas be promptly replanted with native vegetation.” Sheet L0.04 indicates a significant number of trees proposed to be removed. Neither the plan set, nor the submitted Arborist Report by WRA, dated September 2025, specifies the exact quantity/amount of other vegetation proposed to be removed as result of the proposed development. Due to the significant number of trees to be removed and the lack of details provided, the proposal may be inconsistent with this policy.
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Additionally, future biological studies, will be required to determine whether the proposed replanting plan (Sheet L3.00) is adequate native vegetation under this policy. This policy is also found in General Plan policy CD-I-16, and thus the project is also potentially inconsistent with General Plan policy CD-I-16.
79. ER-I-51 states, “Rockaway Quarry Site. Development on the Quarry site should be prioritized in the “flats” and should connect with the adjacent Rockaway Beach district. Development in areas of the Quarry site that would impact the visual qualities of surrounding hillsides or ridgelines should be avoided to the greatest extent feasible.” Development on the Western parcel, which is a significant portion of the overall proposed development, is not situated on the “flats” and could impact the visual quality of the surrounding hillsides and ridgelines. See also Item B.4 regarding open space and trails. As such, the proposal is inconsistent with this policy. This policy is also found in General Plan policy CD-I-18, and thus the project is also inconsistent with General Plan policy CD-I-18.
80. ER-I-52 states, “Trail Design on Coastal Headlands and Bluffs. Develop new trails on Pedro Point Headlands, Aramai Point, the Quarry site uplands, and the Northern Coastal Bluffs in such a way that native vegetation is protected by limiting pedestrians to designated trails and preventing access by motorized vehicles.” As noted in Item B.4 above, there is a lack of specificity regarding the proposed new trail. Without these details and specifications, and from the limited details provided in the plan set, the proposal is inconsistent with this policy. This policy is also found in General Plan policy CD-I-19, and thus the project is also inconsistent with General Plan policy CDI-19.
81. ER-I-53 states, “Underground Utilities. Continue to require underground utilities in all new development. New developmentsshould include undergrounding existing overhead utilities along each project frontage. Within coastal view corridors, place lines underground or located there so they do not break the view line of a roadway vista.” Existing and proposed utilities such as water, gas, electric, telephone and cable, and how the proposed project connectsto the existing systems is not included in the information submitted, nor is there information detailing that all proposed new utilities are installed underground from the nearest joint pole or box. As there is not enough information to determine if the project will meet underground utilities provisions, the project is potentially inconsistent with this policy.
82. ER-I-60 states, “High-Quality Design at Key Points. Ensure that new development directly adjacent to Highway 1 in West and East Park helps to create a strong image of Pacifica's cultural and civic core, and that new development in the Rockaway Quarry site has a visual quality that enhances the natural setting and draws travelers in from the highway.” As noted in Item B.76. above, the siting of the proposed residential buildings is on the hillsides. Additionally, as discussed in Items
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B.1 and B.2 above, the proposed residential land use is inconsistent with the land use designations of Conservation and Visitor Serving Commercial. As such the proposed residential building designs are inherently inconsistent with this policy as it does not produce a visual quality consistent with its designated land uses. This policy is also found in General Plan policy CD-I-27, and thus the project is also inconsistent with General Plan policy CD-I-27.
83. NH-I-9 states, “Hillside Erosion Prevention. Encourage erosion prevention of hillside areas to maintain slope stability by revegetation. Other slope stability methods may be acceptable, consistent with this LCP.” And General Plan policy SA-I-7 states, “Erosion Prevention. Require erosion prevention of hillside areas by revegetation or other acceptable methods.” Variousstudies will be required as the City continues to process this application. As there is not enough information to determine if the project meets the hillside erosion prevention measures, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy SA-I-7, and thus the project is also inconsistent with General Plan policy CD-I-18.
84. NH-I-10 states, “Geotechnical Studies. Within the Coastal Zone and hillside areas, continue to require geotechnical site investigation for proposed development on sites located in any of the following areas, prior to allowing site development: • On slopes greater than 15 percent. • In areasshowing evidence of landslides or landslide potential. • In areasshowing evidence of ground shaking or earth movement. • Within 300 feet of a bluff edge in Coastal Vulnerability Zones. • Within sand dune areas. Geotechnical studies shall identify any geologic hazards affecting the proposed project site, any necessary mitigation measures, and a statement of the site’s suitability for the proposed development and whether or not it will be safe from geologic hazard for its anticipated life. The study shall identify net developable areas, if any, based on landslide or ground shaking potential and/or erosion risk. Impacts from the development, such as those resulting from increased water runoff, shall also be determined. Such studies must be signed by a licensed Certified Engineering Geologist or Geotechnical Engineer and are subject to review and approval by City staff. As detailed in CR-I-19, further technical reports may be required for applicable projects.” The Geotechnical Report does not include a plan to describe infiltration testing and detention basin locations after grading is completed, and does not confirm if there are any known nearby sources ofsoil contamination that would prohibit the use of infiltration on site. Additional studies will be required asthe City continuesto processthis application. Asthere is not enough information to determine ifthe projectmeets all the Geotechnical Study provisions, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy SA-I-8, and thus the project is also inconsistent with General Plan policy CD-I-18.
85. NH-I-11 states, “Maintain Restrictions on Hazardous Areas. Continue enforcing the existing Coastal Zone Combining District and Hillside Preservation District regulations that restrict development in hazardous areas where access is impractical and areas prone to hillside and
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coastal erosion, landslides, seismic shaking, tsunami inundation, or flooding.” The proposed project is potentially inconsistent with the Coastal Zone Combining District and the Hillside Preservation District regulations that restrict development in hazardous areas. Forthcoming review is anticipated as it pertains to Zoning and Municipal Code requirements including zoning requirements in the Coastal Zone Combining District (Article 43) and Hillside Preservation District (Article 22.5). Therefore, the project may potentially be inconsistent with this policy. In addition, various environmental studies will be required as the City continues to process this application and additional inconsistencies may be noted. This policy is also found in General Plan policy SAI-9, and thus the project is also potentially inconsistent with General Plan policy SA-I-9.
86. NH-I-13 states, “Grading and Drainage Plans. Continue to require a grading and drainage plan for proposed development requiring a coastal development permit and a grading permit. The Plan should demonstrate how the project will maintain natural surface drainage and existing vegetation to the greatest extent feasible, by minimizing alteration of natural topography and removal of existing trees and vegetation; stabilizing cut-and-fill surfaces with native vegetation; restricting the movement of heavy equipment and machinery; and other means. Prohibit development-related grading and vegetation clearance on slopes steeper than 35 percent.
Driveways and utilities may be allowed in the case that there is no less environmentally damaging alternative for providing access to the building site.” Various environmental studies and peer review will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding grading and drainage plans, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy SA-I-11, and thus is also potentially inconsistent with General Plan policy SA-I-11.
87. NH-I-16 states, “Development in Coastal Zone. Continue to enforce provisions of the California Coastal Act requiring new development within the Coastal Zone to: • Minimize risks to life and property in areas of high geologic, flood, or fire hazard; • Assure stability and structural integrity, and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding area or in any way require the construction of protective devices that would substantially alter natural landforms along bluffs and cliffs; and • Not violate required coastal resource setback provisions.” The Geotechnical Report does not include a plan to describe infiltration testing and detention basin locations after grading is completed. Details on the 100- year floodplain and a 35-foot creek setback from top of bank are not included in the materials submitted. No Vegetation Management Plan was submitted. In addition, future environmental review and studies may note inconsistencies. As there is not enough information to determine if the project meets all the California Coastal Act provisions for new development, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy SA-I-11, and thus is also potentially inconsistent with General Plan policy SA-I-15.
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88. NH-G-2 states,” Development in Hazardous Areas. Site and design development in 100-year floodplains and tsunami hazard zones to minimize hazard risk without the need for armoring (e.g. flood damage prevention programs).” Details on wetland restoration areas, 100-year floodplain and a 35-foot creek setback from top of bank are not included in the materials submitted.
Therefore, the project may be subject to flooding. Various environmental studies will also be required as the City continues to process this application and will analyze potential hazards. As there is not enough information at this time to determine if the project will comply with development in hazardous areas, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy SA-I-11, and thus is also potentially inconsistent with General Plan policy SA-G-2.
89. NH-1-22 states, “NDPES Enforcement. Enforce NPDES permits, as well as the San Mateo Countywide Water Pollution Prevention Program, to mitigate potential flooding risks by slowing the release of stormwater from development sites into drainage channels.” The Stormwater Management Plan (SWMP) does not identify, nor discuss opportunitiesto reduce imperviousness and incorporate stormwater controls into the site and landscape design. Details on then 100- yearfloodplain and a 35-foot creek setback from top of bank are also not included in the materials submitted. Various additional studies will be required as the City continues to process this application and will analyze flooding risks. As there is not enough information to determine if the project meets this policy regarding NPDES enforcement the project is potentially inconsistent with this policy.
90. NH-I-26 states, “Storm Drainage Impact Assessment. Require developers to provide an assessment of a project’s potential impacts on the local storm drainage system as part of the development review process. If development is found to have a negative impact on storm drainage, require applicable and effective mitigation measures,such asthe creation of permanent or temporary detention or retention basins, provision of additional landscaped areas and green roofs, installation of pump stations, and the use of permeable paving in driveways, walkways and parking areas.” Various environmental studies, including a storm drainage assessment as noted in this policy, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding storm drainage, the project is potentially inconsistent with this policy.
91. NH-I-28 policy states,” Tsunami Inundation Zone. For new development in the tsunami inundation zone, require use of low impact engineering techniques, such as elevating structures above projected water levels, to mitigate impacts to people and structures.” Various studies and analyses will be required as the City continues to process this application to analyze tsunami and flooding risks. As there is not enough information to determine if the project complies with the tsunami inundation zone requirements, the project is potentially inconsistent with this policy.
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This policy is also found in General Plan policy SA-I-26, and thus is also potentially inconsistent with General Plan policy SA-I-26.
92. NH-I-40 states, “Rockaway Quarry Service. Ensure that any new development at the Rockaway Quarry site is adequately served by public infrastructure, including fire and police services.” Various studies, including a Sewer Capacity Study, will be required as the City continues to process this application. As there is not enough information to determine if the project would be adequately served by public infrastructure, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy SA-I-100, and thus is also potentially inconsistent with General Plan policy SA-I-100.
93. CR-G1 states, “Key Coastal Act Policies. The City of Pacifica adopts the following key policies derived from the Coastal Act to address coastal resilience:… PRC 30253. New development shall:
(1) minimize risks to life and property in areas of high geologic, flood, and fire hazard; and (2) assure stability and structural integrity, and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding area or in any way require the construction of protective devices that would substantially alter natural landforms along bluffs and cliffs; and, The Coastal Resilience policies adopted herein are intended to achieve and are consistent with these key policies, subject to periodic updates as resource and development monitoring and program implementation may dictate.” From the materials submitted, 100-year floodplain, creek setbacks from top of bank, nor a Vegetation Management Plan are not included Various studies, will be required as the City continues to process this application to analyze geologic, hazards and other impacts, and will assist in determining whether the project is consistent with the aspects of this policy related to coastal resilience. As there is not enough information at this time, the project is potentially inconsistent with those aspects of the policy.
This policy is also found in General Plan policy SA-G-4, and thus is also potentially inconsistent with General Plan policy SA-G-4.
94. CR-I-2 states, “Development in Coastal Vulnerability Zones. Development located in Coastal Vulnerability Zones may only be approved if such development, as measured over its full anticipated life, is sited, designed, and conditioned: a. to avoid, and where unavoidable, to minimize risks from coastal hazards to the maximum extent feasible; b. to avoid, and where unavoidable, to minimize and mitigate to the maximum extent; c. to avoid creating a nuisance; d. To avoid encroachment onto public trust lands; and e. to assure stability and structural integrity without reliance on shoreline protection devices except as provided in CR-I-38, CR-I-39, and CR-I-40.” And related General Plan policy SA-I-28 states, “Vulnerability Identification and Mapping. The City’s Coastal Vulnerability zones shall be mapped based on the best available science about projected sea level rise, erosion, flooding, and other coastal hazards. Mapping shall be updated as necessary to guide implementation of the LCP’s Coastal Resilience policies.
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Notwithstanding the Coastal Vulnerability Zone Maps, site-specific hazard mapping and assessment may be required as part of the individual development review process for properties within the City’s Coastal Vulnerability zones.
As noted in Item B.3. above, portions of the project site appear to be within the LCP mapped Coastal Vulnerability Zone. Site-specific mapping and assessment will be required as the City continues to process this application. In addition, various environmentalstudies will be required.
As there is not enough information to determine if the project meets the requirements of these policies, the project is potentially inconsistent with these policies.
95. CR-I-19 states, “Development proposed in Coastal Vulnerability Zones shall include coastal engineering, geomorphology and other relevant technical reports unless on-site hazards already identified in a recent Coastal Vulnerability Zone Map or assessment approved within the last five years are adequate for evaluating and ensuring compliance with the LCP, including through use of permit conditions to address any uncertainty. Reports shall • be prepared by a licensed civil engineer or other suitably qualified professional; • use the best available science;
• consider the impacts from the intermediate-high projection (CalNRA & OPC 2024; or similar precautionary projections as reflected in future updated statewide guidance) of sea-level rise for the anticipated life of the proposed development;
• demonstrate that the development will avoid (or if unavoidable, minimize) impacts from coastal hazards for the anticipated life of the proposed development without reliance on any existing or future shoreline protection devices, except that development behind Special Shoreline Resiliency Areas may consider CR-I-38, CR-I-39, and CR-I41; • for blufftop and/or shoreline development, be set back a sufficient distance from the blufftop edge or highest predicted water line, accounting for wave runup, highest astronomical tide, storm surge, and other relevant factors(not less than 25 feet, or as determined by site-specific conditions) to avoid coastal hazard risks to the maximum degree possible while ensuring stability and structural integrity in light of potential erosion and other coastal hazards, where such minimum required setback shall be the distance necessary for all structural development (including any decks, fences, patios, arbors, and other ancillary development, and generally not including native landscaping, minor grading for landscaping/restoration purposes, and other similar non-structural development) to stay inland of a line that identifies the future predicted location of the blufftop edge or highest predicted water line, accounting for wave runup, highest astronomical tide, storm surge, and other relevant factors, accounting for expected erosion and a bluff stability factor of safety of at least 1.5 for static conditions and at least 1.1 for seismic conditions (where K=0.15) or sea level rise and other climate change impacts as applicable; and
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• evaluate the foreseeable effectsthat the development will have on coastal resources over time and mitigate the impacts where they are unavoidable.
Reports may be waived for temporary events, temporary development structures or other minor, short-term development where it is clear there will be no significant hazard risks over the project’s life.
The Geotechnical Report does not include a plan to describe infiltration testing and detention basin locations after grading is completed, and does not confirm if there are any known nearby sources of soil contamination that would prohibit the use of infiltration on site. From the application materialssubmitted, technical reports include a 2017 FEMA Flood Insurance map, and the 1996 Reclamation Plan. None of these technical reports included an assessment approved within the last five years as required by this policy, nor do they contain the necessary information to adequately analyze any impacts of sea level rise, various coastal hazards, or coastal resources as specified by this policy. Various environmental studies will be required as the City continues to process this application to analyze these impacts. As there is not enough information at this time to determine if the project meets this policy regarding coastal development, the project is potentially inconsistent with this policy. This policy is also found in General Plan policy SA-I-70, and thus is also potentially inconsistent with General Plan policy SA-I-70.
96. CR-I-20 states, “Siting and Design. Development in Coastal Vulnerability Zones shall be sited, designed, and setback from the blufftop and/or shoreline to be safe from erosion, bluff failure, wave run-up, flooding and other coastal hazards for the anticipated life of the development or in accordance with CR-I-19, without shoreline protection, considering projected sea level rise and other climate change effects to be determined from best available science and current guidance at the time of approval of the proposed development, as demonstrated by site-specific analyses and/or technical reports. Coastal Development Permit approvals shall prohibit shoreline protection structures for the authorized development, require the property owner to record an acknowledgement that the development does not qualify as an existing structure entitled to construction of a shoreline protection structure under Coastal Act Section 30235, and any other laws, that waive any rights to such protection structures that might exist, and that, where necessary, requires a removal and restoration plan, including bonding for large projects, to avoid future shoreline protection structures or project failure. However, behind Special Shoreline Resiliency Areas development may consider CR-I-38, CR-I-39, and CR-I-40.” As noted in Item B.3. above, portions of the project site appear to be within the LCP mapped Coastal Vulnerability Zone. Site-specific mapping and assessment will be required as the City continues to process this application. In addition, various other environmental studies, will be required as the City continues to process this application. As there is not enough information to determine if the project meets this policy regarding siting and design, the project is potentially inconsistent with
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this policy. This policy is also found in General Plan policy SA-I-71, and thus is also potentially inconsistent with General Plan policy SA-I-71.
97. CR-I-27 states, “Habitat Sea Level Rise Migration Buffers. A sea level rise buffer area shall be added to required habitat buffers if necessary to allow for the migration of wetlands and other coastal habitats caused by sea level rise over the anticipated life of the development. Habitats include all wetlands, riparian, intertidal/shoreline and terrestrial environmentally sensitive habitat areas (ESHAs) as defined by the Coastal Act. The sea level rise projection considered shall be determined based on the type of development and current State guidance. Except for temporary uses, as described below, uses and development within sea level rise buffer areas shall be limited to minor passive recreational uses, with fencing, de-siltation or erosion control facilities, or other improvements deemed necessary to protect the habitat, to be located in the upper (upland) half of the buffer area. Water quality features such as drainage swales required to support development shall not be constructed in wetland buffers. Temporary uses may also be placed in the sea level rise buffer area untilsuch time assea level rise causesthe wetlands or other coastal habitat to migrate to within 100 feet of the temporary uses, at which time, they shall be removed. All habitat and buffers identified shall be permanently conserved or protected through a deed restriction, open space easement, or other suitable device.” The application materials do not address how the project may (or may not) be affected by sea level rise, and do not address any mapped ESHAs on site. From the materials submitted, 100-year floodplain and a creek setbacks from top of bank are not included. Various environmental studies will be required as the City continues to process this application to analyze these potential impacts. As there is not enough information to determine if the project meets this policy, the project is potentially inconsistent. This policy is also found in General Plan policy SA-I-78, and thus the project is also potentially inconsistent with General Plan policy SA-I-78.
98. CR-I-28 (and General Plan policy SA-I-79) states, “Stormwater and Dry Weather Flows.
Development shall provide adequate drainage and erosion control facilities that convey site drainage in a non-erosive manner to minimize hazards resulting from increased runoff and erosion. Runoff shall be directed inland to the storm drain system or to an existing outfall, when feasible. If no storm drain system or existing outfall is present, blufftop runoff shall not be channelized or directed over bluffs and/or to the beach or the ocean.” The Geotechnical Report does not include a plan to describe infiltration testing and detention basin locations after grading is completed, and does not confirm if there are any known nearby sources of soil contamination that would prohibit the use of infiltration on site. Various additional studies will be required as the City continues to process this application to analyze stormwater and hazards. As there is not enough information to determine if the project provides adequate drainage and erosion control facilitiesthe project is potentially inconsistent with this policy. This policy is also found in General
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Plan policy SA-I-79, and thus the project is also potentially inconsistent with General Plan policy SA-I-79.
99. CR-I-39 states, “Development directly inland of public infrastructure in Special Shoreline Resilience Areas. Notwithstanding Policy CR-I-2, development located directly inland of the public infrastructure on the immediate oceanfront of the Special Shoreline Resilience Areas mapped in Figures 6-3 and 6-4 may rely on a shoreline protection structure in that area that is existing at the time of the permit application to help demonstrate that its setbacks meet the requirements of Policies CR-I-19 and CR-I-20. In addition to meeting the requirements of Policy CR-I-21, such developmentshall be conditioned to require the applicant to acknowledge that the development’s long-term safety may be based in part on shoreline protection structures located seaward of the development, which may or may not be effective, and/or be maintained, and/or be present in the future.” The proposed development site is situated inland from the Special Shoreline Resiliency Area Rockaway subarea per Figure 6-1 “Coastal Resilience Subarea” of the LCP, but no information in the project submittal acknowledges this, nor provides any details on a proposed shoreline resilience plan (or not). Various studies and analyses will be required as the City continues to process this application and will provide further clarity on consistency with this policy. However, as there is not enough information to determine if the project meets this policy regarding specialshoreline resilience areas, the project is potentially inconsistent with this policy.
C. Project Inconsistency with Pacifica 2040 General Plan The project is inconsistent with the following 2040 General Plan policies as set forth below. 2 1. Figure 4-3 Land Use Diagram designates the project site as Conservation and Visitor Serving Commercial, which does not allow residential uses as a permitted use. Your project is inconsistent as you have proposed only residential uses at an approximate density of 16.25 units per gross acre, which is not consistent with the City’s General Plan Land Use Designations.
2. ES-I-5 requires visitor-oriented uses on the projectsite and states, “Enhanced Visitor Node. Create a highly distinct visitor-oriented commercial and hospitality node at Rockaway Beach and on developable portions of the Rockaway Quarry site. A key component of this strategy would be to pursue a boutique or high end/resort-oriented hotel and supporting tourist-oriented shopping and dining opportunities.” The project proposes only residential uses and does not include a hotel, nor any shopping or dining opportunities, and is thus inconsistent with this policy.
3. ES-I-7 states, “Mixed Land Uses. Promote development of a broader mix of revenue-generating land uses, including hotels, to increase the City’s fiscal benefits.” The project proposes only 2 In addition, the project is also inconsistent with those 2040 General Plan policies that are identical to LCLUP policies, which are discussed above in Section B, Project Inconsistency with the LCLUP.
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