• Constraints on development as would be required to achieve or maintain these standards would adversely impede achievement of this Plan’s economic,. land use and community development, and environmental goals and policies;
• Mitigation of congestion would negatively affect transit, bicycle or pedestrian circulation, or would conflict with General Plan goals for these alternative modes of circulation, for example by increasing crossing distances, increasing pedestrian safety risk, or restricting bicycle or transit access;
• Traffic congestion is a result of an effort to promote transit ridership and/or access, including the development of higher-density development in mixed use areas; or • A demonstrated significant increase in transit ridership, carpooling, bicycling, and/or walking is achieved.
Various studies, including a transportation study with an LOS analysis, 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 vehicle LOS for other roadways and intersections, the project is potentially inconsistent with this policy.
14. CCI-I-23 states, “Design for Safety. Incorporate safety measures in improvement designs for intersections, roadways, pedestrians, transit, and bicycle facilities.” 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.
15. CI-I-32 states, “Class II Facility Design. Wherever Class II facilities are designated, make bike lanes at least 5 feet wide along local streets and at least 6 feet wide on arterials or highways. Separate Class II facilities from vehicle traffic with a solid stripe and mark them with bike lane symbols.” 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. 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 bike lanes meet these design specifications, thus the project is potentially inconsistent with this policy.
16. CI-I-33 states, “ClassIII Facility Design. Demarcate ClassIII bicycle facilities by painting “sharrows” on streets, where appropriate.” 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. 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, thus the project is potentially inconsistent with this policy .
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17. CI-I-34 states, “Signage Program. Develop and implement a signage program for the bikeway system in order to:
• Alert motorists to the presence of cyclists on the road; • Alert cyclists to route turns junctions, and changes in the class of bicycle facility; and • Provide a clear identity for each bicycle route, and periodically provide distance to key destinations.”
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. No details on any proposed signage program for any proposed bikeway system are included. Various studies, including a Transportation Study, will be required as the City continues to process this application. As such, thus the project is potentially inconsistent with this policy.
18. CI-I-35 states, “Obstructions. Align designated bikeways to avoid obstructions such as light posts, signage, trees, and curb cuts, and relocate or modify these obstructions as necessary.” 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. Various studies, including a Transportation Study, will be required as the City continues to process this application. As such, thus the project is potentially inconsistent with this policy.
19. CI-I-58 states, “Accessible Parking. Require convenient and accessible parking facilitiesfor persons with disabilities, consistent with Americans with Disabilities Act (ADA) requirements.” 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. Variousstudies, including a Transportation Study, will be required asthe City continues to process this application. As there is not enough information to determine if the project is providing accessible parking, the project is potentially inconsistent with this policy.
20. OC-I-65 states, “New Cultural Facilities. Support the location or relocation of cultural facilities as part of redevelopment of the Rockaway Quarry site or in the West Sharp Park neighborhood, where such uses could generate economic benefits.” 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, including any proposed cultural facilities (or not). As there is not enough information to determine if the project is supporting new cultural facilities, the project is potentially inconsistent with this policy.
21. CO-I-53 states “Transportation Control Measures. Ensure compliance with the most current Bay Area Clean Air Plan by implementing the Plan’s recommended Transportation Control Measures.
The 2017 Clean Air Plan identifies 17 TCMs aimed at reducing vehicle trips and vehicle miles traveled; increasing access to and support of alternative modes of transportation; promoting compact, walkable land use patterns; and increasing public education and awareness.” Various File No. 2025-036
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studies, including transportation, air quality and greenhouse gas 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 transportation control measures, the project is potentially inconsistent with this policy.
22. CO-I-65 states, “Establish outdoor lighting performance standards to minimize energy use while ensuring appropriate light levels. These can be met by : • Greater use of photocells or astronomical time switches; • Directional and shielded LED lights • Security lights with motion detectors; and • Prohibitions against continuous all- night outdoor lighting unless needed for security reasons. 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 within the materials submitted. Without these specific lighting details, it appears the proposal could be inconsistent with this policy.
23. SA-I-71 states, “Siting and Design. New development on vacant shoreline property shall be sited and designed to be safe from erosion, bluff failure, wave run-up, flooding and other coastal hazards for at least 100 years 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. 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 a waiver of any rights to such protection structures and where necessary require a removal and restoration plan, including bonding for large projects, to avoid future shoreline protection structures or project failure.” Details on 100-year floodplain and a 35-foot creek setback from top of bank are not included in the materials submitted. 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 environmental studies will be required. As there is not enough information to determine if the project meets the requirements of these policies related to siting and design, the project is potentially inconsistent with this policy.
24. SA-I-90 states, “Cleanup of Contamination. Require applicants for development in a potentially contaminated location to perform inspection and cleanup if the site is found to be contaminated with hazardous substances. The City will require a project applicant to have the site inspected by a registered Environmental Assessor. Reports detailing the results must be submitted for City review, and level of remediation and cleanup must be in compliance with federal and State standards.” 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 studies, such as possibly a Phase 1 and/or Phase 2 site assessment, may be required as the City continues to process this application. As there is not enough information to determine if the File No. 2025-036
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project meets this policy regarding cleanup of contamination, the project is potentially inconsistent with this policy.
25. SA-I-103 states, “Emergency Access on New Roadways. Ensure that new roadways are developed in accordance with standards the Municipal Code. In all new development, require adequate access to be provided for emergency vehicles, including adequate widths, turning radii, hard standing areas, and vertical clearance.” From the plans submitted details on fire hydrants and fire apparatus road with a measurement on the ground as path of travel, minimum NCFA fire apparatus accessturning radii and grade with dimensions and scope of roadway are not included.
As there is not enough information to determine if the project meets this policy regarding emergency access on new roadways, the project is potentially inconsistent with this policy.
26. NO-I-I states, “Community Noise Level Standards. Use the Community Noise Level Exposure Standards, shown in Table 9-1, as review criteria for new land uses. Require all new development that would be exposed to noise greaterthan the “normally acceptable” noise levelrange to reduce interior noise through design, sound insulation, or other measures.” No acoustical analysis or noise study were included in the application materialssubmitted. However, these 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 community noise levelstandards, the project is potentially inconsistent with this policy.
27. NO-I-2 states, “Design Features for Noise Reduction. Require noise-reducing mitigation to meet allowable outdoor and indoor noise exposure standards in Table 9-2. Noise mitigation measures that may be approved to achieve these noise level targets include but are not limited to the following: • Construct façades with substantial weight and insulation; • Use sound-rated windows for primary sleeping and activity areas; Use sound-rated doors for all exterior entries at primary sleeping and activity areas; • Use minimum setbacks and exterior barriers; • Use acoustic baffling of ventsfor chimneys, attic and gable ends; • Install a mechanical ventilation system that provides fresh air under closed window conditions. .” No acoustical analysis, noise study, or noise attenuating construction details were included in the application materials submitted. However these 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 noise reduction, the project is potentially inconsistent with this policy.
28. NO-I-2 states, “Best Available Control Technology. Require new, fixed noise sources (e.g. mechanical equipment) to use best available control technology (BACT) to minimize noise and vibration. Noise from mechanical equipment can often be reduced by applying soundproofing materials, mufflers, or other controls provided by the manufacturer.” And NO-I-4 states, “Mechanical Equipment for New Residential Development. Ensure that building regulations require that noise-generating appliances serving new multi-family or mixed-use residential development are located or adequately insulated to protect residents from the noise.” No details on any proposed on-site mechanical equipment to serve the residential buildings was included in the application materials submitted. As such, the proposal may be inconsistent with this policy.
Additionally, various studies, including a noise study, will be required as the City continues to File No. 2025-036
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process this application. As there is not enough information to determine if the project meets these policies regarding noise and equipment, the project is potentially inconsistent with these policies.
D. Project Inconsistency with Pacifica Municipal Code Chapter 9 – Planning and Zoning The proposed project does not comply with various enforceable provisions of the City's Zoning Ordinance, Pacifica Municipal Code ("PMC") Chapter 9. As discussed in Item A above, the project site is designated C3 Service Commercial under the Zoning Ordinance, a designation established by Ordinance No. 391-C.S.
The C-3 district does not permit residential uses either as a permitted use or a conditional use. (PMC § 9-
4.1201.) PMC § 9-4.1201(b)(8) expressly providesthat no residential uses are authorized in the C-3 district.
Under the Coastal Act, a Coastal Development Permit may only be issued where the proposed development is consistent with the certified LCP, including its implementing ordinances. (Pub. Res. Code § 30604(a), (b).) Because the Coastal Development provisions of the Zoning Ordinance are implementing the LCP, compliance with the LCP’s requirements is a condition of CDP issuance.
The Builder's Remedy provisions of the Housing Accountability Act do not relieve an applicant of the obligation to comply with the Coastal Act or its implementing regulations. As discussed in Item B, courts have recognized that the HAA cannot be construed to override the Coastal Act's independent requirements. B
The project is inconsistent with the following specific provisions of PMC Chapter 9:
1. C-3 Service Commercial District – Prohibited Uses (PMC § 9-4.1201) The project site is zoned C-3 Service Commercial. PMC § 9-4.1201 sets forth the permitted and conditional uses in the C-3 district. Residential uses are not listed as permitted uses or conditional uses. PMC § 9-4.1201(b)(8) expressly states that no residential uses are authorized within the C3 district. The proposed project consists entirely of residential development — approximately 1,225 units — with no commercial component. The proposed use is therefore prohibited under the applicable zoning district.
2. Coastal Zone Combining District (PMC Article 43)
The project site is located within the Coastal Zone Combining District, which overlays the base C3 zoning and imposes additional requirements applicable to development within Pacifica's Coastal Zone. Development within the Coastal Zone Combining District must be consistent with the adopted LCP, including the 2025 LCLUP and its implementing ordinances. As set forth in Item B above, the proposed project is inconsistent with numerous policies of the 2025 LCLUP. Those LCLUP inconsistencies independently constitute non-compliance with the Coastal Zone Combining District requirements. Forthcoming review of the project's consistency with the File No. 2025-036
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specific development standards of Article 43 will be provided in the City's June 6, 2026 final inconsistency letter.
3. Hillside Preservation District (PMC Article 22.5)
Portions of the project site are located within the Hillside Preservation District, which imposes development standards applicable to hillside areas, including restrictions on grading, slope disturbance, and development in areas prone to erosion, landslides, and geologic instability. As noted in Item B.85 above, the proposed project may be inconsistent with the Hillside Preservation District regulations that restrict development in hazardous hillside areas. Forthcoming review of the project's consistency with the specific development standards of Article 22.5, including applicable slope and grading requirements, will be provided in the City's June 6, 2026 final inconsistency letter.
4. Additional Zoning Standards
The City'sreview of the project's consistency with additional applicable provisions of PMC Chapter 9, including but not limited to development standards for setbacks, height, lot coverage, parking, landscaping, and site design applicable within the C-3 district and any applicable overlay districts, consistency with other PMC requirements and consistency with R-3 standards is ongoing. The City reserves the right to identify additional zoning inconsistencies in its June 6, 2026 final inconsistency letter as that review is completed and as additional departmental input is received.
California Environmental Quality Act (“CEQA”) Compliance As noted in the April 7, 2026, Application completeness letter, the proposed project does not qualify for a statutory or categorical exemption from the California Environmental Quality Act (CEQA). Therefore, staff has determined that preparation of an Initial Study, and ultimately an Environmental Impact Report (EIR), will be required for this Project under CEQA. As part of the EIR process, the City will identify any necessary technical studies/reports required to be prepared to analyze the project’s impacts. If you would like us to proceed directly to an EIR, please let us know.
Next Steps
We will be completing our inconsistency review and will provide you with a final letter by June 6, 2026.
We reserve the right to expand, modify and clarify the inconsistencies raised in this letter. In addition, we will be providing inconsistencies related to other City policies and documents not addressed here, including the City’s Municipal Code, as noted above, and design guidelines, in that letter.
Lastly, as the City continues processing of your application, it may identify additional information that is necessary to clarify, amplify, correct, or supplement your application.
If you have any questions, please feel free to email me at [email protected].
File No. 2025-036
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Sincerely,
Samantha Updegrave
Community Development Director
City of Pacifica
Attachments:
1. California Coastal Commission, comments, email dated February 18, 2026 STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR
CALIFORNIA COASTAL COMMISSION NORTH CENTRAL COAST DISTRICT 455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
WEB: WWW.COASTAL.CA.GOV
February 18, 2026
Samantha Updegrave
City of Pacifica
170 Santa Maria Avenue
Pacifica, CA, 94044
Subject: Proposed Multifamily Residential Development Project at the Former Pacifica Quarry Site
Dear Mrs. Updegrave:
Thank you for the opportunity to review, and the request for comment on, the application for the development of some 1,225 residential units on some 86 acres at the site of the former Pacifica Quarry (APNs 018-150-110, -120, and -150). From our initial review of the submittal we have concerns related to lack of City of Pacifica Local Coastal Program (LCP) compliance, unit affordability, and the need for an environmental impact report (EIR). The concerns laid out below do not include previously unaddressed Coastal Act/LCP issues that apply to proposed development of the site, which also apply to the current proposal (related to public access, wetland and ESHA protection, archeological/cultural resources, coastal hazards, coastal view corridors, and transportation/traffic, as further described in our previous correspondence dated November 22, 2016, October 12, 2020, April 4, 2022, October 11, 2024, and October 20, 2025), and where those prior comments remain and are incorporated herein by reference. If any of these issues have been addressed, we suggest that the manner in which that was accomplished be documented in the application materials.
1. Applicable Law
Regarding claims in the submittal letter from Buchalter (dated December 31, 2025) that state that because the preliminary SB 330 application was filed with the City prior to the Commission’s certification of the updated LCP Land Use Plan (LUP) the proposed development does not need to be consistent with the updated LCP, a few clarifications are necessary. Both the Housing Accountability Act (HAA) and Housing Crisis Act (HCA or SB 330) explicitly state that no provisions contained within may be construed to lessen the requirements of the Coastal Act, including through implementing or amending a City’s local coastal program. Specifically, that section states:
Nothing in this section supersedes, limits, or otherwise modifies the requirements of the California Coastal Act of 1976 (Division 20 (commencing with Section 30000) of the Public Resources Code). For a housing development project proposed within the coastal zone, nothing in this section shall be construed to prohibit an affected county or an affected city from enacting a development policy, standard, or condition necessary to implement or amend a certified local Proposed Development at the Former Pacifica Quarry Site 2 coastal program consistent with the California Coastal Act of 1976 (Division 20 (commencing with Section 30000) of the Public Resources Code).
Accordingly, the proposal here must comply with the policies outlined in the City’s updated LCP, irrespective of the date of the preliminary submittal. It is also worth noting that prior to the adoption of the updated LUP, the project site was an area of deferred LCP certification, meaning that the Commission retained coastal permitting jurisdiction over the site. Even assuming the applicant was correct in stating that the updated LCP does not apply, then by extension that is an argument that the prior regulatory condition applies, and that prior condition would require the applicant to apply to the Commission for any proposed development, where the Coastal Act would be the standard of review.
Given that the updated LUP carries out the Coastal Act in Pacifica, and has been found consistent with the Act by the Commission in that regard, it is not at all clear that the substantive difference between the Act and the updated LUP would be significant. And in any case, it is immaterial as the updated LCP applies to this property for the reason articulated above.
2. Zoning Inconsistency
The proposed development conflicts with the LCP’s zoning for the site. Specifically, under the LCP the western portion of the site is zoned as a mix of Conservation and Visitor Serving Commercial, and the eastern portion is zoned as Visitor Serving Commercial, neither of which accommodate multi-family residential development. As a result, for a project of this nature to even be considered, the LCP zoning would require amendment.
3. CEQA
The applicant appears to argue that the project is exempt from CEQA, but this is not the case. Projects pursued under the HCA (including builder’s remedy) are not exempt from CEQA (pursuant to Government Code Section 65589.5(e)). Therefore, this project requires the City, acting as lead CEQA agency, to complete the appropriate CEQA process (e.g., an EIR).
4. Affordability Requirements
The submittal purports to propose a 100% affordable, 1,225 unit project. However, from reviewing the submittal materials we are unable to determine if the affordability is deed restricted or required to remain affordable for the period as required by the law. Under the HAA and State Density Bonus Law (SDBL), the affordable units must be subject to a recorded deed restriction for a period of 55 years for rental units and 45 years for owner-occupied units. Accordingly, please clarify whether this proposal will include deed restricted affordable units, and provide the methodology supporting the rent calculations for the units to constitute affordable units as required by the law.
5. Incomplete Determinations
We understand that the applicant is claiming that the City cannot determine the application to be incomplete, citing to Government Code Section 65589.5. However, the requirements of the LCP pertaining to CDPs are not preempted by HAA and HCA, including as it extends to incomplete determinations, for the same reasons that the LCP applies to this development as articulated above.
Proposed Development at the Former Pacifica Quarry Site 3 6. Site Requirements
We have previously provided many comments related to various proposed projects at this former quarry site, including related to reclamation. To help consolidate our comments for the City and the applicant, please see the below list of primary outstanding questions and comments (and please also refer to previous correspondence dated November 22, 2016, October 12, 2020, April 4, 2022, October 11, 2024, and October 20, 2025, included herein by reference). Please note that these questions and comments are not exhaustive, and we may have different and/or additional comments as the application and development review process unfolds. For now, however, please consider the following:
Reclamation Plan Alternatives Analysis
We understand that the applicant proposes to reclaim the quarry site under a previously proposed 1996 Reclamation Plan. Please require a full evaluation for all possible and previous reclamation alternatives, including at a minimum the alternatives identified in the 1996 and 2016 reclamation plans, a reduced fill alternative, an alternative where the impacted wetlands would be mitigated on the quarry parcel as opposed to the currently proposed eastern parcel, and an alternative that would avoid and minimize impacts to coastal wetlands on the project site to the greatest extent feasible while meeting the Surface Mining and Reclamation Act (SMARA) requirements.
SMARA Regulations
Please require submission of the specific chapters, sections, and language of SMARA which requires the site be reclaimed instead of being able to remain as open space in its current form. Please also provide information regarding SMARA fill requirements, the minimum amount of fill needed for the proposed project, and which alternatives would meet SMARA standards.
Reduced Fill Alternative
We have unanswered questions regarding the reduced fill alternative identified in the previous EIR. As such, please require the following information: (1) explain if and how the Reduced Fill Alternative could accommodate the currently proposed housing project; (2) explain if and how the Reduced Fill Alternative would change the grading ratios compared to the proposed 1996 reclamation plan; (3) provide the specifics for the amount of fill required in the Reduced Fill Alternative according to the minimum SMARA standards, and how this compares to the fill required for proposed preferred project; (4) clarify how much less fill would be placed in the quarry pit in the Reduced Fill Alternative compared to the proposed project; (5) explain how the Reduced Fill Alternative would impact the existing wetlands and the proposed plan for wetland mitigation that would be required, and if reduced fill would lessen impacts to the existing wetlands; (6) analyze how the Reduced Fill Alternative would differ visually from the proposed preferred project and provide new visual simulations; (7) provide the estimate of greenhouse gas emissions and vehicle miles traveled for the Reduced Fill Alternative, including a comparison to the proposed preferred project; and (8) expand on how the proposed public access trails would be altered by the Reduced Fill Alternative, including specifics of which existing trails would remain with the proposed preferred project.
Proposed Development at the Former Pacifica Quarry Site 4 Wetland Delineation
A major concern is that the reclamation plan proposes wetland restoration on the eastern portion of the site when the impacted wetlands are located on the western portion, referred to as the “Quarry Parcel”. As the proposed mitigation wetlands would relocate the resource to a more inland site, they may not fulfill the same ecological role as the current wetlands since they are dispersed throughout the Quarry Parcel and provide habitat value to the site. Typically, on-site, in-kind restoration is the preferred requirement to assure adequate mitigation, and the proposed location of the restoration efforts would likely be considered off-site as currently proposed. If offsite restoration is the chosen approach, it is critical the applicant provides a strong ecological rationale to support the decision to relocate the wetlands. Further, we recommend incorporating a more detailed and thorough analysis of how the proposed project and each of the proposed project alternatives would impact the wetlands and other biological resources on site and how each would mitigate for such impacts.
As such, please require the following information: (1) an updated wetland delineation (given the prior wetland delineation was conducted in peak dry season (August) and is now more than five years old (2019)) completed during the growing season, as is consistent with the U.S. Army Corps of Engineers Wetlands Delineation Manual; (2) anticipated impacts from the proposed reclamation plan and the proposed housing plan in relation to the updated wetland delineation; (3) a comprehensive wetland mitigation plan using the appropriate mitigation ratios; (4) information on how impacts to wetlands, environmentally sensitive habitat areas (ESHAs), and trees will be mitigated, considering the Coastal Commission’s typical mitigation ratios of 4:1 for wetlands and 3:1 for ESHA where these ratios assume habitat creation or substantial restoration strategies; (5) a strong ecological rationale for why the proposed project would restore wetlands in the eastern portion of the site when the wetlands being destroyed are located in the western portion, and why the proposed project would change the number and size of distinct wetland areas (i.e. from wetland complexes composed of multiple smaller features to one larger area that consolidates the acreage); (6) complete analyses assessing the potential ecological effects of mitigating a mosaic of spatially dispersed smaller wetlands as opposed to one continuous larger feature, including the potential impacts for isolation from the riparian corridor at Calera Creek, surrounding upland resources, connections to Mori Point resources in the north, and potentially reduced habitat complexity (7) quantitative monitoring methods and a clear rationale for the methods proposed, as well as a detailed sampling design with quantitative methods, statistical approaches, criteria for assessing success, and assessment methods.
Vegetation Impacts
Please require the following information: (1) information on how the fill proposed would ensure contamination by invasives is avoided; (2) additional information regarding the intention to visually integrate the revegetation with the surrounding open spaces; (3) strategies to reduce aerial erosion and suspension of the imported fill as dust in case that revegetation fails to establish; (4) the technical basis for the native species mix proposed in the revegetation plan, including quantitative data from an appropriate reference site that addresses community composition and proportions, to ensure that what is planted on-site is appropriate for the local conditions and landscape; (5) seed Proposed Development at the Former Pacifica Quarry Site 5 sources that will ensure the genetic integrity of local populations, including through certified local harvest within coastal San Mateo County; and (7) how the project will create a self-sustaining native vegetation community, including consideration for the impacts of any maintenance and vegetation management actions including, but not limited to, weeding, mowing, the application of herbicides, or irrigation inputs.
Hydrology and Water Quality
Please require the following information: (1) how the project will minimize adverse changes to the site’s runoff flows resulting from the increase in impervious surfaces; (2) how the proposed vegetated swales and other best management practices (BMPs) will be sized to infiltrate, retain, and/or treat the volume of runoff produced by the 85th percentile 24-hour design storm; (3) how the project will minimize compaction of soils during construction activities to protect the site’s natural infiltration capacity; (4) how the project will avoid the use of temporary erosion and sediment control products (such as fiber rolls, erosion control blankets, mulch control netting, and silt fences) that incorporate plastic netting (such as polypropylene, nylon, polyethylene, polyester, or other synthetic fibers), in order to minimize wildlife entanglement and plastic debris pollution (5) how the project will minimize the use of landscaping chemicals for the revegetated areas, to the extent feasible; (6) the project’s use of irrigation, and if applicable, how the project will minimize potential adverse effects of dry-weather runoff resulting from irrigation; (7) a summary of measures that will be implemented to minimize increased runoff from the proposed hardscape areas; and (8) an analysis of the continued performance of water quality and drainage control measures into the future, taking into account how such measures and the site will be impacted by ongoing sedimentation and other potential impacts caused by sea level rise.
Tribal Consultation
Please require the completion of a Sacred Lands Inventory Search and Native American Contacts List Request with the California Native American Heritage Commission. Following receipt of information regarding any sacred lands or tribes, please provide us with copies of that information and begin the tribal consultation process. If the process has been completed, please provide copies of the engagement and feedback received.
Landform Alteration
The LUP includes policies ER-G-15 and ER-I-44, which require that site restoration take place with minimal landform alteration. All measures to be taken to limit landform alteration as much as possible should be identified, with all unavoidable landform alteration documented, including the reason for it.
Quarry Policies
The LUP includes policies specific to the former quarry site, including LUP Policies ERI-48 and ER-I-51. Policy ER-I-51 states that Development on the quarry site should be prioritized in the “flats”, should connect with the adjacent Rockaway Beach district, and should avoid degradation of the visual qualities of surrounding hillsides and ridgelines, which should be avoided to the greatest extent feasible. Please outline how the proposed development complies with these requirements.
Proposed Development at the Former Pacifica Quarry Site 6 Coastal View Corridor Impacts
The LUP includes policies specific to impacts on Coastal View Corridors, including LUP Policies ER-G-15 and ER-G-16, and identifies the quarry as an area with view corridors from the west, south, and north. Accordingly, please require the following information:
(1) an outline of how the proposed development is compliant with these policies and how it will not impact coastal view corridors, including in terms of proposed building heights; (2) and analysis of visual impacts that might occur during the various phases of the project including construction, early revegetation, and established revegetation; and (3) visual simulations from all major view corridors identified in the LUP.
Traffic Analysis
LUP policy PR-G-20 requires seeking solutions that ease traffic congestion on Highway 1 near Reina Del Mar Avenue (east of the project site) and Fassler Avenue (south of the project site). The traffic analysis states that 250 days a year for 4 years the project will generate 161 truck trips, or 483 passenger car equivalent (PCE) trips, and that once completed is expected to generate 5,892 daily trips. Accordingly, please require the following information: (1) further analysis on the effect this will have on local traffic and Highway 1; and (2) what measures will be taken to offset the greenhouse gas emissions that will be generated from such trips.
Coastal Hazards
Portions of the proposed development are within the City’s mapped Coastal Vulnerability Zones, and accordingly the project must comply with the Coastal Hazards sections of the LUP. Please require the applicant to detail how the project conforms with the Chapter 6 policies of the LUP, including hazards, setbacks, no future armoring provisions, among others.
Public Recreational Access
The Quarry site provides public access to Rockaway Beach and trails that overlook the ocean and thus serves as an important coastal public access resource. Further, the submittal claims that there is no trail connection between the Calera Creek trail and Mori Point to the north, which is incorrect. There are numerous trail connections between the Quarry, Calera Creek, and Mori Point, which would be heavily impacted by the proposed development. Accordingly, please require the following information: (1) a detailed analysis of the negative impacts to public access by the proposed development, and outline how the project can be designed to ensure maximum public recreational access opportunities; (2) a description of all the existing trails that would remain as part of this project; (3) the type of trail maintenance that would be conducted as necessary; and (4) whether the project includes the trail on the southern bluffs accessed from Rockaway Beach.
Alternatives
It is imperative in our view that the proposed project be the subject of a full alternatives analysis that evaluates its impacts and benefits across a co-equal set of evaluation factors that are derived explicitly from LCP requirements. Such evaluation should also consider variations and permutations of the main alternatives analyzed if needed to ensure that LCP inconsistencies are avoided, including related to public access, Proposed Development at the Former Pacifica Quarry Site 7 wetland/ESHA protection and buffers, coastal hazards, tribal/cultural resources, and coastal view corridors.
Other Agency Approvals
Please require the applicant submit any other agency approvals once they are granted, including but not limited to: the City of Pacifica, the Army Corps of Engineers, the Regional Water Quality Control Board, the State Mining Board, and USFWS.
If you have any questions regarding these comments, please contact me via email at [email protected].
Sincerely,
Julian Honey, Coastal Planner
North Central Coast District Office
California Coastal Commission
cc: Paul Heule, Preserve at Pacifica, LLC (applicant)
Enclosures: Commission correspondence dated November 22, 2016, October 12, 2020, April 4, 2022, October 11, 2024, and October 20, 2025.