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.