Responses to Coastal Commission Comments on Consultation ...

Responses to Coastal Commission Comments on Consultation Draft

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COMMENT BUBBLE/ REVISION CALIFORNIA COASTAL COMMISSION INPUT RESPONSE FROM CITY OF PACIFICA

1 Introduction

1-A1 1-1 Comment Bubble

Overall chapter recommendations: consider shortening this section to be clearer, more relevant to this LCPLUP document, and less redundant. Also need to address corrections to the maps we previously discussed and add in qualifying language for certain figures/maps.

Noted. The comments will be considered where applicable in other sections of the document.


Better to state what is included as defined by the Coastal Act and note some examples. Added footnote referring to definition of "development" in Glossary.

1-2 Revision

Accepted.


Shorten this paragraph to one sentence and note that the City plans to certify these area as part of the Update process.

Paragraph revised for clarity and to include the intent to pursue LCP certification for Shelldance Nursery and the Quarry Site.


Note: Shelldance Nursery is now part of GGNRA federal lands. Federal park projects in the Coastal Zone are not subject to City-issued coastal permits. LCP policies regarding uses within Shelldance Nursery simply provide guidance to both the National Park Service and California Coastal Commission, which typically review federal projects under what is known as the federal consistency review authority. However, all non-federal development that occurs on federal lands is subject to coastal development permit review by the California Coastal Commission with the Coastal Act serving as the standard of review.

Noted. The proposed land use designation for the Shelldance Nursery site is indicative of the City's preferred use of the site.


30519.5 also requires the CCC review LCPs at least once every five years Noted.

1-2 Revision

Deleted redundant text.

1-5 Revision

Added "vegetative" to list of highly sensitive habitats.

1-A6 1-6 Comment Bubble Redundant; stated in 1.1

Redundant text deleted. Replaced with new text describing the Coastal Commission's Environmental Justice authority under AB 2616 (Burke).


Shorten to one or two sentences, mention consistency with Coastal Act. Section shortened, and Coastal Act consistency added.


Process shouldn’t be included here because will be outdated quickly Process language has been deleted.

1-A9 1-6 Comment Bubble Redundant Language deleted.


There are overlapping policies and concepts in these two chapters; see comments in these chapters. Noted. Appropriate revisions have been made in Chapters 5 and 6.

1-A11 1-9 Comment “Should” is considered strongly recommended. Language was revised in response to this comment.

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Note what type of language is binding and mandatory (ex. "shall" or “must”) Language was revised in response to this comment.


Recommend including a note that the Coastal Act Policies in Appendix A are incorporated into the LCP by reference. Language was revised in response to this comment.


Recommend adding stock language regarding maps/diagrams that they are illustrative only and existing conditions on the ground (ex. resources/hazards) control. For example, while maps of biological resources, including special status species, wetlands, and streams, are important indicators of the presence of significant resources that require protection under LCP policies, additional information regarding such resources will become available through site-specific review of proposed projects, through future map updates, and through other means. Thus, protection of biological resources is not limited to those that are mapped in this document. Furthermore, LCP policies address areas adjacent to ESHAs and parks and recreation areas, and as knowledge about those areas increases or as park boundaries change through land acquisitions, the LCP policies will be applied accordingly. The same would apply to areas designated on the hazard maps. Sample language could include the following: “This map was developed for planning purposes and is illustrative only. The City of Pacifica is not responsible or liable for use of this map beyond its intended purpose. This map is representational only. Data are not survey accurate.” Language was revised in response to this comment.


This shouldn’t live in a document that is intended to have a useful life of at least 20 years. Also, doesn’t seem to be framed accurately Language deleted.


There is both a process for minor amendments (CCR Section 13554 and 13555) and de minimis (Coastal Act Section 30514(d)) amendments. Both types of amendments must be reported to the Commission for their concurrence to be considered approved and certified. Language was revised in response to this comment.

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2 Land Use and Development


Overall chapter recommendations: -Add more detail to the policies that mention potential uses of and for the Quarry site. -Add clarifications to language where noted. -Include neighborhood-specific traffic analysis recommendations similar to the existing LUP. -Any proposed land use designation changes should not increase the density of land use over existing designations in hazard areas (ex. Landward of the Pacifica Pier Seawall) or in areas with known sensitive habitat constraints eg. (Pedro Point vacant land). -Areas with severe development constraints (eg. vacant lots where apts or homes were removed) should be designated conservation or similar. For example, there are two remaining yellow lots in the Pacific Manor site that are now vacant and should be changed accordingly. -Shelter cove no longer has formal access, as such, residential development should be phased out as there is no longer public services to support new residential development. -Describe the intended purpose of the italicized language.

Noted. The comments will be considered where applicable in the relevant sections of the chapter.


Incorporate whole Coastal Act into LCP so all relevant policies are captured (e.g. additional potentially relevant Coastal Act policies here include 30211, 30212, 30212.5, 30214, 30223, 30235, 30240, 30251, 30253)

A revision to language in Chapter 1 incorporates the Coastal Act by reference. Added references to PRC sections 30211, 30212, 30223, 30235, 30240, 30251, and 30253. Deleted less relevant provisions from Article 7.


Note sources for numbers and percentages below. Are these current estimates? Figures reflect City staff analysis and are current figures.


Add text re: constraints on sites that likely have numerous development constraints

The requested disclosure of development constraints is stated in the final sentence of the first paragraph of this subsection.


Consider changing the name to Agriculture/Open Space or something to better express the intent of the land uses within this designation.

Designation changed to "Open Space/Agriculture/Residential" (OSAR). The extremely low density of residential development indicated in this designation expresses the intent for significant open space and agricultural areas, with incidental residential development also allowed.


What are these other locations? (Same question for other mixed use zoning designations also.) Clarify.

As used in this and related descriptions, "other locations on the same site" means within a separate building located on the same parcel.


Better differentiate between “city limits” and the other dashed line.

Maps edited to better differentiate between "city limits" and other dashed lines. The maps provided indicate parcel boundaries and reflect areas where public

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-Map should distinguish between paved roads and public right-of-ways (e.g. Calson Property)

rights-of-way have been constructed or offered for dedication. Unlabeled areas which appear as public rights-of-way generally have not been accepted and/or constructed as public streets.

2-A8 2-11 Comment Bubble e.g. a Motel 6 is high intensity, but lower cost.

Noted. Proposed language allowing "lower-cost overnight accommodation" is accepted.

2-A9 2-11 Comment Bubble Clarify language regarding non-conforming uses.

Clarifying language has been added pertaining to abandonment of nonconforming uses.


Would the same City standards regarding abandonment of use apply? If yes, please note that here.

Clarifying language has been added pertaining to abandonment of nonconforming uses.

2-12 Revision

Proposed language regarding "wetlands" and "ESHA" is accepted.


This designation is problematic as defined, as there are other sites fully on beaches and bluffs that are not marked with this designation. Consider using the Conservation designation instead and adding the description here to the bulleted list above.

The "Sandy Beach" designation has been deleted and areas redesignated to "Conservation." New language added to "Conservation" designation to address sandy beaches.


This is more nuanced then written. Modify to better reflect Coastal Act Section 30610 and CCR Sections 13252, 13253, and 13250.

Revised to refer to the relevant sections of the Public Resources Code and California Code of Regulations.


Should also prohibit land divisions on properties in hazard areas similar to ESHA requirements.

The appropriate development density/intensity for any site located within a Coastal Vulnerability Zone is determined by the land use designation applied to the site. Land divisions do not determine the density/intensity of a site, and therefore, the suggested prohibition is inappropriate. See proposed Guiding Policy LD-G-8 to address this concern.

2-14 Revision

Proposed language regarding policies for protecting sensitive habitats is accepted.

2-A14 2-14 Comment Bubble Remove from italics and put in as standard policy language.

Consistent with the new language included in Section 1.5 pertaining to italicized text, the text in italics under this comment adds clarity to application of the policy and it is not necessary to establish this language in the policy itself.

2-16 Revision

Deletion is accepted.


Rephrase to make it clear that this is currently one vision for the site but is not prescribing how the property can and will be developed in the future

The list of potential development applies to the Rockaway Beach district and not the Quarry Site. However, clarifying language has been added.


Would be better to say something like low-impact cabins/tent camping, etc. to better clarify what this language intends. Clarifying language has been added.

2-17 Revision

Deletion is accepted.

2-A17 2-19 Comment 1980 LUP includes information about prevalent coastal hazards Added additional discussion of coastal erosion hazards in appropriate

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Bubble on a neighborhood-by-neighborhood basis (e.g. bluff erosion rates) that should be added here. Can also update with what has occurred in the various neighborhoods given the geologic, erosion, and flood hazards where appropriate.

neighborhoods. Detailed information on bluff erosion rates is more appropriately left to site-specific analyses which the LCLUP would require to be prepared prior to considering development approvals.


Recommend adding in a figure to highlight changes in land use designations from the existing certified LUP to the new proposed LUP.

A figure showing changes in land use will be provided to the Coastal Commission during the LCLUP certification process.


Discuss potential to include a coastal access point for the beach at Shelter Cove

The provision of public coastal access to Shelter Cove will require extensive engineering and great expense. In light of these factors, the establishment of public coastal access to Shelter Cove is unlikely in the near term.


Expand this paragraph to include more details on the reclamation work that is needed prior to any development proposals and the housing initiative needs and process. Please also detail known sensitive habitat and species constraints and note that any development proposals would be subject to such constraints and other relevant LCP policies including hazards. Similarly redevelopment and infill in Rockaway Beach would be limited by hazards.

Additional discussion of reclamation requirements has been added. The narrative already includes discussion of potential sensitive habitats/species on the site and the necessity for detailed site investigations, which could further reduce the development potential of the site. The narrative also already includes mention of the public vote requirement for any residential project. Discussion added regarding hazard/vulnerability assessment prior to future Rockaway Beach infill development.


Expand this paragraph to include more details regarding known sensitive habitat and species constraints and note that any development proposals would be subject to such constraints and other relevant LCP policies including hazards. Discussion added.

2-A22 2-28 Comment Bubble Clarify what this means Language revised to improve clarity.

2-A23 2-28 Comment Bubble Add that this should be outside of hazard areas. Language was revised in response to this comment.


Should include mention of wetlands, riparian corridors, and ESHA Language was revised in response to this comment.

2-A25 2-29 Comment Bubble Add clarifying words about what this means Language was revised in response to this comment.

2-29 Revision

Accepted.


Copy this format and edits throughout document for policies that refer to establishing appropriate zoning standards. Revisions accepted in this policy and made elsewhere in related policies.

2-A27 2-30 Comment Bubble Mention relevant hazards here.

A hazards discussion is not necessary in the context of this policy because it addresses enhancements to an existing public recreational area.


Also need to include that any development will require a detailed evaluation of potential coastal hazard constraints including bluff Language added to require a geotechnical hazard assessment.

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erosion, slope stability, and flooding based on a formal a geotechnical/hazard analysis which may also affect the development footprint.


This should not be included in this document. While it may be the City’s goal, it cannot be seen as a Coastal-Act related requirement for development on the site.

Inclusion of this goal is not in conflict with other goals explicitly stated in the Coastal Act. Coastal Act consistency and revenue generating land uses are not mutually exclusive outcomes. Many visitor-serving commercial uses, such as overnight accommodations, would be consistent with the Coastal Act and would achieve the important City goal of increasing local revenues which in turn can provide valuable services to visitors (e.g., trail maintenance, restroom/trash can service, etc.).


Clarify that this is intended to make the shopping center more efficient with regards to parking and that it could be better oriented to the coastal environment. Clarification added.


Add other requirements specific to the known site constraints including analysis of sensitive species, geotech and hazards including assessment of the railroad berm and ocean hazards with sea level rise and storm surge. Language was revised in response to this comment.

2-21 Revision

Accepted.

2-A32 2-31 Comment Bubble Will need to be certified by CCC if incorporated by reference. Noted. Clarification added.


Clarify – why highly distinct? What does this mean? Ensure this takes all site constraints into consideration here. Clarification added.


Indicate how this was deduced, state constraints that would dictate the actual developable area on-the-ground. Clarification added.

2-A35 2-34 Comment Bubble Add footnote re: 3-5 for Calson property Footnote added.


Add plan for what would happen if this were close to being exceeded/is exceeded Clarification added. See also Policy LD-I-33.


Policies are not prescriptive enough (almost all start with ‘collaborate,’ ‘encourage,’ or ‘support’ rather than actionable items). Need to add in more directive general policies requiring new development to demonstrate that there are adequate public services to serve such development.

The cited policies relate to actions associated with other government entities, the North Coast County Water District and Bay Area Water Supply & Conservation Agency. The City of Pacifica is unable to assert its policies on these partner agencies and instead is adopting policies which reflect the partnership arrangement which will be necessary to achieve the stated goals.


Also need a policy to examine threatened infrastructure already supporting development that needs to be relocated to continue to provide for such existing development (like at SFRV).

This issue is addressed by Policies CR-I-8 and CR-I-9 in Chapter 6. Policies CR-I-17 and CR-I-23 in Chapter 6 support new shoreline protection structures to protect existing public infrastructure in certain situations. In addition, Section 30235 of the Public Resources Code provides that shoreline protection

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structures "shall be permitted when required ... to protect existing structures or public beaches in danger from erosion and when designed to eliminate or mitigate adverse impacts on local shoreline sand supply..."

2-A39 2-39 Comment Bubble How often? Clarify.

The period of evaluation will relate to the term of each solid waste collection franchise agreement executed between the City and the waste hauler. Specifying the period in the LCLUP is inappropriate.

3 Public Access and Recreation


Overall recommendations include: edit policies that start with ‘work with,’ ‘coordinate with,’ etc. and add information throughout as to how these policies are related to coastal access.


3-A2 3-2 Comment Bubble Plus: 30213, 30222, 30222.5, 30253 Added references to PRC sections 30213 and 30222.

3-A3 3-3 Comment Bubble What are the call-outs on this map? Goals? Policies?

The call-outs mirror the "Proposed Improvement" column of Table 3-1. Callout for Access Point 14 was erroneously omitted from Figure 3-1, and has been added.


Clarify what this stems from; add Coastal Act definition of feasibility Clarification added. Footnote references definition of "feasible" in Glossary.


Additional existing Coastal Access Points that should be included: Trail west of Pacific View Villas (CDP requirement), trail west of Esplanade subdivision (CDP requirement); lateral blufftop trail along SFRV and vertical access path from the public parking lot to the beach (CDP requirement); Mori Point Parking Lot; blufftop trail at the Cottages at Seaside Apartments (CDP requirement); and public parking lots for access to the Quarry property across from Reina Del Mar Ave and at the north end of Rockaway Beach. Recommend the City consider pursuing proposed coastal access improvement projects at: west of Esplanade Ave where apartments were removed; potential vertical access to the beach at 6th avenue within the Cottages at Seaside Apartments (also used as an accessway for maintenance of shoreline armoring); potential vertical access to the beach at the northern end of beach boulevard (also used as an accessway for maintenance of shoreline armoring); and an access trail to the beach at Shelter Cove.

Additional coastal access points added to Figure 3-1 and Table 3-1. Potential coastal access points are noted. See new Policy PR-I-20.

3-A6 3-7 Comment Now Oceanaire Apartment Homes. Correction made.

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Bubble


Include maintenance of lateral access along beach boulevard and to the pier.

The lateral access along Beach Boulevard and to the Pacifica Per is located outside of the 2212 Beach Boulevard parcel, west of the Beach Boulevard right-of-way. Therefore, the redevelopment of the 2212 Beach Boulevard site will not affect this lateral access. The referenced public parking area is located on the 2212 Beach Boulevard parcel, could be impacted by redevelopment of the site, and is mentioned in Table 3-1.

3-9 Revision

Language revised for brevity.


Should be more broadly required and not limited to these instances

Broadened beyond Coastal Access Points identified in LCLUP. Language further revised for consistency with Section 30211 of the Public Resources Code.


Allowable structures need to be able to be removed or relocated. All beaches are public and so this would essentially prohibit shoreline armoring. Should refine language to define what the City means by structural development in this policy. Clarification added.


Should be aligned with the CCC temporary event guidelines. This language limits CDP authority inconsistent with Coastal Act requirements.

According to CCC temporary event guidelines accessed from Coastal Commission website (https://www.coastal.ca.gov/la/docs/temp_events_guidelines.pdf), the temporary event guidelines "only apply to areas where the Coastal Commission retains permit authority, including public trust lands and areas for which there is no certified Local Coastal Program (LCP)" (underline in original). Therefore, the temporary event guidelines are relevant only to permitting of temporary events at Pacifica State beach (an area of CCC retained permit authority). Clarification added for temporary event guidelines consistency and potential CDP requirements at Pacifica State Beach.

3-10 Revision

Language revised.

3-A11 3-10 Comment Bubble Add Coastal Act definition of feasibility. Footnote references definition of "feasible" in Glossary.


Clarify origin of this policy (might have been from an older project); Specify both vertical and lateral trail improvements for SFRV as required by their original CDP and City use permit conditions.

Language revised to reference Milagra Creek stormwater outfall project and prior permitted access at San Francisco RV Park.

3-A13 3-10 Comment Bubble Clarify The policy contains an example such as public parking facilities.

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Add sentence about San Francisco garter snake and California red-legged frog, indicating that there may be these or other species on sites and that this doesn’t preclude the existence of these or other sensitive species elsewhere. Language was revised in response to this comment.


Should be continued operation of golf consistent with resource protection policies and exposure to coastal hazards. Need to specify the upland portions of the Park are east of Highway 1. Protection is not the designated long term approach yet. See our related CDP conditions (CDP 2-17-0702).

Language added to address resource protection, natural hazard, and coastal vulnerability policies, as well as upland development located outside of Coastal Zone. The italicized language provides guidance only and is not part of the policy. Revised "must" to "should" to reflect the character of the language as guidance. There are other means to "protect existing development" beyond the terms of CDP 2-17-0702, and reference to this specific permit's terms is not appropriate in this LCLUP policy.

3-19 Revision

Revision accepted.

3-A16 3-19 Comment Bubble Clarify what type of new development this would apply to

Clarification added to specify adopted Quimby Act and Mitigation Fee Act park land dedication/fee requirements.

3-A17 3-20 Comment Bubble Discuss current project underway with Coastal Conservancy

The project underway, led by the Pacifica Land Trust, has enhanced existing trails within the Pedro Point Headlands and conducted invasive species removal. However, these activities do not relate to the Coastal Trail extension described in this paragraph.


Add clear and concise info on City’s goals as they pertain to this section Noted.

3-22 Revision

Revision accepted.

3-A19 3-23 Comment Bubble This table isn’t very informative to the reader for these purposes. Noted.


Need to include trails that exist on private development as CDP requirements like SFRV, the Cottages at Seaside Apartments, etc. See above comments to Table 3-1.

Figure 3-5 depicts the City's roadway network. Trails on private property are not appropriate for this figure.

3-A21 3-37 Comment Bubble Says three, then only list two. Text edited to clarify the actual projects the CIty is pursuing.


What is this an example of? If more users are using that particular intersection given development changes?

Signal optimization is an example of improving the efficiency of existing infrastructure without pursing roadway widening or other physical improvements. The segment of SR 1 in Pacifica services development located inside and outside of the Coastal Zone in Pacifica. SR 1 also services development beyond the control of the City of Pacifica, including other jurisdictions to the north, south, and east.

3-A23 3-37 Comment Bubble These guiding policies don’t mention coastal access at all.

This section of the LCLUP describes the City's roadway network. Pacifica's existing roadway network provides adequate coastal access, including to all Coastal Access locations identified in Figure 3-1. and Table 3-1. Therefore, no

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specific improvements are necessary to improve coastal access from Pacifica's roadway network. However, language has been added in relation to abandonment of public rights-of-way in order to preserve coastal access.


Add clarifying points to explain what sensitivities this would include and what it means to respect the surrounding environment in the context of this policy. Clarification added.


Add more policies on how to connect coastal access points and other pedestrian projects in the vicinity. Policy PR-I-55 updated to include coastal access identification signs.


Add how roadway retrofits will respond to/be based on coastal hazard concerns. Specify that analysis would have to be conducted on a project-by-project basis.

Such a coastal hazard analysis may not be appropriate for every minor modification to existing street facilities, particularly since the described roadway retrofits do not increase capacity of existing public works facilities.

3-A27 3-39 Comment Bubble Please explain why this specific requirement would apply?

The proposed block lengths will ensure a pedestrian-scale circulation system that encourages walkability and discourages automobile use.


Add that it can only be offered to another entity if no coastal access or coastal resource impacts are possible through abandonment of the right-of-way

Language added to address coastal resource impacts from right-of-way abandonment.

3-A29 3-42 Comment Bubble Add to legend: numbers of existing routes Figure 3-6 adequately identifies the route numbers of existing routes.

4 Environmental and Scenic Resources


Overall recommendations include: -In general, and more restrictive than in CEQA, impacts to coastal resources must be first avoided to the maximum extent feasible, then minimized, then mitigated for. -The City may want to explicitly define temporary versus permanent impacts for use in the coastal zone. For us, temporary is limited to resolution w/in 12 months of the initial impact and cannot involve earthwork or other significant disturbance, and any vegetation impacted but be restored to equal or better including similar age/size structure of the community – so for example, woody vegetation cannot be replaced in 12 months and grading work would not qualify for temporary status. Anything exceeding 12 months or otherwise unqualified to meet temporary impact definition is thereby considered permanent. -It seems like there is room to frame some of the issues in the

Noted. The comments will be considered where applicable in other sections of the document.

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chapter under a theme of ‘water security’, where that would be in addition to all of the other considerations. For example, promotion of groundwater recharge, use of recycled water, etc. -Better address protections for marine resource including beaches, rocky intertidal and reef habitats, soft-bottom habitats, offshore rocks (esp. where supporting seabirds and marine mammal haulouts). -Numerous comments are provided with regards to ESHA-related policies, and the relationship between wetlands and ESHA warrants attention. It may help to review workshops we provided to the Commission a few years ago on both ESHA and wetlands, including with legal perspective. These are publicly available on our website at https://www.coastal.ca.gov/meetings/workshops/

4-A2 4-2 Comment Bubble Plus: 30212, 30250 Language was revised in response to this comment


Would be more appropriate to frame as ‘preservation of natural shore dynamics’

Section 30235 of the Coastal Act uses the term "natural shoreline" and this chapter is intended to address Section 30235, therefore the use of consistent terminology is prioritized.

4-2 Revision

Accepted


Need to recognize/cite CCC regulations (see Section 13577(b)) that more clearly articulate the one-parameter criteria and also clearly contrast this with the USACE three-parameter approach, both of which will be important for the local jurisdiction and various requirements. Note that the National Wetlands Inventory is not at all comprehensive and that on-the-ground conditions will prevail; same is true relative to any map the City might produce or provide. Further, and similarly for ESHA, omission of a wetland resource from a designated map cannot preclude on the ground conditions or negate the need to recognize their potential and require a proper delineation. While maps of biological resources, including special status species, wetlands, and streams, are important indicators of the Language was revised in response to this comment.

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presence of significant resources that require protection under LCP policies, additional information regarding such resources will become available through site-specific review of proposed projects, through future map updates, and through other means. Thus, protection of biological resources is not limited to those that are mapped in this document. Furthermore, LCP policies address areas adjacent to ESHAs and parks and recreation areas, and as knowledge about those areas increases or as park boundaries change through land acquisitions, the LCP policies will be applied accordingly.


Meaning by contrast, the area w/in GGNRA is of higher elevation and steeper inclines? Language was revised in response to this comment.


Pink color that isn’t in key needs to be added. Might also be good both saturate the colors for each watershed so they are more apparent and also extend them inland to represent the areas being drained for context. The figure was revised in response to this comment.


Make sure use of seasonal wetlands vs wetlands is consistent throughout this chapter. Further this section seems to speak to more than seasonal wetlands and ponds. It may be simplest to have a section on wetlands and then discuss the different types known within the City. Language was revised in response to this comment.


Explain how this will occur, tie to stormwater management program

This policy is intended to be a guiding policy. The implementation policies and Implementation Plan will explain how this policy will occur.


Unclear whether this is meant to be limited to the identified creeks alone or the many smaller features (e.g., tributaries and other drainages) that would be part of the network. Language was revised in response to this comment.


Add examples, e.g. permeable surfaces to allow natural stormwater infiltration, trying to preserve natural tree cover for shading, low-impact development, BMPs

As a guiding policy, this language is not intended to get into specifics of implementation. The implementation policies provide more specifics of the actions or programs that should be implemented.


Need to recognize perennial and non-perennial resources, as the latter also provide significant habitat value and often support riparian habitat/corridors. Non-perennial resources would be covered under wetlands.


Assume this is inclusive of Rockaway as a fork of Calera but why not mention here as well since separated previously? Or alternatively, not name any and simply leave as blanket to all creeks? Added in Rockaway Creek.

4-A13 4-9 Comment No reference to what has/is being done already? Needs context. The description of San Pedro Creek at the beginning of the chapter provides

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Bubble general information of the restoration efforts that have occurred.


Goes to prior comment re: all Cal-IPC species needing to be avoided throughout the jurisdiction, not just along creeks Non-perennial resources would be included under the definition of a wetland.


Needs to be more prescriptive. Currently in the LUP there is a 100-ft riparian corridor buffer. Minimum buffer requirements should be established for sensitive habitat areas including wetlands and ESHA, including streams, and any uses allowed within such buffers should be specified. Moreover, a defined limit should be established for any exceptions to such minimum buffer requirements resulting in a buffer reduction. Exceptions to such buffer requirements should be supported by a biological report demonstrating that the adjusted buffer, in combination with incorporated siting, design or other mitigation measures, will prevent impacts that significantly degrade the wetland and/or ESHA and will be compatible with the continuance of the wetland and/or ESHA. Buffer adjustments should also be limited to where the entire subject legal lot is within the buffer or where it is demonstrated that development outside the buffer would have a greater impact on the wetland and/or ESHA. Moreover, buffers should be measured from the outer edge of riparian vegetation where it exists; if it does not, then from the edge of the bank; if no bank, then from the mid-line of the watercourse (there’s a hierarchy that will need to be crafted). Buffers for perennial features are usually broader than those for non-perennial features. Language was revised in response to this comment.


Change to something along the lines of “reduce sources of bacterial pollution in waterways based on xxx study…” Language was revised in response to this comment.


Would make more sense in Chapter 6. Needs more detail (does it include SPDs like riprap, what kind of potential impacts to beaches, wetlands and other habitats, what types of mitigations to minimize impacts?) There are multiple references to recognizing the impacts of coastal protection projects (e.g., ER-I-4) and rightly seek to [avoid and] minimize such impacts, imposing mitigation for such – but what of compensatory mitigation requirements for those Language was revised in response to this comment.

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impacts than cannot be avoided?


Specify what Coastal Act says related to this. If the current LCP is more specific on this, need to incorporate

Pacifica's Implementation Plan is more specific on this allowance. However the LCLUP is intended to be the guiding document for the implementation plan and entering specifics here for consistency with the Implementation Plan would be inappropriate.


Also, may want to incorporate some language that speaks to State’s ‘no net loss’ policy regarding wetlands and perhaps elsewhere, something to the value of restoration on-site vs. creation off-site given known performance issues in created vs. restored ecosystems. Language was revised in response to this comment.

4-9 Revision

Accepted.


Note that mitigation to aid in minimizing is different from compensating for that which cannot be avoided – compensatory mitigation may still be necessary for any remainder of impacts Noted.


Is this focused on ecological restoration or strictly physical, meaning beach nourishment? Also note that this might be potentially done to restore dunes as well as beaches… Language was revised in response to this comment.

4-A22 4-10 Comment Bubble This should be incorporated into policy language.

As described in Chapter 1, the italicized language is clarifying language that is part of the policy.


Need more details on what is appropriate. We have some details in our dredge projects we can include.

Noted. Revisions were made to clarify that the policy is intended to support this action at a conceptual level, further evaluation would be necessary to determined suitability.


Conceptually, this is good but needs more information on how sediment is deemed suitable and appropriate. See response to comment 4-A25

4-11 Revision

Accepted with modifications.

4-A25 4-12 Comment Bubble Rephrase for clarity Language was revised in response to this comment.

4-12 Revision

Accepted.

4-12 Revision

Accepted.

4-A26 4-13 Comment Bubble Add more detail.

Details of oil spill containment methods and clean up facilities would be specific to environment in which the spill occurred.


Policies like this that merely implement something that is already required of the City through another document don’t seem to be necessary

While this policy may not be necessary for implementation, the inclusion of this policy here strengthens the importance of the action.


References appear to be fairly outdated and they should aim to incorporate more contemporaneous information. References were reviewed and updated where appropriate.

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4-13 Revision

This language isn't stated in Section 30240 of the Coastal Act

4-13 Revision

Accepted.


CNDDB alone is not the authority but rather, it provides a summary of special status ratings. Other authorities include the California Native Plant Society per it’s establishing act, for example, or other rarity designations come from CDFG Code, etc. Language was revised in response to this comment.


Be careful w/ use of language that appears discretionary and w/o definition (how are values being evaluated?) and also note that ESHA can be quite degraded and still be recognized as having significant value/protections. Language was revised in response to this comment.


Structure of this section needs work – the headers all appear to pertain to vegetation types (some communities, some not) of varying levels of specificity and relevance, and with some troubling omissions. To be clear, we can recognize species or communities as ESHA based upon rarity, and also areas based upon any of these or other significant habitat values (‘especially valuable’). For vegetation communities, determinations are generally made at the level of community alliance and/or association per the Manual of California Vegetation vol. 2 and there are a few other aspects to consider (e.g., CCC recognition of all dunes as ESHA, definition for “native” grasslands having a very low threshold to qualify) Note that these habitats/species listed don’t preclude the possibility of others

According to the California Department of Fish and Wildlife, most of Pacifica falls under the “unclassified” category and has not yet been classified using the Manual of California Vegetation Vol. 2 associations. Figure 4-2, Vegetation uses the Classification and Assessment with Landsat of Visible Ecological Groupings (Calveg) system. The Calveg system crosswalks to types in the California Wildlife Habitat Relationships System. Efforts are underway to finalize crosswalks with vegetation types defined in the revision of the Manual of California Vegetation.


Note that native perennial grasslands are often recognized as ESHA and the component of natives required to rise to the level of ESHA is actually very low since so much of the State’s grasslands have been significantly degraded. More generally, recommend this section is broadened to incorporate additional considerations. Grasslands can also be especially valuable habitat (under ESHA definitions) where documented as supporting persistent raptor foraging, for example.

Your comment is noted. Location of grasslands is incorporated as Potential ESHA in Figure 4-3, and a disclaimer noting that the preliminary delineation of ESHA boundaries does not include an exhaustive compilation of the habitat areas that meet the ESHA definition has been added. Maintaining the heading is preferred, as most of Pacifica is not classified using the Manual of California Vegetation v2, and the Calveg system crosswalks to types in the California Wildlife Habitat Relationships System. Efforts are underway to finalize crosswalks with vegetation types defined in the revision of the Manual of California Vegetation.


Dune habitats also need to be addressed and should categorically be recognized as ESHA. Pacifica has notable

Location of dunes has been incorporated as Potential ESHA in Figure 4-3, and the disclaimer as described in prior comments has been added.

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perched dune features atop bluffs along Palmetto Ave, which are quite rare and should be protected. Bluff faces are also important habitat to discuss.


Generally, should identify vegetation communities per the Manual of California Vegetation (v.2) to levels of alliance and where possible, association, as these are how we determine rarity status apart from those communities that are categorically-treated.

Maintaining the vegetation communities using the Calveg system is preferred, as most of Pacifica is not classified using the Manual of California Vegetation v2, and the Calveg system crosswalks to types in the California Wildlife Habitat Relationships System. Efforts are underway to finalize crosswalks with vegetation types defined in the revision of the Manual of California Vegetation.


Stands or Groves? What about other tree stands, more generally?

The term grove was replaced with stand. Additional tree stands found in Pacifica, specifically Monterey Cypress, are discussed below.


Certainly not the only type of riparian habitat – why treat this alone and not others? Also, riparian habitats should be categorically treated as ESHA.

This list of communities and habitats in Pacifica is not intended to be list of potential ESHA communities. Locations of riparian habitat, including known wetlands and riparian hardwood, have been added as Potential ESHA in Figure 4-3, and the disclaimer described in prior comments has been added.


Clearly articulate why seasonal wetlands are included under ESHA

This list of communities and habitats in Pacifica is not intended to be list of potential ESHA communities. Location of known wetlands is incorporated as Potential ESHA in Figure 4-3, and the disclaimer as described earlier has been added.


Unclear why this is being treated separately from other vegetation-defined habitat types? Clarify and/or consider broader riparian category that includes streams as aquatic habitat types.

Maintaining the vegetation communities using the Calveg system is preferred, as most of Pacifica is not classified using the Manual of California Vegetation v2, and the Calveg system crosswalks to types in the California Wildlife Habitat Relationships System. Efforts are underway to finalize crosswalks with vegetation types defined in the revision of the Manual of California Vegetation. The heading level was updated to be consistent with the preceding and succeeding habitats and vegetation types.


What of other marine habitats? Consider developing further with distinction between onshore/offshore and rocky/soft substrate as basis for discussion. Incorporate offshore areas for seabird and mammal use as well. Any protected areas, whether local refuges or state-designated MPAs, connection to the Greater Farallones NMS, etc. should be discussed.

This list of communities and habitats in Pacifica is not intended to be list of potential ESHA communities. Estuarine and Marine Wetland has been added as Potential ESHA in Figure 4-3. The disclaimer described in prior comments has also been added.


Is this meant to reference supratidal habitat? Also, dunes should be discussed somewhere in the context of their inextricable link

The upper tidal habitat and the supratidal habitat describe the same area. The categories used are consistent with the California Wildlife Habitat Relationship

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to the landscape, particularly with beaches. classification system. See above comment on inclusion of dune location as Potential ESHA in Figure 4-3.

4-A41 4-17 Comment Bubble Need disclaimer language Noted.


Along w/ mods suggested to categories associated with habitats, map should incorporate known wetlands, veg communities, etc. Iceplant is prolific in Pacifica, including around bluffs and dunes – should identify these habitats but address iceplant (and other invasives) in context of restoration goals for the City. Also note misspelling of [Monterey] Cypress on the map legend.

As noted in previous comments, Figure 4-2 depicts categories consistent with the California Department of Fish and Wildlife List of Vegetation Alliances and California Wildlife Habitat Relationshipclassification system. Figure 4-3 incorporates known wetlands, dunes and bluffs (habitat for iceplant), riparian habitat, and habitat for sensitive communities as noted in CDFW’s California Wildlife Habitat Relationship classification system.


All riparian habitat should be treated as ESHA; be clear in articulations of what is meant by ‘streams’ versus ‘creeks’ versus ‘riparian vegetation’ or ’riparian corridors’ – watercourses explicitly relate to appeals jurisdiction, riparian arguably does as well but the language is not as clear and a bit more circular.

The Glossary was revised to clarify the relationship of a stream versus a creek. The glossary contains a definition of riparian.


Delete figure 4-3 and all references to it; does not delineate all ESHA. The figure was revised in response to comments.


Dunes should be categorically designated as EHSA, which are only mentioned once in this draft and yet, are super rare and valuable.

The categories used are consistent with the California Department of Fish and Wildlife List of Vegetation Alliances and Association vegetation classification system. The LCLUP provides a high level understanding of the biological resources present throughout the Coastal Zone. Therefore the level of information provided is appropriate.


There are references to degrees of habitat value without definition; we strongly advise against this without proper framing for a variety of reasons. An area can be severely degraded and yet still constitute ESHA if it can be restored and/or is supporting sensitive resources. Coastal dunes are an excellent example of this, as they are among the rarest of habitats in CA and often invaded with iceplant or other non-natives but yet, can be restored with a bit of effort. The City may wish to indicate areas that seem to have some probability of qualifying as ESHA as guidance but this should be very carefully and clearly expressed to be non-exclusive of other areas not appearing on a map or so designated. References to high habitat value areas were removed.


Need to add language pertinent to ‘especially valuable habitat’ per CCA definitions – this captures natural resources not The language was revised in response to this comment.

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considered rare but as offering some other particular value, such as that of unusually pristine conditions, vegetation supporting other sensitive species (such as Eucalyptus stands supporting monarchs), wildlife corridors, etc.

4-A48 4-23 Comment Bubble What about intermittent creeks and streams? These features would be included under Policy ER-G-8 as appropriate.


Reference to maps and documents not part of the submission are problematic – everything should be incorporated directly to the LUP, not the EIR or GP, etc. The text was revised to reference the figure in the LCLUP.

4-A50 4-23 Comment Bubble Don’t limit to just these species The language was revised in response to this comment.


Why does this have to tie back to this figure? There are many references to this map. It can’t be the end all be all; if want to refer to it, needs to be incorporated into the LCP The text was revised to reference the figure in the LCLUP.

4-24 Revision

Accepted.


Once an area is documented as ESHA, or as supporting sensitive species warranting ESHA, this is very rarely reversed and even then, the bar is extremely high. Where historical records exist, we consider them still relevant. We would need to see very compelling evidence that the resource has been locally extirpated, etc. Noted.


Minimum buffer requirements should be established for sensitive habitat areas including wetlands and ESHA, including streams, and any uses allowed within such buffers should be specified. Moreover, a defined limit should be established for any exceptions to such minimum buffer requirements resulting in a buffer reduction. Exceptions to such buffer requirements should be supported by a biological report demonstrating that the adjusted buffer, in combination with incorporated siting, design or other mitigation measures, will prevent impacts that significantly degrade the wetland and/or ESHA and will be compatible with the continuance of the wetland and/or ESHA. Buffer adjustments should also be limited to where the entire subject legal lot is within the buffer or where it is demonstrated that development outside the buffer would have a greater impact on the wetland and/or ESHA. Noted. Language was revised in response to this comment.

4-A54 4-26 Comment This may not necessarily be the case. Noted.

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Bubble

4-26 Revision

Accepted.


There are multiple references that restrict the use of invasive plant species (including ER-I-1), but it would be easier to simply prohibit the use of 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, throughout the City and to establish requirements for their abatement from sites on a project-by-project basis as well as through broader restoration efforts. For example, New Zealand spinach is listed as limited but it locally-problematic in Pacifica. Language was revised in response to this comment.

4-A56 4-27 Comment Bubble Include as policy





Rephrase. Is this referring to existing access points, in which case management, maintenance, and resources should be allocated to ensure this consistent use (and that should be stated), or is this referring to the creation of new access points? Language was revised in response to this comment.


This policy needs to be rephrased. Planned Developments have their own zoning, so establishing appropriate zoning to allow PD doesn’t seem accurate. Where, specifically will this be allowed? Language was revised in response to this comment.

4-A60 4-28 Comment Bubble Why is PD designation appropriate for this site?

The Planned Development zoning designation allows for the creation of a development plan, which provides a developer some flexibility in project design to accommodate special circumstances on their property.


Significant overlap and redundancy to Natural Hazards/Coastal Resilience chapters Section was removed as suggested.


Should be in Ch. 5/6; eliminate redundancies, include CCC definition of new/existing development Language was removed as suggested


This should reference the appropriate Coastal Act policies and clearly indicate that not all structures are entitled to shoreline protection as a way of protecting infrastructure/erosion Language was removed as suggested.


Is Pacifica State Beach pre-Coastal? Should be in Ch. 6 and not be redundant here. Language was removed as suggested.

4-A65 4-30 Comment Bubble Should be in Ch. 6 and not be redundant here. Language was removed as suggested.

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4-A66 4-30 Comment Bubble Prohibits? Correct, the text was revised

4-30 Revision

Accepted.


Recommend consulting with the tribes to get feedback on these policies. Also, please consider adding aspects from the Commission’s tribal consultation policy: https://documents.coastal.ca.gov/assets/env-justice/tribal-consultation/CCC%20Tribal%20Consultation%20Policy%20Adopted%208.8.2018.pdf to ensure adequate consultation is incorporated on new development projects.

As described in the text, appropriate procedures were completed in 2009 regarding tribal consultation for the City's General Plan Update. Additional efforts will be re-initiated as part of the current General Plan update effort and the Sharp Park Specific Plan preparation. Furthermore, as detailed in the Coastal Commission's tribal consultation policy, the Coastal Commission will further attempt to consult with any interested tribes as part of the Commission's action on certifying Pacifica's LCP. Lastly, language was added to the implementation policy below clarifying that tribal consultations will be conducted as required by law.

4-32 Revision

Accepted.

4-A68 4-35 Comment Bubble It would be helpful to label the Coastal View Corridors by street The figure was revised in response to this comment.

4-A69 4-37 Comment Bubble Clarify what types of visual qualities these are Clarification was added.

4-A70 4-37 Comment Bubble Rephrase Language was revised in response to this comment.


Add information to clarify the type of impacts, site planning and design, reduction of bulk/mass, height limits, etc.

Clarification was added to first bullet. The remaining bullets detail the potential design methods that should be considered to reduce impacts, including the methods the comment suggests.


If this is already covered in Hillside regs, no need to duplicate here

Because the regulations can be amended to be consistent with the LCLUP, it is important to keep this policy so that future applicable amendments must consider this requirement.


If this is already covered in design review regs, no need to duplicate here Please see response above.

4-A74 4-38 Comment Bubble Sentence fragment; rephrase Language was revised in response to this comment.


Add details on what this would depend on and how it would be determined Language was revised in response to this comment.


Ensure clustering is referenced elsewhere as well, not just for hillside properties

This chapter references Section 30250 of the Coastal Act, which encourages clustering of development in general.


Seems redundant to earlier Quarry policies. Doesn’t seem specific to scenic and visual resources here. The language was revised in response to this comment.

4-A78 4-38 Comment These two sentences seem to be saying same thing; combine The sentences are addressing areas with new development and areas with

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Bubble and consolidate. existing development. Language was revised to clarify this point.

4-A79 4-38 Comment Bubble Include in policy




4-A81 4-39 Comment Bubble Specify how

The specific are not known at this time, but would be determined through implementation of this policy.

5 Natural Hazards


Overall recommendations include: consider reducing the amount of overlap between Ch. 5 and Ch. 6, as this chapter currently includes flood and erosion information in addition to seismic hazards; it may be worth assessing which armoring and which development is Pre-Coastal, to determine policy direction for those structures moving forward, and consider adding a discussion on how the risks of armoring projects are being accounted for.


5-A2 5-2 Comment Bubble Plus: 30250 Language was revised in response to this comment.


This isn’t a seismic hazard. Maybe should be moved below where erosion hazards are discussed Language was revised in response to this comment.


Current LUP mentions specific neighborhoods that have high rates of bluff erosion. This should be included.

Long term projected erosion is shown in Vulnerability Zone maps in Appendix B.


How do these two different sections fit together/why are they separated?

Chapter 5 provides policies to address natural hazards in the Coastal Zone. Chapter 6 provides policies to address adapting to sea level rise.

5-A6 5-12 Comment Bubble What kind of standards? Building standards? Language was revised in response to this comment.

5-A7 5-12 Comment Bubble Cross-reference with policies in the next chapter Language was revised in response to this comment.

5-A8 5-13 Comment Bubble Include as part of the policy language. Language was revised in response to this comment.


How is development already restricted in the CZ district in areas prone to coastal erosion? Cite other policies and clarify what this includes.

One example is Article 44 "Coastal Development Regulations," of Title 9, Chapter 4 of the Pacifica Municipal Code, establishes geotechnical suitability development standards for applicable properties. The City doesn't find it appropriate to reference the Implementation Plan regulations in the LCLUP.

5-A10 5-13 Comment No new outfalls to beach of untreated drainage. The language in this policy is not supporting the idea of new outfalls of

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Bubble untreated drainage to the beach.

5-13 Revision


5-A11 5-14 Comment Bubble Recommend including this in next chapter as well Added a cross reference to this policy in Chapter 6.

5-A12 5-14 Comment Bubble Zoning? Bluff? What types of setbacks is this referring to? Language was revised in response to this comment.


Seems like this should be in the next chapter. Should be expanded to more hazardous areas and not just coastal-fronting properties. The policy was relocated to Chapter 6 as suggested.

5-A14 5-15 Comment Bubble Seems like this should be in next chapter The policy was relocated to Chapter 6 as suggested.


Should be next chapter? In addition to avoiding erosion resulting from 100-year seismic and storm event, must also account for long-term bluff erosion, including as exacerbated by SLR

The language is more appropriate in its current location. A cross reference to CR-I-43 was included.


This portion is out of place in this chapter. Ensure this is covered in environmental resources chapter prior instead.

The language was removed in this location. ER-I-24 provides the same guidance.


Would be good to include a note that these are known to be outdated and underestimate risk as these flood and storm events are occurring at higher frequencies now, in the presence of climate change. The City has not included input on the accuracy of FEMA's maps.


Shouldn’t just be to protect new development in these flood/tsunami hazard zones; should also be to limit or restrict new development in these areas, and/or site and design new development to be safe from such hazards.

The guiding policy was revised to remove the word "new", which broadens the guiding policy to all development. Also, in accordance with the guiding policy, the implementation policies below do include measures regarding siting and design.


Rephrase this portion to explain that these would be procedural changes through FEMA. Language was revised in response to this comment.

5-A20 5-19 Comment Bubble Clarify that this is driven by FEMA, rather than by the City The language states that the maps are prepared by FEMA.

Revision

Accepted.

5-A21

Comment Bubble Seems like this should be part of the policy


5-20 Revision

The policy was removed because a duplicate policy exists in Chapter 6.


Including adequate setbacks that will not result in vegetation removal within wetland/ESHA and wetland/ESHA buffers. The language was revised in response to this comment.

5-26 Revision

The City disagrees with this revision.

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6 Coastal Resilience


Comments are mostly the same as our previous iteration of comments, because not much has changed. However, language was removed in one of the armoring policies that stated that “existing” for the purposes of the policy means existing as of 1977, and the City also added a definition of “new development” that specifies that something is new only if its development on a previously vacant lot and that no amount of remodeling would ever trigger redevelopment. We find both these changes problematic and inconsistent with Coastal Act policies including because the changes would result in none of the current structures ever being brought into compliance with updated siting/design and other SLR policies and allowing any new development (other than that on vacant lots) a right to shoreline armoring. Provide information about how the seawalls are managed. Private? Public? For the publically maintained seawalls, the City should indicate where there is priority for continued maintenance.

Noted. The comments will be considered where applicable in the relevant sections of the chapter. Created new definition of “Substantial Exterior Structural Modification” or “SESM” which contains quantitative triggers based on alterations to existing structures. Any portion of the work qualifying as a SESM would be required to comply with all current LCP policies. Unmodified portions of any existing nonconforming structure would be allowed to remain but would not be permitted to increase the degree of any nonconformity with current LCP policies.


Instead of “economic life” we typically use “anticipated life” as this more accurately represents the period of time over which a development will be in place. Recommend referring to anticipated life and including a definition in the glossary.

The City doesn't agree that the terms "economic life" and "anticipated life" are interchangeable. The term economic life is a common term that describes the expected period of time during with an asset remains useful to the owner. The economic life could be different than its anticipated life which is perceived to be associated with the physical life of an asset.

6-A3 6-1 Comment Bubble What about protection of coastal resources?

Section 30001(c) of the Coastal Act states that the Legislative findings and declarations of the Coastal Act include to protect public and private property. The City of Pacifica wishes to emphasize this statement.

6-A4 6-2 Comment Bubble Plus: 30250 Added


Focusing policies on protection and armoring of the shoreline is inconsistent with the Coastal Act.

Policies to protect existing structures using construction that alters natural shoreline processes, such as revetments and seawalls is supported by Section 30235 of the Coastal Act. The City added additional language in the highlighted section to clarify that policies focus on protection and armoring of the shoreline to protect existing structures.


Should be preparing in advance of a catastrophic event, not just in response to The comment on the City Council's goals is noted.

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6-6 Revision

The proposed revision was not incorporated because the term "this area" was unclear. However, the City added a footnote to the sentence to provide the clarification the City believes the revision was intending to make.


This is inconsistent with the Sea Level Rise Guidance published by the Commission. Furthermore, the City is already implementing retreat on an adhoc basis when structures become a public nuisance at a cost to the City.

The City does not agree that this statement is inconsistent with the Sea Level Rise Guidance published by the Coastal Commission. While the Commission's comment does not provide specifics on why this comment was made, the City of Pacifica highlights the following points: 1. The Guidance identifies three categories of adaptation, including: retreat, accommodation, and protection. On page 122, the guidance document states, "[t]he adaptation options described in this chapter are intended to provide guidance for potential LCP and permitting strategies. Not all strategies listed here will be appropriate for every jurisdiction, nor is this an exhaustive list of options. However, as described in Chapters 5 and 6, all local governments and all project applicants should analyze the possible effects of sea level rise and evaluate how the strategies in this chapter, or additional supplemental strategies, could be implemented in LCPs or CDPs to minimize the adverse effects of sea level rise."(emphasis added). 2. The City of Pacifica identified sea level rise adaptation strategies using the step-by-step process detailed in the Guidance document, City Council goals, and public input. 3. The Sea Level Rise Guidance document, as it self identifies, is not regulation or a checklist; therefore, if language in the City's LCP is found inconsistent with the Guidance document, it doesn't conclude that the language is inappropriate. Regarding the second portion of the comment, the City is removing existing structures from the bluffs as a method to remove a public hazard, not a sea level rise adaptation method. The City supports a private property owners right to protect their existing structure.

6-A8 6-12 Comment Bubble Needs to explain existing in terms of how CCC uses it.

6-A9 6-13 Comment Bubble Should specify when

Added specifics of when site specific hazard mapping and assessment may be required.

6-A10 6-13 Comment Bubble Avoid hazards first, minimize if feasible

Accepted with some modifications. Removed mention of mitigation because this is address in item b. below


Need to spell out what this means Accepted. The meaning of "maximum extent feasible" will differ on a case-by-case basis.

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6-A12 6-13 Comment Bubble What is considered mitigation in this context?

This language is the finding regarding mitigation of project impacts on coastal resources; therefore Commission proposed language regarding impacts was not accepted. This finding references two coastal resilience mitigation policies, including CR-I-5, which the Commission's proposed removal of was not accepted, and CR-I-57. The language provided in the latter policy provides mitigation option examples to identify the City's potential mitigation requirements. CR-I-5 directs for the development of a Shoreline Mitigation Program, which once developed, will provide further detail to developers of the expected mitigation requirements.

6-13 Revision

Accepted


Need to explain how this relates to migrating public trust (i.e. may be on public trust in the future)

The finding as written captures the Commission's concerns about migrating public trust land because the finding is written in future tense (i.e. will not). Information to support this finding will have to consider the future location of public trust land and not just the present location of public trust land.

6-13 Revision

This finding was not included because the development may be a shoreline protective structure to protect an existing structure.


Should define triggers for updating the LCP as well (and what happens if the LCP isn’t updated); why five years or sooner? What would trigger the sooner?

As detailed in CR-I-3, the triggers for reassessing the adaptation plan will be determined as part of the monitoring program.


How will mitigation be assessed in the meantime? What happens if the mitigation program is not developed in 3 years? Refer to Policy 57.

The proposed revisions were accepted. Prior to the development of the Shoreline Mitigation Program, policy CR-I-57 would implemented.

6-14 Revision

Accepted. The meaning of "maximum extent feasible" will differ on a case-by-case basis.


Recommend adding a GHAD policy like that in the previous chapter Language was revised in response to this comment.

6-14 Revision

Accepted with modifications. Language regarding avoidance, minimization, and mitigation of impacts was not accepted because this will be evaluated as part of CR-I-2.

6-14 Revision

Accepted with modifications. Language was revised to clarify the hazard that the policy is intended to avoid.

6-15 Revision

Accepted.


Should discuss in each subarea intro whether existing shoreline protection is publicly or privately owned. Also should discuss which development is pre-Coastal.

Narrative was added regarding existing conditions of the shoreline, including existing armoring, in each subarea.

6-A18 6-15 Comment Bubble Define.

The city's adaptation strategies are not tied to timeframes, but environmental triggers. However, based on projections, the near-term adaptation strategies are anticipated to be triggered in the next 0 to 10 years. Mid- and long-term

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adaptation strategies are anticipated to be triggered after 10 or more years.

6-A19 6-15 Comment Bubble Define. See response above.


How will these goals be balanced when they are incompatible with each other now and in the future due to impacts of armoring on beaches?

The City understands that by balancing these goals, the preservation and enhancement of coastal access may not occur in the same location, or these activities may be limited, where protection of existing development occurs in the near-term. The Mitigation Program (CR-I-5) will organize the allocation of mitigation resources collected from protection adaptation efforts to areas where coastal access is more desirable, accessible, or feasible.


Is this for existing utilities, roadways, and public infrastructure? Paragraph framing is odd; if the City “should” do something, include these as policies that the City will take on Language was revised in response to this comment.


Need to consider least environmentally-damaging feasible alternative, which would include alternatives such as elevation or even relocation Language was revised in response to this comment.

6-16 Revision

Accepted with modifications


Should also mention high erosion rates in this neighborhood; this is further exacerbated by SLR.

The Vulnerability Maps provided in Appendix B show the anticipated erosion in the subarea due to sea level rise projections.

6-A24 6-16 Comment Bubble Armoring should not be framed as the go-to response regardless Language was revised to remove the specific mention of armoring.


Sand should match what is currently there to avoid negative impacts

The comment is noted. The language was revised to clarify that CR-I-53 would direct the City to conduct an evaluation of a beach nourishment program.


Efficacy isn’t always increased and depends on various factors, which should be mentioned here.

The comment is noted. The language was revised to clarify that CR-I-53 would direct the City to conduct an evaluation of a beach nourishment program.


Shoreline structures, shoreline protective structures, shoreline protective device, shoreline protection, seawall, and armoring are used interchangeably throughout the document. Please use a consistent phrase to refer to shoreline protective devices.

The term "shoreline protection structure" was standardized throughout the chapter.


Clarify what these triggers mean. Ensure consistency of these triggers throughout the chapter.

A description of how to read the triggers provided in Section 6.6 Sub-Area Policies and Programs was added to the introduction of the section.

6-17 Revision


6-A29 6-16 Comment Bubble And if consistent with Coastal Act, LCP policies Language was revised in response to this comment.


And not require the current or future construction of any shoreline protection structure Language was revised in response to this comment.

6-A31 6-16 Comment Should specific that this will likely involve CCC permitting The need for Coastal Commission coordination related to beach nourishment

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Bubble jurisdiction is identified in policy CR-I-53.


These need to be evaluated re: least environmentally damaging feasible alternative etc.

The comment is noted. The evaluation of beach nourishment impacts would be performed as part of the beach nourishment program detailed in CR-I-53.

6-A33 6-16 Comment Bubble Seems high given Pacifica’s current condition

The width of the beach was determined to be appropriate by our coastal engineering consultants, ESA, as part of the Adaptation Plan.

6-A34 6-16 Comment Bubble Only in ways that are compliant with Coastal Act standards Mitigation efforts will be managed under CR-I-5 and CR-I-57.


Should mention that bluffs here are highly erosive; should include a policy regarding bluff setbacks.

The Vulnerability Maps provided in Appendix B show the anticipated erosion in the subarea due to sea level rise projections.

6-17 Revision

Accepted

6-A36 6-17 Comment Bubble Same comments as for CR-I-15 See response to comments 6-A40 through 6-A43.


Is this referring to existing scour and sloughing? If not, why is that anticipated? Language was revised in response to this comment.


By who? Would this be in conjunction with any new development proposals? How would this work? Language was revised in response to this comment.

6-A39 6-17 Comment Bubble See earlier comments Language was revised in response to this comment.

6-18 Revision



What does this mean? Elevation of structures? Modification of armoring? Add italics or include policy language to add specificity. An example was provided for clarity.

6-A41 6-18 Comment Bubble Same as above See response to comments 6-A40 through 6-A43.


This should be framed differently; improving flood protection is one option – or, the city’s preferred option for protecting homes and businesses in this area.

As supported by the policies in this subsection, flood protection is the City's preferred option for protecting existing homes and businesses.

6-A43 6-19 Comment Bubble Shouldn’t reference specific permits in LCP Language was revised in response to this comment.

6-19 Revision



These are inconsistent with the Coastal Act provisions for what types of structures are eligible for shoreline protection

Policies to protect existing structures using construction that alters natural shoreline processes, such as revetments and seawalls is supported by Section 30235 of the Coastal Act.

6-20 Revision

Proposed language was not accepted, but modifications were made based on previous comments.

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Unlike these notations elsewhere, this one seems to suggest this strategy wouldn’t be used until this trigger is reached – clarify what these triggers mean

A description of how to read the triggers was provided in Section 6.6 Sub-Area Policies and Programs.

6-A46 6-20 Comment Bubble Why isn’t a similar policy included in the other sub-areas?

This sub area includes the old quarry property, which has the potential for future development. This policy is duplicative of other shoreline development policies that would require adequate setbacks, however other subareas don't have a prominent, privately-owned vacant parcel, which is why this policy is included here.


Were these structures/facilities developed pre-Coastal Act? If not, they are not entitled to shoreline protection.

These facilities are existing structures. The City does not agree with Coastal Commission's staff interpretation that "existing structures" only include structures that were legally authorized prior to January 1, 1977.

6-A48 6-21 Comment Bubble Same comment as above. See response to comment 6-A60.


Needs to reference provisions within Coastal Act that indicate what types of structures are entitled to shoreline protection.

Reference to Section 30235 of the Coastal Act was added to CR-I-54 and CR-I-55, which are cited in this policy.

6-A50 6-22 Comment Bubble Move whole section to beginning of this chapter

The comment is noted and staff will consider the reorganization of the section prior to submitting the document to the Coastal Commission for certification. However, reorganizing the section during the current public process may cause confusion. Therefore, staff has not reorganized the section at this time.

6-22 Revision


6-A51 6-23 Comment Bubble Mitigate impacts to coastal resources, where unavoidable Mitigation efforts will be managed under CR-I-5 and CR-I-57.


Should be all new development (including redevelopment, demo/rebuild on non-vacant properties); definition of new development at the very end of the LCP specifically only refers to development on previously undeveloped lots and does not include any type of remodeling/enhancement , which is problematic and inconsistent with the Coastal Act.

The City of Pacifica agrees that new development should comply with all LCP policies including site design without reliance on shoreline protection structures. The City additional agrees that the portion of projects qualifying as a Substantial Exterior Structural modification also should comply with the same policies.


Should be without consideration of any shoreline protection, including any existing shoreline protection Accepted the removal of the word "new".


Suggest putting this in its own policy re: disclosures etc (see draft res guidance language) Noted.

6-23 Revision

Accepted.

6-23 Revision


6-A55 6-24 Comment Bubble Add that this would be conducted by Public Works Language was revised in response to this comment.

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6-24 Revision

Accepted

6-24 Revision

Accepted

6-A56 6-24 Comment Bubble Definition of redevelopment?

Language was revised in response to this comment. The City has created a new definition of “Substantial Exterior Structural Modification” or “SESM” which contains quantitative triggers based on alterations to existing structures. Any portion of the work qualifying as a SESM would be required to comply with all current LCP policies. Unmodified portions of any existing nonconforming structure would be allowed to remain but would not be permitted to increase the degree of any nonconformity with current LCP policies.

6-24 Revision


6-25 Revision

Accepted

6-A57 6-25 Comment Bubble Section should be moved ahead of sub-area policies


6-26 Revision

Accepted

6-A58 6-26 Comment Bubble Would need to be separately reviewed for impacts The comment is noted.

6-A59 6-26 Comment Bubble Should also minimize/avoid impacts to public access/recreation

Using the subject titles of the Articles contained within Chapter 3 (Coastal Resources Planning and Management Policies) of the Coastal Act, Public Access (Article 2) and Recreation (Article 3) are considered coastal resources under the Coastal Act.

6-A60 6-26 Comment Bubble Should be removed OR redeveloped

Redeveloped was not included as suggested. The City has addressed significant modifications to existing structures by defining a “Substantial Exterior Structural Modification.”

6-A61 6-26 Comment Bubble ADD and removed if no longer necessary Language was revised in response to this comment.

6-26 Revision

Accepted


Seems counterintuitive that if a SPD is damaged by a massive storm, it would be able to be rebuilt

Language is consistent with provisions of subdivision (g) of Section 30610 of the PRC.


The earlier draft specifically included the following, which should be added back in (or defined elsewhere): For purposes of this policy “existing principal structures means principal structures that were legally authorized prior to January 1, 1977”

The City does not agree with Coastal Commission's staff interpretation that "existing structures" only include structures that were legally authorized prior to January 1, 1977.

6-27 Revision

Accepted

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Should include if the structure is redeveloped, should specify that the SPDs should be removed after this time

The City has addressed significant modifications to existing structures by defining a “Substantial Exterior Structural Modification.”

6-A65 6-27 Comment Bubble This seems like a loophole Language was revised in response to this comment


This also seems like a loophole to allow continued use of armoring Accepted revision

6-27 Revision

Accepted

6-28 Revision

Accepted


Recommend adding the following policies from the City’s draft: 1 – New development in flood hazard zones shall be avoided. If relocation of existing development in hazard zones is infeasible, substantial improvements shall be sited and designed to be safe from flooding, and without adverse offsite effects, for at least 100 years, considering projected sea level rise and future flooding, including at least the 1% probability event. Design requirements shall include raising finished flood elevations of habitable space above projected flood elevations; storing hazardous materials out of flood areas; elevating mechanical and utility installations; prohibiting basements; and using flood vents and anchoring structures where appropriate. Structure elevations shall be limited to ensure consistency with LCP visual and community character policies and assure access to utilities over the duration of the development. 2 – The City shall monitor repetitive flooding loss and FEMA claims to assist in identification of priorities for adaptation measures, including acquisition of high-risk properties. The comment is noted.

Glossary

G-A1 G-1 Comment Bubble

Ensure consistency with CCR 13577 definitions of steams, wetlands, estuaries, tidelands, submerged lands, public trust lands, beaches, and coastal bluffs.

Where CCR Section 13577 provides definition of these features, the definitions were incorporated into the Glossary as suggested.

G-A2 G-2 Comment Bubble Recommend including “locally-relevant” as well The language was revised in response to this comment.

G-4 Revision

Accepted

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Add the Coastal Act definition of Environmental Justice found in Section 30107.3 The language was revised in response to this comment.

G-4 Revision



Add Coastal Act definition of fill found in Coastal Act Section 30108.2. The language was revised in response to this comment.

G-A5 G-6 Comment Bubble Or for purposes of consistency with Coastal Act requirements. The language was revised in response to this comment.


This is inconsistent with the Coastal Act and the Commission’s definition of ‘redevelopment.’

The City has defined a “Substantial Exterior Structural Modification” to address situations where significant modifications are made to existing structures. The Coastal Act does not define “new development” and this definition of “new development” does not conflict with Coastal Act Section 30212(b), which describes what "new development" does not include.

G-A7 G-6 Comment Bubble Include a definition for non-conforming structure. The language was revised in response to this comment.

G-7 Revision



Add definition of sensitive coastal resource area found in Coastal Act Section 30116. The language was revised in response to this comment.

Comment Letter

L-1

The comment is noted. The City thanks Coastal Commission staff for their time and efforts during this consultation period.

L-2

The comment is noted.

L-3

The City has considered the Coastal Commission staff's feedback and has provided responses here.

L-4

A section addressing Environmental Justice (Section 3.9) and a policy striving to implement the Coastal Commission's environmental justice best practices was added to Chapter 3.

L-5


L-6


L-7


L-8


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L-9

As described in Chapter 6, Coastal Resiliency, the policies addressing sea level rise recognize that sea level rise projections are continually evolving and the effectiveness of hybrid adaptation strategies is not well known. Therefore, the policies focus on protection and armoring of the shoreline in the near term and reassessment of the adaptation plan in the future. Pacifica’s development patter, with significant pre-Coastal Act private development and public infrastructure, leave no other viable near-term policy. Policies such as CR-I-3 Monitoring Shoreline Change, and CR-I-4, Sea Level rise Adaptation Plan Update, would direct the City to monitor the impacts of sea level rise to create a well-established record to guide the implementation of adaptation strategies and based on developed triggers to update or modify adaptation strategies.

L-10

Environmental Science Associates (ESA), the coastal engineering consultant hired to prepare the City's Adaptation Plan, evaluated at a high level the appropriateness of beach nourishment along Pacifica's coastline in the Adaptation Plan (Final Adaptation Plan, September 2018). The Adaptation Plan does identify the likely diminishing benefits of beach nourishment through increasing sea level rise, the likely need to supplement beach nourishment with sand retention structures, and the likely sand characteristics to improve the efficacy of beach nourishment. Policy CR-I-53, Beach Nourishment would direct the City to evaluate a beach nourishment program. This evaluation would provide the program level details regarding feasibility, financial cost, environmental impacts, and efficacy. As mentioned in response to comment L-1, the policies in this chapter recognize that sea level rise projections are continually evolving and the effectiveness of hybrid adaptation strategies is not well known. Policies such as CR-I-3 Monitoring Shoreline Change, and CR-I-4, Sea Level rise Adaptation Plan Update, would direct the City to monitor the impacts of sea level rise to create a well-established record to guide the implementation of adaptation strategies and based on developed triggers to update or modify adaptation strategies.

L-11

The City has defined the term “Substantial Exterior Structural Modification” to address sites with existing structures. This definition contains quantitative triggers based on alterations to existing structures which would determine when sites must be brought into full compliance with LCP policies. Any portion of the work qualifying as a SESM would be required to comply with all current LCP policies. Unmodified portions of any existing nonconforming structure would be allowed to remain but would not be permitted to increase the degree of any nonconformity with current LCP policies.

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L-12


L-13

Comments made in this letter were considered during the preparation of the Final Adaptation Plan (September 2018) and responses to the comments were provided in Appendix K of that document (Refer to letter 49).

L-14


L-15

The City understands that the result of balancing the protection of existing structures in the near-term and preserving coastal resources today and for the future is that the preservation and enhancement of coastal resources may occur in different locations, or may be limited, where the protection of existing development occurs in the near-term, or the modification of adaptation strategies in the future. Policies such as CR-I-3 Monitoring Shoreline Change, and CR-I-4, Sea Level rise Adaptation Plan Update, will direct the City to monitor the impacts of sea level rise to create a well established record to guide the implementation of adaptation strategies and based on developed triggers to update or modify adaptation strategies. CR-I-5, Shoreline Mitigation Program will organize the allocation of mitigation resources collected from protection adaptation efforts to area where preservation of coastal resources is more desirable, accessible, or feasible.

L-16

The City's Adaptation Plan was prepared in accordance with the scope that was approved for a Coastal Commission grant to address sea level rise. ESA prepared an analysis of the feasibility and cost/benefit of various adaptation alternatives within the means provided in accordance with the grant agreement with the Coastal Commission.

L-17

CR-I-53 would direct the City to conduct an evaluation of a beach nourishment program as suggested in this comment.

L-18

CR-I-57 would require mitigation of shoreline impacts while the Shoreline Mitigation Program, directed under CR-I-5 is being prepared.

L-19


L-20


L-21

The design standards for shoreline protection structures were added to CR-I-57, details of proportional mitigation will be determined under CR-I-5,

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requirements for the removal of the shoreline protection structure were added to CR-I-54 and CR-I-56, with the exception of the demolished and rebuilt or redevelopment requirement, and the term "substantial improvement" is no longer included in Pacifica's policy language although the City has defined a new term of “Substantial Exterior Structural Modification” to address sites where existing structures are modified.

L-22

As noted in previous comments, Figure 4-2 depicts categories consistent with the California Department of Fish and Wildlife List of Vegetation Alliances and California Wildlife Habitat Relationship classification system. Figure 4-3 incorporates known wetlands, dunes and bluffs (habitat for iceplant), riparian habitat, and habitat for sensitive communities as noted in CDFW’s California Wildlife Habitat Relationship classification system.

L-23


L-24

Comments made in this letter were considered during the preparation of the Draft LCP Policies (November 2018) and responses to the comments were provided in Appendix A of that document (Refer to letter TWG02).

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