Frequently Asked Questions (FAQ): LCLUP Update

Use the form below to submit your questions to City staff about the Local Coastal Land Use Plan (LCLUP) Update process. All questions submitted by February 16, 2024 will be answered and made part of the staff report for the March 2 community meeting (LCLUP Meeting #3). The City will also attempt to post answers to questions on a rolling basis prior to the meeting, so check back frequently.

Any questions submitted after February 16 will be answered at the March 2 meeting.

Refer the Eventbrite page for the March 2 community meeting for more information on that event. Advanced registration is encouraged to help the City plan for refreshments.

Answers to FAQs

Question 1: Will the Local Coastal Land Use Plan (LCLUP) allow me to replace the roof on my home? Or will a roof replacement trigger additional requirements?

Answer: Modifications to existing structures, including routine maintenance activities like roof replacements, are addressed in the definition of “Substantial Structural Modification,” or “SSM,” in the LCLUP. The definition can be found in the Glossary chapter. See Comment 7.10 in red text as added by the City to the California Coastal Commission (CCC) staff’s suggested modifications to Pacifica’s City Council-approved LCLUP. An excerpt is provided below:

The CCC staff’s modified language makes a distinction between structural and non-structural roof work, and excludes traditional non-structural re-roofing work from the SSM definition.  City staff will recommend alternative modifications to make it clear that various roof types other than shingles, and that replacing the plywood layer as part of re-roofing work, would also be excluded from the SSM definition.

Note A (from image above): Paragraph (i) must be read together in its entirety, and starts by indicating its provisions apply to “exterior walls or other major structural components” (italics added).  The parenthetical language “including but not limited to floor, roof, and foundation structures” when read as a complete sentence, and when considered with the entire Paragraph (i), indicates that “roof structures” will count toward an SSM.  There is nothing in Paragraph (i) that indicates roof waterproofing material replacements, such as shingle replacements, would count toward an SSM.

Note A: An example of a structural roof modification would be adding a second story above an existing one-story building which requires removal of the existing roof at first-story level; or changing a flat roof to a gable roof (or vice versa).

Note B: This paragraph indicates exclusions from the SSM definition.  The exclusions are a companion to the inclusions in Paragraph (i), above and discussed in Note A.  While the inclusions in Paragraph (i) expressly note “exterior walls or other major structural components,” the exclusions expressly note “removal, replacement, or maintenance of nonstructural exterior components such as decorative siding, shingles, and windows” (italics added).

Note B: CCC staff’s deletion of “roofing materials” and replacement with “shingles” is unfortunate.  But it addresses CCC staff’s concern that “roofing materials” could be too broadly interpreted to include structural roof components such as roof trusses/framing.  The inclusion of “shingles” is intended by CCC staff to express that only the exterior waterproofing material may be replaced.

City staff discussed this specific point with CCC staff in 2023 and CCC staff confirmed they are not seeking to prevent traditional re-roof activities such as shingle, tile, or tar and gravel roof replacements.  City staff intends to propose an alternative modification to further clarify these points related to routine re-roof activities, and to further seek exclusion of plywood sheathing replacement beneath shingles to address common dry rot conditions in Pacifica.  If successful, City staff’s alternative modification would provide an important clarification to the policy language in CCC staff’s suggested modifications which already allow routine re-roof activities to occur and not be counted towards an SSM.

Other Ways to Submit Questions

By email: coastalplan@pacifica.gov

By mail/in-person:
City of Pacifica
Attn: Planning Department
540 Crespi Drive
Pacifica, CA 94044