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MOVED TO CONSENT AGENDA. From the Caliifornia Coastal Commission meeting on Wednesday, November 4th, 2026. APPROVED AS RECOMMENDED. Agenda.
Exhibits LCP Amendment.
Correspondence including Technical Review of San Mateo County’s Proposed Midcoast Local Coastal
Program Amendment from Montara Water and Sanitary District (MWSD).
Staff Report for Item #10b.
Commissioners.
Summary of Staff Recommendation
San Mateo County is proposing to amend its Local Coastal Program (LCP) Land Use
Plan (LUP) to modify the methodology used to calculate the annual residential unit
development cap for its Midcoast coastal area. Growth in the Midcoast, which includes
the unincorporated communities of Montara, Moss Beach, Miramar, El Granada, and
Princeton, has long been managed in part through such a cap, which was originally set
at 125 units per year in 1980, but lowered to 40 units in 2012. The cap was meant to
help ensure that the pace of development remained consistent with available water,
wastewater, and transportation infrastructure. Annual residential development in the
Midcoast has historically remained below this limit, averaging 28.5 units per year from
2013 to 2024. However, in 2025, the County approved 102 housing units, of which 71
were affordable, or 62 units above the cap. Such a cap exceedance is allowed by the
LCP if the units are affordable and if the growth rate averaged over a three-year period
does not exceed 40 units per year. Because the County approved 102 units in 2025,
only 18 additional units may be permitted through 2027 to remain at or below the 40 unit
per year average for that three-year period as currently allowed by the LCP.
To address this constraint, the County proposes to amend its LUP to revise the
methodology used to calculate the residential development cap by allowing previously
unrealized development potential from earlier years to be incorporated into the
calculation. Under the proposed amendment, the current forward-looking three-year
rolling average would be replaced with a historical-average method. This new method
would apply beginning January 1, 2013, and would allow for affordable housing projects
to be permitted even if they exceed the annual 40-unit development cap, so long as the
overall number of units approved since 2013, on a per year basis, does not exceed 40
per year. This change would give the County greater flexibility in administering the
existing development cap while addressing the current backlog of permit applications
without altering the longstanding 40-unit annual growth limit. And, to be clear, once the
40-unit cap has been met in any year, the only units allowed above the cap in that year
under the proposed averaging methodology would be affordable units.
The proposed LUP changes raise two primary issues: whether adequate services,
including wastewater capacity, water supply, and transportation management, are
available to support the potential increase in housing units that could result from
allowing the cap to be raised, and whether such changes could adversely affect coastal
resources.
In terms of ensuring that there are adequate services to serve new
development, it is important to note that the LCP includes a series of provisions that
require applicants to demonstrate that proposed development can be served by
adequate and sustainable utility infrastructure, including in relation to water, wastewater
and traffic, and that those provisions apply irrespective of the potential availability of
development units under the cap.
Put another way, the cap is a limitation, but just because a project may fall under the cap
(including using averaging as proposed) such eligibility does not establish that
adequate public services are available to serve the proposed development, and thus
the cap works in tandem with other LCP tests to ensure adequate services under any scenario.
And the same applies to coastal resource protection, where any such project would also
need to prove that it protects coastal resources as required by the LCP, cap or no cap.
In short, the proposed changes would give the County and its Midcoast residents
greater flexibility with respect to the cap to accommodate affordable housing projects,
and the LCP would continue to require demonstration of adequate services and lack of
coastal resource impacts to do so. Accordingly, the proposed amendment is consistent
with applicable Coastal Act requirements, which serve as the standard of review for
LUP amendments. Therefore, staff recommends that the Commission approve the
proposed LCP amendment as submitted.
Staff Note: LCP Amendment Action Deadline
This proposed LCP amendment was filed as complete on October 22, 2026. The
proposed amendment only affects the LCP’s LUP provisions, and the 90-working-day
action deadline is March 3, 2027. Thus, the Commission has until that time to take final
action on this LCP amendment.
Therefore, if the Commission fails to take a final action in this case (e.g., if the
Commission instead chooses to postpone/continue LCP amendment consideration),
then staff recommends that as a part of that action, the Commission vote to extend the
deadline for final Commission action on the proposed amendment by one year. To do
so, staff recommends a YES vote on the motion below. Passage of the motion will result
in a new deadline for final Commission action on the proposed LCP amendment. The
motion passes only by an affirmative vote of a majority of the appointed Commissioners.
Technical Review of San Mateo County’s Proposed Midcoast Local Coastal Program Amendment from Montara Water and Sanitary District (MWSD). (page 4)
Montara Water and Sanitary District {MWSD) supports the County’s objective of facilitating
affordable housing and recognizesthe County’s obligations understate housing law. The District
does not oppose amendment of the Local Coastal Program {LCP) where supported by
substantial evidence and consistent with the California Coastal Act. The District’s concern isthat
the proposed amendment modifies one of the central implementation mechanisms of the
certified Midcoast growth-management program without a corresponding reevaluation of the
integrated infrastructure assumptions upon which the California Coastal Commission relied
when certifying the current LCP.
Under the current LCP, the Coastal Commission did not evaluate the 40-unit growth limitation as
a stand-alone accounting rule. Rather, it evaluated residential growth together with residential
buildout, water demand, wastewater capacity, transportation, public works phasing, priority-use
allocations, and public health and safety. The Commission concluded that growth limitations
were necessary to address infrastructure constraints and further stated that growth limitations
should be revisited after critical infrastructure needs and public service capacities were
reevaluated.
The County proposesto replace the existing rolling three-year averaging methodology with a
cumulative historical accounting methodology extending back to January 1, 2013.1 While
characterized as a minor administrative revision, the practical effect isto create a permanent
bank of previously unrealized permits that never expires. District engineering analysis
{discussed below) concludes that this approach could allow approximately 188 previously
unrealized residential units to be constructed during a future year while remaining below the
cumulative average. Based on MWSD’s historical demand assumptions, such a scenario would
increase average day water demand by more than 28,000 gallons per day, or approximately 10.4
percent above current average day demand, substantially exceeding the annual planning
assumptions historically relied upon by the District.
As this memo describes, the District respectfully requests that the County address several
planning questions before any modification to the certified growth-management methodology:
- What planning principle supports relying upon permit activity dating back to 2013 to
regulate infrastructure planning in 2026, 2030, or future decades? - At what point do unused residential permits become too remote in time to remain a
reliable indicator of current infrastructure demand and public service capacity? - Has the County evaluated how replacing the existing rolling three-year methodology
with a cumulative historical averaging methodology changes the effective annual
growth rate, permit availability, and resulting demand on public infrastructure? - How does the amendment affect water demand, wastewater demand and priority-use
allocations? - What are the fiscal and planning implications for utility providers?
The District believes these questions directly address the proposed amendment so that it
complies with the Coastal Commission’s regulations require that an LCP amendment include “a
discussion of the amendment’s relationship to and effect on the other sections of the certified
LCP.” {14 Cal. Code Regs. § 13552.) Without answers, the Board cannot determine whether the
amendment merely changes an accounting methodology or fundamentally alters the growthmanagement framework previously certified by the California Coastal Commission.
1. Since the initial preparation of this memorandum, the District understands that the County may revise
its proposed permit accounting methodology in response to public comments. Regardless of the
methodology ultimately adopted, the County must still analyze whether the infrastructure assumptions
underlying the existing growth limit continue to support the proposed level of development.
More on the Midcoast LPC Cap Process on Coastside Buzz
San Mateo County Plannning Commission
Author: mdrag
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