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HomeMy WebLinkAboutCity Council - 2008-31 RESOLUTION NO 2008-31 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF HUNTINGTON BEACH, CALIFORNIA, WHICH ACKNOWLEDGES RECEIPT OF THE COASTAL COMMISSION ACTION AND ACCEPTS AND AGREES TO LOCAL COASTAL PROGRAM AMENDMENT NO 1-06 AS MODIFIED WHEREAS, the California Coastal Commission reviewed and approved Huntington Beach Local Coastal Program Amendment No 1-06 as modified at the May 7, 2008 Coastal Commission hearing, and Section 13537 of the Coastal Commission Regulations requires the local government to accept and agree to the modifications by resolution within six (6) months, or certification will expire, and Upon the City Council action staff will forward Resolution No 2008-31 for final Coastal Commission certification, NOW, THEREFORE, the City Council of the City of Huntington Beach does hereby resolve as follows SECTION 1 The City Council accepts and agrees to the Coastal Commission's approval of Local Coastal Program Amendment 1-06 and the Coastal Element of the certified Local Coastal Program as suggested by the Coastal Commission in the letter dated May 20, 2008 attached hereto as Exhibit "A" and incorporated by this reference as though fully set forth herein Said suggested modifications shall become effective 30 days after adoption of Resolution No 2008-31 or upon final Coastal Commission certification, whichever occurs latest 08 1640/22937 1 Resolution No 2008-31 PASSED AND ADOPTED by the City Council of the City of Huntington Beach at a regular meeting thereof held on the 16th day of June , 2008 Ama. /�� ', Mayor REVIEWED , D A ROVED INITIATE AND APPROVED City Administrator Plannm Direc or APPROVED AS TO FORM rty Attorney U� 2 07 1095/12094 Exhibit A - Resolution No 2008-31 Exhibit A - Resolution No 2008 31 STATE nF CAI IFORNIA THE RFSnt 1RCFS AGENCY C;RAY DAVIS CnVAmnr CALIFORNIA COASTAL COMMISSION South Coast Area Office 200 Oceangate Suite 1000 Long Beach CA 90802-4302 (562)590 5071 May 20 2008 city of Huntington Beach Scott Hess Planning Director MAY 2 3 2008 City of Huntington Beach 2000 Main Street Huntington Beach CA 92648 Re Huntington Beach LCP Major Amendment No 1-06 (Parkside) Dear Mr Hess You are hereby notified that the California Coastal Commission at its May 7 2008 meeting in Marina del Rey adopted revised findings reflecting the Commissions action of November 14 2007 approving City of Huntington Beach Local Coastal Program Amendment No 1 06 with modifications Local Coastal Program (LCP)Amendment No 1-06 is reflected in City Council Resolution No 2002- 123 The approved amendment as modified provides land use designations and Land Use Plan text for the area known as Parkside an area that was deferred certification at the time the City s LCP was certified Please note the Implementation Plan portion of LCPA 1-06 was withdrawn by the City and thus the subject area remains an area of deferred certification The Commission approved the LCP amendment subject to the attached suggested modifications Therefore LCP Land Use Plan Amendment No 1-06 will not become effective until 1) the Huntington Beach City Council adopts the Commissions suggested modifications 2) the City Council forwards the adopted suggested modifications to the Commission by resolution and 3) the Executive Director certifies that the City has complied with the Commissions November 14 2007 action as reflected in the findings adopted on May 7 2008 On April 10 2008 the Coastal Commission extended the City Councils six month time limit to accept the suggested modifications Therefore the Coastal Act requirement that the City s adoption of the suggested modifications be completed within six months has effectively been extended until May 14 2009 Thus the City Council must act to accept the Commission s suggested modifications by May 14 2009 Thank you for your cooperation and we look forward to working with you and your staff in the future Please call Meg Vaughn or myself at (562) 590-5071 if you have any questions regarding the modifications required for effective certification of City of Huntington Beach LCP Land Use Plan Amendment No 1-06 Sincerely Teresa Henry District Manager cc Mary Beth Broeren Principal Planner HNB LCPA 1 06 parkslde psthrg Itr AdptdF 5 20 08 my Exhibit A - Resolution No 2008 31 STATE OF CALIFORNIA THE RESOURCES AGENCY ARNOLD SCHWARZENEGGER Governor t CALIFORNIA COASTAL COMMISSION South Coast Area Office 200 Oceangate Suite 1000 Long Beach CA 908024302 (562)590�071 May 20 2008 TO Commissioners and Interested Persons FROM Sherilyn Sarb Deputy Director South Coast District Orange County Teresa Henry Manager South Coast District Karl Schwing Supervisor Regulation & Planning Orange County Area Meg Vaughn Coastal Program Analyst SUBJECT ADOPTED FINDINGS for Major Amendment Request No 1-06 (Shea Homes/Parkside) to the City of Huntington Beach Certified Local Coastal Program Land Use Plan (Pursuant to Commission action at the Public Hearing on the May 7 2008 meeting in Manna del Rey reflecting the Commission s action at the November 14 2007 hearing) SUMMARY OF HUNTINGTON BEACH LCP AMENDMENT REQUEST NO 1-06 Request by the City of Huntington Beach to amend the Land Use Plan (LUP) portion of the Local Coastal Program (LCP) The proposed Local Coastal Program (LCP) amendment is a project-specific amendment designed to make possible a low density residential development on a vacant approximately 50-acre site comprising two legal lots most of which is currently in agricultural production Of the total project area approximately 45 acres have long been located within the City of Huntington Beach The remaining 5 acres were until 2004 located within unincorporated County of Orange jurisdiction within the Bolsa Chica LCP area However with the recent annexation the entire site is within the City of Huntington Beach Of the 45 acre portion of the site approximately 40 acres were deferred certification at the time the City s overall Local Coastal Program was certified and remains uncertified today This LCP amendment would incorporate that 40 acres and the newly annexed area into the City s existing LCP and establish land use and zoning designations for those areas The remaining five acre portion of the 45 acre area was certified at the time the City s overall LCP was certified as Open Space — Park (OS-P) The 40 acre area was originally deferred certification due in part to wetland issues The City s current amendment requests designation of approximately 38 5 acres as RL-7 (Low Density Residential — maximum 7 units per acre) approximately 8 2 acres as OS-P (Open Space — Park) and approximately 3 3 acres as OS—C (Open Space— Conservation) SUMMARY OF COMMISSION ACTION At the Commission hearing of November 14 2007 the Commission reviewed the City of Huntington Beach Local Coastal Program Amendment 1-06 The Commission approved with revised suggested modifications the City s request to amend the LCP Land Use Plan as requested At the Commission hearing of May 7 2008 the Commission adopted Revised Findings with changes to the original staff recommended revised findings The final version of the suggested modifications and findings adopted by the Commission at x Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 2 the May 7 2008 hearing which reflect the Commission s November 14 2007 action on the LCPA are contained in these adopted findings At the November 14 2007 hearing public testimony and Commission discussion included concerns regarding the extent of wetland on site the appropriate distance for ESHA buffer areas and appropriate uses allowed within ESHA buffer areas The Commission found that the area referred to as the Wintersburg Pond (WP) was not wet enough to develop a preponderance of wetland vegetation or wetland soils that the area known as the EPA wetland was wet enough,-to support a preponderance of wetland vegetation or soils in 1996 and that any changes in local hydrology that may have taken place since that time were unpermitted a variable width buffer distance would be adequate to protect the eucalyptus grove ESHA and that areas referred to as intermingled areas found between the areas identified as wetland ESHA and buffer areas should not be designated Open Space - Conservation The changes made by the Commission at the hearing are manifested in the staff report primarily though changes to Exhibit NN (now 0' revised) in that the areas of the site to be designated Open Space— Conservation and the areas to be designated as the development envelope (which allows either active park or residential development) have changed In addition the changes made by the Commission at the hearing result in changes to the suggested modification regarding the width of the ESHA buffer area and uses allowed within that buffer area Also there are changes to the wetland findings supporting the Commission's determination that the WP area is not a wetland and to eliminate the discussion on the intermingled areas Finally changes are made in the ESHA findings to support the variable width ESHA buffer rather than the 100 meter ESHA buffer and to allow a portion of a water quality Natural Treatment System as an allowable use within a portion of the outer ESHA buffer subject to restrictions COMMISSION VOTE The Commissioners voting on the prevailing side were Burke, Clark, Hueso, Secord, Neely, Potter, Reilly, and Chair Kruer STANDARD OF REVIEW For the proposed Land Use Plan amendment, the standard of review is conformance with and satisfaction of the requirements of the Chapter 3 policies of the Coastal Act SUMMARY OF PAST ACTIONS ON THIS LCPA At the May 2007 hearing in San Pedro after presentations by staff the applicant and public testimony the Commission voted to deny the subject Land Use Plan amendment as submitted A motion (i a the main motion) was made to approve the Land Use Plan amendment with modifications but upon deliberation the hearing was continued The LCPA was subsequently scheduled for Commission action at its July 9-13 2007 hearing Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 3 The LCP amendment originally proposed changes to both the Land Use Plan (LUP) and the Implementation Plan (IP) On July 3 2007 the City withdrew the IP portion of the LCPA The Commission recognized the withdrawal of the 1P amendment at its July 11 2007 hearing Also at its July 11 2007 hearing the Commission postponed action on suggested modifications for the LUP portion of the LCPA At the November 14 2007 hearing the Commission approved the proposed LUP amendment with suggested modifications as revised at that hearing At the May 7 2008 hearing the Commission adopted the revised findings with changes Those changes are reflected herein SUMMARY OF PUBLIC PARTICIPATION Section 30503 of the Coastal Act requires public input in Local Coastal Program development During the preparation approval certification, and amendment of any local coastal program the public as well as all affected governmental agencies including special districts shall be provided maximum opportunities to participate Prior to submission of a local coastal program for approval local governments shall hold a public hearing or hearings on that portion of the program which has not been subjected to public hearings within four years of such submission Prior to submittal of the LCPA to the Commission the City held numerous public hearings on the proposed LCP amendment as shown on exhibit D All City staff reports were made available for public review in the Planning Department and in the Huntington Beach Public Library Public hearing notices were mailed to property owners of record for the parcels that are the subject of the amendment as well as parcels within a 1 000 foot radius (including occupants) and notice of the public hearing was published in the Huntington Beach Independent a local newspaper of general circulation ADDITIONAL INFORMATION Copies of the staff report are available online on the Coastal Commission s website at www coastal ca gov or at the South Coast District office located in the ARCO Center Towers 200 Oceangate Suite 1000 Long Beach 90802 To obtain copies of the staff report by mail or for additional information contact Meg Vaughn in the Long Beach office at (562) 590-5071 The City of Huntington Beach contact for this LCP amendment is Scott Hess Director of Planning who can be reached at (714) 536-5271 Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 4 1 RESOLUTION RESOLUTION TO CERTIFY WITH SUGGESTED MODIFICATIONS The Commission hereby certifies the Land Use Plan Amendment No 1-06 for the City of Huntington Beach if modified as suggested and adopts the findings set forth below on the grounds that the Land Use Plan amendment with suggested modifications will meet the requirements of and be in conformity with the policies of Chapter 3 of the Coastal Act Certification of the land use plan amendment if modified as suggested complies with the California Environmental Quality Act because either 1) feasible mitigation measures and/or alternatives have been incorporated to substantially lessen any significant adverse effects of the plan on the environment or 2) there are no further feasible alternatives or mitigation measures that would substantially lessen any significant adverse impacts which the Land Use Plan Amendment may have on the environment 11 SUGGESTED MODIFICATIONS Certification of City of Huntington Beach LCP Amendment Request No 1-06 is subject to the following modifications The City s existing language is shown in plain text The City s proposed additions are shown in bold text The City s proposed deletions are shown in plain te)d strike ou The Commission staff s original (November 2007) suggested additions are shown in bold, italic, underlined text Theme Commis,/scion staffs original (November 2007) suggested deletions are show in bell Ttakc,un Ferhnec tr ke out 4e€ Additions to the November 2007 staff recommendation made by the Commission at the public hearing are shown in bold, italic, double underlined text Deletions to the November 2007 staff recommendation made by the Commission at the public hearing are shown in Staff Note Three corrections are made where due to typos existing certified LUP language was left out The corrections are 1) replacing the word residential in suggested modification No 1 2) replacing the sub-section Public in the table in suggested modification No 2 and 3) inserting the hyphen in the land use category titles Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 5 Open Space — Conservation and Open Space — Parks throughout LAND USE PLAN SUGGESTED MODIFICATIONS SUGGESTED MODIFICATION NO 1 Sub-Area Descriptions and Land Use Plan The City s certified and proposed Land Use Plan (LUP) language on page IV-C-11 under the heading Zone 2 — Bolsa Chica shall be modified as follows Existing Land Uses Inland (Pacific Coast Highway and areas north to the Coastal Zone boundary ) The majority of Zone 2, the Bolsa Chica is located outside the City s corporate boundary within the County of Orange The area is in the City s Sphere of Influence A - 50 acre area between Lis,®atos the residential development along Kenilworth ®rive and the East Garden Grove Wintersburg Flood Control Channel is vacant and includes a small section of the Bolsa Chica bluffs Coastal (Seaward of Pacific Coast Highway) Coastal Element Land Use Plan Inland (Pacific Coast Highway and areas north to the Coastal Zone boundary ) The Coastal Element does not present a land use plan for the Bolsa Chica The land area north of the Bolsa Chica within the City s corporate and Coastal Zone boundaries is built out consistent with its Coastal Element designation of low density resLdenttal The area west of the Bolsa Chica is also developed consistent with the Coastal Element Land Use designation of low density residential and multi-family residential next to the Wntersbur-g Flood Contrel Channel retaIRS its existing designation as aR "Area LOGal Geastal Pinegram will-. required, subjeGt te Coastal Commission approval the /71!1 �.�a d.7 ow ensitV e Wen$ia/1 -nil OS-P (Open CPaGe- U-+r41 /n �+� �+e hon - r�vFrn "-"- jwry Cn Ge_ Censerii-Beni Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 6 The fifty(50) acre area Oncludrng the 5 acre area annexed by the City in 2004) adjacent to and immediately north of the East Garden Grovell&intersbur_g Flood Control Channel and adjacent to and rmmedtately west of Graham Street is land use desI_gnated Residential and Open Space— Conservation (See Figure C-6a) There are wetlands, a Eucalyptus Grove that is an Environmentally Sensitive Habitat Area because it provides important raptor habitat, and buffer areasl at this site These areas are dest_gnated Open Space— Conservation The Wintersbur_g Channel Bikeway is identified at this site on the north levee of the flood control channel in the Commuter B/kewaVS Strategic Plan, which is the regional bikeways plan for Orange County(See page IV-C-49 and ftqure C-14) SUGGESTED MODIFICATION No 2 The table titled Zone 2 — Land Use Designations on page IV-C-11 shall be modified as follows Zone 2 — Land Use Designations Residential RL-Z or RM or RH Open Space OS-P OS-S OS-C Public P -W III t.e leleArea of Deferred GeFtifiGatiGn - Zone 2 — Specific Plan Areas None Zone 2 —General Plan Overlays 4G 4J 4K SUGGESTED MODIFICATION NO 3 Figure C-6 of the City s Land Use Plan shall be modified to reflect the change in the City's corporate boundary and to accurately reflect the correct areas of the certified land use designations (Residential and Open Space Conservation) for the area SUGGESTED MODIFICATION NO 4 New Figure C-6a shall be added to the City s Land Use Plan which shall be a land use plan of the Parkside site and shall depict the approved land use designations on the site as shown on 4th revised exhibit NN Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 7 SUGGESTED MODIFICATION NO 5 Add new subarea 4-K to table C-2 (Community Distnct and Subarea Schedule) as depicted below Subarea Characteristic Standards and Print les 4-K Permitted Uses Categories Residential(R-L or R-M Open Space Conservation (OS-C) See Fi ure C-6a Density/Intensity Residential Maximum of fifteen (15) dwelling units per acre Design and See Figure C-6a Development A development plan for this area shall concentrate and cluster residential units in the aeolheastern portion of the site and include, consistent with the land use designations and Coastal Element pohctes, the following required information (all required information must be prepared or updated no more than one year prior to submittal of a coastal development permit application) 1 A Pubhc Access Plan, including, but not limited to the following features ❖ Class I Bikeway(paved off-road bikeway, for use by bicyclists, walkers,loggers, roller skaters, and strollers) along the north levee of the flood control channel If a wall between residential development and the Bikeway is allowed it shall include design features such as landscaped screening, non-linear footprint, decorative design elements and/or other features to soften the visual impact as viewed from the Bikeway ❖ Public vista point with views toward the Bolsa Chica and ocean consistent with Coastal Element policies C 4 13, C 4 2 1, and C423 ❖ All streets shall be un_gated, public streets available to the_general public for parking, vehicular, i2edestrian, and bicycle access Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 8 All public entry controls (e _g pates, gatelguard houses, -guards, sLgnage, etc) and restrictions on use by the_-ggeneral public (e_g preferential parking districts, resident-only parking periods/permits, etc ) associated with any streets or parkin_q areas shall be prohibited ❖ Pubhc access trails to the Class I Bikeway, open space and to and within the subdivision, connecting with trails to the Bolsa Chica area and beach beyond ❖ Pubhc access signa_ge ❖ When privacy walls associated with residential development are located adjacent to pubhc areas they shall be placed on the private property, and visual impacts created by the walls shall be minimized through measures such as open fencin_glwall design, landscaped screening, use of an undulating or off-set wall footprint, or decorative wall features (such as artistic imprints, etc), or a combination of these measures 2 Habitat Management Plan for all ESHA, wetland, and buffer areas 01W ether designated Open Space- Conservation that provides for their restoration and perpetual conservation and management Issues to be addressed include, but are not limited to, methods to assure continuance of a water source to feed all wetland areas, enhancement of habitats and required buffer areas, restoration and enhancement of wetlands and environmentally sensitive habitats and required buffer areas, and fuel modification requirements to address fire hazard and avoid disruption of habitat values in buffers 3 Archaeological Research Design consistent with Pohctes C5 1 1, C5 12, C5 13, C5 14, and C5 15 of this Coastal Element 4 Water Quahty Management Program consistent with the Water and Marine Resources pohcies of this Coastal Element If develo ment of the parcel creates Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 9 sLgntficant amounts of directly connected impervious surface (more than 10%) or increases the volume and velocity of runoff from the site to adjacent coastal waters, the development shall include a treatment control BMP or suite of BMPs that will eliminate, or minimize to the maximum extent practicable, dry weather flow generated by site development to adjacent coastal waters and treat runoff from at least the 85th percentile storm event based on the desmn criteria of the Cahforma Association of Stormwater Agencies (CASQA) BMP handbooks, with at least a 24 hour detention time Natural Treatment Systems such as wetland detention systems are preferred since then provide additional habitat benefits, rehabihty and aesthetic values 5 Pest Management Plan that, at a minimum, prohibits the use of rodenticides, and restricts the use of pesticides, and herbicides in outdoor areas, except necessary (lector Control conducted by the City or County 6 Landscape Plan for non-Open Space Conservation areas that prohibits the planting, naturalization, or persistence of invasive plants, and encourages low- water use plants, and plants primarily native to coastal Orange County 7 Biological Assessment of the entire site 8 Wetland delineation of the entire site 9 Domestic animal control plan that details methods to be used to prevent pets from entering the Open Space- Conservation areas Methods to be used include, but are not limited to, appropriate fencing and barrier plantings 10 Hazard Mitigation and Flood Protection Plan, includin_g but not hmited to, the following features ❖ Demonstration that site hazards including flood and hguefaction hazards are mite ated Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 10 ❖ Mintmization/miti_gation of flood hazard shall include the placement of a FEMA- certifiable, vegetated flood protection levee that achieves hazard mitigation _goals and is the most protective of coastal resources including wetland and ESHA, ❖ Assurance of the continuance, restoration and enhancement of the wetlands and ESHA Residential Residential development, including appurtenant development such as roads and private open space, is not allowed within any wetland, ESHA, or required buffer areas and area dest_gnated Open Space- Conservation. Uses consistent with the Open Space-Parks desLgnation are allowed in the residential area All development shall assure the continuance of the habitat value and function of preserved and restored wetlands and environmentally sensitive habitat areas within the area designated Open Space-Conservation Open Space-Conservation A Wetlands Only those uses described in Coastal Element PolicV C 6 120 shall be allowed within existing and restored wetlands All development shall assure the continuance of the habitat value and function of wetlands Wetland Buffer Area A buffer area is required along the perimeter of wetlands to provide a separation between development impacts and habitat areas and to function as transitional habitat The buffer shall be of sufficient size to ensure the biological integrity and preservation of the wetland the buffer is designed to 2rotect Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 11 A minimum buffer width of 100 feet shall be established Uses allowed within the wetland buffer are limited to 1) those uses allowed within wetlands per Coastal Element Pohcy C 6 120, 2) a vegetated flood protection levee is a potential allowable use if, due to siting and design constraints, location in the wetland buffer is unavoidable, and the levee is the most protective of coastal resources including wetland and ESHA, 3) No active park uses (e _q tot lots, playing fields, picnic tables, bike paths, etc ) shall be allowed within 100 feet of wetlands preserved to the Open Space Conservation area B Environmentally Sensitive Habitat Areas Only uses dependent on the resource shall be allowed Environmentally Sensitive Habitat Areas (ESHA) Buffer Areas A variable width buffer area is required along the perimeter of the ESHA and is required to be of sufficient size to ensure the biological inte_grtty and preservation of the ESHA the buffer is desLgned to protect A minimum buffer width of 297 to 650 feet shall be established between all residential development or active park use and raptor habitat within the eucalyptus_groves Uses allowed within the ESHA buffer are limited to 1) uses dependent on the resource, 2) wetland and upland habitat restoration and management, 3) ve_getated flood protection levee that is the most protective of coastal resources including wetland and ESHA Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 12 4) within the northern grove ESHA buffer only— passive park use may be allowed if it is more than 150 feet from the ESHA, but only when it is outside all wetland and wetland buffer areas, and does not include any uses that would be disruphye to the ESHA Uses allowed within the passive park areas shall be hmited to a) nature trails and benches for passive recreation, education, and nature study. b) habitat enhancemenL restoration, creation and management 5 within the southern grove ESHA buffer only- a water guahty Natural Treatment System may be allowed so long as it is located in an area that is most protective of coastal resources and at least 246 feet from the ESHA U6) In addition to the regutmd ESHA buffer described above grading shall be prohibited within 500 feet of an occupied raptor nest during the breeding season (considered to be from February 15 through August 31), Ig IA/Eer/lee.,Lt a Ale.*core+/ Trazai imn4 C 2 One ciage nw/ e,e.IOe. algah eye. irada an hnnahac Mr O"Cl not AIC Habitat Management Plan shall be prepared for all areas designated Open Space-Conservation which shall include restoration and enhancement of delineated wetlands, wetland and habitat mitigation, and establishment of appropriate buffers from development Exhibit A - Resolution No 2008-31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 13 D Protective Fencing Protective fencing or barriers shall be installed along any interface with developed areas, to deter human and pet entrance into all restored and preserved wetland and ESHA buffer areas SUGGESTED MODIFICATION No 6 On page IV-C-60 and IV-C-61 under the heading Visual Resources The Bolsa Chica Mesas revise to include visual resources within Parkside area as follows The northwestern side of the Bolsa Chica Ecological Reserve includes bluffs that rise to an upland area known as the Bolsa Chica Mesa These bluffs are primarily under the County s jurisdiction (only a small part of the bluff lies in the City) but are within the City s Sphere of Influence for potential future annexation The mesas constitute a significant scenic resource within the City s coastal Zone The 50 acre site (located west of and adjacent to Graham Street and north of and adjacent to the East Garden Grove Wintersburg Orange County flood Control Channel) known as the "Parkside"site affords an excellent opportunity to provide a public vista point A public vista point in this location would provide excellent public views toward the Bolsa Chica and ocean Use of the public vista point will be enhanced with construction of the Class I bike path along the flood control channel and public trails throughout the Parkside site SUGGESTED MODIFICATION NO 7 On page IV-C-70 add the following language in the first paragraph under the heading Environmentally Sensitive Habitats to include reference to the wetland and Eucalyptus ESHA on the Parkside site The City s Coastal Element identifies two three environmentally sensitive habitat areas' within the City 1) the Huntington Beach wetland areas ai4 2) the California least tern nesting sanctuary, and 3) the wetlands and Eucalyptus ESHA on the Parkside site (See Figure C-21 for location of No 1 and 2) The Coastal Element includes policies to protect and enhance environmentally sensitive habitat areas in accordance with the Coastal Act Also on page IV-C-72 add the following new section describing the Eucalyptus ESHA and wetlands on the Parkside site after the paragraph titled California Least Tern Nesting Sanctuary Exhibit A - Resolution No 2008-31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkslde) Page 14 Parkside Eucalyptus ESHA and Wetlands (See Figure C 6a) Historically, this site was part of the extensive Bolsa Chica Wetlands system and was part of the Santa Ana River/Bolsa Chica complex In the late 1890s the Bolsa Chica Gun Club completed a dam with tide pates, which eliminated tidal influence, separating fresh water from salt water In the 1930s, agricultural ditches began to hmit fresh water on the site, and in 1959, the East Garden Grove-Wintersburg Flood Control Channel isolated the site hydroloWcally Nevertheless, wetland areas remain present at the site There are existing and previously dehneated wetlands, and areas that have been filled without authorization and are capable of being restored These areas as well as their buffer areas are designated Open Space- Conservation, and uses allowed within these areas are limited In addition, on the site's southwestern boundary, at the base of the bluff, is a hne of Eucalyptus trees that continues offstte to the west These trees are used by raptors for nesting, roostrn_g, and as a base from which to forage The trees within this "eucalyptus_prove"within or ad iacent to the subject site's western boundary constitute an environmentally sensitive habitat area (ESHA) due to the important ecosystem functions they provide to a suite of raptor species The Eucalyptus trees along the southern edge of the Bolsa Chica mesa are used for perching, roostinq, or nesting by at least 12 of the 17 species of raptors that are known to occur at Bolsa Chica Although it is known as the "eucalyptus grove", it also includes several palm trees and pine trees that are also used by raptors and herons None of the trees are part of a native plant community Nevertheless, this eucalyptus qrove has been recognized as ESHA by multiple agencies since the late 1970's (USFWS, 1979, CDFG 198Z 1985) not because it is part of a native ecosystem, or because the trees in and of themselves warrant protection, but because of the important ecosystem functions it provides Some of the raptors known to use the prove include the white tailed kite, sharp-shinned hawk, Cooper's hawk, and osprey Many of these species are dependent on both the Bolsa Chica wetlands and the nearby upland areas for their food These Eucalyptus trees were recognized as ESHA by the Coastal Commission prior to its 2006 certification of this section of this LCP most recently in the context of the Coastal Commission's approval of the adjacent BrIghtwater development(coastal development permit 5-05-020) The Eucalyptus _prove in the northwest corner of the site, although separated from the rest of the trees by a gap of about 650 feet, provides the same types of ecological functtons_ " as do the rest of the trees bordenng the mesa At least ten species of raptors have been observed in this prove and Cooper's hawks, a Cahfornia Species of Special Concern, nested there in 2005 and 2006 Due to the important ecosystem functions of providing perching, roosting and nesting opportunities for a variety of raptors, these trees also constitute ESHA These areas as well as their buffer areas onel mfornwnedad fin gneyones a m are designated Open Space-Conservation, and uses allowed within these areas are hmited Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 15 The wetlands, Eucalyptus ESHA areas, and buffer areas . are designated Open Space-Conservation to assure they are adequately protected SUGGESTED MODIFICATION NO 8 Add the following policy to the certified Land Use Plan on page IV-C-100 as new policy C 1 1 3a C913a The provision of pubhc access and recreation benefits associated with private development(such as but not limited to public access ways, pubhc bike paths, habitat restoration and enhancement, etc ) shall be phased such that the pubhc benefits) are in place prior to or concurrent with the private development but not later than occupation of any of the private development SUGGESTED MODIFICATION NO 9 Add the following policy to the certified Land Use Plan on page IV-C-105 as new policy C 247 C247 The streets of new residential subdivisions between the sea and the first pubhc road shall be constructed and maintained as open to the general pubhc for vehicular, bicycle, and pedestrian access General pubhc parking shall be provided on all streets throughout the entire subdivision Private entrance _-ggates and private streets shall be prohibited All pubhc entry controls (e g _gates, _gate%guard houses, guards, signage, etc) and restrictions on use by the _general pubhc (e g preferential parking districts, resident-only parking periods/permits, etc ) associated with any streets or parking areas shall be prohibited SUGGESTED MODIFICATION NO 10 Modify the following existing LUP Water and Marine Resources policies as follows C 6 1 6 (modify third and fourth paragraph) The City shall require that new development and redevelopment as appropriate employ nonstructural Best Management Practices (BMPs) and structural BMPs designed to Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 16 minimize the volume velocity and pollutant load of stormwater runoff, prior to runoff discharge into stormwater conveyance systems receiving waters and/or other sensitive areas All development shall include effective site design and source control BMPs When the combination of site desgin and source control BMPs is not sufficient to protect water quality, structural treatment BMPs along with site design and source control measures shall be required BMPs should be selected based on efficacy at mitigating pollutants of concern associated with respective development types To this end the City shall continue implementation of the Municipal Non Point SourGe Stormwater National Pollution Discharge Elimination System (NDPES) standards pregrai ►permit Santa Ana Regional Water Quality Control Board Order No R8- 2002-0010, dated January 18, 2002, or any amendment to or re-issuance thereof) of which the City is a co-permittee with the County of Orange through the Santa Ana Regional Water Quality Control Board Per program parameters continue to require a Water Quality Management Plan for all applicable new development and redevelopment in the Coastal Zone C 6 1 16 Encourage the Orange County Sanitation District to accept dry weather nuisance flows into the sewer treatment system prior to discharge New developments shall be designed and constructed to minimize or eliminate dry weather nuisance flows to the maximum extent practicable C 6 1 25 Require that new development and redevelopment minimize the creation of impervious areas, espectaHy directly connected impervious areas, and where feasible reduce the extent of existing unnecessary impervious areas and incorporate adequate mitigation to minimize the alteration of natural streams and/or interference with surface water flow The use of permeable materials for roads, sidewalks and other paved areas shall be incorporated into new development to the maximum extent practicable Add new policy C 6 1 30 Natural or vegetated treatment systems (e _q bio-swales, vegetative buffers, constructed or artificial wetlands) that mimic natural drainage patterns are preferred for new developments over mechanical treatment systems or BMPs (e_g water quahty treatment plants, storm dram inlet filters) Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 17 SUGGESTED MODIFICATION NO 11 Add the following policy to the certified Land Use Plan, on page IV-C-123 as new policy C 727 Any areas that constituted wetlands or ESHA that have been removed, altered, filled or degraded as the result of activities carried out without compliance with Coastal Act requirements shall be protected as required by th_e_pohcies in this Land Use Plan III FINDINGS FOR APPROVAL OF THE LAND USE PLAN AMENDMENT WITH SUGGESTED MODIFICATIONS The following findings support the Commission's action of November 14 2006 approving Land Use Plan amendment 1-06 if modified as suggested Changes to the findings contained in the staff recommendation dated November 1 2007 necessary to reflect the Commission s action are indicated as follows Language added as a result of the Commission s action is shown in bold, i•tahc, double underline Language deleted as a result of the Commission s action is shown in The Commission hereby finds and declares as follows A Land Use Plan Amendment Description The proposed Local Coastal Program (LCP) amendment is a protect-specific amendment designed to make possible a low density residential development up to a maximum 7 dwelling units per acre (dua) on a vacant approximately 50-acre site comprising two legal lots most of which is currently in agricultural production Most of the site is currently uncertified and the proposed LUP amendment would incorporate those areas into the City's existing LUP and establish land use designations for those areas as well as for the currently certified parts of the site The geographic area that is the subject of this proposed LUP amendment can be divided into three areas See Exhibit C4 The largest section is an area of the City that was deferred certification by the Commission at the time the City s Land Use Plan (LUP) was originally certified in 1982 and that deferral carried through to the eventual LCP certification in 1985 The area of deferred certification (ADC) is approximately 40 acres ' 1 The staff report and Commission findings from the 1982 LUP certification are not entirely clear about how much area was deferred certification However the City has clearly depicted the area subject to this LCP amendment(through the Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 18 This amendment request proposes to certify this area by bringing it within the City s existing LUP and applying land use designations to the area Just northwest of the ADC is a 5 acre area that is currently certified (see footnote 1) and designated Open Space-Parks The City has resubmitted this area for certification with the same designations Finally there is a five acre area southwest of the ADC that was under the jurisdiction of the County of Orange until it was annexed by the City in 2004 Like the ADC the City proposed to certify that area by bringing it within the broader City LUP and land use designations are proposed for this area as well The proposed amendment would allow the majority of the site to be developed with low density residential development and would also set aside a portion of the site for open space uses including parks and conservation The amendment does not propose to create any new land use designations that are not already used in the existing LUP Each of the land use designations proposed already exist within the certified Land Use Plan (LUP) The land use designations that are proposed to be applied at the subject site have been applied elsewhere within the City s certified LUP However because the site is an area of deferred certification or was recently annexed no land use designation has ever been approved by the Commission at the subject site (with the exception of the 5 acre area designated and zoned Open Space- Parks) The current zoning of approximately 38 acres of the site is Residential Low Density which has not been certified by the Commission Specifically the amendment request proposes the following land use designations (see exhibit C) Land Acres Use RL - 7 Low Density Residential-Maximum 7 units per acre 38 4 acres OS-P Open Space-Park 8 2 acres OS-C Open Space-Conservation 3 3 acres As stated the area of deferred certification is forty acres and the former County parcel is five acres In addition to the 45 acre area the City has also included in this amendment the five acre area that was not deferred certification The certified area totals approximately 5 acres and is land use designated and zoned Open Space — Parks Most of the certified five acre parcel is slope area and not usable as an active park area The proposed amendment would retain that land use and would expand that designation into the formerly deferred area for a total of 8 2 acres of Open Space — Parks This five acre segment brings the total size of the subject site to 50 acres (40 acre ADC 5 acre former County parcel 5 acre certified area) exhibit to its resolution)and clearly resubmitted any portions of that area that may currently be certified For purposes of this staff report we refer to the uncertified area as being 40 acres and the acreage of the other areas subject to this LUP amendment are calculated accordingly However if the City does not accept the Commission s certification with suggested modifications and the current status quo remains the Commission does not by these descriptions take any position on the issue of what area is currently certified and what area is ADC Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 19 Of the approximately 5 acre former County area 1 7 acres are proposed to become low density residential and 3 3 acres are proposed to become Open Space —Conservation (these figures are included within the totals in the chart above) In addition to establishing land use designations for the subject site the amendment also proposes text changes to the LUP The certified LUP includes a section of area-by-area descriptions In this section of the LUP the acreage figure is proposed to be changed to reflect the annexation of the former County parcel (from the current 44 acre figure to the proposed 50 acre figure) In addition language describing the area as vacant and an area of deferred certification is proposed to be replaced with the following language The Coastal Element land use designation for the vacant 45 acre area next to the East Garden Grove-Wintersburg Flood Control Channel was recently certified as RL-7(Low Density Residential) and OS-P (Open Space—Park) In addition approximately 5 acres of land was annexed from the County of Orange into the City of Huntington Beach This area is designated RL-7(Low Density Residential) and OS— C (Open Space— Conservation) The subject area is currently comprised of two parcels one 45 acre parcel (historic City parcel) and one 5 acre parcel (former County parcel) B Site Description and History The site address is 17301 Graham Street Huntington Beach Orange County It is bounded by Graham Street to the east East Garden Grove Wintersburg Flood Control Channel (EGGWFCC)to the south unincorporated Bolsa Chica area to the west and existing residential uses to the north (along Kenilworth Drive) The development to the north is located within the City The land to the north and to the east of the project is located outside the coastal zone The areas located east of Graham Street, south of the EGGWFCC and immediately north of the subject site along Kennilworth Drive are all developed with low density residential uses To the northwest a multi-family condominium development Cabo del Mar exists To the west of the subject site, are undeveloped properties known as the Goodell property and Signal Landmark property To the southwest of the subject site lies the Bolsa Chica wetlands restoration area The 3 3 acre area on the subject site proposed to be land use designated Open Space-Conservation is adjacent to the wetlands restoration area West of the Goodell property is the site of the recently approved Brightwater development for 349 residential units (coastal development permit 5- 05-020) The Brightwater site the Goodell property and the Signal Landmark property are located on the Bolsa Chica mesa The majority of the subject site has been more or less continuously farmed since at least the 1950s The majority of the site is roughly flat with elevations ranging from about 0 5 foot below Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 20 mean sea level to approximately 2 feet above mean sea level The western portion of the site is a bluff that rises to approximately 47 feet above sea level Also generally near the mid-point of the southerly property line is a mound with a height of just under ten feet The EGGWFCC levee at the southern border is approximately 12 feet above mean sea level Historically the site was part of the extensive Bolsa Chica Wetlands system In the southwest corner of the site on the former County parcel the City property owner and Commission are in agreement that an approximately 0 45 acre wetland is present In the 1980s as part of the review of the County s proposed LUP for the Bolsa Chica the Department of Fish and Game (CDFG) in the document titled Determination of the Status of Bolsa Chica wetlands (as amended April 16 1982) identified this area as severely degraded historic wetland — not presently functioning as wetland and considered it within the context of the entire Bolsa Chica wetland system Also in 1989 the U S Environmental Protection Agency (EPA) published its delineation of an approximately 8 acre wetland area in the northwest area of the site near the base of the bluff At the time of the EPA delineation the area was being farmed The topography of the agricultural field has been significantly altered since about 1998 As a result the area delineated by EPA no longer is inundated or saturated for long periods except during exceptionally wet years Water now tends to inundate an area near the flood control channel (designated WP") and an area at the base of the western bluff (designated `AP ) both of which were sari identified as wetlands by the Commission s staff ecologist However. the Commission found at its November 14, 2007_meeting that the WP is not wet enough long enough to result in the formation of hydric soils and does not exhibit sufficient hydrology that would support a predominance of hydrophytes in most years The City and property owner do not contest designation of the AP as wetland In addition on the site s western boundary generally along the base of the bluff are two groves of Eucalyptus trees The trees are used by raptors for nesting roosting and as a base from which to forage At the time the City s LUP was first considered for certification in 1981 the Commission denied certification in part because the City proposed low density residential land use designation for the site that is the subject of the present amendment request and the Commission found the site to contain wetlands The City re-submitted the LUP in 1982, but it made no change to the proposed low density residential land use designation for the subject site Once again the Coastal Commission in its action on the City's proposed Land Use Plan denied the certification for the MWD site (as the subject site was previously known) finding that it did contain wetland resources and that the designation of this parcel was an integral part of the ultimate land use and restoration program for the Bolsa Chica The Commission findings for denial of the LUP for this area note the importance of this area in relation to the Bolsa Chica LCP Of the 3 3 acres proposed to be Open Space — Conservation none is located within the 40 acre area that was deferred certification The site was being farmed at the time of the Commission s denial of the low Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 21 density residential land use designation for the subject site A related coastal development permit application had been submitted for the subject site 5-06-327 Shea Homes but that application has since been withdrawn similar to prior applications (previously submitted and then withdrawn were application Nos 5-06-021, 5- 05-256 and 5-03-029 for the same development proposal), as well as an appeal of a City permit for the certified area (A-5-HNB-02-376) The appealed action remains pending but the applicant waived the deadline for the Commission to act on the appeal The Commission anticipates acting on the appeal in conjunction with a future permit application The permit application and appeal request subdivision of the site to accommodate 170 single family residences construction of the residences and associated infrastructure preservation of the wetland identified on the former County parcel and dedication and grading of active public park area C LCP History The LCP for the City of Huntington Beach minus two geographic areas was effectively certified in March 1985 The two geographic areas that were deferred certification were the bulk of the subject site (known at that time as the MWD site — see footnote 1) and an area inland of Pacific Coast Highway between Beach Boulevard and the Santa Ana River mouth (known as the PCH ADC) The subject site is northeast of the Bolsa Chica LCP area At the time certification was deferred the subject area was owned by the Metropolitan Water District (MWD) The site has since been sold by MWD and is currently owned by Shea Homes Both of the ADCs were deferred certification due to unresolved wetland protection issues Certification of the subject site was also deferred due to concerns that it might be better utilized for coastal-dependent industrial facilities since MWD at that time had a transmission corridor parcel within the Bolsa Chica Lowlands that it indicated could be used to connect seawater intake facilities located offshore to facilities located on its switchyard parcel in the City of Huntington Beach through the subject parcel This is no longer a possibility since the State has taken over the lowlands and given the development of the areas surrounding the subject parcel since 1982 (and pending development that has already been approved) this site is no longer appropriate for coastal dependent industry The PCH ADC was certified by the Commission in 1995 The wetland areas of that former ADC are land use designated Open Space — Conservation and zoned Coastal Conservation No portion of the former PCH ADC is part of the current amendment request A comprehensive update to the City s LUP was certified by the Commission on June 14 2001 via Huntington Beach LCP amendment 3-99 The City also updated the Implementation Plan by replacing it with the Zoning and Subdivision Ordinance (while retaining existing specific plans for areas located within the Coastal Zone without changes) The updated Implementation Plan was certified by the Coastal Commission in April 1996 via LCP amendment 1-95 Both the LUP update and the IP update maintained Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 22 the subject site as an area of deferred certification This LCP amendment was originally submitted as LCPA No 2-02 LCPA 2-02 was subsequently withdrawn and re-submitted as LCPA 1-05 LCPA 1-05 was also withdrawn and re-submitted The current amendment LCPA 1-06 is the most recent submittal of the same amendment No changes have been made to the amendment proposal during any of the withdrawal and re-submittals The withdrawal and re-submittals were done in order to provide the property owner additional time to prepare and submit additional information regarding the presence of wetlands on-site and the use of the eucalyptus grove by raptors, and to allow Commission staff adequate time to review the additional information LCPA 1-06 was received on April 13 2006 On June 13 2006 the Commission granted an extension of the time limit to act on LCPA No 1-06 for a period not to exceed one year Thin donelffna Few n L ^mow Ain 7 na me f.d , On May 10. 2007. the Commission voted to deny the subject Land Use Plan amendment, as submitted A motion ji a the main motion) was made to approve the Land Use Plan amendment with modifications, but upon deliberation, the hearing was continued The LCPA was subsequently scheduled for Commission action at its July 9-13. 2007 heanng The LCP amendment originally proposed changes to both the Land Use Plan (LUP) and the Implementation Plan (IP) On July 3. 2007. the city withdrew the IP portion of the LCPA The Commission recognized the withdrawal of the IP amendment at its July 11, 2007 hearing Also at its July 11, 2007 hearing. the Commission postponed action on suggested modifications for the LUP portion of the LCPA At its November 14, 2007 meeting. the Commission approved the LUP amendment with suggested modifications On April 10, 2008, the Commission granted an extension of the time limit for the City to act on suggested modifications to the LCPA D Land Use Plan Format The City s certified Land Use Plan includes a section of Goals Objectives and Policies These are organized by specific resources including headings such as Land Use Shoreline and Coastal Resource Access and Recreational and Visitor Serving Facilities among many others These are the certified policies that apply City—wide within the coastal zone Another section of the certified LUP is the Technical Synopsis The Technical Synopsis is an area-by-area description of each segment of the City s coastal zone This section includes the descriptions of the existing land use designations It also includes after a narrative description of the sub-areas Table C-2 Table C-2 is titled Community District and Sub-area Schedule and it provides greater specificity of what is allowed and encouraged within each subdistrict This greater level of specificity provides a more detailed site specific description than would be provided if the land use designation or general policies were considered alone Table C-2 provides language on how general policies and designations would apply to specific sub areas of the coastal zone Taken all together these work well as the standard for development in the coastal zone Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 23 The format of the suggested modifications applies this same structure to the amendment site Many of the issues addressed by suggested modifications would be required by the general LUP policies but consistent with the format of the LUP the suggested modifications are intended to provide a greater level of detail that applies to the specific circumstances of the subject site For example, although the City s public access policies may be adequate to require a bike path along the EGGWFCC levee the LUP format calls the reader s attention to the fact that at this particular site, a bike path is appropriate and is therefore being required in this amendment If one were working from the policies alone some opportunities at certain sites may not be recognized The LUP s existing format significantly maximizes the protection of resources within the coastal zone The suggested modifications carry out that same format in order to assure protection of resources at the amendment site E Approval of the Land Use Plan Amendment if Modified 1 Incorporation of Findings for Denial of Land Use Plan as Submitted The findings for denial of the Land Use Plan as submitted are incorporated as if fully set forth herein The Commission denied the LUPA as submitted at the Commission's May 10 2007 hearing The findings for denial of the LUPA as submitted that were provided in the May 2007 recommendation are found in _Attachment A attached to this staff report ' 2 Wetland The proposed amendment includes an Open Space Conservation designation on a 3 3 acre area within the former County parcel The 3 3 acre area includes an undisputed wetland area (see 3`d revised exhibit NN) The proposed Conservation designation is appropriate for this area However, additional wetland areas exist at the subject site that are not proposed to be protected with the Open Space Conservation (OSC) designation and are addressed in the following findings Wetlands often provide critical habitat nesting sites, and foraging areas for many species some of which are threatened or endangered In addition wetlands can serve as natural filtering mechanisms to help remove pollutants from storm runoff before the runoff enters into streams and rivers leading to the ocean Further wetlands can serve as natural flood retention areas Another critical reason for preserving expanding and enhancing Southern California's remaining wetlands is because of their scarcity As much as 75% of coastal wetlands in southern California have been lost and statewide up to 91% of wetlands have been lost Section 30121 of the Coastal Act states Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 24 "Wetland means lands within the coastal zone which may be covered periodically or permanently with shallow water and Include saltwater marshes freshwater marshes, open or closed brackish water marshes, swamps, mudflats and fens The Commission has further specified how wetlands are to be identified through regulations and guidance documents Section 13577(b)(1) of the Commissions regulations states in pertinent part Wetlands shall be defined as land where the water table is at near, or above the land surface long enough to promote the formation of hydric soils or to support the growth of hydrophytes For purposes of this section the upland limit of a wetland shall be defined as (A) the boundary between land with predominantly hydrophytic cover and land with predominantly mesophytic or xerophytic cover (B) the boundary between soil that is predominantly hydric and sod that is predominantly nonhydric or (C)In the case of wetlands without vegetation or sods the boundary between land that is flooded or saturated at some time dung years of normal precipitation and land that is not Section 30231 of the Coastal Act states in pertinent part The biological productivity and the quality of wetlands appropnate to maintain optimum populations of manne organisms and for the protection of human health shall be maintained and where feasible restored through among other means, preventing depletion of ground water supplies and substantial Interference with surface water flow maintaining natural vegetation buffer areas that protect riparian habitats Section 30233(a) of the Coastal Act states The diking filling or dredging of open coastal waters, wetlands, estuanes and lakes shall be permitted in accordance with other applicable provisions of this division where there is no feasible less environmentally damaging alternative, and where feasible mitigation measures have been provided to minimize adverse environmental effects and shall be limited to the following 1) New or expanded port energy, and coastal-dependent Industrial facilities, including commercial fishing facilities 2) Maintaining existing or restonng previously dredged depths in existing navigational channels, turning basins vessel berthing and moonng areas, and boat launching ramps 3) In open coastal waters other than wetlands Including streams estuaries, Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 25 and lakes new or expanded boating facilities and the placement of structural pilings for public recreational piers that provide public access and recreational opportunities 4) Incidental public service purposes including but not limited to burying cables and pipes or inspection of piers and maintenance of existing intake and outfall lines 5) Mineral extraction including sand for restoring beaches except in environmentally sensitive areas 6) Restoration purposes 7) Nature study aquaculture or similar resource dependent activities Section 30250 of the Coastal Act states in pertinent part (a) New residential development shall be located where it will not have significant adverse effects either individually or cumulatively, on coastal resources In addition, the City's LUP includes Policy C 6 1 20, which limits filling of wetlands to the specific activities outlined in Section 30233 of the Coastal Act And LUP policy C 7 1 4 states in pertinent part Require that new development contiguous to wetlands or environmentally sensitive habitat areas include buffer zones ' The Coastal Commission staff ecologist has reviewed considerable amounts of information regarding the extent of wetlands at the site much of which are listed in his memorandum which is attached as Exhibit K The property owner has submitted numerous documents intended to demonstrate that there are no wetlands on site, beyond the wetlands recognized on the former County parcel (i a the CP wetlands) Local citizens have submitted documents intended to demonstrate that there are significantly more wetlands on site than that recognized in the CP wetlands These citizens are concerned by the prospect that development may be allowed to occur within wetlands at the site if the LUP amendment were approved as submitted (and as reflected in the related coastal development permit application 5-06-327, Shea Homes and appeal A-5-HNB-02-376) In addition the staff ecologist has reviewed historical information regarding the subject site and surrounding area All this information has been reviewed by the staff ecologist and is considered in his memoranda attached as Exhibits K LLL and QQQ to this staff report and are hereby incorporated into these findings in their entirety The Commission s Mapping/GIS Program Manager has also reviewed numerous historic and more recent aerial photographs and topographical information The purpose of the Mapping/GIS Program Manager's review was to identify changes due to landform alterations such as grading and filling, and to attempt to delineate disturbed areas dating from the time the Coastal Commission's jurisdiction began at the project site (1/1/77) The results of his review are reflected in his memoranda dated 712/07 and 10/25/07 attached as exhibits MMM and RRR of this staff report and which are hereby incorporated into these findings in their entirety Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 26 In brief summary results of the review of the aerial photos and topographic maps indicates that topography has changed on site particularly in the area delineated by the EPA as wetlands in their 1989 publication (generally in the northwest area of the site) Changes are also identified in the area of the former equestrian facility (generally in the southwestern portion of the site between the CP and WP areas) However, at its November 14. 2007 hearing, the Commission found. +base_d on evidence presented, that no wetlands exist in the WP area In the aerial photo taken on May 21 1970, the western extension of Slater Avenue is visible just north of the flood control channel embankment on the subject property The 1970 photo establishes a pre-Proposition 20 pre-Coastal Act baseline for gauging the extent of land alterations and other changes that occurred later(post Coastal Act 111/77) A clearly distinguishable topographic depression in the area of the EPA wetlands is depicted on topographic maps from 1970 1980 and 1996 However by 2005 that depression was no longer present in the same configuration The lowest area had been displaced to the west abutting the base of the mesa and the historic EPA wetland area had been relatively flattened In the area of the former equestrian facility the aerial photos and topographic maps also show disturbance In the images from 1981 on fill is evident in the area that was developed as an equestrian facility It appears that fill first appears in conjunction with establishment of the equestrian facility with additional fill being placed over the life of the facility The extent of fill has migrated primarily to the north, but also, to some extent to the southwest €� o WP and AP Areas 46ge s With regard to existing wetlands based on his review of the available data the Commission s staff ecologist determined that additional wetland areas exist at the subject site The Commission s staff ecologist considered first questions of whether additional wetland areas exist at two specific areas of the subject site The results of the staff ecologists review regarding the presence of additional wetland at the two specific sites (described below as areas AP and WP) are reflected in his Memorandum dated 7/27/06 attached as exhibit K to this staff report For the reasons listed in that memorandum and below the Commission concurs and adopts its ecologists conclusions with regard to the area known as the Agricultural Pond (AP) wedands Vw4 Two specific areas ®f were evaluated for the presence of additional wetland area The two sites are referred to as the Wintersburg Pond or WP which is adjacent to the East Garden Grove Wintersburg Flood Control Channel (EGGWFCC) levee along the southern edge of the site and the Agricultural Pond or AP, located near the base of the bluff along the western edge of the property The proposed LUP amendment would designate these wetland areas Low Density Residential and Open Space-Parks These land use designations allow grading and the construction of houses, roads and active parks which wcould necessitate the dredging and filling of the wetlands if wetlands are present in these areas Such uses within wetlands are inconsistent with Section 30233 of the Coastal Act and with LUP Policy C 6 1 20 which limits filling of Exhibit `A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 27 wetlands to the specific activities outlined in Coastal Act Section 30233 The memorandum dated July 27 2006 from the Commission s staff ecologist states The available data suggest that portions of the agricultural field are inundated or saturated at a frequency and duration sufficient to support a preponderance of wetland plant species Such areas meet the definition of wetlands under the Coastal Act and the Commission s Regulations There are three factors or parameters that are used to determine whether or not a wetland exists the presence of hydrophyec vegetation the presence of hydric soils and the presence of wetland hydrology The Commission fords an area to be wetland if any one of the three parameters is present Usually the presence or absence of hydrophytes or hydric soils is sufficient to determine whether a wetland exists However those two indicators are not necessary as they do not actually define a wetland Rather, an area is defined as a wetland based on whether it is wet enough long enough that it would support either of those two indicators Therefore the removal of vegetation by permitted activities does not change a wetland to upland Section 30121 of the Coastal Act provides the statutory definition of wetlands " lands within the coastal zone which may be covered periodically or permanently with shallow water and include saltwater marshes freshwater marshes Section 13577(b)(1) of the California Code of Regulations provides the regulatory definition of wetlands land where the water table is at near or above the land surface long enough to promote the formation of hydric soils or to support the growth of hydrophytes Thus the Coastal Act and the Regulations provide that a determination of the presence of wetlands may be made based on whether an area demonstrates the presence of sufficient water to promote hydric soils or to support hydrophytes whether or not the soils and vegetation are present under existing conditions Because this area was historically a salt marsh and because the site has been historically farmed and continues to be farmed as of the adoption of these findings the typically used field indicators cannot be relied upon The grading and repeated discing and plowing associated with the existing agricultural use destroys hydric soil features and prevents the development of natural vegetation The evidence presented in the ecologists memo and summarized below yj& su that the AP and WP areas are wet enough long enough to support the growth of hydophytes T4ws If so the WP and AP areas would meets_the definition of wetlands contained in the Commission s regulations The WP and AP would also meets the Coastal Act definition of wetlands iLthe-y-a-re it fperiodically covered in shallow water " However, based on all the evidence presented~'including the memoranda prepared by Commission staff. information submitted by the City, the property owner the public, and public testimonW the Commission found that the area of the WP is not wet enough Iona enough or frequently enough for the development of a preponderance of hydrophytic vegetation or hydric sods Therefore. the Commission finds that the area known as WP is not a wetland Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 28 The wetland conclusion is based on two lines of evidence (1) an examination of the vegetation at a nearby location that is similar in history physical characteristics and hydrology to the depressions in the agricultural field,2 and (2) an informed estimate of the frequency and duration of continuous inundation at various sites Areas WP and AP were matched by the Commission s staff ecologist with wetland areas on the County parcel that were similar in elevation and topography Inundation in the agricultural and AP areas and at the reference wetlands was similar in pattern further suggesting that the latter is a good proxy for the former Therefore since the dominant vegetation at the reference areas is mostly comprised of wetland species it is reasonable to expect that the agricultural aread AP would also support a predominance of hydrophytes in the absence of farming (i a that thgy4 a it is wet enough Iona enough and frequently enough to support such vegetation) Although prior to about 1990, inundation hadn t been apparent in the depression adjacent to the EGGWFCC (WP area) and inundation occurred there less frequently than in the area of the AP- in recent years a le the Commission consddered avmlen€e nformation regarding whether the WP is inundated for long duration following significant rainfall Weighing the conflicting information submitted. the Commission found that the WP was not inundated for long duration following significant rainfal! Establishing the extent of wetlands at the site given its history of farming and disturbance is not straightforward The best approach for this site regarding WP and AP known to the Commission at this time is to base the wetland boundary on current conditions as inferred from recent topography and the available photographs of recent inundation EPA Delineated Wetland (1989) Prior to about 1990 it appears from aerial photographs that significant inundation was generally confined to the area delineated as wetland Oust east of the area of the AP) by the EPA in its 1989 publication Based on analysis of aerial photographs dating from 1958 to 1985 the property owners biological consultant concluded that inundation in that area tended to have a different footprint in different years and, based on this observation he z In the second to last footnote in Dr Dixon s memo he notes that the topography of the reference site is actually similar to that of WP as it existed in 2003 not at present More recently a box plough was used to fill area WP which is apparent in 2006 topographic maps The box plough fill is under investigation by Commission staff as an alleged violation Accordingly relying on the topography prior to the alleged violation yields the appropriate comparison Additionally the hydrology section of Dr Dixon s memo states that LSA biologists stated that WP didn t pond until after about 1973 However if this is due to changes in topography that occurred before 1973 it is again appropriate to focus on the post 1973 topography as that represents current conditions Conditions prior to 1973 may be irrelevant if topographical conditions changed prior to 1973 as such changes were pre Coastal Act and therefore not Coastal Act violations Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 29 argued that no particular area should be identified as a wetland However all his estimated wetland polygons in the western portion of the agricultural field appear to fall within the area delineated by the EPA In the absence of wetland vegetation the drawing of wetland boundaries is an approximate exercise based on a small and haphazard collection of aerial photographs or ground observations and estimates of topography Given the approximate nature of such delineations, it appears the consultants results are actually additional evidence that the EPA delineation was reasonable at the time it was made However it appears that the area of the EPA delineation (8 3 acres)was based on extra-normal site circumstances As described in the October 25 2007 memorandum prepared by the Commission s staff ecologist the 8 3 acre estimate of the wetland size appears to have been based largely on observations made during the period when increased runoff from off-site was temporarily directed onto the subject site This appears to have occurred during the construction of the Cabo del Mar condominiums on the adjacent property from sometime after 1978 until sometime before 1986 if one considers the area delineated by EPA under normal conditions (i a no excess off site drainage directed on-site) a more likely estimate for the wetland area can be made Based on the Bilhorn (1987) and EPA (1989) estimates of wetland area during the period of construction of the Cabo del Mar condominiums estimates of water availability during the period of interest and the estimated size of ponded areas in available photographs a reasonable estimate of the average area that ponded is 4 0 acres The 1987 and 1989 studies by Bilhorn and EPA were based on field work done prior to 1987 The October 25, 2007 memorandum is attached to this staff report as exhibit QQQ and is hereby incorporated by reference as though fully set forth herein As discussed in detail below the EPA wetland is no longer present Existing CP Wetland Substantial evidence suggests that the wetland area of the CP is larger than what has been recognized in the LCP amendment submittal The wetland area recognized by the City and property owner on what is known as the former County parcel totals 0 45 acres However additional CP area should be included in the CP wetland acreage This wetland area was filled without authorization from the Commission In a letter dated 9/7/82 from the Department of Fish and Game (DFG) to Coastal Commission staff the DFG determined the area, prior to placement of the unpermitted fill to be wetlands and recommended removal of the fill and revegetation (see exhibit BBB) Pursuant to Coastal Development Permit No 5-82-278 the unpermitted fill was to have been removed and the area revegetated Based on comparison of topographic (1980) and vegetation maps (Vegetation Communities Exhibit 26 of the Bolsa Chica Land Use Plan dated January 1982) created before the unpermitted fill was placed with topographic maps (1986 and 1982) created subsequent to the time the fill was placed the elevation of the subject area was increased by at least 2 feet Because of the unpermitted fill, the pickleweed within the filled area was no longer viable Development approved pursuant to Coastal Development Permit 5-82- Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 30 278 included removal of the unpermitted fill to an elevation of approximately three inches below the grade of the existing adjacent pickleweed stand [area of the recognized CP wetland] and revegetation of the area with one or more of the following species pickleweed spiny rush frankenia, sea lavender and shoregrass However elevations in the fill area are not consistent with pre-fill elevations Rather topographic maps prepared subsequent to the unpermitted fill and subsequent to the issuance of Permit 5-82-278 depict the fill area at an elevation at least two feet above the adjacent CP wetland This leads to the conclusion that removal of the fill and revegetation never occurred Were it not for this unpermitted development the area would have remained wetlands area Unpermitted development cannot be used as a basis to justify development in areas where were it not for the unpermitted development such development would not be allowed Thus consideration of appropriate land use designation must consider site conditions as if the unpermitted development had not occurred Therefore this area is considered a wetland As proposed the amendment would allow land uses like residential and related uses, like roads within wetland areas Thus the proposed land use designation is not consistent with Section 30233 of the Coastal Act Potential Unpermitted Development Unpermitted development cannot be used as a basis to justify development in areas where were it not for the unpermitted development such development would not be consistent with the requirements of the Coastal Act The site as has been mentioned has historically been farmed Discerning changes in topography on the order of a few feet to fractions of a foot over the course of 30 years and ascertaining that such changes are not due to normal farming activities at a site where farming activities are on-going is problematic Nevertheless it is important to assure that if wetland areas have been eliminated due to unpermitted activity that those areas are considered as if the unpermitted activity had not occurred Thus if areas that would have met the Commission s definition of a wetland have been altered such that they no longer meet that definition only due to unpermitted activity that area must be afforded the same protection as would be required had the unpermitted activity not illegally altered the wetlands It has been suggested that the land alterations in the area of the EPA delineated wetland were the result of normal farming activity and so could not be considered unpermitted development in terms of the need for a coastal development permit However any activities whether normal farming activities or other that would result in the fill of wetlands cannot be exempt from the need to obtain approval of a coastal development permit Regarding leveling of land as a normal farming activity", a joint EPA and Department of the Army memorandum3 states grading activities that would change any area of water of the United States including wetlands into dry land is not exempt Furthermore Section 323 4(a)(1)(iii)(D) of the Army Corps of Engineers regulations pertaining to discharge of dredged or fill material into the waters of the United States states that the term plowing 'Memorandum Clean Water Act Section 404 Regulatory Program and Agricultural Activities United States EPA and United States Department of the Army May 3 1990 Exhibit A - Resolution No 2008-31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 31 does not include the redistribution of soil rock sand or other surficial material in a manner which changes any area of the water of the United States to dry land The Commission agrees and finds that if a wetland is filled and no coastal development permit has been obtained the fill activity constitutes unpermitted development The Commission makes no determination at this time whether the fill activity constitutes unpermitted development Regardless of the precise nature of the long- time farming activity, because the LCPA proposes allowing non-farming uses such as the proposed residential and park uses outside of the modified wetland and buffer area, and reguares restoration of a 4 0-acre modified EPA wetland. along with establishment of a 900-foot buffer adjacent the Commission finds that the modified EPA wetlands es protected as a wetland under the Coastal Act In a letter dated July 9 2007 submitted to the Commission at its July 2007 hearing from the California Farm Bureau Federation (see exhibit XXX) raises three issues regarding the LCPA staff report 1) staffs recommendation relies on an EPA study but there may no longer be any federal jurisdiction authority based on more recent EPA guidance documents 2) the subject site s status of prior converted cropland and 3) what constitutes "normal farming activities Regarding more recent EPA guidance documents the letter states In light of new USEPA and USACOE memorandums and the Staff Report s reliance on these agencies findings there may no longer be any federal jurisdictional authority over the disputed wetlands In turn this may alter key conclusions in the staff report The documents referenced describe procedures to be followed in determining when the EPA/USACE have jurisdiction in implementing the Clean Water Act The guidance documents assist only in determining when a Section 404 permit is necessary from the EPA and have no bearing on a past wetland delineation and cannot be interpreted as negating a past delineation Furthermore one of the referenced documents (Memorandum Clean Water Act Section 404 Regulatory Programs and Agricultural Activities) states `For example if a farmer has been plowing planting and harvesting in wetlands he can continue to do so without the need for a Section 404 permit so long as he does not convert the wetlands to dry land [emphasis added] " Thus even by the standards cited by the Farm Bureau farming that converts a wetland to dry land is not exempt from the requirement to obtain Section 404 review Furthermore the 1989 EPA wetland delineation assessed the presence of wetlands and found that wetlands did exist at the site Commission staff have reviewed that study as well as a great deal of other information (as cited in the Commission staff memoranda) and as is outlined in the staff memoranda found the EPA wetland delineation valid (with adjustments as described elsewhere) A change in other agencies guidance documents has no bearing on the results of the earlier wetland delineation The letter also raises the question of whether the subject site should be considered "prior converted cropland The Farm Bureau letter states Farm Bureau also believes that the Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 32 Coastal Commission should apply and document the site specific facts of this issue against USACOE RGL 90-7 and USEPA's applicable regulations and guidance documents regarding prior converted cropland The letter further states However, attention should be given to the disputed area s present and recent past characteristics and use as prior converted crop land The letter refers to a November 20 1998 letter from the Natural Resource Conservation Service designating the subject site as prior converted cropland That November 20 1998 Natural Resource Conservation Service letter states that it based its determination that the site is prior converted cropland on two factors 1) the site has been farmed prior to 1985 and 2) designation of the property as "Prior Converted Cropland by the Army Corps of Engineers in 1992, review of their designation in 1998 and an independent report from Lisa Kegarice of Tom Dodson and Associates in December of 1997 have determined that this property meets the criteria for Prior Converted Cropland However the Commission's staff ecologist's memo dated July 27, 2006 (exhibit K) includes review of the Natural Resource Conservation Service's 1998 letter (among many other documents) and addresses the issue of"prior converted cropland at length As described in greater detail in the Commission ecologists 7/27/06 memo, the decision to dismiss the site from regulation under the Clean Water Act was based on the faulty work contained in the Kegance report of 1997 and the fact that errors in that report have been perpetuated without challenge until now Furthermore designation of a site as prior converted cropland simply allows on-going farming to continue The proposed LUP amendment would not continue farming at the site so that designation even if it had been accurately applied is moot when considering allowing non-farming uses such as the proposed residential and active park uses Finally the Farm Bureau letter questions Commission staff s assessment that activities that have occurred on site are not normal farming activities On-going farming activities such as plowing and discing that are consistent with the continuance of existing wetlands constitute normal farming activities However, methods such as grading that go beyond normal farming activities have occurred on site, resulting in the loss and/or fill of wetlands and do not constitute normal farming activities Moreover members of the public have also presented evidence to suggest that activities that are employed at the site do not constitute normal farming activities And they have argued those activities have, over time substantially reduced the presence and extent of areas that would otherwise have met the Coastal Act definition of wetland Such activities include but may not necessarily be limited to use of a bulldozer and a box plough to move earth in the area of the agricultural field The Commission concurs that use of such earth moving equipment particularly when it results in the fill of wetlands, is not typically associated with normal farming activities Development, including earth movement on a scale that requires a bulldozer or box plough in an area of known wetland presence (i e 1989 EPA wetland delineation Commission s 1982 and 1984 actions deferring certification of the site DFG Study of Wetlands at Bolsa Chica) without an approved coastal development permit may constitute unpermitted development Also other non-farming activities have historically occurred on the site In 1982 the Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 33 Commission approved the above mentioned coastal development permit No 5-82-278 The approved development was located near the southwest corner of the site straddling the former City/County boundary (see exhibit BBB) Fill (1 500 to 3,000 cubic yards)for an expanded parking area was explicitly approved as part of that coastal development permit Evidence shows that only the area of the expanded parking lot that was explicitly described in the approved permit was approved for placement of fill under that coastal development permit approval If so any additional fill in the area of the remaining equestrian facility el may constitute unpermitted fill The development described in the application for the coastal development permit requests the following placement of mobile home as a caretaker facility additional stable facilities [emphasis added] grading and fill of a parking facility for approximately 50 cars removal of fill and revegetation [described previously] and placement of a fence around the revegetated area The City s 1981 Conditional Use Permit for the project (CUP No 81-13) refers to a request to expand [emphasis added] an existing horse facility The City s CUP staff report states The existing [emphasis added] temporary horse stable on the site has been in operation since 1966 and According to the applicant most of the existing [emphasis added] facilities were installed prior to 1977 These characterizations of portions of development existing prior to the Commission s jurisdiction in the area (which began on 1/1/77) were carried over into the Coastal Commission staff report for 5-82-278 However review of aerial photos indicates that the equestrian facility was not present until 1978 after the Commission s jurisdiction in the area began Both the City and County of Orange planning staff have reviewed their records for permits for the stable facility that predate 1978 but have found no permits earlier than 19814 Regardless of whether or not any portion of the equestrian facility pre-dates the Coastal Act review of historic aerial photos and topographic maps indicate subsequent actions at the subject site have resulted in fill beyond the footprint and/or at higher elevations than what was approved under coastal development permit 5-82-278 Any fill placed on the site other than that specifically approved for the 50 space parking area approved under cdp 5- 82-278 jo mmaa��be unpermitted It should be noted that a coastal development permit application was submitted in 1993 5- 93-376 (Hole in the Wall Stable) The 1993 application requested approval of continued use of the existing equestrian facility (formerly Smokey s Stables) At that time Commission staff determined the request was exempt from the need for a coastal development permit because it simply requested continued use of an existing facility no construction or grading/fill was proposed (see exhibit DDD) It appears the request was mischaractenzed in that the equestrian facilities present in 1993 were larger still than even those requested in 1982 In addition at the direction of Commission staff the current property owner submitted a 4 The County approved CUP No 80 92 to permit the establishment of a commercial stable on the County portion of the site on 2/26/81 Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 34 coastal development permit application for discing the site in 1999 (5-99-303 Shea Homes) In response to that application staff informed the applicant at that time that no permit was needed based on the property's prior usage for agricultural purposes n (see exhibit NNN) However staffs determination that no permit was necessary was based on a 1998 letter from CDFG (Exhibit YYY) stating that based on a consultant s report no wetlands were present and the likelihood of wetland restoration on site was slim But that CDFG assessment relied not on an actual wetland delineation by CDFG but rather on the flawed analysis contained in a wetlands assessment of the site conducted by Tom Dodson and Associates (Kegance, 1997P Thus staffs determination that no permit was needed was in error, based on faulty information prepared by others Furthermore staffs determination that no permit was necessary was also based on the characterization by the applicant (Shea Homes) that the development requested was discing of the site The letter from staff indicating no permit was necessary responded only to the request to continue shallow discing of the farmed area However the site has been subjected to farming practices that may go beyond what can be considered normal farming activities and which were not described as part of the project description in the permit application Supporting this conclusion are recently documented incidents at the site that include use of a bulldozer and a box plough In addition in his memorandum dated 7/2/07 (exhibit MMM) regarding the history of the EPA wetland area the Commission s Mapping/GIS Program Manager concludes dramatic changes have occurred in this decade The 7/2/07 memorandum states "Although agriculture has gone on in this area since the 1930 s the elevations have consistently indicated a topographic depression here Aerial photography shows repeated instances of ponding in the area In this decade the topography has changed dramatically, with the obliteration of the depression in its original location and the creation of a smaller narrower depression at the western margin of the agricultural field However, other than permit 5-82-278 and the two circumstances mentioned above no other permit history for the site has been discovered The question of whether development occurred without benefit of an approved coastal development permit is particularly important due to the history of wetlands on site There is evidence to suggest that areas where topography has been modified may have supported wetlands If wetlands were present at the time of past development the Coastal Act requires that those wetlands be protected Review of historic aerial photos of the site comparison of various historic and recent topographic maps of the site photos of earth moving equipment not normally associated with farming activities and earth moving in the area of previously delineated wetlands (i e EPA) also raise significant questions as to whether the site has been altered in ways that would have required a coastal development permit Construction of the Cabo del Mar condominiums —outside the coastal zone but adjacent to the subject site —appears to have included development that extended onto the subject 'See exhibit K Memo from the Commission s staff ecologist explaining why that analysis is flawed and does not reflect actual site conditions Exhibit A - Resolution No 2008-31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 35 site and thus within the coastal zone Prior to the development of the Cabo del Mar condominiums (c 1983 — 1985) a portion of the runoff from the approximately 22-acre site drained onto the Parkslde property and contributed to the hydrology of the wetland mapped by EPA At some point after the Cabo del Mar construction the drainage was directed to new drain pipes that were installed across the subject site Section 30231 of the Coastal Act requires that all wetlands be maintained by preventing substantial interference with surface water flow Construction of the drainage pipes impacted one source of water that fed the EPA wetland inconsistent with Section 30231 of the Coastal Act Such development would have required a coastal development permit from the Coastal Commission However no such permit was obtained Regarding the EPA wetland area evidence suggests that this wetland relied on surface water rather than groundwater Any loss of runoff would have a negative effect on the wetland that was historically present in the EPA area and on the wetlands that are currently present Open Space Conservation Area In summary in order to be most protective of wetlands, the additional wetland area beyond what is proposed to be designated Open Space-Conservation must be recognized and appropriately designated under this LUP amendment At a minimum that would include the AP and expanded CP areas and portions of the wetland area identified by the EPA in a document published in 1989 Although it is very likely the area between the former equestrian facility and the WP would be considered wetland area now were it not for unpermitted development that determination cannot be conclusively made mcud r e.w..rwwe. 4hw gjr=e/ h... 7and rnnt®-fnr—//ier9s - .. 4hw a thni m,tai him daclesnotarl Annion cnnoe The area delineated by the EPA as wetland totaled approximately 8 3 acres However as described in the October 25 2007 memorandum prepared by the Commission s staff ecologist the 8 3 acre figure appears to have been based on observations during a period when construction activities on an adjacent property resulted in a temporary direction of excess off-site drainage onto the subject site Several lines of evidence suggest that a reasonable estimate for the size of the wetland before and after the construction is about 4 0 acres Long-time farming activities resulted in the loss of the 4-acre EPA wetland area Section 30233 of the Coastal Act requires that loss of wetlands due to fill must be mitigated The Commission typically requires mitigation at a ratio of 4 1 (area of mitigation to wetland area lost) The Commission finds that the kwfi a 4 0-acre modified EPA wetland ^ 40 • ^^•�•��^�' �^4••-•4'-must beffl—#W@t@d restored However the activates that resulted in the loss of the EPA wetland area also contributed to the creation of wetlands in the area of the AP Thus it would be appropriate to fl^••• 4hw === wf 4hw '"/D M AG .. 01 Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 36 preserve the area of the AP (0 61 acres) Ln hn '•^,� tn.w,arrd ihn {nip/ wr^^ ^f.w— and mitigate the loss of the 4-acre EPA wetland area thr ucqh restoration of the 4 0-acre modified EPA wetland, as delineated by the Staff A1: in h^ n wL^nd A AG' wi.r^c. 1:9 aor^c /AD7 - / Ia.` wnroa I A Al 4 /.'L: porn - IQ ?A 4A AA .,r„t ar.d area %t.11 to hn nrnat^ Therefore in addition to the araea af A. AP an additional 4444 4 0 acres of wadgnd ar. restoration on site surrounded y a 900- foot buffer would be required to nuftgto address the loss of the 4-acre EPA wetland Thus area that must be preserved on site includes the AP 1 expanded CP areas modified 4 0 acre EPA wetland wa ochageind wrae/ .,..•ar ESHA areas wetland and ESHA buffer area, Preservation and/or restoration of the AP 14e expanded CP and restored d 4 0-acre EPA wetlands may require supplemental water Thn COM..e.,....,.., f nde rho rJnr.."nat.nr. ..hnrrlrl ra/rr oarnaa ahn , ninrr. rinrtroM ni n ..rrhrnoi r..Lo io wr.lo ..a{n/.r .. n{nni ahn oerr r.roarwt n e.aw/ r detvns"aw of thn r.r.h.nnt ., mire eAnrn r. nrf na►l.r ahn nr.nra gran "v�- F. /fin rl r.n rarer irn r. •./..r.. aLn r.l w rrlwl nvtn Mrl �nrr. 4hn r+ rrth nrM ..r^w^rL.r Irrw^ wl.�.ra .+ CM211AIrun ` F nrr.t Wawa of{hn nanangiant h ahn CE40 in n ranrthorr. nra bran wt w rat Want nF 4hn .+ or.owr.r hr.FF r it i n CDA The area to be designated Open Space Conservation is depicted on —4T revised Exhibit NN A Uhnggesh__thnro am n oLn{o nF Iar.rJ .rrrthrr. Lho a a {ho ^nr arr.rr.ornra f ncle rniggi h .atnri Crag—ants; Lha{ .. ..Irl rani r ah/.r ho r�/o.rn in ra ors/ i r za o.r,/n ra i.al nr ihn h on Monroe and thorn r somerar^..n l.rnrJ ry oL.n ra w.. Lo .w rhnihnr r. nw urnrr/� hw.rn r�tnlrMnwin r/ a of/and rraara ratter r�M�o rn r/ntw . nrn wh/o 2nd4 r M ri taro r/ a/fora trnn hwrdM!a noorrrrnd C•.r-ihnrr.lnrn {w/iora to Nnihnr ihn a' 2 that m of ho einorrrMai-d /1C is an M ntnoa ICCLJA Hand aMd thnrr a .urth rM 4hn arna t^ ho rJnorrinni^ 1 Thnrnirn G. ihaa nMirrn am wtnt.,„/n...rYMwtn,a nC 1M w.�,a.a. r.hr.taMt.al n,:.r.rnMnn nr.r,.rXnQar. that nthnr.rrntlanCI !3=QQ QVICil0d M rrnr in rwrhaL a r.n..rc� to harm hnnM nrwartan r.I rdn.rn/ r'.1n Mi Thn (ten .a+rr.orn implanth' r requ e. r.a.t.rvairnM it.wrn{lancl rr.Nnaotc canMnrat►rr n4 w rain nP A �1 l ,wr MrJ wrnwr. h MrJ thnc•^ o orF owI/.r rJnr.orrh ad ohn an orLn 14fam /no{ .rMM^rrr.ratad aot.rrra.r nt nMl.r uingtW ihn ..,^stand wrnwr+ nand to ho Mrnanntnri wMrt hr.L rrarir—boM it the Manr.rra /nor. in'hah•iwa.ralr.nr. .wrn 'd hio �'� � Th _ _..- .r,.ai.nn amnrrMa n-.rrndaMr-I • na -..- thn M nrJ i r wa.t ..rnrr/r./ ra. r.a w Mrratn/.r hhn Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 37 of tho f..r.� w I.4wI efmj,aI^.,...AH{ h Ir�I* r ih— c14,. .c. ,.^ne.Idera,J T It 100, rwfl.,,1 Mai fig w •,. d I nefor th III Mf M^f r. w/.Iwl^ wrrr^rw rlw4� •a.^�/w n r/ r wfI^r rwe.L^rw it^aw wmwl rv•^ • w., .+raw/II,J. el rho daclegnohnM �r rae.4^904.^ and Md ohnn In ncdimr in m that imnnI.,.t, ..r,.a Fr. of w.+Ida i r 211 mighars ,J^..^rlL,,,,1 _The Commission finds that only if modified consistent with the land use designations depicted on 41' revised exhibit NN, can the proposed LUP amendment be found to be consistent with Sections 30233 and 30231 of the Coastal Act which require protection of wetlands Moreover the entire area was originally deferred certification due to the historic presence of wetland on site In deferring certification originally the Commission found North Properties of the Bolsa Chica (Between Wintersburg Channel& base of Bluffs) (MIND Site #1 (virtually identical to the subject site of current LCP amendments]) The LUP designates this site for low density residential uses No modifications were made in the LUP from the previous denial by the Commission The Commission found in its `Preliminary Wetlands Determination for the Bolsa Chica Local Coastal Plan March 11 1980 that all available information demonstrated that the vast majority of the Bolsa Chica low lands exhibit all the characteristics set forth for the identification of wetlands pursuant to Section 30121 of the Coastal Act and concluded that the information supported a preliminary determination that areas identified on Exhibit J of the "Preliminary Determination are wetland for the purposes of the Coastal Act The Commission had also previously found in its denial of the City's LUP that this area contained wetland resources Since that action and the previous review of the City's LUP the Commission and staff have examined additional information concerning the Bolsa Chica wetlands system As part of the review of the Bolsa Chica LUP the Dept of Fish and Game in the document "Detennination of the Status of Bolsa Chica wetlands (as amended April 16 1982) identified this area as severely degraded Historic wetland— Not Presently Functioning as Wetland and considered it within the context of the entire 6 As indicated in footnote 1 the boundaries of the MWD site at the time of the 1982 staff report were not entirely clear However the site clearly covered what is now the 40 acre ADC and may have covered the former County parcel and some of the 5 acre certified area as well Moreover it did not extend south of the flood control channel so the observations recounted here are definitely applicable to the site that is the subject of the current application Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 38 Bolsa Chica wetland system The DFG determined that this area is part of a 1,000 acre degraded wetland system in the area outside State ownership which is capable of being restored The DFG report noted The 440 acres of historic wetland which no longer function viably as wetland consists of approximately 250 acres of roads and pads, 70 acres of agricultural land(including the subject site], and about 120 acres of viably functioning upland habitat The roads and fill areas presently function as resting substrate for wetland-associated wildlife and form narrow ecotones which add to and enhance the diversity of habitat available to wildlife The 120 acres of upland habitat considered in union may be considered environmentally sensitive because of their special role in the Bolsa Chica wetland ecosystem Were it not for the involvement of dikes, roads and relatively shallow fills these 440 acres would be viably functioning wetlands The entire 1 324 acre study area, including 1 292 acres of historic wetland(in which 852 acres still function viably as wetlands[sic]constitutes a fundamentally inseparable wetland system of exceptional value to wildlife The DFG also discussed potential restoration of these areas and noted that the amount of acreage and location of wetlands to be restored will be dependant on the amount of till and existing wetlands which could be consolidated to allow some development in the lowlands Thus when the Commission originally deferred certification of the subject site, it did so based on the presence of wetlands The Commission found that the site contained wetlands even though the wetland functions were impaired as is the case today Moreover farming was on-going at the time certification was deferred Thus, the area was deferred certification even though the wetlands were impaired and farming was on-going No change to those conditions have occurred in the intervening years Thus one cannot argue today that the site does not contain wetlands due to on-going farming activities or due to the impaired condition of the wetlands Furthermore unpermitted activities cannot be used as a basis to say that wetlands no longer exist at the site In addition in deferring certification of the site the Commission recognized that the site was an integral part of the overall Bolsa Chica wetland system and could feasibly be restored If the site were to be restored it would be a valuable addition to the Bolsa Chica wetlands restoration project Sources to feed a restored wetland at the site would come from rainfall and possibly from the adjacent EGGWFCC as well as urban runoff And perhaps also from re-establishing the site as the location to accept runoff from the Cabo del Mar condominiums In any case restoration of the site as a freshwater wetland would be consistent with the historic wetland system which would typically have included a freshwater component albeit significantly inland of the subject site The addition of freshwater habitat to the Bolsa Chica wetlands restoration would greatly increase the biodiversity of the overall restoration project In addition taken with the preservation of the Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 39 eucalyptus grove described below the area would provide significant habitat benefits In addition to protecting the wetland area itself it is important to establish buffer areas between the wetland and development Buffers by separating development from wetlands minimize the adverse effects of development on wetlands thereby avoiding significant adverse effects to resources Buffers also provide transitional habitat and upland area necessary for survival of various animal species The Commission has typically found that a minimum 100-foot buffer or larger is necessary to protect wetlands Without the establishment of a minimum buffer size protects could be approved with an inadequate buffer jeopardizing the continuing viability of the wetland Section 30250 of the Coastal Act requires that new development be located where it will not have significant adverse effects either individually or cumulatively on coastal resources Wetlands constitute a coastal resource In addition Section 30231 of the Coastal Act requires that all wetlands be maintained by providing natural vegetation buffer areas The City's certified LUP includes Policy C 7 1 4 which requires buffers around wetlands This policy would apply to the subject site but it allows a lesser buffer area if existing development or site configuration preclude a full 100 feet In this case, such circumstances do not apply because the site is 50 acres in size and is not constrained by the site configuration or by existing development A buffer less than 100 feet from all on-site wetlands is not adequately protective of the wetland The proposed amendment does not recognize all wetland areas present on site and does not provide any buffer requirements specific to the site Thus as proposed the amendment could result in locating development too close to the wetland threatening the survival of the resource inconsistent with Section 30250 which requires that the location of development avoid significant adverse effects on coastal resources such as wetlands and Section 30231 which requires natural vegetation buffer areas The extent of wetlands on site over the last 30 years and past activities on the site that may have impacted those wetlands are difficult to determine with certainty The Commission is charged with protecting wetlands and limiting uses allowed within wetlands as well as assuring that any allowable use is the least environmentally damaging alternative and that adequate mitigation is provided The Commission must also assure that the quality of wetlands is maintained by among other things preventing substantial interference with surface water flow In order to achieve these requirements the Commission must review the evidence available to it even when that evidence may conflict or be incomplete and arrive at a conclusion that is most protective of wetlands In this case the Commission after reviewing available evidence finds that on balance there is stronger evidence to support the conclusion that there are significantly more wetlands at the site than has been recognized in the LUPA request At a minimum, the additional wetland area includes the AP expanded CP the area delineated by the EPA in 1989 (as adjusted Any wetland delineation prepared for the subject site must recognize that the site is both a difficult site to delineate (i a an area where conditions make the use of standard field indicators of wetland parameters difficult fe g soils formed under hydric conditions Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 40 associated with tidal inundation that is no longer present]) and atypical because human activities (i a farming) have resulted in the lack of positive indicators of one or more wetland parameters The wetland delineation must account for circumstances where indicators are absent or difficult to interpret but other evidence demonstrates that the component(s) recognized by the Commission that comprise a wetland are present or would be present if not for the difficult' or atypical situation For example, the wetland delineation must recognize and account for circumstances where vegetation indicators cannot be expected hydnc soil indicators may be artifacts of prior conditions the sod surface is frequently disturbed which removes indicators of recent inundation plowing may drastically alter the soil profile irrigation might confound the interpretation of the presence of recruiting wetland plants and the presence of indicators of recent hydric conditions Because the site historically has been, more or less continuously farmed these indicators may be lacking even though the area may be "wet enough long enough that wetland features would develop It is critical that future wetland delineations of the site recognize this protocol and that, consequently even if the usual wetland indicators are not observable wetland areas must still be identified if those areas meet Coastal Commission criteria Wetland delineations must be sufficiently current to represent present site conditions As proposed the LUP amendment does not include this clarifying information Therefore a modification is suggested to specifically incorporate this standard into the site specific section of the LUP It should be noted that construction of a flood protection levee within the wetland buffer area provided it is the least environmentally damaging alternative would not be incompatible with the continuance of the wetland In order to be the least environmentally damaging alternative the flood protection levee should be placed outside the buffer wherever possible and as close to land designated for residential and/or active park uses as much as possible According to the related coastal development permit application for the subject site and the project proponent the type of flood protection levee to be constructed would be a vegetated flood protection feature (VFPF) essentially vegetated earthen berm with an internal sheet pile wall The VFPF would not be expected to adversely impact the wetland because 1)there would only be temporary construction- related impacts 2) once constructed the VFPF would be planted to provide upland habitat that complements the wetland vegetation and 3) the VFPF would not require maintenance once constructed thus intrusions into the buffer would be limited only to those necessary during construction For these reasons locating a flood protection levee such as the one described above within the wetland buffer would be consistent with Sections 30233 and 30250 of the Coastal Act regarding wetland protection .,.,..,1,....,,, th..t a ar-16sionfint amn th..t h..c h,00" e,I„e...r.,. io d nr.,,., cr...,.e. r1rd •.mot e. ...t.. �t/.�r..�le. �.r.far to nniar.s..tte.el ..e.t....t.� r th .t w..rre...1 that aff e.te..d wail.+r.da th..t e..r.ele....ag &0 ..t the, t.ma th., iminnaint eimnoldnnmiant narmii onnit If ■e•.e.nnal..e...ee./...,1., by the, .�.i.eJones that r alcL nis 1 r w4 _ Atf1II Ilth/M tho nc. !� Idi1e..MN tAiJ r/�A th t /I / I./ Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 41 n cIn/ r�e �•.r�i.e. •t may, h w0/110 to .11:160tb.o amandma mug. big Magi 19notaoinfon niannaint nel go ArAlar.in Aft an hoc-el Qnnga Furthermore Section 30250 of the Coastal Act requires that new development be located where it will not have adverse effects on coastal resources Wetlands constitute a coastal resource Section 30231 of the Coastal Act requires that all wetlands be maintained and where feasible restored by preventing depletion of ground water supplies and substantial interference with surface water flow and by maintaining natural vegetation buffer areas Based on information submitted with the related coastal development permit application, a significant amount of earthwork would be necessary to prepare the site for residential development It is essential that any earthwork undertaken on the site not interfere with the continuance of all on-site wetlands No grading is allowed within the wetland and its buffer area under the Coastal Act (unless the grading is for the express purpose of wetland restoration) Grading outside of the wetland ESHA and necessary buffers, could only be considered if no adverse impacts to the wetlands resulted If grading redirected groundwater and/or surface water flow such that water from the site no longer fed the wetlands it would create an adverse effect on the wetland which is a coastal resource inconsistent with Sections 30231 and 30250 of the Coastal Act The proposed amendment does not include any requirements that other site development including earthwork assure that no adverse effect occur to the wetlands Thus even if no grading were to occur within the wetlands and buffer areas adverse impacts to on-site wetlands might result from the LUP amendment as proposed However if the amendment is modified to include language that requires the protection of the wetlands from all development on-site the amendment could be found to be consistent with Section 30250 of the Coastal Act which requires no adverse effects to coastal resources occur In addition to the modifications suggested above, additional measures must be incorporated into the LUP amendment for the subject site to assure that future development adjacent to the wetland and buffer areas and throughout the site does not adversely impact the wetland For example if no restrictions were placed on landscaping throughout the site invasive plants within the residential areas could invade the wetland areas, potentially displacing the wetland plants In addition pets from the residential development if unrestricted may enter the wetland area causing disruption As proposed the LUP amendment does not include any site specific restrictions regarding potential impacts to continuation of the wetland inconsistent with Section 30250 of the Coastal Act However if modified to include a prohibition on invasive plants throughout the site and a requirement for a domestic animal management plan and fencing along the buffer/development interface as part of the site specific LUP language the amendment could be found consistent with Section 30250 of the Coastal Act Specific suggested modifications to accomplish this are necessary to bring the proposed amendment into conformance with the Coastal Act Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 42 Members of the public have raised concerns that unpermitted development has taken place on the property that is the subject of this amendment and that such unpermitted development has affected the extent of wetlands on the site Unpermitted development cannot be used as a basis to justify development in areas where, were it not for the unpermitted development such development would not be allowed This is true whether there is a specific policy reflecting this in the LUP or not In this case however #fie the Commission has estabhshed the extent of wetlands on the property and a development footpnntAMM14--con hips a4 4hw pa-&-n-if / I g a a 44ww/ 1/w..w/ws3.ww.e4 w4 430 w.4w ww. w4w/.Jw / 4 4 r 4h.w�ity 4w 6®i pi Flw,ii9�9 C9w7�oi9-7�9�i9®i�i99a9ig 6699� 4rw.iwrw1 4 the ^wmm.ww.w rw ni 4hw .+ / //Q ..w/.wa.4hw4 .....Lime .4 w/wwr 4h..4 impar.r..44 ycff ra ss not GCOUFMO-F The Commission finds that only if modified as indicated on staff exhibit NN f4th Revised) can the proposed land use plan amendment be found to be consistent with and adequate to carry out Sections 30233 and 30250 of the Coastal Act regarding wetlands 3 Eucalyptus ESHA The subject site contains environmentally sensitive habitat areas (ESHA) The trees within the eucalyptus grove, within and adjacent to the subject site s western boundary are ESHA due to the important ecosystem functions they provide to a suite of raptor species Section 30240 requires that ESHA be protected from significant disruption and that only uses dependent upon the resource are allowed within ESHA In addition Section 30240 requires development adjacent to ESHA be sited and designed to prevent impacts which would significantly degrade those areas Section 30240 further requires that development be compatible with the continuance of the habitat area This policy is carried over into the City s certified LUP ESHA policies In order to assure the ESHA is not significantly degraded and is protected and remains viable, in addition to precluding non-resource dependent development within the ESHA a buffer zone around the ESHA must be established A buffer zone would require that development adjacent to the ESHA be set back an appropriate distance from the ESHA The setback is intended to move the development far enough away from the ESHA so as to reduce any impacts that may otherwise accrue from the development upon the ESHA and that would significantly degrade the ESHA or be incompatible with its continuance The distance between the ESHA and development the buffer zone must be wide enough to assure that the development would not degrade the ESHA and also would be compatible with the continuance of the ESHA Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 43 The property owner has suggested a variable width buffer as a means of protecting the ESHA (see Attachment C. exhibits 1 and 2) A variable width buffer would be appropriate The variable width buffer proposed by the property owner would establish a minimum distance of 297 feet between the ESHA and residential or active park development(note 100 meters is 328 feet) The vanable w►dth buffer proposed by the property owner would establish a maximum buffer distance of at least 650 feet between the ESHA and residential or active park development In some areas of the site the effective width of the buffer area would substantially exceed 100 meters due to the relative location of the EPA wetland area and buffer and the AP wetland and buffer The area occupied by EPA and AP wetlands and their buffers would provide appropriate ESHA buffer in that development with the related nose and activities would not occur within them and also those areas would remain viable as raptor foraging-area The property owner's proposed variable width ESHA buffer►ncludes a water auahty Natural Treatment System (NTS) as an allowable use within the ESHA buffer near the southern grove (see Attachment C. exhibits 1 and 2) The NTS as proposed by the property owner►s setback a minimum of 246 feet from the ESHA Port►ons of a Natural Treatment System (NTS), would be appropriate within the ESHA buffer as long as it is located as shown on Attachment C exh►b►ts 1 and 2 An NTS within the ESHA buffer. subject to the setback described above, would be acceptable because it would occupy only a very small portion of the overall buffer area Furthermore. the NTS itself will provide some habitat value The shallow water habitat will increase the variety of habitats within the buffer area For these reasons, allowing an NTS type system within the outer ESHA buffer as shown on Attachment C. exhibits 1 and 2 would not be expected to degrade the ESHA and would be compatible with its continuance As proposed by the property owner, the variable width ESHA buffer would prevent development that is not compatible with the continuance of the ESHA from occurring in a location where it would disrupt the ESHA and disrupt it Therefore. the Commission finds the variable width buffer proposed by the property owner will adequately protect the entire ESHA The buffer should not be measured from myoporuin It is important to note however, that the "eucalyptus"ESHA is an area that includes several species of non-native trees that provide important habitat for a large suite of raptors These trees are predominantly eucalyptus, but also include pines and palms Using aerial photographs, staff has drawn the boundaries of the ESHA by connecting the apparent drip lines of the outmost trees It has been suggested that this has resulted in including a clump of mvoporum, an invasive exotic that probably►s not important to raptors Although. it is appropriate to ignore the myoporum when drawing the boundary if other nearby trees are species that provide habitat for raptors, the latter should be included within the ESHA boundary even if that results in some mvoporum being present within the ESHA Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 44 '•. =17 L..... Encl...afa d E/..w+ ..••. /+ l., ..•Jt/. l...fi ..I.J ...�•,r.. 79A f t / C Q f 1�...«....paag�...f.. 'ue i9®ai94S'®09�® i® ®��®®9�' �i tl3I�c:S ig v®t�'ai�i v�aa® ®v a®a®�i�m�ign�aei�ag��r-A �r it •e. abIJEF13160 that 9160 •� rl•J / anf M. L. r.wl...lio e. 9��i�E7rri®�®� 9®®®1_F=1I`1®i9 6i�99�i�99 6i�®�.S th- pnp* fit face than lied fmat A Mi0forr.1 from 030 r.O•.fla .r.. C•....,I.•r.t••.. AA Mato r-Rud .. ...�••.rad b.• As proposed ESHA area would be land use designated Open Space Parks which would allow active park uses within the ESHA In order to assure the ESHA is protected in addition to precluding development within the ESHA, a buffer zone around the ESHA must be established As proposed the LUP amendment designates necessary buffer area Open Space Parks and Low Density Residential The proposed designations would allow residential and park uses within the required buffer areas Residential and park uses within ESHA and its buffer are inconsistent with Section 30240 of the Coastal Act The land use designation that protects ESHA by limiting uses within ESHA to those allowed under Section 30240 and that prevents disruption of the habitat is Open Space Conservation In order to assure that development adjacent to the ESHA does not significantly degrade or impair the continuance of the ESHA the appropriate land use designation for both the ESHA and its buffer area is Open Space Conservation Uses allowed within the ESHA buffer for the southern grove are limited to resource dependent uses, habitat restorat►on. and VFPF(described below) In addition. within the northern grove ESHA buffer passive park use may be allowed if 11 1-s located more than 150 feet from the ESHA but the uses within the passive park are limited to nature trails, benches for passive use, and habitat enhancement restoration, creation and management Such_uses are acceptable within the ESHA buffer because they are compatible with the continuance of the ESHA It is also worth noting that California gnatcatchers (Polioptila californica californica) a species listed as threatened under the Endangered Species Act are known to frequent the subject site especially the western portion Also Southern tarplant (Centromedia parryi ssp Australis) a California Native Plant Society 1 b 1 species (seriously endangered in California) also exists at the site However the Southern tarplant exists in scattered areas on the site A focused survey documented the presence of 42 individuals distributed in 6 locations The Commissions staff ecologist in a memo dated 12/19/06 (see exhibit N) concludes that neither the seasonal gnatcatcher foraging habitat nor the Southern tarplant on the subject site meet the Coastal Act definition of ESHA Nevertheless regarding gnatcatcher habitat on-site the staff ecologists memo states it is worth noting that the areas of marginal habitat where gnatcatchers have been observed Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 45 are not proposed for development " Regarding the Southern tarplant the memo states In contrast to the habitats on the Bolsa Chica mesa, the scattered areas containing southern tarplant on the Parkside property do not appear to be significant habitat for this species and it is my opinion that these areas do not meet the definition of ESHA under the Coastal Act In any case, if the amendment is modified as suggested the gnatcatcher s habitat and the southern tarplant on site will be retained within the Open Space- Conservation designation The land use designations within the ESHA must be limited to the designation that allows only those uses dependent upon the ESHA In addition the land use designation within the buffer zone must be the designation that allows only those uses compatible with the continuance of the ESHA, and that will not degrade the ESHA Furthermore it is important to assure the continuance of the raptor community by reserving adequate foraging area In fact, the California Department of Fish and Game (CDFG) provided statements to this effect in a letter to the City dated June 15, 1998 commenting on the Draft Environmental impact Report for the Parkside project (see Exhibit 777) in that letter CDFG states that If [a]gricultural areas grasslands and wetlands are of seasonal importance to several species of raptors in Orange County by providing important if not vital staging and wintering habitat These habitats also provide foraging areas for resident breeding raptors " CDFG goes on the express concern about the loss of raptor foraging areas within the project site and vicinity and the impacts such loss may have on the adjacent Bolsa Chica Ecological Reserve However CDFG didn't suggest any specific mitigation for this loss in this letter The wetland areas, their buffers as well as the ESHA buffers wrll provide some raptor foragmg area r n ^^�` -am r^C^ onan ,.. War= 4h•e_ ihe b er es-o eet edoc. 0joel/mean inn^ems /�^M.+e+sw e.+4•e.n n+L fin .++•4•ev+�o she, line. ls ^�� ~�~•`�` ^`r^n`^ ^ As proposed the LUP amendment would not preserve all ESHA areas or provide required buffers and thus is not consistent with Section 30240 of the Coastal Act In addition because the proposed land use designations within and adjacent to ESHA do not limit the uses to those consistent with Section 30240 of the Coastal Act the proposed LUPA is inconsistent with this Coastal Act requirement to protect ESHA Therefore the amendment must be denied as proposed However if the proposed amendment were modified to land use designate all ESHA and necessary ^— n buffer area Open Space-Conservation as depicted on _ 4th revised exhibit NN the amendment would be consistent with Section 30240 of the Coastal Act The above referenced exhibit depicts all areas on site that are recommended for designation as Open Space-Conservation (OS-C) The recommended OSC area encompasses all known wetland areas on site and necessary buffer n area all ESHA on site and the required buffers By retaining adequate area on site as OS-C a Residential designation on the remainder of the site could be found compatible with continuance of the ESHA Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 46 ■rl.sl...+ -.....sr., ne:fillad w—fland =Rldod nr messeerael Miff r nne ....srro..s..... ..fie eaaeanLet•• .,-.s.rr..I sr....sw.....s r. .r.s...,.. /,ter..ro...3"al n'ti Wild be .,r...,r...s., A.. A/TC la. _ __-rs rnr.*ror E rnro.rnro a ron Tho . hollw..r.unsar hnh.sg4.e n..l..l Inamn.00 ih nnrf 6 r It should be noted that construction of a flood protection levee within the ESHA buffer provided it is the least environmentally damaging alternative, would not significantly degrade the ESHA Alternatives that minimize encroachment into buffer area are preferred According to the related coastal development permit application for the subject site and the project proponent the type of flood protection levee to be constructed would be a vegetated flood protection feature (VFPF), essentially a vegetated earthen berm with an internal sheet pile wall The VFPF would not be expected to degrade the ESHA because 1)there would only be temporary construction-related impacts 2)once constructed the VFPF would be planted thus providing habitat and, 3) the VFPF would not require maintenance once constructed thus intrusions into the ESHA buffer due to the VFPF would be limited only to those necessary dunng construction For these reasons locating a flood protection levee such as the vegetated flood protection levee described above within the ESHA buffer would be consistent with Section 30240 of the Coastal Act regarding protection of ESHA The actual design and construction of the flood protection levee would depend on its location In addition to land use designating all ESHA area and necessary buffer and mitigation areas Open Space-Conservation additional measures must be incorporated into the LUP amendment for the subject site to assure that future development does not adversely impact the ESHA For example fuel modification requirements necessary to protect future development from fire hazard must be addressed to assure habitat values within the ESHA and required buffer areas are not adversely affected In addition, if no restrictions were placed on landscaping throughout the site, invasive plants within the residential areas could invade the ESHA areas potentially displacing the ESHA plants In addition, pets from the residential development if unrestricted may enter the ESHA area causing disruption As proposed the LUP amendment does not include any site development restrictions intended to eliminate the site developments potential disruptions to the ESHA inconsistent with Section 30240 of the Coastal Act However if modified to include a prohibition on invasive plants throughout the site and a requirement for a domestic animal management plan and fencing as part of the site specific LUP language the amendment can be found consistent with Section 30240 of the Coastal Act Specific suggested modifications to accomplish this are necessary to find the proposed amendment consistent with the Coastal Act Therefore the Commission finds that only as modified can the proposed amendment be found to be consistent with Section 30240 of the Coastal Act Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 47 4 Density As proposed the amendment would allow a density of up to 7 dwelling units per acre on approximately 38 acres of the 50 acre site which would yield a maximum of 266 units on the area proposed to be designated residential However the related coastal development permit application contemplates just 170 detached single family homes on relatively large lots The City has proposed a residential land use designation of RL (Residential Low maximum of 7 units per net acre) However the City s certified LUP includes a residential land use designation of RM (Residential Medium from 7 to a maximum of 15 units per net acre) The Commission's suggested modifications necessary to protect coastal resources would reduce the allowable development footprint from the proposed approximately 38 acres to approximately 26 5 acres If developed at the maximum allowed under RL, a total of 119 units would be the maximum number possible This would still provide a viable use of the site However density consistent with the RM designation would also be acceptable within the allowable development footprint If the RM designation were applied to the site the maximum total number of units possible would be 255 units significantly more than the number currently contemplated by the property owner s development plan Although 255 units are not guaranteed under the RM designation the ability to establish more units under RM leaves the property owner with greater flexibility in determining the best use of its property It is worth noting that although the project site abuts a low density single family detached residential development to the north (along Kenilworth Drive and Greenleaf Avenue) there are also higher density multi family residential developments adjacent to and nearby the project site The previously described Cabo del Mar condominium complex is adjacent to the subject site Immediately to the north and west of Cabo del Mar are additional multi family residential developments Thus developing at a higher density at the subject site would not be out of the scale or character of the surrounding development In addition, Section 30250 of the Coastal Act encourages residential development to be concentrated in areas able to accommodate it The higher residential density allowed under the RM designation would allow development at the site to be concentrated in the northeast portion of the site consistent with this Coastal Act requirement Thus a modification is suggested which would allow the City at the time it considers accepting the suggested modifications recommended herein to apply either the RL or the RM designation 5 Water Qualilty Section 30230 of the Coastal Act requires that marine resources be maintained, enhanced and where feasible, restored Section 30231 of the Coastal Act requires that the biological productivity and quality of coastal waters be protected The City's certified LUP includes policies that reflect the requirements of 30230 and 30231 of the Coastal Act Development has the potential to adversely impact coastal water quality through the Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 48 removal of native vegetation increase of impervious surfaces increase of runoff erosion and sedimentation introduction of pollutants such as petroleum sediments metals cleaning products pesticides and other pollutant sources The 50 acre protect site is currently undeveloped with the exception of farming activities Under existing conditions no runoff leaves the site during most rainfall events However installation of impervious surfaces and activities associated with residential development and related hardscape represent a potentially significant impact to water quality downstream of the project which include the Inner and Outer Bolsa Bay, Muted Tidal Pocket wetlands Huntington Harbour, and Anaheim Bay Wildlife Refuge These downstream areas are likely to suffer increases in water quality impairment when site development produces greater volumes and velocities of runoff as well as introducing increased pollutant loads It is important that LUP language for the subject site clearly address potential adverse impacts arising due to post development runoff into the channel and significant water bodies downstream This is especially true because little or no runoff currently leaves the site during most rainfall events However the proposed amendment does not include such language Without such language the LUP amendment is not consistent with the water quality policies of the Coastal Act The subject site represents an excellent opportunity to incorporate a natural treatment system such as a wetland detention system There are multiple benefits from natural treatment systems such as pollutant removal groundwater recharge habitat creation and aesthetics Furthermore maintenance needs are typically more apparent and less frequent with natural/vegetative treatment systems and thus are more likely to remain effective than mechanical systems such as storm drain inserts and the like which can become clogged and otherwise suffer mechanical difficulties If mechanical treatment control BMPs are not continually maintained they will cease to be effective and consequently water quality protection would not be maximized Incorporating a natural treatment system such as wetland detention pond system is feasible at the site The site is an appropriate candidate for a natural treatment system because it is a large site unconstrained by existing development limited lot size or limited by topography There is plenty of space on the site to accommodate a wetland detention or similar type system while still allowing a reasonable development footprint Moreover because little or no drainage currently leaves the site it is important that development of the site not result in creation of new adverse water quality impacts such as would result from increased runoff leaving the site In order to achieve the goal of not creating new adverse water quality impacts all dry weather flow would need to be retained on site to the maximum extent practicable The best way to accomplish retention of dry weather flow on site typically is some type of natural treatment system Furthermore, in order to protect water quality year round it is appropriate to impose a standard that any runoff that leaves the site must meet The generally accepted standard for stormwater runoff is a requirement to treat at least the 85t' percentile storm event with at least a 24-hour Exhibit A - Resolution No 2008-31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 49 detention time If dry weather runoff cannot be retained on site it should be treated (e g detained for at least 48 hours and where practicable for seven days in a natural treatment system) The current LUP amendment does not require these site-specific water quality measures and standards Therefore there is no assurance that water quality will be protected Consequently the amendment is not consistent with the water quality policies of the Coastal Act and must be denied In addition, although the existing LUP includes policies that require projects to incorporate water quality BMPs none of the existing LUP policies express a preference for types of treatment control BMPs The preferred option for treatment control BMPs is first a natural treatment system (e g bio-swales vegetative buffers constructed or artificial wetlands) then second a combination of natural treatment and mechanical systems or BMPs and last use of mechanical treatment systems or BMPs alone (e g site-specific water quality treatment plants storm drain filters and inserts) In addition application of appropriate site design and source control BMPs reduces the amount of runoff that would need treatment control measures Thus site design and source control BMPs should be considered first in order to adequately size any necessary treatment control BMPs In addition the LUP does not contain any policy citing a hierarchy of preference for different types of BMPs Without such an LUP policy there is no guarantee they will be incorporated into projects when it is feasible to do so Natural treatment systems, for the reasons described above provide better water quality protection, among other benefits Consequently the amendment is not consistent with the water quality policies of the Coastal Act and must be denied However, if the amendment is modified as suggested to include this in LUP policy language it would be consistent with the water quality policies of the Coastal Act The use of permeable materials for paved areas in new developments is a site design and source control measure which can reduce the rate and volume of the first flush of stormwater runoff and can help to minimize or eliminate dry weather flow The proposed amendment does not include any discussion on the benefits of incorporating permeable materials into the design of future projects However if the amendment is modified as suggested to include this in LUP policy language, it would be consistent with the water quality policies of the Coastal Act In addition as proposed the amendment does not include any requirements to minimize or eliminate dry weather flows through the use of site design and source control BMPs Consequently adverse water quality impacts due to dry weather flows are not minimized However if the amendment were modified as suggested to incorporate policy language addressing this measure the amendment would be consistent with the water quality policies of the Coastal Act The current City of Huntington Beach LCP Policy 6 1 6 (paragraph 4) states that, the City shall continue implementation of the Municipal Non-Point [sic] Source National Pollution Discharge Elimination System (NPDES) standards program which is required by an order Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 50 of the Santa Ana Regional Water Quality Control Board The policy also states that the City will continue to require a Water Quality Management Plan for all applicable new development and redevelopment in the Coastal Zone The Commission finds this policy should be modified to include the correct name and date of the permit and to incorporate this permit by reference into the Local Coastal Program Updates to the NPDES permit (such as the update expected in 2007) should be submitted to the Executive Director for an LCP amendment While the Commission recognizes that the City s existing policies address water quality protection and improvement within the City it also recognizes that there are additional more specific steps that could be taken to further protect restore and/or enhance the water quality of downstream sites (EGGW flood control channel Bolsa Chica wetlands restoration area Huntington Harbour, and Anaheim Bay Wildlife Refuge)that will be effected by runoff generated by development of the site The proposed amendment could not be found consistent with Sections 30230 and 30231 of the Coastal Act if feasible measures known to positively impact water quality were not included in language specific to the subject site as part of the current amendment proposal The Commission s standard of review which requires the preservation protection and enhancement of coastal resources including water quality necessitates that the additional measures outlined above be imposed Thus the Commission finds that only if modified as suggested is the proposed amendment consistent with Sections 30230 and 30231 of the Coastal Act regarding water quality 6 Public Access and Recreation Section 30210 of the Coastal Act states In carrying out the requirement of Section 4 of Article X of the California Constitution maximum access which shall be conspicuously posted, and recreational opportunities shall be provided for all the people consistent with public safety needs and the need to protect public nghts rights of pnvate property owners and natural resource areas from overuse Section 30252 of the Coastal Act states in pertinent part The location and amount of new development should maintain and enhance public access to the coast by (3) providing nonautomobile circulation within the development, (4) providing adequate parking facilities or providing substitute means of serving the development with public transportation, (6) assunng that the recreational needs of new residents will not overload nearby coastal recreation areas by correlating the amount of development with local park acquisition and development plans with the provision of onsite recreational facilities to serve the new development Coastal Act Section 30212 5 states Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 51 Wherever appropriate and feasible, public facilities including parking areas or facilities shall be distributed throughout an area so as to mitigate against impacts social and otherwise, of overcrowding or overuse by the public in any single area Coastal Act Section 30213 states in pertinent part Lower cost visitor and recreational facilities shall be protected encouraged and, where feasible, provided Developments providing public recreational opportunities are preferred Coastal Act Section 30223 states Upland areas necessary to support coastal recreational uses shall be reserved for such uses, where feasible In addition the City s certified LUP contains the following policies regarding public access Provide coastal resource access opportunities for the public where feasible and in accordance with the Cahfomia Coastal Act requirements Encourage the use of City and State beaches as a destination point for bicyclists pedestrians shuttle systems and other non-auto onented transport Encourage the utilization of easements and/or rights-of-way along flood control channels public utilities railroads and streets wherever practical for the use of bicycles and/or pedestrian (emphasis added) Maintain existing pedestrian facilities and require new development to provide pedestrian walkways and bicycle routes between developments Link bicycle routes with pedestrian trails and bus routes to promote an interconnected system Develop a riding and hiking trail network and support facilities that provide linkages within the Coastal Zone where feasible and appropriate Balance the supply of parking with the demand for parking Maintain an adequate supply of parking that supports the present level of demand and allow for the expected increase in private transportation use Maintain and enhance where feasible existing shoreline and coastal resource access sites Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 52 Promote and provide, where feasible additional public access including handicap access to the shoreline and other coastal resources Promote public access to coastal wetlands for limited nature study passive recreation and other low intensity uses that are compatible with the sensitive nature of these areas Maintain and enhance where necessary the coastal resource signing program that identifies public access points bikeways recreation areas and vista points throughout the Coastal Zone Preserve protect and enhance where feasible existing public recreation sites in the Coastal Zone Ensure that new development and uses provide a variety of recreational facilities for a range of income groups including low cost facilities and activities Encourage where feasible facilities programs and services that increase and enhance public recreational opportunities in the Coastal Zone Promote and support the implementation of the proposed Wintersburg Channel Class l Bikeway The provision of public access in new development proposals is one of the main tenets of the Coastal Act This emphasis has been carried over into the City s certified LUP In certifying the LUP the Commission recognized via the approved LUP policies the importance of including measures such as providing and enhancing public access to the sea and other coastal resources adequate parking and alternate means of transportation low cost recreational uses and public access signage, with new development The 50-acre site is located in close proximity to the Bolsa Chica wetlands restoration area (see exhibit BBBB) The Bolsa Chica Wetlands at approximately 1 000 acres is the largest remaining wetland in Southern California Because it is tidally influenced the Bolsa Chica wetlands constitute sea according to the Coastal Act definition (Section 30115) Because there is no public road between the subject site and the Bolsa Chica wetlands the site is between the sea and the first public road As such the area is given special significance with regard to the requirement for the provision of public access Given the prominence of the adjacent Bolsa Chica wetlands appropriate public access and passive recreational opportunities must be provided and conspicuously posted Further, the Coastal Act gives priority to land uses that provide opportunities for enhanced public access public recreation and lower cost visitor recreational uses Beyond the Bolsa Chica wetlands restoration area is the Pacific Ocean and its sandy public beaches Thus public access across the subject site to the Bolsa Chica area Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 53 would in turn facilitate public access via alternate means of transportation (bicycle and pedestrian) to the ocean beach beyond It is also worth noting that the visitor serving uses available within the Bolsa Chica reserve (such as walking nature study or bird watching) are served by only two small parking areas One located at the Interpretive Center at the corner of Warner Avenue and Pacific Coast Highway and the second at about the midway point along the reserves Pacific Coast Highway frontage There is no public parking available along Pacific Coast Highway adjacent to the reserve Thus the benefits of providing alternate forms of transportation to access the area such as biking or hiking from inland areas, are substantially increased The lack of adequate parking to serve the reserve area is also a limiting factor in maximizing public use of the reserve s amenities Assuring that any future streets within the subject site are public and provide public parking is critical to maximizing public access in the area It is also important to note that the Brightwater residential development approved by the Coastal Commission under Coastal Development Permit No 5-05-020 (Brightwater), is located less than one half mile west of the subject site That development was originally proposed as a private guard gated community However as approved by the Commission the development will be open to general public vehicular and pedestrian access also allowing public parking on all subdivision streets Also as approved by the Commission the development will include a public trail along the bluff edge of the development with public paseos and pocket parks throughout (see exhibit BBBB) The Commissions approval also required public access signage In approving the Brightwater development the Commission found The provision of public access in new development proposals is one of the main tenants [sic]of the Coastal Act especially in conjunction with new development located between the sea and the first public road such as the subject project The 225-acre Bolsa Chica Mesa is located between the first public road and the mean high tide of the sea At roughly 50 ft above mean sea level, spectacular views of the wetlands and the associated wildlife and uninterrupted views of the Bolsa Chica State Beach and Pacific Ocean are available from the upper bench of the Bolsa Chica Mesa Santa Catalina Island is also often visible from the project site The Bolsa Chica Wetlands at approximately 9 000 acres is the largest remaining wetland in Southern California Following the 1997 State acquisition of most of the remaining wetlands that were under private ownership a comprehensive Bolsa Chica wetlands restoration effort is now underway Given the prominence of the adjacent Bolsa Chica wetlands appropnate public access and passive recreational opportunities must be provided and conspicuously posted Further, the Coastal Act gives pnonty to land uses that provide opportunities for enhanced public access public recreation and lower cost visitor recreational uses A trail connection between the Brightwater trail system and the East Garden Grove Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 54 Wintersburg Flood Control Channel levee trail is also anticipated in the future and shown on the approved public access plan for the Brightwater development The public access trails of the approved Brightwater protect link to the trail system along the Bolsa Chica wetlands and beyond These trails in addition to providing recreational opportunities also provide significant opportunities for nature study and views of the wetlands and ocean beyond The Bolsa Chica Ecological Reserve public trail system is a public access resource of regional significance Members of the general public come from throughout the entire County of Orange and beyond to bird watch hike or bike the trail system As the largest remaining wetland in Southern California the public trail system leading to and within the Bolsa Chica area constitutes a resource of statewide significance Further Bolsa Chica State Beach located across Pacific Coast Highway from the Bolsa Chica wetland area can be accessed via this trail system The proposed LUP amendment contains no language to assure public access will be provided throughout the site in conjunction with future site development Although the certified LUP includes (as listed above) strong public access policies the proposed LUP amendment does not include any public access language specifically addressing public access needs appropriate for the site taking into consideration the recreational needs of both the new residents and other users of the adjacent public recreational resources Specifically identifying the necessity of these provisions in the LUP is especially important at the subject site due to its unique position to link with and expand the very significant public trail systems within the Bolsa Chica Ecological Reserve the Brightwater development and the public beaches beyond In order to assure that access is maximized at the time of future site development specific language addressing access in the site specific section of the LUP is necessary As proposed no such language is included in the LUP amendment Some specific methods for assuring the provision of public access at the subject site are described further below a) Bicycle Path The subject site is immediately adjacent to the north levee of the East Garden Grove Wintersburg Flood Control Channel (EGGWFCC) The County s Commuter Bikeways Strategic Plan (the regional bikeways plan for Orange County) identifies a Class I bikeway along the flood control channel This is also reflected in the City s certified LUP Figure C- 14 Trails and Bikeways Map in the certified LUP identifies a proposed bikeway along the EGGWFCC adjacent to the site A letter from the County s Public Facilities & Resources Department dated January 8 1998 (exhibit J) states `Regarding the City s proposal to continue the Class I bikeway northerly along the Wintersburg Channel to Graham Street The County supports this It would provide an excellent bikeway connection between the City's road system and the off-road wetlands perimeter route (We suggest referring to this entire route — between Graham Street and PCH —as the Bolsa Chica Bikeway) In addition a letter from the County s Public Facilities & Resources Department dated Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 55 February 13 1998 (exhibit J) commenting on a proposed tentative tract map for the subject site states A bicycle trail along the CO5 [East Garden Grove-Wintersburg Channel] north levee maintenance road will be required A bike route in this area would provide substantial public access benefits It is encouraged in existing LUP policies It would provide a connection between existing inland routes and the Bolsa Chica area and is expected to be extended in the future along the remainder of the EGGWFCC levee adjacent to the Bolsa Chica Restoration area When such an extension occurs (as is anticipated in the City s LUP and by the County Public Facilities & Resources Department) the bike route would eventually link to the coast An off road bicycle path already exists along the entire length of the City s ocean fronting beach A bike path at the subject site and along the remainder of the EGGWFCC would provide a new connection from inland bicycle paths to this coastal path Not only would such a bicycle path provide substantial public recreational benefits but it would also improve public access opportunities by providing alternate means of transportation to get to the coast and to the trails within the Bolsa Chica area The City and the County have both indicated that a bicycle path in this location is desirable and appropriate However, the proposed LUP amendment does not include any language specific to this site assuring that implementation of the bicycle trail will occur prior to or concurrent with site development Current LUP policy merely states promote and encourage the bicycle path s implementation Therefore there is no assurance that it will be built in a timely manner or perhaps that it will be built at all Thus the amendment as proposed cannot be found to be consistent with Sections 30210 30213 and 30252 of the Coastal Act regarding maximizing public access b) Public Streets and Parking In addition if the residential development that the proposed land use designation would allow were to be a private and/or gated development public access would not be maximized or enhanced inconsistent with Sections 30210 30212 5, 30223 and 30252 of the Coastal Act All public entry controls such as gates gate/guard houses or other guarded entry signage that discourages access and any other restrictions on the general public s entry by and use of any streets or parking areas (e g private streets, preferential parking districts resident-only parking periods/permits etc ) would constrain the publics ability to access the area proposed as public park as well as the public's ability to access the public bike path along the EGGWFCC levee In turn public access to the Bolsa Chica area and ocean beyond would also not be provided As stated previously the site is between the first public road and the sea (in this case the Bolsa Chica wetlands) The provision of public parking within the area would allow visitors to begin a bike ride or walk along the levee through the Bolsa Chica area and on to the ocean front Public streets and public parking within the residential area would not only support public recreational use in the vicinity of the subject site but also allow visitors from beyond the immediate vicinity to use the park area and public recreational and open space resources in the Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 56 Bolsa Chica area In addition ungated public streets would facilitate the use of interior public trails within the development Interior trails would further maximize support and enhance public access opportunities Public trails could be established leading from Graham Street to the outer edge of the area recommended to be designated Open Space conservation and from within the development back onto the bike way along the north levee of the EGGWFCC Establishing such trails would provide an excellent public access experience consistent with the requirements of Sections 30210 30212 5 30213 30223 and 30252 to maximize and enhance lower cost public recreational and public access opportunity with new development and assure adequate support facilities are provided The provision of interior trails within a future development at the site would be especially consistent with Section 30252's requirement that non-automobile circulation be provided within the new development In order to assure that this aspect of public access (the provision of public parking within an ungated residential area with public streets and interior trails) is provided at the time the site is developed language reflecting this must be incorporated into the LUP However, no such language is proposed as part of the LUP amendment Thus the amendment cannot be found to be consistent with Sections 30210 30212 5 30213 30223 and 30252 of the Coastal Act regarding maximizing and enhancing public access c) Provision of Recreation and Public Access Benefits Residential development of the subject site that would occur pursuant to the proposed amendment would have adverse impacts on public access and recreation unless the above described measures are incorporated into the design of a future protect In order to assure maximum public benefit the public recreation and access measures would need to be provided in a timely manner However nothing in the proposed amendment or in the City s LUP currently requires that lower priority developments (such as residential) be phased to assure the provision of those uses that are a higher priority under the Coastal Act (such as public trails parks and parking) occur prior to or concurrent with the lower priority development Without such a phasing requirement it is difficult to assure that necessary public benefits would occur in a timely manner, or possibly even at all Thus as proposed the amendment is inconsistent with Sections 30210 30212 5 30213 and 30252 of the Coastal Act regarding maximizing and enhancing public recreation and access Coastal Act Section 30210 requires that public coastal access be maximized Coastal Act Section 30252 requires that public access be maintained and enhanced through the provision of nonautomobile circulation within the development adequate parking and adequate recreational opportunities These requirements are carried over and re- emphasized in the City s Land Use Plan public access policies As proposed the LUP amendment would allow significant residential development to occur with no corresponding requirement for public access specific to the site The site is located between the sea and the first public road Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 57 Although a portion of the site is proposed to be designated park, nothing in the proposed amendment would assure that it would be available to the general public via public streets and trails The certified LUP identifies a Class I bicycle path along the flood control channel levee at the subject site However, the proposed amendment makes no reference to the suitability of a bicycle path at the subject site If a future residential development at the site included gates or private streets a significant public access opportunity would be lost in addition public parking in the area would increase public access opportunities to public resources including the park area the bicycle path the public trails of the Brightwater development and to the Bolsa Chica area beyond as well as ultimately to the coast However there is nothing in the LUP amendment that would require the residential streets to be open and available to the public Nor is there any requirement for interior trail connections between Graham Street any future public park areas and the bicycle path to areas within the development and beyond In addition, nothing in the proposed amendment or in the City s LUP requires that lower priority developments (such as residential) be phased to assure provision of associated recreation and public access (such as public trails parks, and parking) occur prior to or concurrent with the lower priority development Without such a phasing requirement it is difficult to assure that Coastal Act high priority uses would occur in a timely manner or possibly even at all However the proposed amendment could be modified such that site specific language in the LUP include reference to the Class I bicycle path along the flood control channel levee interior trail connections public parking and access on residential streets This would allow direct public access throughout the site, the public trails within the Brightwater development and the Bolsa Chica area and to the beach beyond Furthermore the proposed amendment could be modified to incorporate a policy requiring phasing of recreation and public access uses prior to or concurrent with lower priority uses Modifications to accomplish these goals would bring the proposed amendment into conformity with Coastal Act Sections 30210 30212 5, 30213 30223 and 30252 which require that public access and recreation be maximized and enhanced Therefore, the Commission finds that only if modified as suggested is the proposed amendment consistent with Sections 30210 and 30252 of the Coastal Act 7 Visual Resources Section 30251 of the Coastal Act requires that the scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance The subject site offers the opportunity to provide public views from the site to the Bolsa Chica wetlands area and toward the ocean beyond The VFPS would provide an excellent opportunity to provide public views to and along the coast and scenic areas as required by Section 30251 However the proposed LUP amendment does not include any discussion regarding provision of public view points in association with development of the site Future residential development of the site is expected to include a wall separating residential development adjacent to the flood control levee from the anticipated public Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 58 bicycle path along the top of the levee If such a wall is proposed in the future it could create adverse impacts to public views along the bicycle path However adverse impacts could be minimized by incorporating measures such as open fencing/wall landscaped screening use of an undulating or off-set wall footprint or decorative wall features (such as artistic imprints etc ) or a combination of these measures In addition any such wall should be located upon the private property for which it is intended to provide privacy The proposed amendment does not provide language to address site specific visual impacts and does not assure that potential visual resources will be protected at the time the site is proposed for development Therefore the proposed amendment is inconsistent with Section 30252 of the Coastal Act regarding protection of visual resources within the coastal zone and must be denied However if the amendment were modified to incorporate measures specific to the site that protect and enhance public views, the amendment would be consistent with Section 30252 of the Coastal Act regarding protection of public views 8 Archaeological Resources Coastal Act Section 30244 requires that any impacts to significant archaeological resources be reasonably mitigated The City s certified LUP includes policies which require among other things identification of resources and mitigation of any impacts Significant archaeological resources are known to exist in the project vicinity and may occur on the subject site However the proposed LUP amendment does not include a specific requirement to avoid and/or mitigate archaeological impacts even though the site is known to be in a potentially significant archaeological area Without a cross reference in the site specific area discussion of the proposed LUP amendment to the archaeological policies in the LUP there is no assurance that the potential for archaeological resources to occur on the site will be recognized in conjunction with future development proposals If the potential for archaeological resources at the site is not recognized in the proposed LUP amendment for the site application of the policies cited above may be overlooked The proposed LUP amendment which specifically addresses the subject site provides the appropriate opportunity to make clear that archaeological resources may be present on this site and therefore these specific policies must be applied If the amendment were modified to include a cross reference to the archaeological policies of the LUP adverse impacts may be avoided and reasonable mitigation for unavoidable impacts could be implemented in conjunction with future site development, consistent with Section 30244 of the Coastal Act Therefore the Commission finds that only if modified as suggested is the proposed amendment consistent with Section 30244 of the Coastal Act which requires that reasonable mitigation be required for adverse impacts to archaeological resources Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 59 9 Hazards Coastal Act Section 30253 state in pertinent part New Development shall (2) Minimize risks to life and property in areas of high geologic flood, and fire hazard (3) Assure stability and structural integnty and neither create nor contribute significantly to erosion geologic instability or destruction of the site or surrounding area or in any way require the construction of protective devices that would substantially alter natural landforms along bluffs and cliffs The proposed LUP amendment would designate much of the subject site for residential development land use The Commission s staff geologist has reviewed a great deal of technical information submitted in conjunction with the proposed LUP amendment and related coastal development permit application Potential geotechnical and hydrological issues are identified in the staff geologists memo The staff geologists memo is attached as exhibit I and is hereby incorporated by reference as if fully set forth herein Residential development of the site carries with it certain risks Although information submitted relative to the related coastal development permit application indicates there are feasible mitigation measures available to minimize the level of risk involved with site development there is no specific requirement in the proposed amendment to assure that measures necessary for risk reduction would be incorporated into future site development Without such requirements in the amendment there is no assurance that risks will be minimized as required by Section 30253 of the Coastal Act However if the amendment were modified to include such a requirement it would be consistent with Section 30253 of the Coastal Act The subject site and much of the surrounding area are susceptible to tidal flooding Tidal flooding could occur when extreme high tides occur concurrently with storm surge events According to some studies the existing tidal flooding risk was increased with the opening of the ocean inlet into the Bolsa Chica Restoration area Regardless of the cause of the flooding high tides and storm surge will create tidal flooding The worst case scenario would occur when high tide and storm surge occurs during failure of the levees of the lower reaches of the East Garden Grove Wintersburg Flood Control Channel (EGGWFCC) (which is possible as the levees are not FEMA certified) Under any of these scenarios up to 170 acres of inland developed area would be flooded Consequently contemplation of any development of the subject site must address this flooding issue With or without development of the subject site the inland 170 acres of existing development must be protected from flood hazard The path the tidal flooding would follow unavoidably crosses the subject site The only way to adequately insure protection of the s Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 60 inland 170 acres of existing development is to install a flood protection levee (a k a VFPF) on the subject site or to the southwest of the subject site within the Bolsa Chica Pocket Wetlands" between the EGGWFCC and the Bolsa Chica mesa Protection of the inland 170 acres would also protect the 50 acre subject site from flooding The property owner has indicated in documents submitted with the related coastal development permit application that a vegetated flood protection feature (VFPF) is proposed The EGGWFCC is approximately 11 feet above sea level and the bluff at the western site boundary raises some 40 feet above sea level A flood protection levee at this site could effectively capture tidal floods if it is constructed to an elevation above the expected flood flow The existing EGGWFCC levee in the area adjacent to the subject site is expected to be reconstructed to meet FEMA certification standards and would have an elevation of 11 feet above sea level (the existing levee's elevation is also 11 feet above sea level) If a flood protection levee were constructed to the same elevation flood waters would be prevented from flooding the subject site as well as the additional 170 inland acres With or without development of the proposed site some form of flood protection is necessary to minimize risks to life and property in areas of high flood hazard and to assure stability and structural integrity and not contribute significantly to destruction of the surrounding area As it happens the subject site provides the optimum location for the flood protection levee necessary to minimize risk to life and property in the 170 developed acres inland of the subject site Construction of some type of flood protection levee would be necessary with development of the subject site However, such a feature would be necessary even without site development The flood protection levee expected to be constructed as an earthen levee with an internal sheet pile wall would serve an important function Without construction of the flood protection levee even with reconstruction of the north levee of the EGGWFCC along the subject site flooding of 170 inland acres (including the subject site)would result during either a tidal surge or a levee failure downstream of the subject site The 170 acre inland area is developed with approximately 800 homes Floodwater depth in some homes it is estimated would be at least two feet However construction of a flood protection levee on the site would be adequate to assure structural integrity and neither create nor contribute significantly to erosion geologic instability or destruction of the site or surrounding area in addition construction of the flood protection levee would minimize risks to life and property from flood hazard In order for the flood protection levee to function effectively it would have to be placed within the site s necessary buffer areas However as described previously, a flood protection levee in the ESHA or wetland buffer area may be an allowable use within a buffer provided it is the least environmentally damaging feasible alternative Furthermore the construction of the flood protection levee may eliminate the need for the flood control levee downstream of the flood wall If the flood control levee downstream of the flood wall is not reconstructed, potential impacts to wetlands in the CP wetland area can be avoided The appropriateness of reconstructing the downstream levee area will be Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 61 considered when the related coastal development permit is processed It should be noted that an emergency coastal development permit was issued to the County of Orange to install sheet pile within the north levee of the flood control channel adjacent to the subject site However the County has indicated it is willing to consider alternatives that limit changes to the levee downstream if such an alternative is deemed feasible and environmentally desirable Construction methods proposed by the County to install the sheetpiles will not involve any wetland fill Impacts to coastal resources may occur which will be addressed in the follow-up permit The question of whether the bluff along the western edge of the property should be considered a "coastal bluff has been raised The Commissions staff geologist has evaluated the bluffs status The staff geologists evaluation is contained in a memorandum attached as exhibit P The subject bluff was carved by the ancestral Santa Ana river as it meandered across the Bolsa Chica lowlands Assertions have been made that the bluff was subject to marine erosion within the past 200 years based on an 1873 T- sheet that shows tidal channels adjacent to the toe of the bluff The staff geologist's response to these assertions is I concur that there is strong evidence that there were tidal wetlands in the Bolsa Chica lowlands prior to dike construction in the early twentieth century but tidal wetlands generally are not the site of extensive marine erosion Indeed they are commonly depositional not erosional and serve as an efficient buffer from marine erosion The staff geologist concludes In summary I believe that the bluff at the Shea Home property is best described as a river bluff and is not a coastal bluff in a genetic or geomorphic sense Thus, the Commission finds that the bluff on the subject site is not a coastal bluff For the reasons described above, the Commission finds that only if modified can the proposed amendment be found to be consistent with Section 30253 of the Coastal Act which requires that risks to life and property be minimized and that development assure stability and structural integrity and neither create nor contribute significantly to erosion, geologic instability or destruction of the site or surrounding area 10 Priority of Use Section 30222 of the Coastal Act states The use of pnvate lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have prionty over private residential general industrial or general commercial development, but not over agnculture or coastal-dependent industry The LUP amendment does not propose to designate any portion of the site visitor serving commercial Generally in the City of Huntington Beach the areas recognized as best for visitor serving commercial development are the areas along Pacific Coast Highway, and adjacent to and inland of the pier and areas within and around Huntington Harbour The subject site is surrounded on three sides by existing single family residences and does not Exhibit A - Resolution No 2008 31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 62 lend itself to visitor serving commercial development Moreover the LUP amendment as proposed and as amended will provide a Class I bicycle path a public view area public park area and interior trails as well as public parking along the residential streets Such uses constitute lower cost visitor serving recreational uses As modified the recreational and public access provisions will be constructed prior to or concurrent with the residential uses Therefore the Commission finds that the proposed LUP amendment is consistent with Sections 30213 and 30222 of the Coastal Act which requires visitor serving commercial recreational facilities have priority over residential development and encourages provision of lower cost public recreational facilities 11 Conclusion As proposed the Land Use Plan amendment contains significant deficiencies with regard to consistency with the Coastal Act As proposed the amendment cannot be found consistent with Sections 30210 and 30252 regarding maximizing and enhancing public access 30251 regarding protection of public views 30233 and 30250 regarding wetlands 30240 regarding ESHA 30244 regarding archaeological resources and 30230 and 30231 regarding water quality of the Coastal Act However if the proposed amendment were modified as suggested in Section 11 of this staff report the amendment would be consistent with the Chapter 3 policies of the Coastal Act Therefore, the Commission finds that only if modified is the proposed amendment consistent with the Chapter 3 policies of the Coastal Act IV CALIFORNIA ENVIRONMENTAL QUALITY ACT Section 21080 9 of the California Public Resources Code —within the California Environmental Quality Act (CEQA) - exempts local governments from the requirement of preparing an environmental impact report (EIR) in connection with its activities and approvals necessary for the preparation and adoption of a local coastal program (LCP) instead the CEQA responsibilities are assigned to the Coastal Commission However the Commission s LCP review and approval program has been found by the Resources Agency to be functionally equivalent to the EIR process Thus under Section 21080 5 of CEQA the Commission is relieved of the responsibility to prepare an EIR for each LCP Nevertheless the Commission is required in approving an LCP submittal to find that the LCP does conform with the provisions of CEQA including the requirement in CEQA section 21080 5(d)(2)(A) that the amended #P LUP will not be approved or adopted as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen any significant adverse impact which the activity may have on the environment 14 C C R Sections 13542(a) 13540(f) and 13555(b) The City of Huntington Beach LCP amendment 1-06 consists of an amendment to beffi the Land Use Plan (LUP) onl and the faw and .,,.� ®�a" As outlined in this staff report the LUP amendment is not consistent with the Chapter 3 Exhibit A - Resolution No 2008-31 Adopted Findings (Approval of LUP with Modifications) Huntington Beach LCP Amendment 1-06 (Parkside) Page 63 polices of the Coastal Act regarding public access and recreation wetland ESHA marine resources and land resources as proposed "„d °s^ as ^•d"•„^d ai„ r^„^•t the orages--' "® .,„e.,nd—mo-n-9 . ..tent. 01th tha r_Q ..4^..F... Iry i of tho ,.,,rs. 19-1 ° and Ilea pion =a Madif�+..° However if modified as suggested the amendment will be consistent with the public access and recreation wetland, ESHA marine resource and land resource policies of the Coastal Act Thus the Commission finds that the proposed LUP amendment as modified meets the requirements of and conforms with the Chapter 3 policies of the Coastal Act t�nn^�A• ^d non .+.■ aste .° is in gh with and Ut, thq °ws.rl Therefore the Commission finds that approval of the LUP amendment as modified will not result in significant adverse environmental impacts under the meaning of CEQA Therefore the Commission certifies L=GP LUP amendment request 1-06 if modified as suggested herein HN8 LCPA 1 06 Parkside AdptdF 5 08 my Res No 2008-31 STATE OF CALIFORNIA COUNTY OF ORANGE ) ss CITY OF HUNTINGTON BEACH I JOAN L FLYNN the duly elected qualified City Clerk of the City of Huntington Beach and ex-officio Clerk of the City Council of said City do hereby certify that the whole number of members of the City Council of the City of Huntington Beach is seven that the foregoing resolution was passed and adopted by the affirmative vote of at least a majority of all the members of said City Council at a regular meeting thereof held on June 16, 2008 by the following vote AYES Hansen Bohr Coerper Green Carchio NOES Hardy Cook ABSENT None ABSTAIN None iV CU Clerk and ex-office Jerk of the City Council of the City of Huntington Beach California