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HomeMy WebLinkAbout2025-08-05; Public Access & Open Space Protections near Mountain View Drive (District 1); Murphy, JeffCommunity Services Branch Community Development Department 1635 Faraday Avenue | Carlsbad, CA 92008 | 442-339-2600 t Council Memorandum August 5, 2025 To: Honorable Mayor Blackburn and Members of the City Council From: Jeff Murphy, Community Development Director Via: Re: Sheila Cobian, Assistant City Manager Public Access & Open Space Protections near Mountain View Drive (District 1) The Community Development Department and City Attorney’s Office each received a letter from the Coastal Commission asserting violations of recorded open space and public access easements and a 1998 coastal development permit involving a single-family home and locked gate at 2401 Mountain View Drive. City staff do not agree with all the claims being made by the Coastal Commission. This memorandum summarizes the issues raised by the Coastal Commission and city staff’s response to the allegations. Background The allegations raised in the letters from the Coastal Commission involve two coastal development permits (CDP): CDP 6-83-051 (The Beach HOA) and CDP 97-59 (Levy Residence). The Beach HOA In March 1983 the Coastal Commission issued a CDP for the subdivision of 7.65 acres - located northwest of Ocean Street and Mountain View Drive --- into three parcels. Parcel 1 included the construction of 14 condominium units. As a condition of the CDP, the rest of the site was to remain as open space resulting in the recordation of a public access easement over parcels 2 and 3 and an open space easement over parcel 3. The open space area has been maintained by the city since 2005 when it accepted and recorded the easements. To access the beach for public safety and maintenance purposes, the city enters the property via a locked gate that takes access off Mountain View Drive. Levy Residence The city issued in July 1998 a CDP to Mr. John Levy for the construction of a 2,713 square-foot single family residence and a second dwelling unit on a 1.9-acre lot on the south shore of Buena Vista Lagoon. The property is landlocked (no direct access to a public road) and therefore is accessed via an access driveway over the eastern boundary of parcel 3 to Mountain View Drive (through the previously Memo ID# 2025045 To the members of the: CITY COUNCIL Date: 8-5-25 CA  CC  CM  ACM  DCM (3)  Council Memo – Public Access & Open Space Protections near Mountain View Drive (District 1) August 5, 2025 Page 2 mentioned locked gate). The city’s 1998 approval of the CDP was considered by the Coastal Commission on appeal and upheld, where the commission found no substantial issue with the city’s approval; meaning that the commission did not change or impose any additional conditions to the CDP. The city subsequently issued a building permit in October 1998, and final inspection occurred in December 1999. Mr. Levy continues to own the property. Discussion On May 23, 2025, (Attachment A) and June 24, 2025, (Attachment B), the city received correspondence from the Coastal Commission asserting numerous violations of recorded open space and public access easements as well as several conditions associated with Mr. Levy’s CDP. The Community Development Department (Attachment C) and City Attorney’s Office (Attachment D) each responded to the accusations, respectfully disagreeing with most of the Coastal Commission’s assertions and including substantial evidence supporting city staff’s position. While there are several topics covered in the letters, there are three main issues raised by the Coastal Commission that have also been raised during public comment at recent City Council meetings. Mountain View Drive Gate The Mountain View Drive gate is located on property owned by The Beach HOA and pursuant to Coastal Commission documents, was installed at some point long before the 1983 approval of the 14-unit condominium project and therefore was allowed to remain as a locked gate. When the city approved the CDP for the Levy Residence in 1998, plans were provided indicating that the gate would continue to have a locking mechanism, through electronic means. The city did not impose any conditions addressing the continued use of the locked gate. Although the continued use of the gate was an issue in the Coastal Commission appeal of the city’s CDP --- i.e., Coastal Commission staff recommended that the gate be open to the public --- the Coastal Commission’s final decision on the appeal did not require the gate to be removed or to be opened for public use during certain times of day. Notwithstanding the Coastal Commission’s prior findings and decisions on both CDPs, the Coastal Commission now asserts that the city’s 2005 acceptance of the access easement and open space easement on parcels 2 and 3 caused the Mountain View Drive gate to violate the terms of the easements. The Coastal Commission has not provided any authority for this position, and it is inconsistent with the Coastal Commissions prior findings and decisions on the matter. It is also inconsistent with the Council Memo – Public Access & Open Space Protections near Mountain View Drive (District 1) August 5, 2025 Page 3 language of the easements, which do not require removal or timed opening of the gate upon acceptance of the easements. However, since The Beach HOA owns the property this gate is located on, city staff believe the Coastal Commission, as the permitting authority for this property, is best suited to work out access and any additional terms and conditions allowable under the existing easement. This would align with previous action the Coastal Commission took in 2016 when asked to take the lead on Coastal Act violations by Mr. Levy. City staff are willing to work with the Beach HOA, Mr. Levy and the Coastal Commission to resolve pedestrian beach access concerns. Lagoon Public Access Trail As a condition of the CDP for the Levy Residence, an Irrevocable Offer of Dedication (IOD)1 for a public trail (Lagoon Public Access Trail) needed to be recorded prior to the city’s issuance of a building permit. This proposed trail would ultimately transverse the northwestern portion of Mr. Levy’s property, where it would terminate roughly 3/4 of the way into Mr. Levy’s property. The IOD was recorded, but the city has not yet accepted the offer to dedicate and has correspondingly not officially included the short trail segment (i.e., approximately 300’) as part of the citywide trail system. The Coastal Commission contends that when the City Council adopted the Trails Master Plan in 2019 (distinct from the citywide trail system), it accepted the IOD and is now obligated to improve the trail segment to city standards and make it available to the public. However, the resolution that adopted the Trails Master Plan makes no reference to the IOD in question nor is that resolution the appropriate process/vehicle for acceptance of an IOD under city code. Only the City Council or City Manager (or designee) has the authority to accept an IOD. Moreover, to formalize the acceptance of an easement, the city clerk must record a Certificate of Acceptance. Since neither the City Council nor the City Manager have accepted the Lagoon Public Access Trail IOD and no such acceptance has been recorded, the IOD remains as an unaccepted offer. There is no specified date for when the city will accept the IOD, nor does it have to accept this IOD. The trail segment would provide limited benefit to the public, 1 An irrevocable offer of dedication (IOD) is a formal, recorded promise by a property owner to dedicate land to the public (e.g., road, easement, or park) that cannot be withdrawn. While the IOD is recorded against the property, it is not enforceable or useable by the public until the public agency formally accepts the IOD and assumes liability and responsibility of the easement. Council Memo – Public Access & Open Space Protections near Mountain View Drive (District 1) August 5, 2025 Page 4 particularly so long as the lagoon mouth remains heavily impacted by overgrown vegetation, including tules within the water. Lagoon Public Access Trail Access Gate The Coastal Commission contends that Mr. Levy is restricting public access to the Lagoon Public Access Trail by keeping the access gate consistently locked in violation of his CDP, which requires that the gate remain open to the public from “dawn to dusk.” However, city staff do not believe this requirement is effective since the Lagoon Public Access Trail has not yet been accepted by the city and the public cannot legally access it. If the IOD is accepted and the trail is improved, the gate hours would become effective and enforceable. Next Steps City staff is reaching out to The Beach HOA Board of Directors to see if the Beach HOA is willing to voluntarily modify the Mountain View Drive entrance gate to address the pedestrian public access concerns. City staff have also received an email from the Coastal Commission staff acknowledging receipt of August 1, 2025, letters and the commission’s intention to respond. Attachments: A.Coastal Commission letter dated May 23, 2025 B.Coastal Commission letter dated June 24, 2025 C.Community Development Department letter dated August 1, 2025 D.City Attorney’s Office letter dated August 1, 2025 cc: Geoff Patnoe, City Manager Cindie McMahon, City Attorney Christie Calderwood, Police Chief Mike Calderwood, Fire Chief Dalton Sorich, Assistant City Attorney Kyle Lancaster, Parks & Recreation Director Mike Strong, Assistant Director Marissa Kawecki, Deputy City Attorney Robbie Hickerson, Code Enforcement Manager STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR CALIFORNIA COASTAL COMMISSION 455 MARKET STREET, SUITE 300 SAN FRANCISCO, CA 94105 FAX (415) 904-5400 TDD (415) 597-5885 VIA ELECTRONIC MAIL May 23, 2025 Eric Lardy City Planner of Carlsbad eric.lardy@carlsbadca.gov Subject: Violations at 2401 Mountain View Drive (Levyland), Carlsbad Dear Mr. Lardy, We write with regards to the Coastal Act and Coastal Development Permit (“CDP”) violations at and around the property at 2401 Mountain View Drive, Carlsbad, also known as ‘Levyland,’ that were discussed during our videoconference with City of Carlsbad (“City”) staff yesterday. We understand that John C. Levy, Jr., the violator, has met with City staff, and while he has thus far declined to meet with or speak to Coastal Commission (“Commission”) Headquarters Enforcement staff, he has provided Commission staff with his many arguments via letters. Therefore, we also write to correct the record with regards to his arguments, many of which were raised during the videoconference, and provide you with context regarding this matter. We wish to continue working with the City towards resolution of all of the violations and hope that the information provided in this letter will help us work together. Importantly, please note that it is also our understanding from our conversation yesterday that Mr. Levy is requesting that the City provide him with documentation asserting that Mr. Levy is somehow in compliance with CDP 97-59. This is unfortunate, since this would be clearly contrary to the facts and the CDP, as well as contrary to the City’s prior written positions. As you know, CDP 97-59 included conditions requiring both public access along the lagoon, as well as several layers of protection and restoration for a wetland buffer area surrounding the house, among other requirements. For your information, we have attached four emails from the City’s prior Community Development Director as examples of the City’s prior positions on these violations. We sincerely hope that the City will not now concede to Mr. Levy’s request that the City become a party to the many violations at issue, since that would create a variety of difficulties and would not help the environment or public access here. We hope that the City will continue to work with Commission staff to finally open the two public access easements that the City has accepted and that Mr. Levy has blocked without any Coastal Act authorization, and in violation of two different CDPs, for many decades. These public access easements are already advertised on the City’s website and will clearly be an amenity for residents of the City, and we look forward to working with you to help provide public access to them at long last. Attachment A Levyland May 23, 2025 2 Mr. Levy’s Recent Attempts to Embroil the City in his Violations It is our understanding that Mr. Levy has engaged City staff to finally dedicate land, as was required by Condition 13 of CDP 97-59 nearly three decades ago, to the California Department of Fish and Wildlife (“CDFW”). While this is some progress, we also understand that Mr. Levy has argued that this is one of only two outstanding violations of CDP 97-59 (along with Mr. Levy’s failure to install light shielding fencing to protect the same area, which is a violation of Condition 14). While Commission staff is of course pleased at any forward movement by Mr. Levy in remedying the many violations at this site, please note that the approved plans for that CDP include 6 foot tall light shielding fencing that is made opaque via vegetation, but Mr. Levy never complied with that permit condition either. We also note that any construction of the required light shielding fencing in this area will require Coastal Act authorization from the Commission. As you know, our mapping department has reviewed the information, and has advised that this area is within the Commission’s retained permit jurisdiction, and so any activities that require Coastal Act authorization, including installing fencing and opaque landscaping, would require Coastal Act authorization from the Commission, including via a CDP, or could be addressed via a Cease and Desist Order. In addition to the many CDP violations at issue, we understand that Mr. Levy is also attempting to involve the City in one of his more recent violations, the unpermitted installation of a pickleball court and other pavement. These violations also fall within the Commission’s retained permit jurisdiction, and therefore must similarly receive Coastal Act authorization from the Commission, via an after-the-fact CDP, or be addressed via a Cease and Desist Order for their removal and a Restoration Order for their restoration. Mr. Levy’s Failure to Revegetate the Wetland Buffer Area We also understand that Mr. Levy has argued to City staff, as he has argued to Commission staff for many years, that he complied with the Condition 16 requirement to remove invasive plants from the wetland buffer and vegetate the area with native plants. We note that Mr. Levy does not dispute the fact that he has since regularly mowed the area and used it as a parking lot, both without any CDP. Moreover, as we noted during our conversation, the Commission’s ecologist visited the site soon after the time Mr. Levy claimed to have performed this work, and observed that in her professional opinion, she saw no evidence of the invasive removal and native vegetation work Mr. Levy claimed to have performed. In addition, please note that the City has concurred with the Commission’s position in the past, as shown in the attached email dated September 7, 2018. Moreover, if the wetland buffer had been stripped of invasive plants and vegetated with native plants, that area of would have risen to the level of environmentally sensitive habitat area (“ESHA”) due to the many native plants and the proximity to wetlands and endangered birds, and any removal of ESHA without a CDP is a violation. In addition, Levyland May 23, 2025 3 since this particular area was required to be protected by Condition 12, any unpermitted development there would not only be a violation of the Coastal Act, it would also be a violation of Condition 12. We understand that Mr. Levy has argued that he may take an area that is required to be protected via deed restriction, protected via dedication to CDFW, and vegetated with native plants, none of which Mr. Levy has done, regularly mow it and use it as a parking lot for many years, and that he can now simply belatedly comply with Conditions 12, 13, and 16 without remedying the decades of impacts to the ESHA and wetlands that the buffer is supposed to be protecting. In fact, the area must be restored to the pre-violation condition and with native plants, and there must be additional mitigation for the decades of lost resources for Mr. Levy to come into compliance with the CDP, as well as the Coastal Act, in addition to monetary penalties. Please note that any removal of invasive plants, remedial grading to correct the changes to topography created by Mr. Levy’s use of this area as a parking lot, and planting of native plants will require Coastal Act authorization by the Commission, as described above, via a CDP or Restoration Order, in addition to an Administrative Penalty. Unpermitted Locked Gates Restricting Public Access to Accepted Easements We are also aware that Mr. Levy has made assertions to City staff, as he has to Commission staff, that he is allowed to block the lagoon public access easement because he argues that the City has not accepted it, but this is incorrect. The fact of the matter is that the City has accepted the lagoon public access easement, as the City itself has noted in the attached email dated June 26, 2018. By the terms of the recorded easement at Document No. 2018-0142309, the easement may be accepted by either resolution of the City Council or as authorized by Municipal Code Chapter 11.04.060. In this case, the City has actually accepted it via both means. This code section addresses the issue that the City of Carlsbad is not responsible for maintaining trails until they are formally accepted into the Citywide Trails System. Accordingly, shortly after the offer to dedicate was recorded, on August 27, 2019, the City Council formally accepted this trail into the Citywide Trails System via the adoption of the Trails Master Plan, which included the lagoon public access easement trail, via City Council Resolution No. 2019-150. Thus, by the terms of the easement, it is accepted, and it is even viewable as a public trail on the City’s website. In addition, regardless of whether this public access easement is accepted, which as noted above it clearly is, Condition 17 of the CDP only allows Mr. Levy to restrict public access to this area from dawn to dusk. It thus remains unclear to Commission staff how Mr. Levy could request that the City take the position that he is allowed to restrict public access to an accepted public access easement permanently, and still be in compliance with Condition 17. Further, although we understand that Mr. Levy has shared the gate code with the City for his unpermitted permanently locked gate placed within the accepted beach public access easement (recorded as Document No. 84-309895), Mr. Levy has thus far refused to open it to the public as required by CDP 6-83-051. This is the case even though Mr. Levy has not argued that this easement has not been accepted by the City, and has simply found other arguments to justify his refusal to comply with the easement Levyland May 23, 2025 4 and CDP. Please note that our Notice of Intent dated October 2, 2024, attached, addresses Mr. Levy’s arguments regarding this violation. In addition, Mr. Levy appears to have demanded that the City not open the gate to the public either, because the City has not done so. This situation is particularly unfortunate given that in the past, the City held the position that the City could remove the gate entirely and the City even planned to do so, as is stated in the attached emails dated July 20, 2018, and September 7, 2018. Please note that as part of our upcoming cease and desist order against Mr. Levy, we will require that Mr. Levy finally open the unpermitted permanently locked gate to allow for public pedestrian access. In conclusion, we hope to continue working with the City, as the Commission has for many years, towards a resolution of Mr. Levy’s many serious violations and towards ensuring that the two public access easements Mr. Levy is blocking, both of which have been accepted by the City and are labeled on the City’s website as public trails, finally become actually open to the public for the use and enjoyment that the public is legally entitled to. We look forward to working with you on this matter, and if you have any questions regarding these violations or this letter, please do not hesitate to reach out to me at robert.moddelmog@coastal.ca.gov. Sincerely, Rob Moddelmog Headquarters Enforcement Counsel cc: Lisa Haage, Chief of Enforcement Aaron McLendon, Deputy Chief of Enforcement Marsha Venegas, District Enforcement Officer Alex Helperin, Assistant General Counsel Karl Schwing, District Director Diana Lily, District Manager Jennifer Jessers, City of Carlsbad Marissa Kawecki, City of Carlsbad Attachment: Notice of Intent dated October 2, 2025 Email from City dated September 12, 2016 Email from City dated June 26, 2018 Email from City dated July 20, 2018 Email from City dated September 7, 2018 STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR CALIFORNIA COASTAL COMMISSION 455 MARKET STREET, SUITE 300 SAN FRANCISCO, CA 94105 FAX (415) 904-5400 TDD (415) 597-5885 VIA ELECTRONIC MAIL June 24, 2025 Marissa Kawecki City Prosecutor/Deputy City Attorney City of Carlsbad Marissa.Kawecki@carlsbadca.gov Subject: Easements Required By CDP 6-83-051 Dear Ms. Kawecki, We write to coordinate with you regarding public access and open space easements on property owned by The Beach HOA and designated as Assessor’s Parcel No. 203-010-21 (“the Beach HOA Property”), which easements were required by the California Coastal Commission (“Commission”), through conditions it included in its approval of Coastal Development Permit (“CDP”) 6-83-051, and accepted by the City of Carlsbad (“the City”). We appreciate that the management of this area has been the subject of a significant amount of controversy that has raised numerous legal issues, and we would like to work with you to resolve these issues. As you may be aware, the easement offers were accepted by the City on July 11, 2005, via an acceptance document that was recorded as Instrument No. 2005-0579627. The three easements that were created are: (1) a public access easement, for which an Offer to Dedicate (“OTD”) was recorded on August 15, 1984, as Instrument No. 84- 309895 (“the Beach Access Easement”); (2) an open space easement to provide habitat protection and habitat buffer areas, for which an OTD was recorded on August 15, 1984, as Instrument No. 84-309898 (“the Open Space Easement”); and (3) another open space easement to specifically protect the bluff face, for which an OTD was recorded on August 16, 1984, as Instrument No. 84-309986 (“the Bluff Open Space Easement”). A map of the easements was recorded as an exhibit to the acceptance, and for your convenience, I have attached a higher resolution version of the same map to the cover email I am using to transmit this letter. The Beach Access Easement As you know, we recently became aware that the City possesses the code for the gate installed by John C. Levy, Jr., at the entrance road to, and within, both the Beach Access Easement and the Open Space Easement.1 Both because it is development that is not consistent with the open space restrictions, and because this gate is now 1 Gate Access Agreement between the City of Carlsbad and John C. Levy, Jr, dated July 17, 2023. Attachment B Levyland June 24, 2025 2 permanently locked, thus blocking public pedestrian access, the gate is inconsistent with the easements required by CDP 6-83-051 and therefore is in violation of CDP 6-83-051. We also understand that even though the City has accepted the Beach Access Easement, the City and Mr. Levy keeps Mr. Levy’s gate permanently closed. As you know, although CDP 97-59 (issued by the City) authorized a gate in this location before the Beach Access Easement and the Open Space Easement were effectuated through the City’s acceptance of the offers, CDP 97-59 did not purport to, nor could it, amend the requirements of the pre-existing CDP 6-83-051 or the OTDs that the permit required for the Beach Access Easement and the Open Space Easement, both of which had already been recorded when the City approved CDP 97-59. The Commission noted as much in its findings in support of its decision to leave CDP 97-59 in place, stating that the Open Space Easement condition prohibited almost all development in this area, but that since the offer to dedicate that easement had not yet been accepted, the Commission could allow CDP 97-59 to become final, authorizing the gate for the time being, and leave it to later to address “the ability of the landowners to maintain the fence after the offer of dedication has been accepted.” As the offers have now been accepted, the gate is now in violation of the easements and the permit requirements and must come out. Indeed, the only way to alter the requirements of the prior CDP would have been through an amendment, but no such amendment is possible, as any amendment that would reduce the restrictions of the prior CDP so as to allow the permanent retention of a gate blocking access to this area would “lessen or avoid the intended effect” of that prior permit, and would therefore have to be rejected pursuant to 14 CCR § 13166. The Ingress/Egress Easement In response to your question about the Commission’s process for dealing with prior liens and encumbrances during the condition compliance process, the Commission has a Recorded Documents Unit that is dedicated entirely to processing these sorts of requirements. Part of that process involves requesting preliminary title reports before and after any document is recorded in order to ensure that the property interest being created, as required by the Commission, is not in any way undermined by any other property interests or other encumbrances that may already be recorded against the property. Through that process, our staff learned that Mr. Levy possessed two ingress/egress easements across the Beach HOA Property, the first recorded November 11, 1971, as Instrument No. 262981, and the second recorded August 2, 1984, as Instrument No. 84-294255 (“the Ingress/Egress Easement”), the latter easement covering the actual location of the road used to reach Levyland today. At the time the Commission approved the recordation of the offers of the Beach Access Easement and the Open Space Easement, the Commission’s Recorded Documents Unit had access to current title reports and was aware of both ingress/egress easements. Notably, the Ingress/Egress Easement was recorded just before the Beach Access Easement and Open Space easements. However, because both ingress/egress easements are non-exclusive and therefore do Levyland June 24, 2025 3 not conflict with the Public Access Easement, the Commission was not concerned, and therefore did not require the subordination of the Ingress/Egress Easement to the new OTDs. Subsequently, the non-exclusive nature of the Ingress/Egress Easement was emphasized by the underlying property owner, the Beach HOA, in a May 1998 letter of authorization for Mr. Levy’s application to install said gate (and also attached to this cover email), which did not grant Mr. Levy exclusive access to the gate, but to the contrary, stated that the Beach HOA’s approval was conditional, and one of the conditions was that “the BHA [the Beach HOA], it’s designees and others legally entitled thereto shall have access at all times to Lot 3 [the Beach Access Easement area] through the gate by means of the controlling device used i.e. key pad, card, lock, or other controller.” (emphasis added). Once the Beach Access Easement was accepted, the public became legally entitled to use the gate. Thus, the highlighted language refers to the public and requires Mr. Levy to provide the public access through the gate. Moreover, Mr. Levy does not need a gate on the Beach Access Easement to exercise his right, pursuant to the Ingress/Egress Easement, to obtain ingress or egress to Levyland, and he has no basis for seeking to preclude the public from accessing areas with public rights. Please note that this combination of protected public access, open space, and ingress/egress easements is not unusual, and in fact is very similar to a recent case in Big Sur that the Commission successfully resolved via an amicable settlement that was approved by the Commission on June 14, 2024.2 In that matter, the violator (Rocky Point Restaurant) had an ingress/egress easement across property owned by another party, providing the necessary access between its restaurant property and Highway One. After the recordation of that easement, the public still regularly used the area of the ingress/egress easement for public access, and the Commission believed there was strong evidence of prescriptive rights there. Then, long after the violator’s ingress/egress easement was recorded, the County of Monterey bought the land underlying the ingress/egress easement and recorded an open space easement there. The ingress/egress easement was not subordinated or otherwise disposed of during recordation. The County then gave Rocky Point Restaurant a permit to build a gate within the ingress/egress easement, even though that permit was authorizing the gate in what was by then an open space easement as well. The terms of the open space easement allowed for any private party to enforce it, and as such, the Commission informed Rocky Point Restaurant that the Commission would be enforcing the open space easement and requiring the removal of the gate, among other permitted items within the open space easement. Rocky Point Restaurant agreed to remove the gate in an amicable resolution that was supported by the County of Monterey. This is just one example of the common public and private property rights coexisting. The Open Space Easement In addition, we are aware that the City has been maintaining and operating within the Open Space Easement an unmarked series of roads, parking areas, and storage areas 2 The resolution was implemented via a cease and desist order, restoration order, and penalties, designated as CCC-24-CD-02, CCC-24-RO-02, CCC-24-AP-02, & CCC-24-AP3-02, respectively. Levyland June 24, 2025 4 for various city vehicles and city equipment. We also understand that from the Gate Access Agreement between the City and Mr. Levy that the City has also agreed to undertake limited maintenance of Mr. Levy’s paved road within the Open Space Easement. However, we wanted to note that the Open Space Easement requires that the area be used for habitat protection and prohibits “any alteration of landforms” or “placement or removal of vegetation except as specified herein.” The Open Space Easement then specifies that while it expressly recognizes the “right of access to the weir for maintenance purposes,” it also states that “the erection of some public access improvements may be allowed, in consultation with the State Department of Fish and Game, and subject to Coastal Commission permit requirements.” The Commission has found no evidence of any CDP being issued to authorize an unmarked series of roads, parking areas, or storage areas for various city vehicles and city equipment. In fact, approximately a quarter of an acre of excellent potential coastal habitat area, immediately adjacent to both Buena Vista Lagoon, wetlands, and the beach appears to be used for such activities, in addition to the wide unmarked road that leads to this area. This unpermitted development has caused negative impacts, including removal of vegetation there, as well as alteration of landforms, including by repeatedly driving over areas that would otherwise likely become undulating coastal dunes or be otherwise vegetated. Easement Holder Obligations All three easements state that “acceptance of the Offer is subject to a covenant which runs with the land, providing that any offeree to accept the easement may not abandon it but must instead offer the easement to other public agencies or private associations acceptable to the Executive Director of the Commission for the duration of the term of the original Offer to Dedicate.” This is a common provision to allow easement holders who do not want to continue to manage the easement in compliance with the terms of the easement to work to transfer that to another entity. Here, the City’s actions of jointly operating a permanently locked gate directly within and blocking access to the Beach Access Easement, which is a legal requirement of the Commission CDP (CDP 6-83-051), as well as use of the Open Space Easement for a series of unpermitted and unmarked roads, parking areas, and storage areas for city equipment and vehicles are both in direct conflict with the terms of those easements. As the easement holder, it appears that the City has effectively abandoned both easements by not complying with the terms of either easement. We would like to work with you to immediately rectify this situation and finally restore the public access here that was to be provided for the last several decades, as well as come up with a plan to minimize impacts to habitat area. Thus, the Commission formally requests that the City assist us in resolving the situation and violations of the Commission permit (CDP 6-83-051) and all of the easements, including by opening the gate within the Beach Access Easement, or by simply sharing the gate code with the public via a posted sign. Or, rather than open the gate or post the gate code itself, the City could offer the easements to other public agencies or private associations acceptable to the Commission’s Executive Director, as is provided for in the original Offers to Dedicate. We would appreciate your responding as to your Levyland June 24, 2025 5 preferences by July 7, 2025, and we are readily available to discuss the options and issues. In addition, Commission staff is prepared to provide you with draft Offers to Dedicate for your review and approval to enact such a transfer and looks forward to working with you on this matter. Please note that the Commission wants to resolve this matter in a manner that would assist the City, and in no way seeks to harm the City’s interests in continuing to use the Open Space Easement for vehicular access as the City has done for many years. On the contrary, the Commission anticipates that the Commission’s action involving Mr. Levy may well result in litigation, and as the current easement holder, the Commission expects that the City may become a party to the litigation. To prevent this, the Commission would be happy to work with the City to offer the three easements to other entities and thus assist the City in avoiding likely litigation. We believe that in this matter, the City’s interests and the public’s interests are one and the same, and we look forward to working with you. Please do not hesitate to reach out to me at robert.moddelmog@coastal.ca.gov with any questions. We hope to hear from you soon. Sincerely, Rob Moddelmog Headquarters Enforcement Counsel cc: Lisa Haage, Chief of Enforcement Aaron McLendon, Deputy Chief of Enforcement Marsha Venegas, San Diego District Enforcement Alex Helperin, Assistant General Counsel Karla Galvez, Senior Staff Counsel, Recorded Documents Unit Karl Schwing, District Director Diana Lily, District Manager Eric Lardy, City Planner of Carlsbad Attachment: Map of Native Sun Easements Letter from the Beach HOA from May of 1998 Attachment C Mr. Moddelmog August 1, 2025 Page 6 may violate the Coastal Act and require review and approval of a separate coastal development permit to address. We appreciate the opportunity to continue collaborating with the Coastal Commission on this matter. At this time, however, we defer to the Coastal Commission's retained jurisdiction to contemplate, analyze, and approve future development proposals and/or conduct enforcement proceedings for any Coastal Act violations associated with the development of 2401 Mountain View Drive since this area is within the original permitting jurisdiction of the California Coastal Commission. As noted in the companion City Attorney's Office letter dated Aug. 4, 2025, the city will contact The Beach HOA in support of a Coastal Commission request that the HOA modify the Mountain View Drive gate entrance to resolve the pedestrian public access issue the gate presents. Please do not hesitate to contact me as needed to further discuss our recent correspondence. JEFF MURPHY, Director Community Development Department Attachments 1.Coastal Commission letter dated May 23, 2025 2.Conditions of approval for CDP 97-59 3.Doose Landscape invoice 4.Draft conservation easement to CDFG 5.City Council Resolution No. 2019-150 6.Email dated June 26, 2018 7.Instrument number 2018-0142309 8.City Attorney's Office letter to CCC dated Aug. 1, 2025 cc: Geoff Patnoe, City Manager Sheila Cobian, Assistant City Manager Marissa Kawecki, Deputy City Attorney Dalton Sorich, Assistant City Attorney Kyle Lancaster, Director of Parks & Recreation Mike Strong, Assistant Director Eric Lardy, City Planner Robbie Hickerson, Code Enforcement Manager Lisa Haage, Chief of Enforcement Alex Helperin, Assistant General Counsel STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR CALIFORNIA COASTAL COMMISSION 455 MARKET STREET, SUITE 300 SAN FRANCISCO, CA 94105 FAX (415) 904-5400 TDD (415) 597-5885 VIA ELECTRONIC MAIL May 23, 2025 Eric Lardy City Planner of Carlsbad eric.lardy@carlsbadca.gov Subject: Violations at 2401 Mountain View Drive (Levyland), Carlsbad Dear Mr. Lardy, We write with regards to the Coastal Act and Coastal Development Permit (“CDP”) violations at and around the property at 2401 Mountain View Drive, Carlsbad, also known as ‘Levyland,’ that were discussed during our videoconference with City of Carlsbad (“City”) staff yesterday. We understand that John C. Levy, Jr., the violator, has met with City staff, and while he has thus far declined to meet with or speak to Coastal Commission (“Commission”) Headquarters Enforcement staff, he has provided Commission staff with his many arguments via letters. Therefore, we also write to correct the record with regards to his arguments, many of which were raised during the videoconference, and provide you with context regarding this matter. We wish to continue working with the City towards resolution of all of the violations and hope that the information provided in this letter will help us work together. Importantly, please note that it is also our understanding from our conversation yesterday that Mr. Levy is requesting that the City provide him with documentation asserting that Mr. Levy is somehow in compliance with CDP 97-59. This is unfortunate, since this would be clearly contrary to the facts and the CDP, as well as contrary to the City’s prior written positions. As you know, CDP 97-59 included conditions requiring both public access along the lagoon, as well as several layers of protection and restoration for a wetland buffer area surrounding the house, among other requirements. For your information, we have attached four emails from the City’s prior Community Development Director as examples of the City’s prior positions on these violations. We sincerely hope that the City will not now concede to Mr. Levy’s request that the City become a party to the many violations at issue, since that would create a variety of difficulties and would not help the environment or public access here. We hope that the City will continue to work with Commission staff to finally open the two public access easements that the City has accepted and that Mr. Levy has blocked without any Coastal Act authorization, and in violation of two different CDPs, for many decades. These public access easements are already advertised on the City’s website and will clearly be an amenity for residents of the City, and we look forward to working with you to help provide public access to them at long last. Exhibit 1 Levyland May 23, 2025 2 Mr. Levy’s Recent Attempts to Embroil the City in his Violations It is our understanding that Mr. Levy has engaged City staff to finally dedicate land, as was required by Condition 13 of CDP 97-59 nearly three decades ago, to the California Department of Fish and Wildlife (“CDFW”). While this is some progress, we also understand that Mr. Levy has argued that this is one of only two outstanding violations of CDP 97-59 (along with Mr. Levy’s failure to install light shielding fencing to protect the same area, which is a violation of Condition 14). While Commission staff is of course pleased at any forward movement by Mr. Levy in remedying the many violations at this site, please note that the approved plans for that CDP include 6 foot tall light shielding fencing that is made opaque via vegetation, but Mr. Levy never complied with that permit condition either. We also note that any construction of the required light shielding fencing in this area will require Coastal Act authorization from the Commission. As you know, our mapping department has reviewed the information, and has advised that this area is within the Commission’s retained permit jurisdiction, and so any activities that require Coastal Act authorization, including installing fencing and opaque landscaping, would require Coastal Act authorization from the Commission, including via a CDP, or could be addressed via a Cease and Desist Order. In addition to the many CDP violations at issue, we understand that Mr. Levy is also attempting to involve the City in one of his more recent violations, the unpermitted installation of a pickleball court and other pavement. These violations also fall within the Commission’s retained permit jurisdiction, and therefore must similarly receive Coastal Act authorization from the Commission, via an after-the-fact CDP, or be addressed via a Cease and Desist Order for their removal and a Restoration Order for their restoration. Mr. Levy’s Failure to Revegetate the Wetland Buffer Area We also understand that Mr. Levy has argued to City staff, as he has argued to Commission staff for many years, that he complied with the Condition 16 requirement to remove invasive plants from the wetland buffer and vegetate the area with native plants. We note that Mr. Levy does not dispute the fact that he has since regularly mowed the area and used it as a parking lot, both without any CDP. Moreover, as we noted during our conversation, the Commission’s ecologist visited the site soon after the time Mr. Levy claimed to have performed this work, and observed that in her professional opinion, she saw no evidence of the invasive removal and native vegetation work Mr. Levy claimed to have performed. In addition, please note that the City has concurred with the Commission’s position in the past, as shown in the attached email dated September 7, 2018. Moreover, if the wetland buffer had been stripped of invasive plants and vegetated with native plants, that area of would have risen to the level of environmentally sensitive habitat area (“ESHA”) due to the many native plants and the proximity to wetlands and endangered birds, and any removal of ESHA without a CDP is a violation. In addition, Levyland May 23, 2025 3 since this particular area was required to be protected by Condition 12, any unpermitted development there would not only be a violation of the Coastal Act, it would also be a violation of Condition 12. We understand that Mr. Levy has argued that he may take an area that is required to be protected via deed restriction, protected via dedication to CDFW, and vegetated with native plants, none of which Mr. Levy has done, regularly mow it and use it as a parking lot for many years, and that he can now simply belatedly comply with Conditions 12, 13, and 16 without remedying the decades of impacts to the ESHA and wetlands that the buffer is supposed to be protecting. In fact, the area must be restored to the pre-violation condition and with native plants, and there must be additional mitigation for the decades of lost resources for Mr. Levy to come into compliance with the CDP, as well as the Coastal Act, in addition to monetary penalties. Please note that any removal of invasive plants, remedial grading to correct the changes to topography created by Mr. Levy’s use of this area as a parking lot, and planting of native plants will require Coastal Act authorization by the Commission, as described above, via a CDP or Restoration Order, in addition to an Administrative Penalty. Unpermitted Locked Gates Restricting Public Access to Accepted Easements We are also aware that Mr. Levy has made assertions to City staff, as he has to Commission staff, that he is allowed to block the lagoon public access easement because he argues that the City has not accepted it, but this is incorrect. The fact of the matter is that the City has accepted the lagoon public access easement, as the City itself has noted in the attached email dated June 26, 2018. By the terms of the recorded easement at Document No. 2018-0142309, the easement may be accepted by either resolution of the City Council or as authorized by Municipal Code Chapter 11.04.060. In this case, the City has actually accepted it via both means. This code section addresses the issue that the City of Carlsbad is not responsible for maintaining trails until they are formally accepted into the Citywide Trails System. Accordingly, shortly after the offer to dedicate was recorded, on August 27, 2019, the City Council formally accepted this trail into the Citywide Trails System via the adoption of the Trails Master Plan, which included the lagoon public access easement trail, via City Council Resolution No. 2019-150. Thus, by the terms of the easement, it is accepted, and it is even viewable as a public trail on the City’s website. In addition, regardless of whether this public access easement is accepted, which as noted above it clearly is, Condition 17 of the CDP only allows Mr. Levy to restrict public access to this area from dawn to dusk. It thus remains unclear to Commission staff how Mr. Levy could request that the City take the position that he is allowed to restrict public access to an accepted public access easement permanently, and still be in compliance with Condition 17. Further, although we understand that Mr. Levy has shared the gate code with the City for his unpermitted permanently locked gate placed within the accepted beach public access easement (recorded as Document No. 84-309895), Mr. Levy has thus far refused to open it to the public as required by CDP 6-83-051. This is the case even though Mr. Levy has not argued that this easement has not been accepted by the City, and has simply found other arguments to justify his refusal to comply with the easement Levyland May 23, 2025 4 and CDP. Please note that our Notice of Intent dated October 2, 2024, attached, addresses Mr. Levy’s arguments regarding this violation. In addition, Mr. Levy appears to have demanded that the City not open the gate to the public either, because the City has not done so. This situation is particularly unfortunate given that in the past, the City held the position that the City could remove the gate entirely and the City even planned to do so, as is stated in the attached emails dated July 20, 2018, and September 7, 2018. Please note that as part of our upcoming cease and desist order against Mr. Levy, we will require that Mr. Levy finally open the unpermitted permanently locked gate to allow for public pedestrian access. In conclusion, we hope to continue working with the City, as the Commission has for many years, towards a resolution of Mr. Levy’s many serious violations and towards ensuring that the two public access easements Mr. Levy is blocking, both of which have been accepted by the City and are labeled on the City’s website as public trails, finally become actually open to the public for the use and enjoyment that the public is legally entitled to. We look forward to working with you on this matter, and if you have any questions regarding these violations or this letter, please do not hesitate to reach out to me at robert.moddelmog@coastal.ca.gov. Sincerely, Rob Moddelmog Headquarters Enforcement Counsel cc: Lisa Haage, Chief of Enforcement Aaron McLendon, Deputy Chief of Enforcement Marsha Venegas, District Enforcement Officer Alex Helperin, Assistant General Counsel Karl Schwing, District Director Diana Lily, District Manager Jennifer Jessers, City of Carlsbad Marissa Kawecki, City of Carlsbad Attachment: Notice of Intent dated October 2, 2025 Email from City dated September 12, 2016 Email from City dated June 26, 2018 Email from City dated July 20, 2018 Email from City dated September 7, 2018 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 e 0 PLANNING COMMISSION RESOLUTION NO. 4332 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CARLSBAD, CALIFORNIA, APPROVING A ALLOW FOR THE CONSTRUCTION OF A SINGLE FAMILY RESIDENCE AND SECOND DWELLING UNIT OVER A DETACHED GARAGE ON PROPERTY GENERALLY LOCATED ALONG THE SOUTH SHORE OF BUENA VISTA LAGOON, WEST OF THE AT&SF RAILROAD, NORTH OF MOUNTAIN VIEW DRIVE IN LOCAL FACILITIES MANAGEMENT ZONE 1. CASE NAME: LEVY RESIDENCE CASE NO.: CDP 97-59 WHEREAS, John C. Levy, “Developer”, has filed a verified application COASTAL DEVELOPMENT PERMIT NO. CDP 97-59 TO City of Carlsbad regarding property owned by John C. Levy, “Owner”, described as Parcel “A” of City of Carlsbad Adjustment Plat #471. (“the Property”); and WHEREAS, said verified application constitutes a request for a Development Permit as shown on Exhibits “A” - “G” dated July 1, 1998,on file in the E Department, LEVY RESIDENCE, CDP 97-59 as provided by Chapter 21.201.04C Carlsbad Municipal Code; and WHEREAS, the Planning Commission did, on the 1st day of July 1998 duly noticed public hearing as prescribed by law to consider said request; and WHEREAS, at said public hearing, upon hearing and considering all te and arguments, if any, of all persons desiring to be heard, said Commission considered all relating to the CDP. NOW, THEREFORE, BE IT HEREBY RESOLVED by the I: Commission of the City of Carlsbad as follows: ~ A) That the foregoing recitations are true and correct. Exhibit 2 e 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 B) That based on the evidence presented at the public hearing, the Corr APPROVES LEVY RESIDENCE, CDP 97-59, based on the following and subject to the following conditions: FindinEs: 1. That the proposed development is in conformance with the Mello I1 segmen Certified Local Coastal Program and all applicable policies in that the site is des for single family residential development, second dwelling units are pursuant to Mello I1 Affordable Housing Policy 1-1, and no agricultural acti7 geologic instability exists on site. 2. The project is consistent with the provisions of the Coastal Resource Protection Zone (Chapter 21.03 of the Zoning Ordinance) in that the project will adherl City’s Master Drainage and Storm Water Quality Management Plan and C Ordinance to avoid increased runoff and soil erosion, no steep slopes or vegetation is located on the subject property and the site is not located in : prone to landslides, or susceptible to accelerated erosion, floods or liquefactic adjacent Buena Vista Lagoon wetlands have been delineated and the proj been designed to include a minimum 100’ setback between the wetlands structures. The developer has been conditioned to record an open spa4 restriction over the entire wetland buffer setback area and to make an irre offer of dedication of the wetlands buffer to the California Department of F Game. 3. The project is consistent with the provisions of the Coastal Shoreline Devel Overlay Zone (Chapter 21.204 of the Zoning Ordinance) in that the proposed will require minimal grading (75 cubic yards of cut and 75 cubic yards of f project has been designed to avoid increased runoff and soil erosion, and the applicant has been conditioned to make an irrevocable offer of dedication City of Carlsbad for a 25’ wide public access trail easement over an existing ! trail which is located along the western perimeter of the project site. 4. The Planning Commission of the City of Carlsbad has reviewed, analyzed and con Mitigated Negative Declaration CDP 97-59, the environmental impacts therein id1 for this project and said comments thereon, and the Mitigation Monitoril Reporting Program, on file in the Planning Department, prior to APPROVII project. Based on the EIA Part I1 and comments thereon, the Planning Coml finds that there is no substantial evidence the project will have a significant effec environment and hereby APPROVES the Mitigated Negative Declaration. 5. The Planning Commission does hereby find that the Mitigated Negative Dec CDP 97-59 and Mitigation Monitoring and Reporting Program have been p in accordance with requirements of the California Environmental Quality Act, tk Guidelines and the Environmental Protection Procedures of the City of Carlsbad. PC RES0 NO. 4332 -2- e 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6. The Planning Commission finds that the Mitigated Negative Declaration CD reflects the independent judgment of the Planning Commission of the City of Ci 7. All necessary public improvements have been provided or will be required as cc of approval. 8. The Developer has agreed and is required by the inclusion of an appropriate conc pay a public facilities fee. Performance of that contract and payment of the enable this body to find that public facilities will be available concurrent with required by the General Plan. 9. The project has been conditioned to pay any increase in public facility fee, construction tax, or development fees, and has agreed to abide by any a( requirements established by a Local Facilities Management Plan prepared pur Chapter 21.90 of the Carlsbad Municipal Code. This will ensure continued availa public facilities and will mitigate any cumulative impacts created by the project. 10. The project has been conditioned to ensure the building permits will not be issue( project unless the District Engineer determines that sewer service is availal building cannot occur within the project unless sewer service remains available, District Engineer is satisfied that the requirements of the Public Facilities Elemel General Plan have been met insofar as they apply to sewer service for this project. 1 I. Statutory School fees will be paid to ensure the availability of school facilitie Carlsbad Unified School District. Conditions: 1. Staff is authorized and directed to make, or require Developer to make, all cor and modifications to the CDP 97-59 document(s) as necessary to make them ir consistent and in conformity with final action on the project. Development sha substantially as shown in the approved Exhibits. Any proposed development ( from this approval, shall require an amendment to this approval. 2. The applicant shall apply for and be issued building permits for this pro within two (2) years of approval or this coastal development permit will ex] unless extended per Section 21.201.210 of the Zoning Ordinance. 3. The Developer shall comply with all applicable provisions of federal, state, ar ordinances in effect at the time of building permit issuance. 4. Building permits will not be issued for development of the subject property un. District Engineer determines that sewer facilities are available at the time of app for such sewer permits and will continue to be available until time of occupancy. 5. The Developer shall pay the public facilities fee adopted by the City Council on i 1987, (amended July 2, 1991) and as amended from time to time, and any devel PC RES0 NO. 4332 -3 - 0 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 fees established by the City Council pursuant to Chapter 21.90 of the Carlsbad M Code or other ordinance adopted to implement a growth management system or I and Improvement Plan and to fulfill the subdivider’s agreement to pay thl facilities fee dated May 26, 1998, a copy of which is on file with the City Cler incorporated by this reference. If the fees are not paid, this application wil, consistent with the General Plan and approval for this project will be void. 6. The Developer shall provide proof of payment of statutory school fees to conditions of overcrowding as part of the building permit application. The an these fees shall be determined by the fee schedule in effect at the time of buildin; application. 7. If any condition for construction of any public improvements or facilities, or the 1 of any fees in-lieu thereof, imposed by this approval or imposed by law on this re housing project are challenged this approval shall be suspended as prov Government Code Section 66020. If any such condition is determined to be inv, approval shall be invalid unless the City Council determines that the project wit! condition complies with all requirements of law. 8. Consistent with subsection 21.203.040(4)(e) of the Carlsbad Municipal C grading shall be allowed during the winter season (October 1 - April 1). 9. This project shall comply with all conditions and mitigation measures which are as part of the approved Mitigated Negative Declaration, as contained in P Commission Resolution No. 4331. 10. Prior to the issuance of the building permit, Developer shall submit to the City 2 of Restriction to be filed in the office of the County Recorder, subject to the sati of the Planning Director, notifying all interested parties and successors in interest City of Carlsbad has issued a Coastal Development Permit by Resolution No. ‘ the real property owned by the Developer. Said Notice of Restriction shall I property description, location of the file containing complete project details conditions of approval as well as any conditions or restrictions specified for inch the Notice of Restriction. The Planning Director has the authority to execute and an amendment to the notice which modifies or terminates said notice upon a sho? good cause by the Developer or successor in interest. 11. The Developer shall implement, or cause the implementation of, the CDP 97-59 Mitigation Monitoring and Reporting Program. 12. Prior to the issuance of a building permit or grading permit (whichever occu: the applicant shall record a deed restriction over the entire wetland buffer b area to restrict the property for open space/wildlife uses only, except for a public access trail as shown on the site plan for CDP 97-59. 1 PC RES0 NO. 4332 -4- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 e e 13. Prior to the issuance of a building permit or grading permit (whicheve first), the property owner shall submit evidence satisfactory to the 1 Director that an irrevocable offer of dedication of the wetland buffer area 1 made to the California Department of Fish and Game. 14. Prior to the issuance of building permits, an exterior lighting plan submitted to the Planning Director for review. All exterior lighting shall i, combination of low-level lights and shields to minimize the amount of light the adjacent wetlands and wetland buffer area. 15. Due to the potential presence of the light-footed clapper rail within the I adjacent to the project site, project construction shall be prohibited du breeding season, (March 1 to August l), unless a focused survey for the clal is conducted immediately prior to project construction and determines clapper rails were observed during the survey. 16. Prior to the issuance of a certificate of occupancy, non-native plant species removed from the wetland buffer area and the wetland buffer area sha, vegetated with a hydro-mulched coastal scrub grass seed mix. 17. Prior to the issuance of a building permit or grading permit (whichever oca the applicant shall irrevocably offer to dedicate in perpetuity to the City of C a minimum 25 foot wide public access trail easement over the public acc which is shown on the site plan for CDP 97-59. 18. Prior to the issuance of a building permit or grading permit (whichever OCCI the wetlands buffer area shall be staked and flagged in the field by a surveyor. A minimum of three notices shall be posted within this area tc that this area is off-limits to construction activity. 19. If any of the foregoing conditions fail to occur; or if they are, by their tern implemented and maintained over time, if any of such conditions fail tc implemented and maintained according to their terms, the City shall have the revoke or modify all approvals herein granted; deny or further condition issuan future building permits; deny, revoke or further condition all certificates of oc issued under the authority of approvals herein granted; institute and prosecute liti compel their compliance with said conditions or seek damages for their violat vested rights are gained by Developer or a successor in interest by the City’s apl this Coastal Development Permit. NOTICE Please take NOTICE that approval of your project includes the “imposition” dedications, reservations, or other exactions hereafter collectively referred to for conver “fees/exactions.” ~ PC RES0 NO. 4332 -5- . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 e 8 You have 90 days from July 1, 1998 to protest imposition of these feedexactions. If yc them, you must follow the protest procedure set forth in Government Code Section 6602 file the protest and any other required information with the City Manager for proc accordance with Carlsbad Municipal Code Section 3.32.030. Failure to timely fo. procedure will bar any subsequent legal action to attack, review, set aside, void, or ar imposition. You are hereby FURTHER NOTIFIED that your right to protest the specified fees/< DOES NOT APPLY to water and sewer connection fees and capacity charges, nor I zoning, grading or other similar application processing or service fees in connection project; NOR DOES IT APPLY to any feedexactions of which you have previously be a NOTICE similar to this, or as to which the statute of limitations has previously c expired. PASSED, APPROVED AND ADOPTED at a regular meeting of the Commission of the City of Carlsbad, California, held on the 1st day of July 1995 following vote, to wit: AYES: Chairperson Noble, Commissioners Compas, Heineman, rV Nielsen, Savary, and Welshons NOES: ABSENT: ABSTAIN: &. 4% y%, & g &? - @w4J*fi ,$ 4 ,&e- yt't.iE -.&f Ft L- BAILEY NO@, Chairperson CARLSBAD PLANNING COMMISSION ATTEST: U MICHAEL J. HOLZMILMR Planning Director PC RES0 NO. 4332 -6- Exhibit 3 1825 Aston Avenue &arkbad, CA 92008 Phone (760) 937-9009 X-705 +Fax (760) 937-9089 March 23, 1998 From: John C. Levy Jr. To: Juliet Virtue RE: Conservation Easement Form- Buena Vista Lagoon Good Morning Julie, Pursuant to your letter I have attached the conservation agreement that was forwarded to me by your office. As requested I have signed and notarized the document per your instructions. If you have any questions I can be reached a (760) 931-9009 extension 105. CC: Mr. Chris DeCerbo Planning Department City of Carlsbad Exhibit 4 =!.; Sea ·Bright--s;_.,company 4322 Sea Bright Place •-Carlsbad, CA 92008 • Telephone/FAX 760-720-0098 \J MESSAG E 7 _J DAlE I • SUBJECT co.P �:-!3�} \j ' � �11,\\� .,\\---�J--Q., ,A.1 ' .�£.:� I -_J,.,n AA .1. p o h.9 Ji >L,t.�� , R E P LY DAlE ---------------------SIGNED--------------- INSTRUCTIONS TO SENDER: I.KEEP WHITE CO"Y. 2. SEND YELLOW ANO PINK COPIES INTACT. INSTRUCTIONS TO RECEIVER; I.WRITE REPLY. 2. KEEP PINK COPY. RETURN COPY TO SENDER. August 27, 2019 Item #8 Page 7 of 351 RESOLUTION NO. 2019-150 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA, 1) ADOPTING A MITIGATED NEGATIVE DECLARATION AND A MITIGATION MONITORING AND REPORTING PROGRAM; 2) APPROVING A GENERAL PLAN AMENDMENT FOR THE TRAILS MASTER PLAN; AND 3) ADOPTING THE TRAILS MASTER PLAN. WHEREAS, the Trails Master Plan is a comprehensive planning document intended to guide the future development and maintenance of the city's trail system; and WHEREAS, the Trails Master Plan furthers the community's vision to have a fully connected trail system to provide more opportunities for active living, and to create new, non-vehicular connections to destinations through appropriate standards and design guidelines; and WHEREAS, the City Council of the City of Carlsbad, California has determined that the Parks and Recreation Commission did, on June 17, 2019, hold a duly noticed public hearing as prescribed by law recommending to the City Council adoption of the Trails Master Plan; and WHEREAS, the City Council of the City of Carlsbad, California has determined that the Planning Commission did, on July 17, 2019, hold a duly noticed public hearing as prescribed by law to recommend to the City Council adoption of the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program, and approving an amendment to the Open Space, Conservation, and Recreation Element ofthe Carlsbad General Plan to achieve consistency between the Trails Master Plan and the General Plan; and WHEREAS, the City Council of the City of Carlsbad, held a duly noticed public hearing to consider said Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program, General Plan Amendment, and Trails Master Plan; and WHEREAS, at said public hearing, upon hearing and considering all testimony and arguments, if any, of all persons desiring to be heard, the City Council considered all factors relating to the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program, General Plan Amendment, and Trails Master Plan. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as follows: 1. That the above recitations are true and correct. Exhibit 5 August 27, 2019 Item #8 Page 8 of 351 2. That the recommendation of the Parks and Recreation Commission for the adoption of the Trails Master Plan is adopted. 3. That the recommendation of the Planning Commission for the adoption of a Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program; and approval of General Plan Amendment GPA 2017-0001, are adopted and approved, and that the findings and conditions of the Planning Commission contained in Planning Commission Resolution Nos. 7279 and 7280 on file with the City Clerk and incorporated herein by reference, are the findings and conditions of the City Council. 4. This action is final the date this resolution is adopted by the City Council. The provisions of Chapter 1.16 ofthe Carlsbad Municipal Code, "Time Limits for Judicial Review" shall apply: "NOTICE" The time within which judicial review of this decision must be sought is governed by Code of Civil Procedure, Section 1094.6, which has been made applicable in the City of Carlsbad by Carlsbad Municipal Code Chapter 1.16. Any petition or other paper seeking review must be filed in the appropriate court not later than the ninetieth day following the date on which this decision becomes final; however, if within ten days after the decision becomes final a request for the record is filed with a deposit in an amount sufficient to cover the estimated cost or preparation of such record, the time within which such petition may be filed in court is extended to not later than the thirtieth day following the date on which the record is either personally delivered or mailed to the party, or his attorney of record, if he has one. A written request for the preparation of the record of the proceedings shall be filed with the City Clerk, City of Carlsbad, 1200 Carlsbad Village Drive, Carlsbad, CA 92008. August 27, 2019 Item #8 Page 9 of 351 PASSED, APPROVED AND ADOPTED at a Regular Meeting of the City Council of the City of Carlsbad on the 27th day of August 2019, by the following vote, to wit: AYES: Hall, Bhat-Patel, Blackburn, Schumacher, Hamilton. NAYS: None. ABSENT: None. ~~ 1-/eetor 6o"1tz, (( . 1(/ BARBARA ENGLESON, City Clerk Dtpv C/1~ {SEAL) C /eoC PLANNING COMMISSION RESOLUTION NO. 7279 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CARLSBAD, CALIFORNIA, RECOMMENDING ADOPTION OF A MITIGATED NEGATIVE DECLARATION AND MITIGATION MONITORING AND REPORTING PROGRAM FOR THE CITY OF CARLSBAD TRAILS MASTER PLAN CASE NAME: CASE NO.: CITY OF CARLSBAD TRAILS MASTER PLAN GPA 2017-0001 (PUB17Y-0008) EXHIBIT 4 WHEREAS, the City of Carlsbad, "Applicant," has filed a verified application with the City of Carlsbad to adopt a citywide Trails Master Plan; and WHEREAS, a Mitigated Negative.Declaration and Mitigation Monitoring and Reporting Program was prepared in conjunction with said project in compliance with the California Environmental Quality Act (CEQA); and WHEREAS, during the public review period staff received 25 comment letters; and WHEREAS, sections of the Initial Study (IS)/Mitigated Negative Declaration (MND) were revised based upon the comments received; and WHEREAS, no new information has been presented in the Final IS/MND that would require recirculation of the Draft IS/MND pursuant to CEQA Guidelines Section 15073.S(c); and WHEREAS, the trail segments added to the IS/MND (2C, 6A, 121, and 12J) would result in potentially significant biological and/or cultural resources impacts; however, these impacts are similar' to impacts for other trail segments and would be covered under the Draft IS/MND mitigation measures; and WHEREAS, these mitigation measures would reduce the potentially significant impacts to less than significant; and WHEREAS, other revisions to the Final IS/MND are new information to clarify, amplify, or to make insignificant modifications to the Draft IS/MND that does not require recirculation; and August 27, 2019 Item #8 Page 17 of 351 WHEREAS, the Final IS/MND has not been changed in such a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the Trails Master Plan or a feasible way to mitigate or avoid a substantial environmental effect, and WHEREAS, the Planning Commission did on July 17, 2019, hold a duly noticed public hearing as prescribed by law to consider said request; and WHEREAS, at said public hearing, upon hearing and considering all testimony and arguments, examining the Final IS/MND, analyzing the information submitted by staff, and considering any written comments received, the Planning Commission considered all factors relating to the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program. NOW, THEREFORE, BE IT HEREBY RESOLVED by the Planning Commission of the City of Carlsbad as follows: A) That the foregoing recitations are true and correct. B) That based on the evidence presented at the public hearing, the Planning Commission hereby RECOMMENDS ADOPTION of the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program, attached hereto and made a part hereof as Attachment 1A, based on the following findings: Findings: 1. The Planning Commission of the City of Carlsbad does hereby find: a. it. has reviewed, analyzed, and considered the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program for GPA 2017-0001 -City of Carlsbad Trails Master Plan the environmental impacts therein identified for this project and any comments thereon prior to RECOMMENDING APPROVAL of the project; and b. the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program have been prepared in accordance with requirements of the California Environmental Quality Act, the State Guidelines and the Environmental Protection Procedures of the City of Carlsbad; and c. it reflects the independent judgment of the Planning Commission of the City of Carlsbad; and PC RESO NO. 7279 -2-August 27, 2019 Item #8 Page 18 of 351 From: Debbie Fountain <Debbie.Fountain@carlsbadca.gov> Sent: Tuesday, June 26, 2018 11:15 AM To: Venegas, Marsha@Coastal <Marsha.Venegas@coastal.ca.gov> Subject: RE: Procedural question regarding City's acceptance of Levy IOD Hi Marsha. Our City Attorney’s Office has already provided legal opinion to the Parks Department indicating that the Carlsbad Municipal Code authorizes the City Manager or designee to accept trail easements into the the Citywide Public Trails system. City Council has designated the City Manager as the authorizing official to accept trails easements. Chandra’s example is not related to a trail. Kyle can answer her other question on the Trails Master Plan. Debbie Fountain Community & Economic Development Director City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, Ca. 92008 Debbie.fountain@carlsbadca.gov (760) 434-2935 – office (760) 720-2037 – fax www.carlsbadca.gov From: Chandra Slaven [mailto:cslaven@joncornlaw.com] Sent: Tuesday, June 26, 2018 10:59 AM To: Venegas, Marsha@Coastal <Marsha.Venegas@coastal.ca.gov> Cc: Debbie Fountain <Debbie.Fountain@carlsbadca.gov> Subject: Re: Procedural question regarding City's acceptance of Levy IOD Hi Marsha, Thank you for your email. I just left you a voicemail. I have a meeting with Jon Corn and the client to discuss next steps based on our meeting last week. As states in my voicemail, I need to have two questions answered between now and then: 1. Where in the Trails Master Plan is our trail called out? Maybe Kyle can assist with this? 2. It appears that all IODs must be adopted by resolution at the City Council level and not staff level. Please confirm this. You might have to check with the City Attorney on this. Anyhow, please give me a call at your earliest convenience so that I can have these questions resolved prior to my meeting on Thursday afternoon. Thanks so much! Chandra Slaven, AICP Permit Specialist 619-316-7645 cslaven@joncornlaw.com On Tue, Jun 26, 2018 at 9:38 AM Venegas, Marsha@Coastal <Marsha.Venegas@coastal.ca.gov> wrote: Good Morning Chandra, Exhibit 6 As Debbie mentioned to you at the meeting, any communications directly related to the Levy property needs to be directed to me and not City staff. I am your point of contact for the City for this matter. I agreed to provide you Kyle’s information because you stated you had general questions regarding parks and rec procedures but your question below is specifically related to Levy. As you know, I do not communicate via email regarding any potential enforcement matters. If you would like to discuss, please feel free to call me. We did answer this question last week but there was a lot going on so I am happy to discuss it again with you. Sincerely, Marsha Venegas San Diego District Enforcement Analyst California Coastal Commission From: Chandra Slaven [mailto:cslaven@joncornlaw.com] Sent: Sunday, June 24, 2018 4:53 PM To: kyle.lancaster@carlsbadca.gov Cc: Venegas, Marsha@Coastal Subject: Procedural question regarding City's acceptance of Levy IOD Good evening Kyle, As a follow up to our meeting on Thursday, I have been researching previous City Council agendas and it appears that acceptance of IODs are in fact heard by the City Council, if nothing else at least on consent agenda. Case in point, a recent example, "AB #21,573 - Adoption of Resolution No. 2014-071, entitled, "A Resolution of the City Council of the City of Carlsbad, California, accepting a portion of a previously rejected Irrevocable Offer of Dedication for Lemon Leaf Drive, PR 11-41, generally located at the west end of Lemon Leaf Drive.." Therefore, I am confused as to why our IOD would not go in front of City Council for review and approval. Would you be so kind as to provide clarification? I would greatly appreciate it. Thank you as always for your time in this matter. Best regards, Chandra Slaven, AICP Permit Specialist 619-316-7645 cslaven@joncornlaw.com RECORDING REQUESTED BY City of Carlsbad AND WHEN RECORDED MAIL TO: City Clerk CITY OF CARLSBAD 1200 Carlsbad Village Dr. Carlsbad, CA 92008 The undersigned grantor(s) declare(s): Documentary transfer tax is $� DOC# 2018-0142309 111111111111 lllll 111111111111111 lllll lllll 1111111111111111111111111111 Apr 10, 2018 04:18 PM OFFICIAL RECORDS Ernest J. Dronenburg, Jr., SAN DIEGO COUNTY RECORDER FEES: $0.00 (SB2 Atkins: $0.00) PAGES: 5 SPACE ABOVE THIS LINE FOR RECORDER'S USE Assessor's Parcel No. 155-101-67,155-101-68, 155-190-15, 155-190-16 Project ID: CDP 97-59 ( ) computed on full value of property conveyed, or ( ) computed on full value less value of liens and ---------Re I ate d Project ID: PR 2.3.154 ---------Re I ate d Project ID: ---------encumbrances remaining at time of sale. Project Name: _L_e_v..._y_R_e_s_id_e_nc_e ___ _ ( ) Unincorporated area: (x) City of Carlsbad, and IRREVOCABLE OFFER TO DEDICATE AN EASEMENT FOR PUBLIC TRAIL ACCESS FOR VALUABLE CONSIDERATION, receipt of which is hereby acknowledged, Jim Kelly, Trustee of the John C. Levy, Jr. Revocable Trust, hereinafter designated Granter, represents that he is the legal representative of the owner of the hereinafter described real property in the City of Carlsbad, County of San Diego, State of California, and for a valuable consideration, hereby makes an Irrevocable Offer of Dedication to the City of Carlsbad, a Municipal Corporation hereinafter designated Grantee, its successors and assigns, a public trail access easement upon, through, under, over and across the hereinafter described real property for the following purpose: AN EASEMENT FOR PUBLIC TRAILACCESS The real property referred to above is situated in the City of Carlsbad, County of San Diego, State of California and is described in Exhibit "A" attached hereto and made a part hereof. Exhibit "B" is attached for clarity only. The Granter, for himself, his successors and assigns, hereby waives any claim for any and all damages to Grantor's remaining property contiguous to the public trail access easement hereby conveyed by reason of the location, construction, landscaping or maintenance of said trail. This Offer of Dedication is made pursuant to Section 7050 of the Government Code of the State of California and may be accepted by resolution of the City Council of the City of Carlsbad or as authorized by Carlsbad Municipal Code Chapter 11.04.060. This Offer of Dedication may be terminated and the right to accept the offer may be abandoned in accordance with the summary vacation procedures in Section 8300 et seq. of the Streets and Highways Code of the State of California. The termination and abandonment may be made by the City Council of the City of Carlsbad. C:\Usersldfoun\AppData\Local\Microsoft\Windows\Temporary Internet Flles\Content.Outlook\ROPG2SDE\Levy lrreY Offer to Ded Easemenl.doc REVD1125/13 lf 1 Exhibit 7 City Attorney 1200 Carlsbad Village Drive ï Carlsbad, CA 92008 ï 760-434-2891 ï 760-434-8367 fax www.carlsbadca.gov VIA REGULAR MAIL AND EMAIL TO: robert.moddelmog@coastal.ca.gov 6city August 1, 2025 Mr. Rob Moddelmog Headquarters Enforcement Counsel California Coastal Commission 495 Market Street, Suite 300 San Francisco, CA 94105 Re: Easements Required by CDP 6-83-051 Dear Mr. Moddelmog: Thank you for your assistance to date in providing various documents and laying out the history of Coastal Development Permit, or CDP, 6-83-051 and CDP 97-59. This letter is in response to your letter dated June 24, 2025, regarding three easements you refer to as the Beach Access Easement, the Open Space Easement, and the Bluff Open Space Easement. Offers to dedicate the easements were made in 1984 by the then property owner as a condition of approval for CDP 6-83-051. The city accepted the offers of dedication in 2005. Use of Property and Mountain View Drive Gate Coastal Commission documents indicate a fenced and locked gate at or near the present-day location of the Mountain View Drive gate was installed at some point long before the approval of the 14-unit subdivision under CDP 6-83-051. Both the previous and existing gate at Mountain View Drive were or are within the Beach Access Easement and the Open Space Easement. The Coastal Commission did not require the gate’s removal as a condition of CDP 6-83-051. Rather, the Findings and Declarations in the corresponding staff report concluded that the 14-unit subdivision was “consistent with all applicable LCP and Coastal Act policies since adequate vertical access already exists and the project will provide lateral access opportunities.” (Exhibit 1, page 13.) Additionally, CDP 6-83-51 required the Beach Access Easement to be “free of prior encumbrances which the Executive Director determines may affect the interest being conveyed.” (Exhibit 1, page 4.) By not requiring removal of the existing gate, the Executive Director implicitly determined the gate would not interfere with the public's right to lateral access to the sea or affect the Beach Access Easement. When the City of Carlsbad’s Planning Commission later approved CDP 97-59 for the Levy Residence, the city did not impose any conditions addressing the continued use of the gate. (Exhibit 2.) Although the continued use of the gate was an issue in the Coastal Commission appeal of CDP 97-59, the Coastal Commission’s decision on the appeal did not require the gate to be removed or to remain open during certain times of Exhibit 8 Page 2 day. Rather, the Coastal Commission’s revised findings discuss a long history of a “fenced and locked gate.” The Coastal Commission ultimately decided to allow the existing gate to be replaced with an electric vehicle gate, finding the gate consistent with the public access and recreation policies of Carlsbad’s certified Local Coastal Program and Chapter 3 of the Coastal Act. Specifically, the Coastal Commission found in its Revised Findings on appeal for CDP 97-59 (Exhibit 3, page 7): The proposed project simply replaces the existing manual gate with an electric gate and therefore, it does not change the existing access. In addition, adequate pedestrian access opportunities exist in the area (as a vertical accessway from Ocean Street to the ocean is located about 500 feet to the north) and the public will still be able to access the beach as they have in the past. Therefore, the Commission finds the development as approved by the City does not raise a substantial issue with regard to consistency with the public access and recreation policies of the certified LCP and Chapter 3 of the Coastal Act. The Coastal Commission’s Revised Findings are consistent with California Public Resources Code Section 30212(a)(2), which provides public access from the nearest public roadway to the shoreline and along the coast is not required in new development projects when adequate access exists nearby. Notwithstanding the Coastal Commission’s prior findings and decisions, the Coastal Commission now asserts the city’s acceptance of the Beach Access Easement and Open Space Easement caused the existence of the gate to violate the easements. The Coastal Commission has not provided any authority for this position, and it is inconsistent with the Coastal Commissions prior findings and decisions. It is also inconsistent with the language of the easements, which do not require removal or timed opening of the gate upon acceptance. The Beach Access Easement appears to allow for the recording of additional reasonable terms, conditions, and limitations prior to the opening of the Beach Access Easement. Specifically, Paragraph 3 of the Beach Access Easement (Exhibit 4, page 4) provides: ADDITIONAL TERMS, CONDITIONS, AND LIMITATIONS. Prior to the opening of the accessway, the Grantee, in consultation with the Grantor, may record additional reasonable terms, conditions, and limitations on the use of the subject property in order to assure that this Offer for public access is effectuated. However, The Beach Homeowners Association, the current owner of the property where the gate is located and the successor to the original Grantor, must first be consulted. The Coastal Commission, as the permit authority for The Beach HOA project and the representative of the Grantee People of the State of California,1 is best suited to determine the appropriate terms, conditions, and limitations regarding the gate and initiate the consultation with The Beach HOA. City staff are available to meet with Coastal Commission representatives to discuss options for the additional terms, conditions, and limitations and to support the consultation process. 1 The Beach Access Easement does not expressly define “Grantee.” However, the discussion in paragraph 6 the easement indicates the People of the State of California are the intended Grantee. Page 3 Use and Condition of the Open Space Easement Your letter also asserts the city has been inappropriately using the Open Space Easement, resulting in harm to the open space. As acknowledged in the Coastal Commission’s Staff Report and Recommendation on Appeal for CDP 97-59, the city uses the Open Space Easement for fire and maintenance vehicular access: “It is the only beach vehicle access in northern Carlsbad and has been used by lifeguard personnel and city maintenance crews to maintain the lagoon weir which regulates the water level in Buena Vista Lagoon.” (Exhibit 5, page 9; see also Exhibit 3, page 7.) The city also uses this easement to maintain the city trail within the easement. The easement allows for this type of vehicle access. (Exhibit 1, page 3; Exhibit 3, page 7.) The city’s gate access agreement balances the need for the city’s emergency and maintenance access with the existence of the gate, which, as noted above, is allowed by the Coastal Commission’s past findings and decisions. During select fall and winter months over the recent few years, city staff temporarily placed three small lifeguard towers in an already disturbed area of the Open Space Easement without a full understanding of the potential conflict with existing habitat. City staff subsequently removed the lifeguard towers from the Open Space Easement and does not intend to return them to the already disturbed area. Further, aerial photographs showing the easement area in 2003 (two years before the city’s acceptance of the easement) and recently in 2024) demonstrate the condition of the Open Space Easement has noticeably improved, not worsened, with substantially increased vegetation and reduced disturbed areas. (Exhibit 6.) For the reasons stated, the city does not believe that it is in violation of any CDP or easement connected with 2401 Mountain View Drive or The Beach HOA parcels. The city wishes to continue collaborating with the Coastal Commission to protect public access, recreation, habitats, and views of the coast and scenic coastal areas, consistent with the terms of all applicable permits and instruments. The city will continue to ensure that lateral beach access is protected and enhanced to the maximum degree feasible; and vertical accessways, where applicable, are required in new development consistent with California Public Resources Code Section 30212. Additionally, the city will contact The Beach HOA in support of a Coastal Commission request that the HOA modify the Mountain View Drive gate entrance to resolve the pedestrian public access issue the gate presents. Please do not hesitate to contact me as needed to further discuss our recent correspondence. Sincerely, Marissa Kawecki City Prosecutor/Deputy City Attorney Page 4 1.Staff Report and Preliminary Recommendation for CDP 6-83-051 2.Planning Commission Resolution 4332 for CDP 97-59 3.Revised Findings for CDP 97-59 4. Beach Access Easement (associated with CDP 6-83-051) 5.Staff Report and Recommendation on Appeal for CDP 97-59 6.Aerial photograph of Open Space Easement in 2003 and 2024 cc: Geoff Patnoe, City Manager Sheila Cobian, Assistant City Manager Cindie McMahon, City Attorney Kyle Lancaster, Parks & Recreation Director Jeff Murphy, Community Development Director Mike Strong, Assistant Community Development Director Eric Lardy, City Planner Robbie Hickerson, Code Enforcement Manager Lisa Haage, Coastal Commission Chief of Enforcement Alex Helperin, Coastal Commission Assistant General Counsel Exhibits: City Attorney 1200 Carlsbad Village Drive ï Carlsbad, CA 92008 ï 760-434-2891 ï 760-434-8367 fax www.carlsbadca.gov VIA REGULAR MAIL AND EMAIL TO: robert.moddelmog@coastal.ca.gov 6city August 1, 2025 Mr. Rob Moddelmog Headquarters Enforcement Counsel California Coastal Commission 495 Market Street, Suite 300 San Francisco, CA 94105 Re: Easements Required by CDP 6-83-051 Dear Mr. Moddelmog: Thank you for your assistance to date in providing various documents and laying out the history of Coastal Development Permit, or CDP, 6-83-051 and CDP 97-59. This letter is in response to your letter dated June 24, 2025, regarding three easements you refer to as the Beach Access Easement, the Open Space Easement, and the Bluff Open Space Easement. Offers to dedicate the easements were made in 1984 by the then property owner as a condition of approval for CDP 6-83-051. The city accepted the offers of dedication in 2005. Use of Property and Mountain View Drive Gate Coastal Commission documents indicate a fenced and locked gate at or near the present-day location of the Mountain View Drive gate was installed at some point long before the approval of the 14-unit subdivision under CDP 6-83-051. Both the previous and existing gate at Mountain View Drive were or are within the Beach Access Easement and the Open Space Easement. The Coastal Commission did not require the gate’s removal as a condition of CDP 6-83-051. Rather, the Findings and Declarations in the corresponding staff report concluded that the 14-unit subdivision was “consistent with all applicable LCP and Coastal Act policies since adequate vertical access already exists and the project will provide lateral access opportunities.” (Exhibit 1, page 13.) Additionally, CDP 6-83-51 required the Beach Access Easement to be “free of prior encumbrances which the Executive Director determines may affect the interest being conveyed.” (Exhibit 1, page 4.) By not requiring removal of the existing gate, the Executive Director implicitly determined the gate would not interfere with the public's right to lateral access to the sea or affect the Beach Access Easement. When the City of Carlsbad’s Planning Commission later approved CDP 97-59 for the Levy Residence, the city did not impose any conditions addressing the continued use of the gate. (Exhibit 2.) Although the continued use of the gate was an issue in the Coastal Commission appeal of CDP 97-59, the Coastal Commission’s decision on the appeal did not require the gate to be removed or to remain open during certain times of Attachment D Rob Moddelmog August 1, 2025 Page 2 day. Rather, the Coastal Commission’s revised findings discuss a long history of a “fenced and locked gate.” The Coastal Commission ultimately decided to allow the existing gate to be replaced with an electric vehicle gate, finding the gate consistent with the public access and recreation policies of Carlsbad’s certified Local Coastal Program and Chapter 3 of the Coastal Act. Specifically, the Coastal Commission found in its Revised Findings on appeal for CDP 97-59 (Exhibit 3, page 7): The proposed project simply replaces the existing manual gate with an electric gate and therefore, it does not change the existing access. In addition, adequate pedestrian access opportunities exist in the area (as a vertical accessway from Ocean Street to the ocean is located about 500 feet to the north) and the public will still be able to access the beach as they have in the past. Therefore, the Commission finds the development as approved by the City does not raise a substantial issue with regard to consistency with the public access and recreation policies of the certified LCP and Chapter 3 of the Coastal Act. The Coastal Commission’s Revised Findings are consistent with California Public Resources Code Section 30212(a)(2), which provides public access from the nearest public roadway to the shoreline and along the coast is not required in new development projects when adequate access exists nearby. Notwithstanding the Coastal Commission’s prior findings and decisions, the Coastal Commission now asserts the city’s acceptance of the Beach Access Easement and Open Space Easement caused the existence of the gate to violate the easements. The Coastal Commission has not provided any authority for this position, and it is inconsistent with the Coastal Commissions prior findings and decisions. It is also inconsistent with the language of the easements, which do not require removal or timed opening of the gate upon acceptance. The Beach Access Easement appears to allow for the recording of additional reasonable terms, conditions, and limitations prior to the opening of the Beach Access Easement. Specifically, Paragraph 3 of the Beach Access Easement (Exhibit 4, page 4) provides: ADDITIONAL TERMS, CONDITIONS, AND LIMITATIONS. Prior to the opening of the accessway, the Grantee, in consultation with the Grantor, may record additional reasonable terms, conditions, and limitations on the use of the subject property in order to assure that this Offer for public access is effectuated. However, The Beach Homeowners Association, the current owner of the property where the gate is located and the successor to the original Grantor, must first be consulted. The Coastal Commission, as the permit authority for The Beach HOA project and the representative of the Grantee People of the State of California,1 is best suited to determine the appropriate terms, conditions, and limitations regarding the gate and initiate the consultation with The Beach HOA. City staff are available to meet with Coastal Commission representatives to discuss options for the additional terms, conditions, and limitations and to support the consultation process. 1 The Beach Access Easement does not expressly define “Grantee.” However, the discussion in paragraph of 6 the easement indicates the People of the State of California are the intended Grantee. Rob Moddelmog August 1, 2025 Page 3 Use and Condition of the Open Space Easement Your letter also asserts the city has been inappropriately using the Open Space Easement, resulting in harm to the open space. As acknowledged in the Coastal Commission’s Staff Report and Recommendation on Appeal for CDP 97-59, the city uses the Open Space Easement for fire and maintenance vehicular access: “It is the only beach vehicle access in northern Carlsbad and has been used by lifeguard personnel and city maintenance crews to maintain the lagoon weir which regulates the water level in Buena Vista Lagoon.” (Exhibit 5, page 9; see also Exhibit 3, page 7.) The city also uses this easement to maintain the city trail within the easement. The easement allows for this type of vehicle access. (Exhibit 1, page 3; Exhibit 3, page 7.) The city’s gate access agreement balances the need for the city’s emergency and maintenance access with the existence of the gate, which, as noted above, is allowed by the Coastal Commission’s past findings and decisions. During select fall and winter months over the recent few years, city staff temporarily placed three small lifeguard towers in an already disturbed area of the Open Space Easement without a full understanding of the potential conflict with existing habitat. City staff subsequently removed the lifeguard towers from the Open Space Easement and does not intend to return them to the already disturbed area. Further, aerial photographs showing the easement area in 2003 (two years before the city’s acceptance of the easement) and recently in 2024) demonstrate the condition of the Open Space Easement has noticeably improved, not worsened, with substantially increased vegetation and reduced disturbed areas. (Exhibit 6.) For the reasons stated, the city does not believe that it is in violation of any CDP or easement connected with 2401 Mountain View Drive or The Beach HOA parcels. The city wishes to continue collaborating with the Coastal Commission to protect public access, recreation, habitats, and views of the coast and scenic coastal areas, consistent with the terms of all applicable permits and instruments. The city will continue to ensure that lateral beach access is protected and enhanced to the maximum degree feasible; and vertical accessways, where applicable, are required in new development consistent with California Public Resources Code Section 30212. Additionally, the city will contact The Beach HOA in support of a Coastal Commission request that the HOA modify the Mountain View Drive gate entrance to resolve the pedestrian public access issue the gate presents. Please do not hesitate to contact me as needed to further discuss our recent correspondence. Sincerely, Marissa Kawecki City Prosecutor/Deputy City Attorney Rob Moddelmog August 1, 2025 Page 4 Exhibits: 1.Staff Report and Preliminary Recommendation for CDP 6-83-051 2.Planning Commission Resolution 4332 for CDP 97-59 3.Revised Findings for CDP 97-59 4.Beach Access Easement (associated with CDP 6-83-051) 5.Staff Report and Recommendation on Appeal for CDP 97-59 6.Aerial photograph of Open Space Easement in 2003 and 2024 cc: Geoff Patnoe, City Manager Sheila Cobian, Assistant City Manager Cindie McMahon, City Attorney Kyle Lancaster, Parks & Recreation Director Jeff Murphy, Community Development Director Mike Strong, Assistant Community Development Director Eric Lardy, City Planner Robbie Hickerson, Code Enforcement Manager Lisa Haage, Coastal Commission Chief of Enforcement Alex Helperin, Coastal Commission Assistant General Counsel ~,.. <ii:•. .... - f • Calif omia Coastal Commisiicn SAN DIEGO CO...ST OISlRICT ~ 154 M:5s,oo Corge Koad,Suite ~20 San D•P.Go, C.\ 92120 • (114) W(H,992 534 rlLED, 49th DAY: ls.10th DJ\Y: S'?Al'l!': STAFI' RZPCR'J': DATE: REGULAR CALIWDAR January 31, 1983 Wai~ed· July 30, 1983 ONL:lro Mn~ch 22-25, 1993 March 11, 1983 STAFF ~PORT ANO PRI:;LIMINARY R£t:.<!._-IHENDATION Application No,, 6-83-Sl e:~H\131, W ,, E ,, Applicaut1 Native Sun Inve:st.Jnent Group Agcnt1 Mike Mahoney/Robert O. Sukcp Deocription: Minor 1oubdiviE.io;1 of 7.1!>5 •lCrt? paz:cel into throo lots: Lot l - 2.2 acres, 1/.>t 2 -2.2 ocr~~ a~d Let 3 -3.1~ ~cres. Also, construction of 14 condomin 111"'~ m:d swimming p~,ol on Lot L Site: Lot area J,ot 1; Building cov~!rage Paveiacut '.:OVC:rago t.andsca1~0 coveL·age Parking spaces Zoning Plan designation Project dennity Ht: abv fin grade 95,8J2 sq.ft. 30,956 $1,ft.(32~} 32,967 sq.ft.(35\) Jl,909 sq.ft.(33\) J5 . R•J o-4 dua '(ne:t w/density credit) 2, 5 (net) 35 tt. max:lmum Parcel located no.cthwest of Ocean St./1-tountain View Or. J.nt~r- e~ction, Carlsbad, San uie90 c.:ounty, APN 203-0l0-i4 Substantive File I>ocum~nts: °City of Carlsbad LCP ... •statewide lnterpretive Guidalin~s °CCC/t6-81-249-Nativ~ Sun tlt.afl-~~ ~~g •P-~QVal. wi tl\ ~P'l-ditions ~~seing .~v_iH,41 .,~t.e ploi,s / publ.lc liability, open space easic111enls over the bluff hcc, runoff and grading controls, open space cas-,m(?ncs ovt.tr scnsiti•1e habitat/buffer areas, land- scaping, lateral access and public access in1provcmonts "I'!" -:''Y':'hc!t:!:.bgic.ll n:i tlgation (see pages 2 .. 'I ) for Lha spl')cfol conditfon!>. Ha:t-ol:, i _SSl.fP.•. f ~~lpde ~e ?)nt:Cllltf-Ot_i~n o.t.,.4evolQlffllont on µpbnd #l~eas, lcvalc,pmerit of ailtt"8t'\?9·,,-,n&fst\1nt with ·the eertifiucl 'LCP, tho retention ()f natural buffr.:r area~ and preccdential effects on th'-' LCE' implcincutatiou. ... ~' .- r--~ ~: : . •• • + . -------,,-------iiicr !· r EXHIBIT 1 t 'I .... STAFF RECOMMENDATION: The staff reccmaends the Commisdion adopt the following resolution. l. A~roval with Conditions. The Coll\llliesion J;lf#.:•ieby g·onts a pemi~ for the proposed development, subject to the condi~ions bal.ov, on the grounds tha~, as conditioped, the developmGnt will be in conformity with the provisions of"Chapter l 9f the Cc\lifornia Coastal Act of 1976, will not prejudice the ability of,~a local government having jurisdiction over the area to prppare a Loca~9astal Program confomtng to the provisions of Chapter 3 of t.hc Coastal Act,..-ahcl will not have any sig- nificant adverse impacts on the environment within the meaning of the californi~ EnviroJ11110ntal Quality Act. / / II. Stand~rd Conditions. See page 16. III. Special Conditions. The pormi.t is subject to the following conditions, 1. Revised Site Plan. Prior to transmittal of the permit, the applicant shall submit a revised site plan, ·any associated floor or grading plans which eliminate any alteration of the bluff fa,tl. by re-siting the units generally behind the 30 ft. contour line on thG northwesterly and westerly slopas_1 :(or as specifically shown on Exhibit C), relocating ,$,he proposed swialmig ~&«ec$8 i-~ oi--i;he blU:f:;up ~-~l~~-l~h~l~~ting the propo1::1E:.:. ~~~e-a'e1\'"tta'inra1• ~owards t3uild1ngs D and E in the vicinity of the eroded dir.t r~ad. Said plans shall be submitted to, reviewed and accepted in writing ·~y the Executive Director. 2. O~en Space Easement/Bluff Face. Prior.to the transmittal of a pormit, the. applicant shall record an irrevocable offer to dedicate to a public .i\~,~~1,_or ~o a private association acc~ptable to the EXocutive. Director, '&n .. ~,••e=-1mat~<!l!,~. ~~ bl~~ ~~acf as shown in Exhibit o. Said open space easelllOnt shall prohibit any .. alieration o! landforms, plocomont or re110val of vegetation, or er~ction of structures of any type, unless approved by the California Coastal Com:nission or its successor in interest. The offer shall be h:revocab!.e for a period of 21 y~ars, shall run in fa'lor of lhe People of the State of California, binding successors and assiqna .,f the applicant and/or landowners, and shall be recorded prio~ to all ot~ -~r liens and encutllhr11ncos except tax liens. The offor. to dedicate shall be .:.n a for.m and of I!· ,ntont acceptable to tho Executive Director and the ,1.;,--.. lfent shall incl :.Irle legal deacr ,tpeiona of both tho applicant• s entiro pe.1 c-'ll and the ea::ielft&;nt area. 3. Waivor of Public Liability. Prior. tu transmittal of the coastal development pemit, t.ha applicant shall submit to the Executiv~,D1roetor a deod re~triction for recording free of ~rior lions e~cept for tox liens, that binds tha applicant and uny successoro in i~terest. Tbe tom-and content of the dead rcstdction sh<lll bo submitted to tho review ,md I •- ... ' l il l -· i • • J §·I ,r.- ... -• I , -536 ·-6-83-51 I'age 3 ap~roval of the Executive Director. The deed restriction shalt provide (a) that the applir;ants understand that the site m,•Y be subject to extraordinary hazar~ from c:Ioaion and frOlll landslides ane1 th~ applicants assume t.he liability fro@ thonc h~r..irdsr (L) the applic:ant:s unconditionally wdvu any claim of liab.Uity on the part of the ComMission or ~ny other rogulatQ?}' agency for any dAl!lclge from such hazQrds, and (c) the applicants understand that construction in th~ face of these known hazards may lrlake thein ineli,;Jible for public diaster funds or loans for repair, replacement, or rehabilitation of the property in the event of storms. 4. Runoff Coritrol. Prior t" the transmittal of the parrnit, the appll~nt sh.all submit a runoff control plan prepared by a licensed engineer qualified in hydrology and hy~raulics which would assure that there will be no increase in pea.Jc runoff rate from the developed site over the greatest discharge expected from the existing undeveloped site as a result of a 10-year frequency stona. Runoff control shall bo accompli$hed by a variety of Dleasures, including, but not limited to, on-si tc catchment basiats, detention basins, siltation traps, and energy dissipators, and shnll not be conc~ntrated in one area. Sub-drainage syotems, if necessary, to remove groundwater frO!II the bluffs shall also be incorporated. Said plans including suppoi:ting calculations shall be submi tt.ed t:o, reviewed "'nd accepted in writing by the Executive Piroctor. Tho applicant shall ah.o submit, for his review and acceptance in writing, dctail~d 1naintc-nance arrangements for providing tha ongoing repair and mainte:nancc for all a.pprovod and erosion-control facilities. 5. Gradin<J Jtest.1:idions. ,a .. , , __ -~~-~.,,fi~~ shall l.;!c prohibi tad during the rainy soaaon trom '!1iBr Mrt'CS'i\l2-' . l' __ Tit m: ea~~. b) All gra~ed are3s shall be l3nascapod prior to OctoLer 1st of each year with oither temporary ot' permanent landscaping materials, to reduc..:e erosion potential. Such landscaping £hall be maintained and replanted if not we.11-ostablJ.shed by Ducclllber ) st followi1;g the iilitial planti-ng. c) All pel""lrulnent ero.-don control devices shall ha d~v.elored rlnd installed concurrent with or prior to any on··site grading activities. d) Sandba!Js, gravclbags .:.nd temporary drainage basins shall ba inst~lled along all !ill slop~s and along the shoreline of Buena ViGta La9O0n d11ring grading and ccnstruction op"!r«tions. 6. OE,cn Space Easc:ml•r.t!.i/llabit..1t Prot~cti~n and Ruffl"lr Areas. Prior to ~ansmi Unl of ca 1>crn111·, the applicant shall record ~ it:;:r,o~ocable of far to~ J R AA-~-4~-J~:F.-v-i~m9y, or to a private assaeiatiotr·l(~le•to t.ts~f bl:Jl~ ·1n ·ogen apace casol!IOnt over ~t·l,cif'the·proposcd sub- on ilS shown on" ~xhrn1t·~.i. .. 1-'S'a11d o~cn ·~r11'co ·•~a~cnt sh.111 prohibit. any altcr.ition of landforms, th<? pla.:.-em~nt o.t· removal of vegetation ~xcept as spoclficd heroin. Thtl irrt:voc.11..>lt? offer to t1ccUcc1tc an open epttcc easa:ment shall include condiliom1 px-ohibitir.•J any futun• l«nd divisions, commercial or residential development but t.!Xprc!lsly ro~oCJnizin9 the r i ght of access to the weir for mc1intenclnct: l'Urposas. It shall a loo rccogniz.o the right of the accepting c1qcncy to conduct act:ivi t.ic•!i within thu oprm spaco arNl whieh ,1c.,uld cnh,tncc tltu l.:1gocm hJbi L,1l hy <h:"!.!ll<J.in•J c,r <.>lh<.:i-wi~..: removing fill, • --! II ·-53? 6•83-51 Page 4 . . The offer shall recoqni~e tha~ tha erection of soma public access iU1provements may be allgwed, in consultation with the State Dcpa~tJllont of Fish and Game, and aubjaet to Coastal CQ!mlission permit requiTements. The offer sh4l.l be irrevocable fer a period of 21 years, shall run in favor of the People of the State of California, binding successors in assigns of the applicant and/or landowners, and· shall be recorded prior to all other liens and encumbrances except tax liens. The offer. to dedicate shall be in 6 fona and of content a~ceptable to the Exocutive Director and the document shall include legal des~riptions of both the applicant's entire pQrC~l and eaaement arus. 7. Landscaping. Prior to transmittal of a coastal develop,nent permit for the subject project, a detdiled landscape plan indicating the type, aize, extent and location of plant materials, the proposed irrigation ayatem, &nd other l&ndacape feat~es shall be submitted to, 'rcviowoa, and ~ctermined adequate in writing by the Executive Director. Drought tolerant and salt-tolerant plant materials shall he 11tilized to the maximum extent feasible. e. Latei:ul Access. Prior to transmittal of the permit, the Executive Director shall cextify in writing that the followin9 condition has been &atis£ied. The applicant :h~ll c:::~ut~ ~.d =~cQ~d a dac~nt, in~ fQr• and content approved by the Executive Director of the Corn111ission irrevocably offering to dedicate to a public agency or private association approved by the ~~utJ.va . D:,rect.or, ff e~!em~t for public accean. and .,I:'-~~~-~¥-.J!Wl \we::~119.na~'ll , st} Y,z31'ho clocumeh"·"shatt also · restrfct tho applicant lt~fu-rni.er\Yring with prcser.t use by t.he Puljli~ of the a~eas $u.l,ject to the eaawnon~ pric,r to .icccptance ur Lh•-· offer. 1~ ea1•--m~:.,l:'li~!! J:t .J.rrt.!-'d/ .... w~~~ .lP~. 2 ~~-,Lat { of the proposti~ s'llbdlvision, as shown on Exhibit~cnctea8f!lllent"sha11 be recorded fra::-.-.f prior liens e>tcept tax liens and free of prior enc.umbrancas which tht:-• ·•:Gc:utive 1.'irector determines maY-affect the interest being conveyed. The offer shall run .... with the la_nd ·1n favor of the People of the State of California, binding successors and assigns of the applicant or landowner. The offer of dedi- c~tion shall be irrevocable for a period of 21 yaar~, :u::h period r,..1.n.n!.!!'J from the date of recordi;-;9. Th~ document !iha.ll include le9al descriptions of both the applicant's entire fldrcel and the easement area. 9. Archaeological Resources. The applicant shall comply with the adopted mitigation measures on cultural resources in the certified E.I.R. for the project. IV. Findings and Declarations. The Commission finds and doclarcs as follows: l. Project History. The appllcclnt has previou:lly applied for a coastal development parmit (16-01-249) for the same proj,~ct on the site lasl: yoar. In June 1982, the Commission conditionally lpprov~d the projoct with two alternatives for the construction of either 14 or 10 condominiwns on the upland portion, dopcndent oo the incorporation of an adjacent par~ol (corn111only rcf~rrcd t, us th,• "Tcn.a•Jlin" property) with thr. projC'!ct. situ, consistent with th\! ccrtifiud Carlu~ad t-CP. With the excr.ption of the I ... ! i : r- Ill • :;1 . ·-. 538 . 6-83-51 P,r;qo S ~U: . .1:fV,!.,1tiona«5.9. .F.Q~Wtl,~~$P-\)fft.iea, ~ho -,.•ta4at :~n C 1-tloae-,ct,.,J a■ 11M tr 7:±f~~ pN>pOJ,,ed h~mint . . .Tho prcvi~usly approved condition:.; to. resiui~~ PF~perty c_on.so~i~~-uauat/i ·J_!.C!Li;be, qst~ ~ls~ La .~lic}:~s and "' ~~~~~!',. ~~ra!U'-dispute -,ma-T!Hgal~~tween-·~h~ applic~nt, ~ltle Insurance and Tru3t· Company and the State Lands Commission. l\s backgrqund, Native Sun ,~ri9inc1lly took out ti.tle insurance on th~ adjoining Tcnagli.a site ,.I\PN's 155-190-06, 1!;~-101-62/aee Exhihit G) and intended to collllllit it to opan space ~s a t~adeoff for developing the lowlands area, CQm~ri9ed in tha proposed Lot 3, in their firse local govern• merit submittal. However. dnring th~ original propo2al' s r1.:•1iew by the City of Carlsb~d, the applicant stopped mo1·tga9e payment.a on the "Tenaglia parc~l" after the State Lands Commission ass~rted public trust cl.iims. After Native Sun stopp$d payments, Title Insurance stepped bc1d; in and purchased the Tenaglia ptoperty and it holds the actual grant deed while Nativa sun possesses title. As a result ~f these circuMstanccs, Native Sun is in litigation against both the title compauy and State Lc'.lnds with Title Insurance representing them against th'l Lands Commission. Although th~ original coastal devel~ment permit application (#6-81-249) did not includ~ tho adjoining pa1:c:el, ~! .. fr~~se": i-0.1:_)J'~! __ sh~ ~1 "~•~!1 for future J ~~~;r' ...... ,Sh .... ;'< u • ,.4 !' • •' • • • • •••••• :. • . r' • r .,_-&iiii.1 I t:Wiiil}I ' Whilo the applic~~t finally Ayteed to the open space easement over Lot 3, they contended that commiLting to an open spac~ easement over thn adjoining 2.65 parcel ("Tenaglia property")· would damage their position with Title Insurance and Trust Company. specifically, the applicant is litigating that it 1id not r«:~cive f ee title to an Wh::ncumbcred parcel of property and the property should not therefore have been insured. Once the applicant learned of thE: potential public: rights over the property, they stopped payments and the original own~r. began foreclosure proceedinqs. However, ~s pr;eviously noted,_ Title Ins urance stc:ppcd in, paid off the origit\fl. seller and now huldH the nott:! and security on the parcel. ·~'l'herefore•, t11thOUib.,.tba.~9.U~ ))ol4i no titla to the adjoirµ.nq pa:-cel and indicate~ '::~iA1:-~~,t~t.a,1~0 o~q space, .. tJl.,Y .f?~d ~~r ,~~U~G_,_~¥, !~"f;t ~>:~' -~~t~-~ o{. 'l;~~:;Jlpa~tn<:a_ ae a th!:td ~ti•'/ Under t~o:3e circumst.r,mccs, tiAl;4m>1!can~.))Etiicves any agrecaent to cc,mmi t the adjoining parcel to op~n space would damage their lawsuit, since Title Insurance and Trust Coroi,,,ny could ass('rt that its commi tmcnt is only part of the developraen~ prlce for th~ permitted condondniums, rather than any title defects on the p.ropcrty. f'urtilcr, the applicant continues to contend that Title Insurance, as holder of the note and secur.ity, will only co-sign on the open space cas cmunl vffer if tho applicant scttl~s thair la~Auit, possibly losing a substantial investment. Tlu.is,J l.iwsttits aro st ill pending and th~ i~t1uea. remain unn.solvr-d. ~ Given the applicant's d~clarationa of ,1 \heiJ ~1.edJ:flbi.:.ity to e~cc:;t1ta . ~h,t:pe_c;~sr--ary Pta;eementf!. bocaus_e of th~ . JrisoJnst,M~ , • ~l\~i~ ~eaif~ to 9ain opproval for the or,igidl/ ~!! .,,.~-~~Jl~!'.~f~~flitqd ~~ ~cc~8~}1.1~,r:2~a,1:,: IM''.:, I li-iigi~ , . , -~$1\I,. f:'IIV~, . . •· a ,- 2. Detailod Projn-:L Doscriplion/Loc.,t ion. The applk.:uat is rr.t(Juesting approval of a 111inor subdivisio11 of a 7 .65 acre parcel into throo lotu. Tho lots wodd bo divjde<.l as follows, Lot 1 -2.2 acres1 Lot 2 -2.2 acr,ni and Lot 3 -3.25 acrci. The ilpplk.inl then propo:;c·s to c:011:;truf.t 14 i.;ontlcw;lnium • ---··· ':"l"-# -·-.. -.-..... • •• . a....----..-.,...--. ( ---- --,----------·-. ·---i:-:r,..._~ • 6•83-51 -~· ·.,,v .. 539 Page Ei \11\its on Lot l. Th~ subjr.ct property is topographically dist~ngQi&hed b~ two areas. An upper bluff extend~ out from Oc:ean Street and fronts along the .beach. The second ar~a, app~oximately 10-15 ft. below the bluff, consists of sandy/rocky beach areas terminating at the wood weir on tho inouth of Buena Vista I.agQon and then extends eastward to some lowlands abutting the lagoon behind some adjoining aparcmcnt9. I.ot 1 generally co~prioes the upper bluff area and the proposed condatniniums would be developed priu,arily on its level mesa. The applicant proposes to dedicate tot 2, comprised inainly of boac:h area. land t.ho lagoon mouth, to the public for open epclce. a-o;J.giA&l.ly 8Ubmitted, the applicant proposed to reserve the remainfng ~. ~$ ·-•~•' • ·Qf {~,.a. 9,1; .,•~· for poaeible· t'uttn"d •\favelopment ~:SJ, ..... lit)ll:--~~.fo# ~Ql,J.lo·--Wo.~opa;...-· . ses. The proposed 14 condominiwn units will be comprised in seven townhouses (or ~common-wall") structures. Ten of the proposed units will have two bedrooms and living area between 2500-2600 sq.ft. The remaining four units will havo three bedrooms and approximately 2,850 sq. ft. living area. All of the unite have two-car gnra9cs and 6even open guest parking spaces are provided on the site. There is a single access point for the project from Ocean Street. The proposed condom.lni\llDS are mainly comprised in two living floor areas with some spilt-level entrances and garages. However, because of the Tudor architectural dusigr., the structures' roof peak$ will reach ft maximum height of 35 teet above grade. The submitted site plan delineates the construction of ten unite along and over the bluff top (refer to sections) a~d the remaining four units are located along the southeastern property line. As Gubmittcd, a retaining wall of varying height will be constructed along the bluff face. There will be minimal grading perfotmed on the property r~sul~in9 in a bal~nced 4,000 cu. yds. of c:ut ana 1..1..U, An -4V-.:ra9e v,. two feet of cut and fill will be done and most of t~e fill will be deposited along the southeastern cornP.r to elevate Building~ F and G. As subtnittad, the sito plan incorporates a conunon .pool/deck area situated within tha ocean bluff face and private beach access itairu which trav~rse down the bluff to the shore~ine . . For background purposes, the applicant had previously submlttcd a 40 Wlit condominium projec:t on tho subject site to the City of Carlt;bad and for draft consultation with Coastal Commission staff. .l\t that tim~, the project dte included not only the subject 7 .65 acre parcel, but an additional 2.65 acre property (sec Exhibit G) located adjacent to the lowlands area of the proposed Lot 3. ~lhile the. acreage is Gtill owned by the applicant, it was not included in the current application. The originally proposed 40 ut1its were sited on both the upper and lower portions of the property. Due to exprossed concerns by tho City of carl9bad, Cosnmi~~ion staff and interested parties relating to beach erosion, public lands determinations and visual iD1PDcts, among others, tho applicnnt subsequently vithdr'1a' the project from the City. The original 40 unit project was never f~rrnally submitted to the Coastal commission. The Pointe San Halo project is located within th!! City of Carlsbad on the south sido of Buena Vista lagoon and adjacent to thn ocean (sec Exhibit A). Tho par~el ia located northwest of the Ocean Street/Mountain Viow Drive intersection. on tho wcat, tho site fronts t'n the ocean shoreline:, and on tho north, it faces tho lagoon, an "ecological rcscr"c", oppot.ito tho • ,. .. ! . r-: r-! -' . . . ~ . . •·. I ·:·•· · ...... Ail &Ell&. ,-540 6-83-51 Page 7 exinting SJn Malo rosi~ential area in South Ocannsido lying on the north sido of the lagoon. A public teach accessway abuts tha southern property line. Multi-famUy residontial dovelopmont is located to the east with the lagoon ·and railroad tracks nituatnd Curt.hex-to t.he northeast.. 'l'h&r'! aro single- family residences situ.atQd to the south and ~cross O<.·oan Strc~t to the southeast. l. Geolggic StabilitX• As previously stated, the Gubject site can generally be divided into two topo9raphic areas. Tho upper level, a coastal bench, i& actually part of a larger b~nch which terminata~ at this site. The top of the bt:I\Ch aloros graduc1lly northward with slope gradients r<loging from 25-45 pe1cent along the ocean. The sccontl lopographic area .is the lowor lcvc~l consh,ting of the ocean, beach and lowlandn fronting the laqoon. The beach •rea cwn be best charactari~eJ as A p~bbly ono with only a limit~d a,rour.t , f eondy area. Tho project site i9 overlai.n Ly throe dlffere:tt soil sories - Marina Loamy coarse Sand, 'l\nrc1c<: t:scarpmonts and Coaotal Beaches. Mot.t of the project area is covered by Muina Loamy coarse Sand which is found on the gently sloping upper b<'nch and has a rnoder.ito oror.ion hazard. Thu Terra'-c Escarpment soil is found near the western boundary and is characterized by staep to very steep slopes in th~ southwest corner occurring on t~rrace fronts 01· alluvial fans; it exhibits a scvc;c erosion hazard. The third soil type, Coaatal Beach~sf found along th~ lo~cr !ev~l is cc~po~ed of ;r~~cl or sand and is susceptible to tidal inundation from the ocean, it alno ~xhibits severe erosion characteristics. Th~ certified carlebad LCP specifies the.nead for new development projects t~ subll1it a site-spe~ific 9colo9ic investigation, to limit ahoreline structures, and to ~xecute ltaivers of puh.iic Hak>ili l:Y. Adch uonauy ~ 1-'0 I 111y 4-4 sp~-::1 ft!:S "no development shall be permitted on any sand or rock beach or on the face of ~ny ocean bluff, with the exception of accessways to providt'l public beach access and of limitod public recreation facilities." In reference to this specific site, Policy 7-8 sp~cifically states "residential dP.velopment shall be clustered on the highland area and the bluff face shall not be ~ltered [and) t-.hern s'1all t-"" ~ppr()p!'!i!t~• bluff top S!:tbac:l-..!.ba~cd en g!'o!ogic reportf: taking into account the prominent location, shoreline instabil.i.ty and signi- ficant habitat adjacent to thl? lagoon." Additionally, Policies 3-1 and 4-7a specifically state the development of slop<!s greater than 25\ incline shall be prohibited and such slopes be left undisturbed. These .LCI? policies rcpre!;cnted the incorporation of the Act's policies (Sections 30235 and 30253) into the general plan. As detailed in the JJroject "dcscriplion, ten of the proposed condominiuni:1 aru sited directly on or over the ocean bluff top and face with a retaining wall constructed Uong tho ocean frcnt!lg<-'. 'l'hc proposed retaining wall was primarily designed tQ .:llo.; some backfilling to crccltc a4ditional yard a~ca for the future condominiums on the hluf! top. Uowovor, as submitted, tho proposed development woul<l th11rcforc bo inconsist,mt with the certified LCP policies, sinco it would involve alteration of erodible and stacp slope~ particularly located ·a.long the property• s wci.turly bluff face and could therefore precipitatu coa8tal erosion. Special Condition 11 requires the applicant to redesign tho site plan and construct th<J proposed units behind th~ bluff top, relocate tho swill'IJ!ing pool/du~k away from tho bluff face and rr.locato tno private beach acccssway. G~n~rally, the Commission dor.s not and tho certified LCP doou 11vt cnJorsu ll1,i c.:~nstru~t-ion rJf priv<1tc acccs s .. m1:;. • Jill r- 542 6-8J-5l Page 9 located about lOO feet cast of the weir. Portions of the adjoining property ~o the ocU;t also d-cain into the lagoon via this oxistin<J pipe. Buer.a Vista Lagoon is considered thn northernmost lagOC\n in San Dlego County, and in some wayo is not typical of most other lagoomi in the county. ThQ lagoon is composed of fresl\ and brackish 1-1atcrs, is not open to the sea, and it.s nonMl surface level is approximately six fe~t abov<:! HSL. At the mouth of t.ho lagoon iu a sand beach barrier which was natur::.ally formed by wave and littoral cutrcnt action. A wooden weir is located within a manmade channgl at the n1outh ~f t.he lagoon which permanently cmpounds watuE in the lagoon c1.nd controls th3 wat.~r lc"el. A land area of approximately 22 squar~ miles drains into t.he la9oon through Buena Vista Creek. The main Murce of water in the lagoon iz land dr~inage, agricultural runoff and rising g~ounewatcr. Buena Vista Lagoon has been designated an "Ecological Res'et"vc" by the State o~partment of Fish and Game. It is both a valuable biol~gical resource and an aesthetic open space element. As is the cas~ with all of the lagoons in San Oie90 County7 Buena. Vista tago~n has been adversely affected by increased deposition of sediment resulting from agricultural and suburban developll'ent in its watershed. Primary effects of this development include the infilling of the lagoon and a reduction of its total volume and the introduction of various nut%ients or pollutants which contribute to periodic algal bl~pms. The primary off~ct! of th~ pTnpnsod development would be the alter4tion of local drainage patterns, increased runoff due to th~. ·~resonce of impervious surfaces, tha exposure of soils to increased erosion and the introduction of incroas-ed levels of urban runoff.pollutants irito the lagoon • . The certified LCP for the City of Carlflbad contains several policies relating. t.o grading requirements, drain11ge and coastal erosion. Polic}· 3-2, in reference i:o develo~ii\°ants located along the first row of lots borderin<; the lagoon, incl1,1din9 the subject parc,~l at the motJth, states "storrn drain alignments ... which '-lould bf:! carried through or empty int.o Buona Vinta Lagoon shall not be permit:t.ed; ... " Policy 3-4 prohibits any gz:4ding act.i vily during the rainy season and requires the inunedi~tc revegotation of graded arr.an to zcducc erosion potonti<1l. Lastly, Policy 4-7 also states that no development shall be 1~.mitted w.i Lhuut $11LmlLt. .. l of ac.::~f,table ru,ivff co,,trvl pl.;;;;;, maintenance ag~eeMents ~nd certain specifications f~r the installation and operation of runoff control devices. The tcP policies ware derived from the resource protection and water qualit.y standards (Sections. 30231 and 30240 (,1} {b}} of the Act. As previously stated, although the applicant will be performing a minimal amount of grading over the site, the construction activity occurring along the bluff face and top, will present a significant erosion hazard. The con- struction activity and 9rad.i.r.q operations will thus establish ahort-t~rm iMpacts. Along with the required site plan redesign dn~opcn space e~sement <.Wet the bluf.f face, Special Conditions 4 and 5 rl?quh:u the submittal of a runoff control plan and establish. r~strictions to detail the time and method for the grading activity. With these ~onditions, app~opriatc erosion controls will bo established to mi ti9ate the short-t.e~ impacts of grading and prevent further &iltc1tion of the lagoon. With regard to drainage and runoff, tho project, as submitted, inc;Jrpot·ates roof down-prain systems connected to the stonn dratn nnd a requirement that a drainage outfall shall bo ~csigncd to discharqo at a point w~st of the lngoon weir. Sinco the dis- charq~ voint. is wctit of the wdr, the 1,ou•11li..1l for ,rny lr.,ng-tl?t1TI imp..ic:ts to the closed lagoon will L>u offectivdy miligi.lll!d. 'l,,a sul>mittal of a runoff , ' -~ ·J.·.° __ ·:· •-•. • ' • I . -' ' ..... ~ 543 6-83-51 Page 10 control plan wil-1 serve to document the effectiveness and oporation of the 4esigned drainage s1stem. Thorafore, given the rP.quired runoff and gradir.9 controls, along with the submit~ed drain~ge system, the Conu:nisnion finds the proposed development, as c:onditionad, consistent with all applicable LCP and Coastal Act policies. Fur.ther, the Commission thus determines that the project approval, as conditioned, should protect the bialogicAl product.- iv.Hy and ql.l4U.ty of the lagoon and other adjacent environntcntally sensiti..,.,1 habitat values ~y controlling runoff and effectively mitigAting cff-sita impacts. 5. ~iolosi,isal Reso_llrces. Although the existing vegelation on the site • consists primarily of non-native grasses and weeds, two regionally significant habitats, a coastal lagoon and coastal strand community, do occur on the subject property. Only a sma.11 port.ion of the lagoon habitat, however, actu.illy lies within the property bound,:ir·1, but activities on the • property could affect the quality of the entire habitat. This seemingly small l~goon located in and around the subject property, i9 actually a portion of the larger Buena Vista Lagoon, which has been di:. tlssod as essential habitat for the Califo~nia Least Torn. The lagoon also provides nesting and foraging habitat for other avian species although the quality of this habitat is decreasing due to continuous d~velopment along the edge of the lagoon. The Pointe San Malo property is one of the la~t vacant areas along this portion of the Buena Vista Lagoon. Additionally, the coastal strand habitat is a plant community which has beco~e rare in San Diego Coundy due to development along the coast. The community consists of plant specias which are tolerant of salt air and sandy soil conditions. ii:his habitat is located on the sandy soils near the base of the west-facing slope. Although the coastal strand habitat on the property has been disturbed by hwnan activity, it still c:ontaims zieverai oi the plant speciel'I charac~E:riscic of 1:hc coas~al stranci community. In reviewing the po!icies of the certified V.::P, Policy 3-2 specifies foe devel- opments located along the first row of lots bordering Buena Vista Lagoon, including the subject site, as follows: ~-------------- Development shall be clustered to preser~e open space for habitat protection. Minimum setbacks of at least 100 feet frolll the wetlands shall be rcquirf.'d in all development, in order to buffer sensitive habitat ftreas from intrustion. Such buffor a~eas, as well as other open space areas required in permitted development to pres~rve habitat areas, shall be permanently preserved for habitat uses through provision of an open space easement as a condition of project approval. 'l'he density of any permitted development shall be based upon the net developablc araa of tho parcel, nxcludin41 any portion of aparcel which is in wetlands. As describ~d in Policy 3-l, a density crodit rnay bo p~ovided for any portion of a parc~l which is in steep slopes .... Land, divleions sh~ll only be pcmittcd on par~els bordering the Lagoon pursuant to a ::;inglc plannccj urtit dovolopm~nt pr.rmit .!2E., tho t:ntiro odgin.'.ll 1,c1rcd. (cmphr,.Gi~ ~dllcd) • ·------·---~-• --~ --------· ---~- .. _,.., -... ·-:~· .. ·.·,:' . -.· .... •, ... ' ( ;··- ,,..- -544 In addition to thitJ site spttcific: policy, Policies l-1 and 4 77a ag<lin prohibit grading of steep slopes and Policy 4-4 prohibits developmont or. th~ face of any ocean bluff. These LCP palicies were derived from Sections ·302Jl, 30240(a) and 30240(b} of the Act which require th~ p~eservation of habitat values by maintaining natural vegetation buffer areas and prcven~ing off-site impacts to environ.mnntally sensitive areas. As submitted, the project would involva elimination of the eoast~l strand vegetation on the west-facing ~lopmi and rescrvfl the lowl,,nds area, comprisin9 Lot 3 of the proposed subdivision, for future dcvclcpment:.. The project would therefore bo inconsit.tcnt with the crrtificd LCP policies and resource pro·· taction policies of the Act. Howcvert with the attached speci~l condition to preserve thll bluff faco a$ open space, the coastal strand community will J:·e minimally impacted. As ccndi tioncd, the Col!1111ission has also requirEld Let 3, consi&tcnt with the sitc-sp..:cific, certified LCP policy, to be committed to open space for habitat protection and natural buffer area. With re9ard to tho inclusioa of lhe adjoining parcel, along with ~ropoaed Lot 3, and their commitment to open space, their consolidation would fulfill and implement the certified Carlsbad LCP. However, given the a1:.plicant•s limited ability to properly commit the adjoining property to open spa~e duo to the existing legal constraints and the Commission 1 s previous approval which offered two alternatives. on~ without the lot consolidation, the submitted project, in and cf itself, ~~y ba few.ad ccn=i;tQnt with Chapter J policies. With the open Spfce restrictions on Lot 3, the project will incorporate adequate natural veget.ai.iVt: buffer areas necessary to mit.,igate. the impacts of construction and increased human activity near the lagoon and penanently preserve cr:i ti cal ,:ip-2n ~p;i,·•e r:or.ridors. 1'hcrcfore, as conditioned, 1.he Commission finds project approval consi.atent with applicable Chapter 3 ,iiV1.l~ieo. 6. Visual Impt1cts. The proposed condominiums arc situated on a prominent e..icean bluff and also located within the Buena Vista Lagoon vicwshed. Although the proposed units arc generally clu~tercd on an upper bench level, the prQj~ct, as 9~tted~ ~ill elter =nd cn~~c~;h ontc thn bluff face. ~s previo~sly stated, the certified LCP for Carlsbad specifically requires that development of thi$ $itc bo clustered to preserve open space and retain the natural landforn1s of the ocean bluffs (Policies l-2 and 4-4). These policies wore partially derived from Sect.ion l02Sl of the Act which mandates the protection cf public views, the preservation cf scenic amonitics in coastal areas and the retention of natural landforms. As conditioned above, the project will be raquired to setback from the ocean on its blufftop, preserve the nceiln hluff face in its natural state and retain the on-site lowlands ~s open space. These conditions will largely miti~atc the project' a visual impact by clustering tha units away. from thQ uluff line, thus rninimizing it8 intrusie;n &long the shorn line or within the lagoon view~ shed, and by retaining the natural vcg~tation of tho area to serve as visual b\lffors. The applicaat contends that the submitted site plan conforms tc t~e existing atring1ine of development along tho shoroline. Whila the adjacent residences to the south and ~he existing San Malo residential comm1:111lty to the north in Oc~nsidc across tho mouth of ttcc laguon do extend furthQr scnward than the proposod development, the subject sito does not rcpl'csunt an infill area. but, rnthcr, it is vfowcd aa on cxtcnninn of dovclopmcnt northward at .:i critical lnl1..:rf,1cc ln:twucn th,.: oc,1J11 i.11111 t.hll la,goon. Therefore, not only !or hauitat and resourco prote:ction }-iUrposos, .. ':'.J ._!.:. 1 .. ,· 546 Sections 30210, 30211 and 30212 of the Act all require tho1t public: acccso to the shoreline and along the coaJ;t bQ maximize~ ,mti ptovided in al.i new dov.:il~pft+Gnt.i;. Although the propos~d drn•eloprr.cr.t will not obstruct use of the existing public acccus casement alonq it:; southern boundary, the d.cvclopment will certainly inhibit. lat.cr;il acc<?ss along the ocean shor~line or lagoon either indirectly by proximity or directly through private attempts to rt>strict public beach access. Therufore, in order to be consistent with the ccrtifiod LCP, to maintain public bl!a~h access, r~cogniz~ and protect the informal use of th~ site, spllcial conditJ.cm. havcbc~rn attached to 1<>q11ire thQ provisi<.m ot lateral accessways along th~ shoreline: and lagcon lowlands. r'urthc1·, tc enhance opportunities for public uccess and recreation, it is recom . .-ncnded lhut, along w:tt the provision ot lateral access, an access trail or other r.ccessary public access improvements ba developed on the aouthc.i:ly side of Du.ana Vista Lagoon, consistent with resourcf! protcction policies and in consultation with the State Department of l'i!;h and Game. Therefore, as conditioned, the Commission find:; the proros(:d dcvP.lopmcnt con.-;istcnt with applicable LCP and Coastal Act policies since adequate vertical acct'!ss alread1,· exists and the project will provide lntcral acccs~ opportunities. Further, as specifically required by Section J0604 (cl of the Act, the Commission fi11ds the proposed development confor.n~ with all the public access and recreation policies of the Act. e. P.cu~ing. The proposed d•.:velo1,munt provides for tho construction of fourtE'an condorniniums on a vacant parcel. under previous Coastal Act polici cs and the adopted Statewide Interp1 . .-€?tive Guidelines, the queslion of affordable housing protection c<>uld have ll,'!c•n raise~. Howc1-·cr, recent legi sl.:ition has tr.:.nsferred this responsibility to local gov~rnments consistent with Section 65590 of the revised Government Codo. Further, pursuant to Section 30519.l of tha A.:t, thGaw ::-~ulatc,,y tc-::vl:.ions w~r~ itlso applied to the certified Carl:;bad local coastal program and any previously approvc-d .i.ffordablc housing LCP policies deleted. Therefore, the houlling issue is no longer a matter o~ coastal policy revfcw. • 9. Arch~ological P.escurcc::. As " result. u1: ~omu p"eliminary re!learcn and s i tc inspections by qualified archaeologists, one: archaeological site was locat,:d. Thi$ site, SDi-626, was originally recorded by William J. Wallace iri 1958, and is located in the upper a.rca of the projc-ct at the western and southern e~-tent of th~ property. Surface 111(1tcrials included flake ston~ arti far.ts, bona and shell, and there is a pot;:r,tial fot· a depth in r?Xcess of 50 centimeters. Th<? surf ace area of th•~ suLjc.;ct parcel is obscured in places by a thick m.it of grass, and the ground vi~ability in tho «roa of the site wan limited. Bc::.::1use of thi:3, tho acJ:ual extent of the: site and the degree to which it lt.\3 been impacted c;.mn-:_,t. l.;I! determined without somu limi tnll subsurf'1CEI testing and clearinq of the grassf:s. It i!. impossible th<lt the si9nificant portion o! the site haa been r.cmoV!.!d, and th~t only lirn.i.tcB, dlsturbc>d ntateriah; ren;ain. Dclinc<1tion of this disturbanct', howl!ver, rnquirc~ additional investigation. Special Condition 9 requires that, in order to appropri.dtcly study ancl d,Jt1.:rminc the f,i(Jnificanco of t1i,~ site, a~l the adopted mi ligiltion measures of the E. I. R. be met. With its provisions to complete a limil'cd suhsurf..lco sample and any Curth~r information rctrleval, the Colill-nission find!. the sito I r; archaeological. rcsourcc:s will LE: appropriately t,,rot~cted against adve-4ac impacts. 10. Local Coa~:t.ll l'launin!J_, Section JOti\14 (<1) of tho 1\ct provid,:s Lhat a .r- ~ r :, • t ~ '• .. ,,_,.: -I I Iv• 548 6-83-51 h9e 15 adjacent lagoon, provide ade<\uat.e landscaping .~11d design revidons to enhance and prcsci:ve the sceriic a,nenit,ies of tha ar.ca, provid~ ad~quate parking ru1d .fo'111alhe public ac:cess op!,iortunities. Ther')forc, the Cotn!llission tinds project approv~l, as conditioned should not seriously prejudice the implementation of the Carlsbad LCP. With the ~Kclusion of the "T~naglia Prdperty" from the proposed developmont, the Commission is presented with the possibility for socno development propoaal to be submitted on the (•nvironmentally sensitive "Tenaglia Proporty" far review at a later date. Hhile the Commission wi 11 not and cannot evaluate the permissabtlity of any use on tho "Tenaglia" site, not p.;esently within wetlands, the Commission does want to 1,1rovide direction to future applicants ahout its position on the property in qu~stion. Although a density crodit of l <lua for each net devclopable acre ur.dcr the certified LCP was previously assigned to the "Tenaglia ~it~" t,!hen it was proposed for transfer to the blufftop as a density bonus for l:he lot consolidation and implementation of the certified LCP, the actu.ll project impacts of any physical development on the site are much more critical. Thercf<lrP., only very low intensity uses, ~ch as possibly a single-family resid,.mco, educational-science research activities or nature study, are appropriace for the uniquely-situated and constrained property. Given its 1:Jhy::.ica! dclinP.ations, a single residence c<lu\.d evcm reprosont inappropriate overdevclopment. Further, any proposal must address and adequately mitigate the id~ntified issues herein and merit independent approval based on sitP.•specific Commission review. .r-·· . . I ,- " i •'.! .,, •.~~1 ,:··-.. v; ~ 1. ·._ •• • C • .. . , i I I -.._ I I . • ! ·'\ •. ·, , jBIT NO. A ,. • APPLICATION N -PJ-5/ " h-I-J4 J.c&.✓ lk t ,t(f}v ~'\\\ I Commi::Jon u.'-l.t: C111ifornl:i Co:tSl.:i ... . }.p I ~ ... . ,,, - CL·'{-~ I.CF.a~ •-"\ ' '-'\. ,_,.,..,_,._.....,_- \ SJ' r ~•'~'/\- •lo.: 7 .. ••u ~• .... ., . ....., • .:.N, . ~~ A EXHIBIT ·No. C APPLICATION NO. (p-fJ-'J..l/11 rrB-J-51 E 'I .. ~ t,· J;.#,tLI.. C t::.(,Jy / fl,/-1 . I -_, c1[C Califtltnln C1uu1tnl C1,mmfoGI01t C rn I r- .. \ . . .. ,f !.. . .J 553 . .. ... • .. . . I • . . . jt;- --- ff , __ _ .... ./'\. .... t /r \. •~1•m ~ l { ~~~o ,.,~ EXHIBIT NO. D APPLICATION NO C,.-8' - " • " ~~ !Jalilornll\ Constnl Commlor;lon ... P't-"iiWWWW ..,. ~,.-, • .. -~-··•-·. . ----· -·~--. .. ..,.,.. • .,.,.. I --, -,._ f -. - -.--~:.--. --~-__ s·-_J_-'~------ • •. * &--~~r:::,:: . . :t· • ! ~ . ,{ . J _-Ja---' I •• KJ (Ii- . .. EXHIBIT NO. F(L} APPLICATION NO. ~ -f I-~Lf ~"63J/ J.tUtra,/ IUC-1$5 v-.. ~ ~ ,,,.r~ ). ,l,.,d ?) ~~ --"-:4..~ Colltotnli\ Col\$1~1 Conun10~1on . · . . ._...,.. -.. ... 'I •• r-. ~ ,; .. . '. ' ~ .• --·· ~ ....... -~~?'-,¥' .... ;,r w • ,. ... ly • 555 I . ... ' ,1 .n• I-I • I . :~--- EXHIBIT ' NO. Et~ APPLICATION NO. 0 "5 I -) J./ 1}t,i~5 / c9,,w! .... ~ce., ..1?d.1t11~ : ?-t_ /,;~,_1/_ {'J_'f ., ; J. ~---t1/ A f ] ~~ I\\ ~ C1difc,rnln Const11l Cc>1nmi:1:ilon .. I i ' -.. ' .,-.. L~-. ---------· -... 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 e 0 PLANNING COMMISSION RESOLUTION NO. 4332 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CARLSBAD, CALIFORNIA, APPROVING A ALLOW FOR THE CONSTRUCTION OF A SINGLE FAMILY RESIDENCE AND SECOND DWELLING UNIT OVER A DETACHED GARAGE ON PROPERTY GENERALLY LOCATED ALONG THE SOUTH SHORE OF BUENA VISTA LAGOON, WEST OF THE AT&SF RAILROAD, NORTH OF MOUNTAIN VIEW DRIVE IN LOCAL FACILITIES MANAGEMENT ZONE 1. CASE NAME: LEVY RESIDENCE CASE NO.: CDP 97-59 WHEREAS, John C. Levy, “Developer”, has filed a verified application COASTAL DEVELOPMENT PERMIT NO. CDP 97-59 TO City of Carlsbad regarding property owned by John C. Levy, “Owner”, described as Parcel “A” of City of Carlsbad Adjustment Plat #471. (“the Property”); and WHEREAS, said verified application constitutes a request for a Development Permit as shown on Exhibits “A” - “G” dated July 1, 1998,on file in the E Department, LEVY RESIDENCE, CDP 97-59 as provided by Chapter 21.201.04C Carlsbad Municipal Code; and WHEREAS, the Planning Commission did, on the 1st day of July 1998 duly noticed public hearing as prescribed by law to consider said request; and WHEREAS, at said public hearing, upon hearing and considering all te and arguments, if any, of all persons desiring to be heard, said Commission considered all relating to the CDP. NOW, THEREFORE, BE IT HEREBY RESOLVED by the I: Commission of the City of Carlsbad as follows: ~ A) That the foregoing recitations are true and correct. EXHIBIT 2 e 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 B) That based on the evidence presented at the public hearing, the Corr APPROVES LEVY RESIDENCE, CDP 97-59, based on the following and subject to the following conditions: FindinEs: 1. That the proposed development is in conformance with the Mello I1 segmen Certified Local Coastal Program and all applicable policies in that the site is des for single family residential development, second dwelling units are pursuant to Mello I1 Affordable Housing Policy 1-1, and no agricultural acti7 geologic instability exists on site. 2. The project is consistent with the provisions of the Coastal Resource Protection Zone (Chapter 21.03 of the Zoning Ordinance) in that the project will adherl City’s Master Drainage and Storm Water Quality Management Plan and C Ordinance to avoid increased runoff and soil erosion, no steep slopes or vegetation is located on the subject property and the site is not located in : prone to landslides, or susceptible to accelerated erosion, floods or liquefactic adjacent Buena Vista Lagoon wetlands have been delineated and the proj been designed to include a minimum 100’ setback between the wetlands structures. The developer has been conditioned to record an open spa4 restriction over the entire wetland buffer setback area and to make an irre offer of dedication of the wetlands buffer to the California Department of F Game. 3. The project is consistent with the provisions of the Coastal Shoreline Devel Overlay Zone (Chapter 21.204 of the Zoning Ordinance) in that the proposed will require minimal grading (75 cubic yards of cut and 75 cubic yards of f project has been designed to avoid increased runoff and soil erosion, and the applicant has been conditioned to make an irrevocable offer of dedication City of Carlsbad for a 25’ wide public access trail easement over an existing ! trail which is located along the western perimeter of the project site. 4. The Planning Commission of the City of Carlsbad has reviewed, analyzed and con Mitigated Negative Declaration CDP 97-59, the environmental impacts therein id1 for this project and said comments thereon, and the Mitigation Monitoril Reporting Program, on file in the Planning Department, prior to APPROVII project. Based on the EIA Part I1 and comments thereon, the Planning Coml finds that there is no substantial evidence the project will have a significant effec environment and hereby APPROVES the Mitigated Negative Declaration. 5. The Planning Commission does hereby find that the Mitigated Negative Dec CDP 97-59 and Mitigation Monitoring and Reporting Program have been p in accordance with requirements of the California Environmental Quality Act, tk Guidelines and the Environmental Protection Procedures of the City of Carlsbad. PC RES0 NO. 4332 -2- e 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6. The Planning Commission finds that the Mitigated Negative Declaration CD reflects the independent judgment of the Planning Commission of the City of Ci 7. All necessary public improvements have been provided or will be required as cc of approval. 8. The Developer has agreed and is required by the inclusion of an appropriate conc pay a public facilities fee. Performance of that contract and payment of the enable this body to find that public facilities will be available concurrent with required by the General Plan. 9. The project has been conditioned to pay any increase in public facility fee, construction tax, or development fees, and has agreed to abide by any a( requirements established by a Local Facilities Management Plan prepared pur Chapter 21.90 of the Carlsbad Municipal Code. This will ensure continued availa public facilities and will mitigate any cumulative impacts created by the project. 10. The project has been conditioned to ensure the building permits will not be issue( project unless the District Engineer determines that sewer service is availal building cannot occur within the project unless sewer service remains available, District Engineer is satisfied that the requirements of the Public Facilities Elemel General Plan have been met insofar as they apply to sewer service for this project. 1 I. Statutory School fees will be paid to ensure the availability of school facilitie Carlsbad Unified School District. Conditions: 1. Staff is authorized and directed to make, or require Developer to make, all cor and modifications to the CDP 97-59 document(s) as necessary to make them ir consistent and in conformity with final action on the project. Development sha substantially as shown in the approved Exhibits. Any proposed development ( from this approval, shall require an amendment to this approval. 2. The applicant shall apply for and be issued building permits for this pro within two (2) years of approval or this coastal development permit will ex] unless extended per Section 21.201.210 of the Zoning Ordinance. 3. The Developer shall comply with all applicable provisions of federal, state, ar ordinances in effect at the time of building permit issuance. 4. Building permits will not be issued for development of the subject property un. District Engineer determines that sewer facilities are available at the time of app for such sewer permits and will continue to be available until time of occupancy. 5. The Developer shall pay the public facilities fee adopted by the City Council on i 1987, (amended July 2, 1991) and as amended from time to time, and any devel PC RES0 NO. 4332 -3 - 0 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 fees established by the City Council pursuant to Chapter 21.90 of the Carlsbad M Code or other ordinance adopted to implement a growth management system or I and Improvement Plan and to fulfill the subdivider’s agreement to pay thl facilities fee dated May 26, 1998, a copy of which is on file with the City Cler incorporated by this reference. If the fees are not paid, this application wil, consistent with the General Plan and approval for this project will be void. 6. The Developer shall provide proof of payment of statutory school fees to conditions of overcrowding as part of the building permit application. The an these fees shall be determined by the fee schedule in effect at the time of buildin; application. 7. If any condition for construction of any public improvements or facilities, or the 1 of any fees in-lieu thereof, imposed by this approval or imposed by law on this re housing project are challenged this approval shall be suspended as prov Government Code Section 66020. If any such condition is determined to be inv, approval shall be invalid unless the City Council determines that the project wit! condition complies with all requirements of law. 8. Consistent with subsection 21.203.040(4)(e) of the Carlsbad Municipal C grading shall be allowed during the winter season (October 1 - April 1). 9. This project shall comply with all conditions and mitigation measures which are as part of the approved Mitigated Negative Declaration, as contained in P Commission Resolution No. 4331. 10. Prior to the issuance of the building permit, Developer shall submit to the City 2 of Restriction to be filed in the office of the County Recorder, subject to the sati of the Planning Director, notifying all interested parties and successors in interest City of Carlsbad has issued a Coastal Development Permit by Resolution No. ‘ the real property owned by the Developer. Said Notice of Restriction shall I property description, location of the file containing complete project details conditions of approval as well as any conditions or restrictions specified for inch the Notice of Restriction. The Planning Director has the authority to execute and an amendment to the notice which modifies or terminates said notice upon a sho? good cause by the Developer or successor in interest. 11. The Developer shall implement, or cause the implementation of, the CDP 97-59 Mitigation Monitoring and Reporting Program. 12. Prior to the issuance of a building permit or grading permit (whichever occu: the applicant shall record a deed restriction over the entire wetland buffer b area to restrict the property for open space/wildlife uses only, except for a public access trail as shown on the site plan for CDP 97-59. 1 PC RES0 NO. 4332 -4- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 e e 13. Prior to the issuance of a building permit or grading permit (whicheve first), the property owner shall submit evidence satisfactory to the 1 Director that an irrevocable offer of dedication of the wetland buffer area 1 made to the California Department of Fish and Game. 14. Prior to the issuance of building permits, an exterior lighting plan submitted to the Planning Director for review. All exterior lighting shall i, combination of low-level lights and shields to minimize the amount of light the adjacent wetlands and wetland buffer area. 15. Due to the potential presence of the light-footed clapper rail within the I adjacent to the project site, project construction shall be prohibited du breeding season, (March 1 to August l), unless a focused survey for the clal is conducted immediately prior to project construction and determines clapper rails were observed during the survey. 16. Prior to the issuance of a certificate of occupancy, non-native plant species removed from the wetland buffer area and the wetland buffer area sha, vegetated with a hydro-mulched coastal scrub grass seed mix. 17. Prior to the issuance of a building permit or grading permit (whichever oca the applicant shall irrevocably offer to dedicate in perpetuity to the City of C a minimum 25 foot wide public access trail easement over the public acc which is shown on the site plan for CDP 97-59. 18. Prior to the issuance of a building permit or grading permit (whichever OCCI the wetlands buffer area shall be staked and flagged in the field by a surveyor. A minimum of three notices shall be posted within this area tc that this area is off-limits to construction activity. 19. If any of the foregoing conditions fail to occur; or if they are, by their tern implemented and maintained over time, if any of such conditions fail tc implemented and maintained according to their terms, the City shall have the revoke or modify all approvals herein granted; deny or further condition issuan future building permits; deny, revoke or further condition all certificates of oc issued under the authority of approvals herein granted; institute and prosecute liti compel their compliance with said conditions or seek damages for their violat vested rights are gained by Developer or a successor in interest by the City’s apl this Coastal Development Permit. NOTICE Please take NOTICE that approval of your project includes the “imposition” dedications, reservations, or other exactions hereafter collectively referred to for conver “fees/exactions.” ~ PC RES0 NO. 4332 -5- . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 e 8 You have 90 days from July 1, 1998 to protest imposition of these feedexactions. If yc them, you must follow the protest procedure set forth in Government Code Section 6602 file the protest and any other required information with the City Manager for proc accordance with Carlsbad Municipal Code Section 3.32.030. Failure to timely fo. procedure will bar any subsequent legal action to attack, review, set aside, void, or ar imposition. You are hereby FURTHER NOTIFIED that your right to protest the specified fees/< DOES NOT APPLY to water and sewer connection fees and capacity charges, nor I zoning, grading or other similar application processing or service fees in connection project; NOR DOES IT APPLY to any feedexactions of which you have previously be a NOTICE similar to this, or as to which the statute of limitations has previously c expired. PASSED, APPROVED AND ADOPTED at a regular meeting of the Commission of the City of Carlsbad, California, held on the 1st day of July 1995 following vote, to wit: AYES: Chairperson Noble, Commissioners Compas, Heineman, rV Nielsen, Savary, and Welshons NOES: ABSENT: ABSTAIN: &. 4% y%, & g &? - @w4J*fi ,$ 4 ,&e- yt't.iE -.&f Ft L- BAILEY NO@, Chairperson CARLSBAD PLANNING COMMISSION ATTEST: U MICHAEL J. HOLZMILMR Planning Director PC RES0 NO. 4332 -6- ' . . STATE OF CAUFORNIA-THE RESOURCES AGENCY PETE WILSON, Governor CALIFORNIA COASTAL COMMISSION SAN DIEGO AREA 3111 CAMINO DEL RIO NORTH, SUITE 200 SAN DIEGO, CA 92108·1725 1. "'"'C~P" n~D PACKE \ .. ,, ' .9) 521-8036 • • Staff: WNP-SD StaffReport: 1115/98 Hearing Date: 12/8-11/98 REVISED FINDINGS APPLICATION NO.: A-6-CII-98-98 1/JIDh LOCAL GOVERNMENT: City of Carlsbad DECISION: Approved With Conditions APPLICANT: John Levy Agent: Bob Sukup DESCRIPTION: Construction of a 30-foot high, 2, 713 sq. ft. single-family residence and a 35-foot high, 1,633 sq. ft. detached garage with a 577 sq. ft. second unit above on a 1.9 acre lot of a 2.6 acre site. Estimated grading quantities include 75 cubic yards of cut and 75 cubic yards of fill to be balanced on-site. Also proposed is off-site private access improvements, the replacement of a gate and fencing on the site . PROJECT LOCATION: The south shore of Buena Vista Lagoon, west of the AT&SF Railroad and north of Mountain View Drive, Carlsbad, San Diego County. APN 155-190-13, APN 155-101-65 APPELLANTS: California Coastal Commissioners Christine Kehoe and Pedro Nava DATE OF COMMISSION ACTION: September 11, 1998 COMMISSIONERS ON PREY AILING SIDE: Herron, Flemming, Johnson, Potter, Reilly, and Chairman At"eias SUMMARY OF COMMISSION ACTION: Staff recommends that the Commission adopt the following revised findings in support of the Commission's action on September 11, 1998 finding no substantial issue exists with respect to the grounds on which the appeal was filed. SUBSTANTIVE FILE DOCUMENTS: Certified City of Carlsbad Local Coastal Program Mello II segment; City of Carlsbad CDP 97-59, CDP #6-83-51 EXHIBIT 3 NO SUBSTANTIAL ISSUE-RESOLUTION A -6-Cll -98-98/Revised Findings Page2 The Commission adopted the following resolution and findings following the public hearing: _\. .tl-ts .'tr;:by detennines that NO SUBSTANTIAL ISSUE exists with respect n~J;dD:ch the appeal was filed, pursuant to Section 30603. Findings and Declarations. The Commission finds and declares as follows: · 1. Project Description. Proposed is the construction of a 30-foot high, 2,713 sq. ft. single-family residence and a 35-foot high, 1,633 sq. ft. detached garage with a 577 sq. ft. second-unit above on one lot of a 2.6 acre site. Estimated grading quantities include 75 cubic yards of cut and 75 cubic yards of fill to be balanced on-site. Also proposed is off-site private access improvements, fencing of the site and replacement of an existing gate. The 2.6 acre project site is comprised of two lots located along the south shore of Buena Vista Lagoon, west of the AT &SF Railroad and north of Mountain View Drive in northern Carlsbad. The project site is vacant and is covered with disturbed shrub habitat. There are no steep slopes or native vegetation on the project site. Fresh water marsh occurs on the northwest and eastern boundaries of the site below the riprap line. An existing unimproved lagoon trail is located around the outer edge of the property running from its western edge and continuing to circle the site like a loop. The AT &SF railroad right-of-way lies to the east of the site, and multi-family housing is located to the south of the project site. The site is designated Residential Low (RL, 0-1.5 dulac) and zoned R-1-30,000 in the certified Mello II LCP. 2. Protection of Visual Resources. The project site is located at the confluence of the mouth of Buena Vista Lagoon and the Pacific Ocean at the boundary between the cities of Carlsbad and Oceanside. Although there is existing development in the area, because of the site's unique setting adjacent to the lagoon, it is like no other site in Carlsbad. Open waters of Buena Vista Lagoon are on the west side of the site with some riprap on the banks; fresh water marsh associated with lagoon environs occurs on the northwest and eastern boundaries of the site below the riprap line. The property is vacant and an existing unimproved lagoon trail is located along its western edge and circles the site like a loop. The following policies and goals of the certified Mello II LCP address protection of public views and are applicable to the proposed development: . . . " • • I • • • • Policy 8-1 A-6-CII-98-98/Revised Findings Page3 The Scenic Preservation Overlay Zone should be applied where necessary throughout the Carlsbad Coastal Zone to assure maintenance of existing views and panoramas. Sites considered for development should undergo individual review to determine if the proposed development will obstruct views or otherwise damage the visual beauty of the area. The Planning Commission should enforce appropriate-height limitations and see-through construction, as well as minimize any alterations to topography. Policy 3-2 of the Mello II LCP also requires that development be clustered to preserve open space for habitat protection, which also serves to minimize the visual impacts of new development. In addition, Section 21.40.135 of the City's certified LCP Implementation Plan is applicable to the proposed development and states, in part: Within the coastal zone, existing public views and panorama shall be maintained. Through the individualized review process, sites considered for development shall be conditioned so as to not obstruct or otherwise damage the visual beauty of the coastal zone. In addition to the above, height limitations and see-through construction techniques should be employed. Shoreline development shall be built in clusters to leave open areas around them to permit more frequent views of the shoreline. Vista points shall be incorporated as a part of larger projects. Additionally, Section 21.204.100 (B & C) of the Coastal Shoreline Development Overlay Zone of the City's certified LCP is applicable and states: B. Appearance -Buildings and structures will be so located on the site as to create a generally attractive appearance and be agreeably related to surrounding development and the natural environment. C. Ocean Views-Buildings, structures, and landscaping will be so located as to preserve the degree feasible any ocean views as may be visible from the nearest public street. The proposed 2,713 sq. ft. residence is over 30 feet tall, consists of two-stories, and features a copper-colored metal roof and concrete block walls. Also proposed is a 1,633 sq. ft. detached garage with a 577 sq. ft. second-unit above that will be 35 feet in height. Second dwelling units are addressed in the City's LCP. As approved in the LCP, such units are allowed by right subject to restrictions on size (650 sq. ft. maximum), affordability, etc. Second units must also meet all the requirements of the local coastal program, with the exception ofbase density . The subject site is visible from the beach, the railroad and portions of Old Highway 101 (Carlsbad Boulevard), which is designated as a Scenic Road in the LCP. Old Highway 1 0 1 is heavily used by beachgoers to get to the beaches of northern Carlsbad. Existing A-6-CII-98-98/Revised Findings Page4 cattails and the elevated railroad berm are high enough to block views to the west from • the portion of Old Highway 101 that is along side the site. The site is however, visible both from the highway as it descends south from the City of Oceanside into Carlsbad and at a point close to the Buena Vista Lagoon pump station going north on the highway. As noted above, the approximately 2.6 acres under the applicant's ownership constitutes a unique, low-lying area immediately adjacent to the lagoon where no development has occurred. As such, the proposed project, consisting of two large structures located directly adjacent to the lagoon, has the potential to adversely impact public views in this scenic area by presenting a significant structure in an otherwise natural setting. Policy 8-1 of the City's LCP provides that the Scenic Preservation Overlay Zone should be applied where necessary to assure the maintenance of existing views and panoramas and that sites be evaluated for potential public views that should be preserved and enhanced. Its purpose is to provide regulations in areas which possess outstanding scenic qualities or would create buffers between incompatible land uses which enhance the appearance of the environment and contribute to community pride and community prestige. The subject site does not represent an infill area but rather should be viewed as an extension of development northward at a critical scenic interface between the ocean and the lagoon, which is visible from Highway 101. The City has indicated that the Scenic Protection Overlay Zone is only applied to properties and projects that are visible from El Camino Real. The subject site is not visible from El Camino Real. Therefore, the City did not apply the requirements of the Overlay Zone to the project. The • Commission does not agree that application of the overlay zone within the City's Coastal Zone depends on a site's visibility from El Camino Real. However, the proposed project has been designed to mitigate adverse impacts on views. The mitigation includes a I 00-ft. setback of structures from the lagoon and landscape screening of the proposed structures. In addition, the height of the proposed structures is consistent with both the height limits contained in the certified LCP and the height of other structures in the area. Therefore, the Commission finds that even though the City failed to apply the requirements of the Scenic Preservation Overlay Zone, the intent of these requirements has been satisfied and therefore, the project, as approved by the City, does not raise a substantial issue with regard to consistency with the visual resource policies of the certified LCP. The Commission notes however, that Commission staff and City staff need to work together to assure the Scenic Preservation Overlay Zone is implemented consistent with its certification in the City's LCP. 3. Public Access/Recreation. The Coastal Act contains policies that call for protecting public access to the coast. The following Coastal Act policies are applicable to the proposed development. Section 30210. 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 • • • A -6-CII -98-98/Revised Findings Page 5 and the need to protect public rights, rights of private property owners, and natural resource areas from overuse. Section 30211. Development shall not interfere with the public's right of access to the sea where acquired through use or legislative authorization, including, but not limited to, the use of dry sand and rocky coastal beaches to the first line of terrestrial vegetation. Section 30212. (a) Public access from the nearest public roadway to the shoreline and along the coast shall be provided in new development projects except where: (1) it is inconsistent with public safety, military security needs, or the protection of fragile coastal resources, (2) adequate access exists nearby, or, (3) agriculture would be adversely affected. Dedicated accessway shall not be required to be opened to public use until a public agency or private association agrees to accept responsibility for maintenance and liability of the accessway . In addition, several policies of the Mello II LCP apply to the project site. Policy 7-3 -ACCESS ALONG SHORELINE The City will cooperate with the state to ensure that lateral beach access is protected and enhanced to the maximum degree feasible, and will continue to formalize shoreline prescriptive rights. Irrevocable offers of dedication for lateral accessways between the mean high tide line and the base of the coastal bluffs, and vertical accessways where applicable, shall be required in new development consistent with Section 30212 of the California Coastal Act of 1976. There is evidence of historic public use adjacent to Buena Vista Lagoon. Paths criss-cross the area near the railroad tracks to the ocean shoreline. Development shall provide access and protect existing access consistent with the needs to protect the habitat. Policy 7-6-BUENA VISTA LAGOON An access trail shall be provided along the southern shoreline of Buena Vista Lagoon (exhibit 4.10, page 63) to facilitate public awareness of the natural habitat resources of the Lagoon. To protect sensitive resources of this area, access development shall be limited and designed in consultation with the State Department ofFish and Game. In permitted development of properties adjacent to the Lagoon, offers of dedication of lateral accessways, irrevocable for a term of 21 years, shall be required to be provided to the City of Carlsbad, State Coastal Conservancy, or other appropriate public A-6-CII-98-98/Revised Findings Page6 agencies. Such access dedications shall be of at least 25 feet in width upland from • environmentally sensitive areas and any required buffers thereto. In addition, the City of Carlsbad, State Coastal Conservancy and Wildlife Conservation Board shall seek to obtain lateral accessways across developed lands. The subject site is located between the first public roadway and the sea. The beach area to the west of the project site can be reached via a public access stairway on Ocean Street. To reach the lagoon area immediately adjacent to the subject site, it is apparent that visitors to this area use a well worn path near Mountain View Drive which leads behind tennis courts on the adjacent lot and then down to the lowland area that comprises the subject property. The beach and lagoon areas are currently used by walkers, fishermen and naturalists. As noted above, the Mello II LCP envisions an areawide pathway along the south shoreline of the lagoon. The City of Oceanside is planning pathways on the northern side of the lagoon along with a bird sanctuary. The Department ofFish and Game owns properties on the south side of the lagoon, east of the subject site and on the north side. Because of its location, the project site is at a crucial point in any potential trail linkage between public beach areas and the public lagoon areas. There is evidence of historic public use of this site. This evidence is the existence of a well-worn path around the perimeter of the site. The path is evident in numerous aerial photographs of the site taken as early as 1972. In recognition of the existing trail on the south side of the lagoon, the City has required that the applicant record an offer to • dedicate a public access easement along the south shore of Buena Vista Lagoon, along the western edge of the site consistent with Policy 7-6 ofthe"Mello II LUP. The City's approval also required that the development maintain a 1 00-foot setback from the lagoon's edge, consistent with input provided by the resource agencies and LCP requirements. This 1 00-foot setback would then function as a wetland buffer. The existing worn path where the City's required access easement is to be located is within the 100-foot wetland buffer. However, the resource agencies found that the trail was·a permitted use within the buffer. However, to provide protection of the adjacent biological resources, the resource agencies also required that the applicant construct a fence at the inland edge of the buffer. The fence will serve to help keep domestic pets out of the buffer area to protect wildlife that occurs near the water's edge. The City's approval also authorized the installation of a fence along the southern property boundary and a gate across the southern lagoon trail (that is the subject of an offer to dedicate a public access easement). The gate is proposed within a fence on Parcel B, the other lot under the applicant's ownership, which is not proposed for residential development at this time. As approved, the gate would be open from dawn to dusk. The Commission found in a recent permit decision, (Ref. CDP # 6-96-159/Cade ), that limiting the hours of public access along the shoreline of Agua Hedionda Lagoon through a time lock gate was inappropriate. In that case, there was substantial evidence of a prescriptive right of access along the shoreline, and there was no evidence of a need for the limitations on hours of access. However, in this case, the subject site and surrounding • area suffers from a number of nuisances (vandalism, transients) which warrant that access be closed at dusk to assure privacy and security. Further, access along the south shore is • • • A -6-CII -98-98/Revised Findings Page7 being dedicated by the applicant consistent with the LCP provisions through a 25-foot wide easement and construction of a 10-foot wide path within the easement. Thus, in this case, the Commission fmds that the time-lock gate as approved by the City raises no substantial issue as to conformity with the certified LCP or the public access policies of the Coastal Act. As stated, the City's approval included replacement of an existing manually operated gate with an electric gate near Mountain View Drive for access for the proposed residence, fire and maintenance vehicular access. The existing fenced and locked gate is located just off Mountain View Drive on property that is not owned by the applicant. However, the applicant has a private access easement over the property. The installation date of the existing gate is unknown. The fence/gate appears on a 1981 tentative map for a neighboring project. In addition, representatives of the City have verbally stated that it has been in place since the 1960s. The gate/fence limits public access from Mountain View Drive to the applicant's site. This gate is where the applicant will take access to the subject site via an existing private access easement. According to the City, this gated access is the only beach vehicle access in northern Carlsbad and has been used by lifeguard personnel and city maintenance crews to maintain the lagoon weir which regulates the water level in Buena Vista Lagoon. In CDP #6-83-51, the Commission approved the subdivision of the property immediately adjacent to and south of the subject site. The permit allowed subdivision of a 7.65 acre parcel into three lots and construction of 14 condominiums. In its approval of CDP #6- 83-51, the Commission required Lot 3, the lot over which the applicant must take access to get to the project site, to be reserved as open space thro¥gh an offer to dedicate an open space easement. In its open space easement condition, the Commission prohibited all development except for development needed to allow for vehicle access across Lot 3 to the lagoon weir and for public projects that were planned on this low-lying area, including wetland restoration and possibly as a depository site for beach replenishment projects. The condition did not recognize any private vehicular access across Lot 3, which is needed for the applicant to get to the project site. However, the applicant asserts that he has a right of private vehicular access across Lot 3 to the project site through an easement that was initially granted in 1971 and then re-recorded in a slightly different location in 1984. The offer of dedication has not yet been accepted. The Commission finds that at this time, it need not address the legality of the fence or the ability of the landowners to maintain the fence after the offer of dedication has been accepted. The proposed project simply replaces the existing manual gate with an electric gate and therefore, it does not change the existing access. In addition, adequate pedestrian access opportunities exist in the area (as a vertical accessway from Ocean Street to the ocean is located about 500 feet to the north) and the public will still be able to access the beach as they have in the past. Therefore, the Commission finds the development as approved by the City does not raise a substantial issue with regard to consistency with the public access and recreation policies of the certified LCP and Chapter 3 of the Coastal Act. 4. Environmentally Sensitive Habitat Areas. A-6-Cll-98-98/Revised Findings PageS Policy 3-2 of the certified Mello ll LUP addresses the protection of this environmentally sensitive area and provides the following: Policy 3-2 -Buena Vista Lagoon Developments located along the first row of lots bordering Buena Vista Lagoon, including the parcel at the mouth of the Lagoon (see Exhibit 4.5, Page 61), shall be designated for residential development at a density of up to 4 dwelling units per acre. Proposed development in this area shall be required to submit topographic and vegetation mapping and analysis, as well as soils reports, as part of the coastal development permit application. Such information shall be provided as a part of or in addition to any required Environmental Impact Report, and shall be prepared by qualified professionals and in sufficient detail to enable the City to locate the boundary of wetland and upland areas and areas of slopes in excess of 25%. Topographic maps shall be submitted at a scale sufficient to determine the appropriate developable areas, generally not less than a scale of 1" - 1 00' with a topographic contour interval of 5 feet, and shall include an overlay delineating the location of the proposed project Criteria used to identify wetlands existing on the site shall be those of Section 30121 of the Coastal Act and based upon the standards of the Local Coastal Program Mapping Regulations, and shall be applied in consultation with the State Department ofFish and Game. Development shall be clustered to preserve open space for habitat protection. Minimum setbacks of at least 100 feet from wetlands shall be required in all development, in order to buffer such sensitive habitat areas from intrusion. Such buffer areas, as well as other open space areas required in permitted development to preserve habitat areas, shall be permanently preserved for habitat uses through provision of an open space easement as a condition of project approval. In the event that a wetland area is bordered by steep slopes (in excess of25%) which will act as a natural buffer to the habitat area, a buffer setback of less than 100 feet in width may be permitted. The density of any permitted development shall be based upon the net developable area of the parcel, excluding any portion of a parcel, which is not within wetlands. Storm drain alignments as proposed in the Carlsbad Master Drainage Plan which would be carried through or empty in to Buena Vista Lagoon shall not be permitted, unless such improvements comply with the requirements of Sections 30230, 30231, 30233, and 30235 of the Coastal Act by maintaining or enhancing the functional capacity of the lagoon in a manner acceptable to the State Department ofFish and Game. Land divisions shall only be permitted on parcels bordering the lagoon pursuant to a single planned unit development permit for the entire original parcel. • • • • • • A -6-CII -98-98/Revised Findings Page9 Additionally, the Coastal Resource Protection Overlay Zone, an implementing ordinance of the City of Carlsbad LCP, contains identical language to Policy 3-2 above with respect to Buena Vista Lagoon. Numerous other policies of the LCP provide that new development not contribute to erosion and sedimentation of sensitive resources, including Buena Vista Lagoon. Policy 4-3 and Policy 4-6 address this issue. Policy 4-3-ACCELERATED SOIL EROSION (A) Areas West ofi-5 and the existing Paseo del Norte and Along El Camino Real Upstream of Existing Storm Drains For areas west of the existing Paseo del Norte, west ofi-and along El Camino Real immediately upstream of the existing storm drains, the following policy shall apply: A site specific report prepared by a qualified professional shall be required for all proposed development, identifying mitigation measures needed to avoid increased runoff and soil erosion. The report shall be subject to the requirements of the model erosion control ordinance contained in the appendix to the Carlsbad Master Drainage Plan (June, 1980), and to the additional requirements contained herein. Such mitigation shall become an element of the project, and shall be installed prior to initial grading. At a minimum, such mitigation shall require construction of all improvements shown in the Master Drainage Plan for the area between the project site and the lagoon (including a debris basin), as well as restriction of grading activities to the months of April through September of each year; revegetation of graded areas immediately after grading; and a mechanism for permanent maintenance if the City declines to accept the responsibility. Construction of drainage improvements may be through formation of an assessment district, or through any similar arrangement that allots costs among the various landowners in an equitable manner. Policy 4-6 -SEDIMENT CONTROL PRACTICES Apply sediment control practices as a perimeter protection to prevent off-site drainage. Preventing sediment from leaving the site should be accomplished by such methods as diversion ditches, sediment traps, vegetative filters, and sediment basins. Preventing erosion is of course the most efficient way to control sediment runoff. The 2.6-acre project site consists of two lots located along the south shore of Buena Vista Lagoon, west of the AT&SF Railroad and north of Mountain View Drive in northern Carlsbad. The project site is covered with disturbed shrub habitat. There are no steep slopes or native vegetation on the project site. Fresh water marsh occurs on the northwest and eastern boundaries of the site below the riprap line. • > • • • JUL-22 98 WED 14:07 c I'I'Y OF CEiRLSBAD COftM DE FIDr NU. qJtluo~;:~<+ LEVY RESIDENCE COP 97-59 S" ] # j EXHIBIT NO. 1 APPUCA TION NO· A-6-Cll-98-98 Location Maps a california Coastal Commission ,_ I I I I 0 -....../ I ) <I 0 1·1 I <:> l \ 0 /I '1.,' ., <. l ) 6 I I I .. , ~· "-? \ \ --1, t;. . ·' o4 z c 1-\P-.\t-l t:e.~c.e. -"t '$-~··· / ----. !>. ~~· ·~~-?A~CSL-A. AD::f Pt-A\ ~ 11 ~ cW"'~ ~.,.IN\( o;::e.tlC.~ wl t,-At-'t)'5c..Jl'..~1 tJG. .. PARCE.l-l3 Ao::r pLAT ~l N.A..F. , , ~ // <t' 1/ (J ~ .~,/ {10 ,/ ,~ ,/ ~ ~ , ,, I/ '!.b ~\)\\l~E-c;e.tl\lJ''i:.~ \P.._,; \Ot-\ c.~'c..'c'\ ~,._s\tl r. \!OIL (\1000 zen . I 0 z 00 c: z o en m t-i=..!.O. -<(-!:'QuO~ :x: :::; I en xo..CO UJ 0.. I <(<( J '3 .. ;'' \ EXHIBIT 4 > - STATE OF CALIFORNIA -THE RESOURCES AGE! PETE WILSON, Governor C A L I FO R N I A CO ASTA L C 0 M M I S S I 0 N SAN DIEGO AREA 3111 CAMINO DEL RIO NORTH, SUITE 200 SAN DIEGO, CA 92108-1725 (61 9) 521 -8036 Filed: July 27, 1998 49th Day: September 14, 1998 180th Day: January 23, 1998 Staff: WNP-SD StafFReport: August 18, 1998 Hearing Date: September 8-1 1, 1998 STAFF REPORT AND RECOMMENDATION ON APPEAL LOCAL GOVERNMENT: City of Carlsbad DECISION: Approved With Conditions APPEAL NO. : A-6-CII-98-98 APPLICANT: John Levy PROJECT DESCRPTION: Construction of a 30-foot high, 2,713 .sq.ft. single family residence and a 35-foot high, 1,633 sq.ft., detached garage with a 577 sq.ft. second unit above on 1.9 acre lot of a 2.6 acre site. Estimated grading quantities include 75 cubic yards of cut and 75 cubic yards of fill to be balanced on-site. Also proposed is off-site private access improvements, the replacement of a gate and fencing on the site. PROJECT LOCATION: The south shore of Buena Vista Lagoon, west of the AT&SF Railroad and north of Mountain View Drive, Carlsbad, San Diego County. APN 155-190-13, APN 155-101-65 APPELLANTS: California Coastal Commissioners Chnstine Kehoe and Pedro Nava SUBSTANTNE FILE DOCUMENTS: Certified City of Carlsbad Local Coastal Program Mello I1 segment; City of Carlsbad CDP 97-59, CDP #6-83-5 1 STAFF NOTES: SUMMARY OF STAFF RECOMMENDATION: The staff recommends that the Commission, after public hearing, determine that substantial issue exists with respect to the grounds on which the appeal has been filed. Staff also recommends that the Commission approve the de novo permit with special EXHIBIT 5 Ad-CII-98-98 Page 2 conditions that require 100-foot habitat setbacks on the east and west sides of the site to be secured through an open space condition, a public access easement on the south side of Buena Vista Lagoon, revised plans that indicate the proposed residential development will be redesigned to be subordinate to its lagoon setting to be no higher than 25 feet in height and that building materials and colors be earth-tone colors, that fencing and gating plans be revised to not adversely affect public access, that grading, drainage and runoff control plans be submitted to ensure that downstream resources will not be indirectly affected from proposed development and that a clapper rail protection plan be implemented which ensures this endangered avian will not be adversely affected from residential development in this scenic and sensitive area. I. Appellant Contends That: The City's decision is inconsistent with the certified LCP and the Coastal Act relative to public access and visual resource protection. II. Local Government Action The coastal development permit was approved by the City of Carlsbad on July 1, 1998, and the Notice of Final Action was received on July 13, 1998. Several special conditions were attached pertaining to the protection of public access and environmental resources. 111. Appeal Procedures. After certification of a Local Coastal Program (LCP), the Coastal Act provides for limited appeals to the Coastal Commission of certain local government actions on coastal development permits. Projects within cities and counties may be appealed if they are located within mapped appealable areas. The grounds for appeal are limited to the assertion that "development does not conform to the certified local coastal program." Where the project is located between the first public road and the sea or within 300 A. of the mean high tide line, the grounds of appeal are limited to those contained in Section 30603(b) of the Coastal Act. Those grounds are that the development does not conform to the standards set forth in the certified local coastal program or the access policies set forth in the Coastal Act. Section 30625(b) of the Coastal Act requires the Commission to hear an appeal unless it determines that no substantial issue is raised by the appeal. If the staffrecommends "substantial issue" and no Commissioner objects, the Commission will proceed directly to a de novo hearing on the merits of the project. A-6-CII-98-98 Page 3 If the staff recommends "no substantial issue" or the Commission decides to hear arguments and vote on the substantial issue question, proponents and opponents will have 3 minutes per side to address whether the appeal raises a substantial issue. It takes a majority of Commissioners present to find that no substantial issue is raised. If substantial issue is found, the Commission will proceed to a full public hearing on the merits of the project. If the Commission conducts a de novo hearing on the permit application, the applicable test for the Commission to consider is whether the proposed development is in conformity with the certified Local Coastal Program. In addition, for projects located between the sea and the first public road paralleling the sea, Sec. 30604(c) of the Act requires that a finding must be made by the approving agency, whether the local government or the Coastal Commission on appeal, that the development is in conformity with the public access and public recreation policies of Chapter 3. In other words, in regard to public access questions, the Commission is required to consider not only the certified LCP, but also Chapter 3 policies when reviewing a project on appeal. The only persons qualified to testifl before the Commission at the "substantial issue" stage of the appeal process are the applicant, persons who opposed the application before the local government (or their representatives), and the local government. Testimony from other persons must be submitted in writing. At the time of the de novo hearing, any person may testifl. IV. Staff Recommendation On Substantial Issue. The staff recommends the Commission adopt the following resolution: Staff recommends that the Commission determine that SUBSTANTIAL ISSUE exists with respect to the grounds on which the appeal was filed, pursuant to PRC Section 30603. MOTION Staff recommends a vote on the following motion: I move the Commission determine that Appeal No. A-6-CII-98-98 raises no substantial issue with respect to the grounds on which the appeal has been filed. A majority of the Commissioners present is required to pass the motion. Ad-CII-98-98 Page 4 V. FINDINGS ON SUBSTANTIAL ISSUE 1. Project Description. Construction of a 30-foot high , 2,713 sq.ft. single family residence and a 35- foot high, 1,633 sq.ft., detached garage with a 577 sq.ft. second unit above on one lot of a 2.6 acre site. Estimated grading quantities include 75 cubic yards of cut and 75 cubic yards of fill to be balanced on-site. Also proposed is off-site private access improvements, the replacement of a gate and fencing on the site. The 2.6 acre project site is comprised of 2 lots located along the south shore of Buena Vista Lagoon, west of the AT&SF Railroad and north of Mountain View Drive in northern Carlsbad. The project site is vacant and is covered with disturbed shrub habitat. There are no steep slopes or native vegetation on the project site. Fresh water marsh occurs on the northwest and eastern boundaries of the site below the rip-rap line. An existing unimproved lagoon trail is located around the outer edge of the property running from its western edge and continuing to circle the site like a loop. The AT&SF railroad right-of-way lies to the east of the site, and multi-family housing is located to the south of the project site. The site is designated Residential Low (RL, 0-1.5 ddac) and zoned R-1-30,000 in the certified Mello I1 LCP. 2. Protection of Visual Resources. The project site is located at the confluence of the mouth of Buena Vista Lagoon and the Pacific Ocean at the boundary between the cities of Carlsbad and Oceanside. Although there is existing development in the area, because of the site’s unique setting adjacent to the lagoon, it is like no other site in Carlsbad. Open waters of Buena Vista Lagoon are on the west side to the site with some rip-rap on the banks; fresh water marsh associated with lagoon environs occurs on the northwest and eastern boundaries of the site below the rip-rap line. The property is vacant and an existing unimproved lagoon trail is located along its western edge and circles the site like a loop. The following policies and goals of the certified Mello II LCP address protection of public views and are applicable to the proposed development: Policy 8-1 The Scenic Preservation Overlay Zone should be applied where necessary throughout the Carlsbad Coastal Zone to assure maintenance of existing views and panoramas. Sites considered for development should undergo individual review to determine if the proposed development will obstruct views or otherwise damage the visual beauty of the area. The Plannins Commission should enforce appropriate height limitations and see-through construction, as well as minimize any alterations to topography. A-6-CII-98-98 Page 5 Policy 3-2 of the Mello I1 LCP also requires that development be clustered to preserve open space for habitat protection which also serves to minimize the visual impacts of new development. The proposed 2,713 sq.ft. residence is over 30 feet tall, consists of two-stories, and features a copper-colored metal roof and concrete block walls. Also proposed is a 1,633 sq.ft., with a 577 sq.fi. second unit above that will be 35 feet in height . Second dwelling units are addressed in the City’s LCP. As approved in the LCP, such units are allowed by right subject to restrictions on size (650 sq.fi. maximum), Bordability, etc. Second units must also meet all the requirements of the local coastal program, with the exception of base density. The subject site is visible from the beach, the railroad and portions of Old Highway 101 (Carlsbad Boulevard), which is designated as a Scenic Road in the LCP. Old Highway 101 is heavily used by beachgoers to get to the beaches of northern Carlsbad. Existing cattails and the elevated railroad berm are high enough to block views to the west from the portion of Old Highway 101 that is along side the site. The site is however, visible both from the highway as it descends south from the City of Oceanside into Carlsbad and at a point close to the Buena Vista Lagoon pump station going north on the highway. As noted above, the approximately 2.6 acres under the applicant’s ownership constitutes a unique, low-lying area immediately adjacent to the lagoon where no development has occurred. As such, the proposed project, consisting of two large structures located directly adjacent to the lagoon, has the potential to adversely impact public views in this scenic area by presenting a significant structure in an otherwise natural setting. policy /- 8-1 .Qf_the City’s LCP p~~des that -_ the I___ Scenic Preservation - Overlay Zone- sho~ld be applied where necessary to assure the maintenance of existing views and panoramas, ‘which requires that sites be evaluated for potential public views that should be preserved and enhanced. Its purpose is to provide regulations in areas which possess outstanding scenic qualities or would create buffers between incompatible land uses which enhance the appearance of the environment and contribute to community pride and community prestige. The subject site does not represent an infill area but rather should be viewed as an extension of development northward at a critical scenic interface between the ocean and the lagoon which is visible from Highway 101. Therefore, the site is located in a highly scenic area that meets the criteria for application of the Scenic Preservation Overlay Zone. Based on the above, the Commission finds that there is a substantial issue as to the proposed project, as approved by the City and conformity with Policy 8-1 of the LCP. As approved by the City, the proposed structures are 30 - 35 feet high which will represent a project that is out of character with the setting of the surrounding lagoon environment. The LCP requires that appropriate height limitations be enforced. While the proposed A-6-CII-98-98 Page 6 development is within the current required height limit, by allowing the project to extend to the maximum height limit allowed by zoning, the City failed to recognize the unique setting where the residence is to be sited. Additionally, the California Department of Fish and Game has indicated that structures this high at this location could discourage shore and migrating birds from visiting the area, or act as “predator perches” affecting sensitive avian species in the area. Moreover, the proposed exterior treatment includes copper- colored metal roofs and concrete block walls. These design features will degrade the natural beauty of this area. That is, the project will “stand out” rather than blend in or be subordinate to the surrounding natural environment. Therefore, the Commission finds the project as approved by the City raises a substantial issue with regard to consistency with the visual resource policies of the certified LCP. 3. Public AccessRecreation. The Coastal Act contains policies that call for protecting public access to the coast. The following Coastal Act policies are applicable to the proposed development. Section 30210. 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 rights, rights of private property owners, and natural resource areas from overuse. Section 302 1 1. Development shall not interfere with the public’s right of access to the sea where acquired through use or legislative authorization, including, but not limited to, the use of dry sand and rocky coastal beaches to the first line of terrestrial vegetation, Section 30212. (a) Public access from the nearest public roadway to the shoreline and along the coast shall be provided in new development projects except where: (1) it is inconsistent with public safety, military security needs, or the protection of fragile coastal resources, (2) adequate access exists nearby, or, (3) agriculture would be adversely affected. Dedicated accessway shall not be required to be opened to public use until a public agency or private association A-6-CII-98-98 Page 7 agrees to accept responsibility for maintenance and liability of the accessway. In addition, several policies of the Mello I1 LCP apply to the project site. Policy 7-3 - ACCESS ALONG SHORELINE The City will cooperate with the state to ensure that lateral beach access is protected and enhanced to the maximum degree feasible, and will continue to formalize shoreline prescriptive rights. Irrevocable offers of dedication for lateral accessways between the mean high tide line and the base of the coastal bluffs, and vertical accessways where applicable, shall be required in new development consistent with Section 30212 of the California Coastal Act of 1976. There is evidence of historic public use adjacent to Buena Vista Lagoon. Paths criss-cross the area near the railroad tracks to the ocean shoreline. Development shall provide access and protect existing access consistent with the needs to protect the habitat. Policy 7-6 - BUENA VISTA LAGOON An access trail shall be provided along the southern shoreline of Buena Vista Lagoon (ehbit 4.10, page 63) to facilitate public awareness of the natural habitat resources of the Lagoon. To protect sensitive resources of this area, access development shall be limited and designed in consultation with the State Department of Fish and Game. In permitted development of properties adjacent to the Lagoon, offers of dedication of lateral accessways, irrevocable for a term of 2 1 years, shall be required to be provided to the City of Carlsbad, State Coastal Conservancy, or other appropriate public agencies. Such access dedications shall be of at least 25 feet in width upland from environmentally sensitive areas and any required buffers thereto. In addition, the City of Carlsbad, State Coastal Conservancy and Wildlife Conservation Board shall seek to obtain lateral accessways across developed lands. The subject site is located between the first public roadway and the sea ( reference Exhibit #1 attached). The beach area to the west of the project site can be reached via a public access stairway on Ocean Street. To reach the lagoon area immediately adjacent to the subject site, due to a well-worn path, it is apparent that visitors to this area use a path near Mountain View Drive which leads behind tennis courts on the adjacent lot and then down to the lowland area that comprises the subject property. The beach and lagoon areas are currently used by walkers, fishermen and naturalists. As noted above, the Mello 11 LCP envisions an areawide pathway along the south shoreline of the lagoon. The City of Oceanside is planning pathways on the northern side of the lagoon along with a bird sanctuary. The Department of Fish and Game owns properties on the south side of the lagoon, east of the subject site and on the north side. Because of its location, the project ,- A-6-CII-98-98 Page 8 site is located at a crucial point in any potential linkage between public beach areas and the public lagoon areas. There is evidence of historic public use of this site. This evidence is the existence of a well-worn path around the perimeter of the site. The path is evident in numerous aerial photographs of the site taken as early as 1972. In recognition of the existing trail on the south side of the lagoon, the City has required that the applicant record an offer to dedicate a public access easement along the south shore of Buena Vista Lagoon, along the western edge of the site consistent with Policy 7-6 of the Mello I1 LUP. The City’s approval also required that the development maintain a 100 foot setback from the lagoon’s edge, consistent with input provided by the resource agencies and LCP requirements. This 100-foot setback would then function as a wetlands buffer. The existing worn path on the site is located within the 100- foot wetland buffer. However, the agencies found that the trail was a permitted use within the buffer. In order to further protect the resources, the resource agencies also required that the applicant construct a fence at the inland edge of the buffer to keep domestic pets out of the buffer area to protect wildlife that occurs near the water’s edge. However, the City’s approval does not address other public access issues raised by the proposed development. First, the City’s approval authorized a gate across the southern lagoon trail that is the subject of an offer to dedicate a public access easement. The gate is proposed within a fence on Parcel B (exhibit #7), the other lot under the applicant’s ownership which is not proposed for residential development at this time. As approved, the gate would be open from dawn to dusk. The Commission found in a recent permit decision, (Ref. CDP # 6- 96- 159/Cade), that regulating hours of beach access along property fronting Agua Hedionda Lagoon through a time lock gate was inappropriate. The Commission finds that a time-lock gate raises a substantial issue as to conformity with as the certified LCP as policies 7-3 and 7-6 do not contain a provision which would permit such a device. On the contrary, both policies recognize public use in the area and provide for a public trail. The only restrictions the policies make on access is that it should be provided without requiring habitat impacts. No restrictions on what time of day access should be restricted are stated. Time lock gates are also inconsistent with the public access policies of the Coastal Act. As noted above, Policy 7-3 of the LUP states that ”...There is evidence of historic public use adjacent to Buena Vista Lagoon. Paths criss-cross the area near the railroad tracks to the ocean shoreline. Development shall provide access and protect existing access consistent with the needs to protect the habitat ....” Due to the fact that there is historic use by the public on this site, the City required that the applicant record an offer to dedicate for the path on the west. However, the City’s decision did not recognize the remainder of the perimeter path on the site that appears to be historically used by the public (as noted previously, a well worn path is evident on the site and is also evident in Ad-CII-98-98 Page 9 aerial photos dating back to 1972). The City’s approval includes a fence across the 100- foot buffer with a dawn to dusk gate and a fence fiom the proposed cul-de-sac to the marsh to the east. As such, the City’s approval will adversely affect continued use of the on-site trails by the public. These proposed fences are not needed for security as the entire building area will be fenced. In addition, such fences close to the lagoon and the marsh may have adverse impacts on birds and wildlife by restricting movement in the buffer and providing potential perches for birds of prey. In addition, the City’s permit decision did not recognize the public’s use of an existing trail from Mountain View Drive to the existing trail on the south shore of the lagoon and the ocean shoreline to the west. The City’s approval included replacement of an existing manually operated gate with an electric gate near Mountain View Drive for access for the proposed residehce, fire and maintenance vehicular access. The existing fenced and locked gate are located just off Mountain View Drive on property that is not owned by the applicant. However, the applicant has a private access easement over the property. The installation date of the gate is unknown. The fencdgate appears on a 198 1 tentative map for a neighboring project. In addition, representatives of the City have verbally stated that it has been in place since the 1960s. The gate/fence limits public access from Mountain View Drive to the applicant’s site. This gate is where the applicant will take access to the subject site via an existing private access easement. According to the City, it is the only beach vehicle access in northern Carlsbad and has been used by lifeguard personnel and city maintenance crews to maintain the lagoon weir which regulates the water level in Buena Vista Lagoon. In CDP #6-83-51, the Commission approved the subdivision of the property immediately adjacent to and south of the subject site. The permit allowed subdivision of a 7.65 acre parcel into three lots and construction of 14 condominiums (ref exhibit #6). In its approval of CDP #6-83-51, the Commission required Lot 3, the lot over which the applicant must take access to get to the project site, to be reserved as open space through an offer to dedicate an open space easement. In its open space easement condition, the Commission prohibited all development except for development needed to allow for vehicle access across Lot 3 to the lagoon weir and for public projects that were planned on this low-lying area, including wetland restoration and possibly as a depository site for beach replenishment projects. The condition did not recognize any private vehicular access across Lot 3 which is needed for the applicant to get to the project site. However, the applicant has demonstrated the right of private vehicular access across Lot 3 to the project site through an easement that was initially granted in 1971 and then recorded again n 1984. In its approval of CDP 6-83-51, the Commission also required a public access easement over the entirety of Lot 3. Neither the offer to dedicate an easement for public access nor the offer to dedicate an open space easement have been accepted by a public agency or private association. The City’s decision on this project formalizes lateral access along the lagoon but does not address how the public will access the trail, lagoon and A-6-(211-98-98 Page 10 ocean from Mountain View Drive. Section 30212 of the Coastal Act and Policy 7-6 of the LUP require that vertical access to and along the shoreline be provided where appropriate. The City’s action failed to provide public vertical access from Mountain View Drive to the trail on the south shore of the lagoon which is inconsistent with these provisions. As such, the Commission finds that replacement of the existing manual gate with a new electric gate will give the impression that this area is private which could hrther limit access by the public, inconsistent with Coastal Act and LCP policies. In summary, because the proposed fencing and gating plans would adversely affect public access, the Commission finds the development as approved by the City raises a substantial issue with regard to consistency with the public access and recreation policies of the certified LCP and Chapter 3 of the Coastal Act. 4. Environmentally Sensitive Habitat Areas. Policy 3-2 of the certified Mello I1 LUP addresses the protection of this environmentally sensitive area and provides the following: Policy 3-2 - Buena Vista Lasoon Developments Iocated along the first row of lots bordering Buena Vista Lagoon, including the parcel at the mouth of the Lagoon (see Exhibit 4.5, Page 61), shall be designated for residential development at a density of up to 4 dwelling units per acre. Proposed development in this area shall be required to submit topographic and vegetation mapping and analysis, as well as soils reports, as part of the coastal development permit application. Such information shall be provided as a part of or in addition to any required Environmental Impact Report, and shall be prepared by qualified professionals and in sufficient detail to enable the City to locate the boundary of wetland and upland areas and areas of slopes in excess of 25%. Topographic maps shall be submitted at a scale sufficient to determine the appropriate developable areas, generally not less than a scale of 1” - 100’ with a topographic contour interval of 5 feet, and shall include an overlay delineating the location of the proposed project. Criteria used to identi@ wetlands existing on the site shall be those of Section 30121 of the Coastal Act and based upon the standards of the Local Coastal Program Mapping Regulations, and shall be applied in consultation with the State Department of Fish and Game. Development shall be clustered to preserve open space for habitat protection. Minimum setbacks of at least 100 feet from wetlands shall be required in all development, in order to buffer such sensitive habitat areas from intrusion. Such buffer areas, as well as other open space areas required in permitted development to preserve habitat areas, shall be permanently preserved for habitat uses through A-6-(211-98-98 Page 11 provision of an open space easement as a condition of project approval. In the event that a wetland area is bordered by steep slopes (in excess of 25%) which will act as a natural buffer to the habitat area, a buffer setback of less than 100 feet in width may be permitted. The density of any permitted development shall be based upon the net developable area of the parcel, excluding any portion of a parcel which is not within wetlands. Storm drain alignments as proposed in the Carlsbad Master Drainage Plan which would be carried through or empty in to Buena Vista Lagoon shall not be permitted, unless such improvements comply with the requirements of Sections 30230, 3023 1, 30233, and 30235 of the Coastal Act by maintaining or enhancing the functional capacity of the lagoon in a manner acceptable to the State Department of Fish and Game. Land divisions shall only be permitted on parcels bordering the lagoon pursuant to a single planned unit development permit for the entire original parcel. Additionally, the Coastal Resource Protection Overlay Zone, an implementing ordinance of the City of Carisbad LCP, contains identical language to Policy 3-2 above with respect to Buena Vista Lagoon. Numerous other policies of the LCP provide that new development not contribute to erosion and sedimentation of sensitive resources, including Buena Vista Lagoon. Policy 4-3 and Policy 4-6 address this issue. Policv 4-3 - ACCELERATED SOIL EROSION (A) Areas West of 1-5 and the existing Paseo del Norte and Along El Camino Real Upstream of Existing Storm Drains For areas west of the existins Paseo del Norte, west of I-and along El Camino Real immediately upstream of the existing storm drains, the following policy shall apply: A site specific report prepared by a qualified professional shall be required for all proposed development, identifylng mitigation measures needed to avoid increased runoff and soil erosion. The report shall be subject to the requirements of the model erosion control ordinance contained in the appendix to the Carlsbad Master Drainage Plan (June, 1980), and to the additional requirements contained herein. Such mitigation shall become an element of the project, and shall be installed prior to initial grading. At a minimum, such mitigation shall require construction of all improvements shown in the Master Drainase Plan for the area between the project site and the A-6-CII-98-98 Page 12 lagoon (including a debris basin), as well as : restriction of grading activities to the months of April through September of each year; revegetation of graded areas immediately after grading; and a mechanism for permanent maintenance if the City declines to accept the responsibility. Construction of drainage improvements may be through formation of an assessment district, or through any similar arrangement that allots costs among the various landowners in an equitable manner. Policy 4-6 - SEDIMENT CONTROL PRACTICES Apply sediment control practices as a perimeter protection to prevent off-site drainage. Preventing sediment from leaving the site should be accomplished by such methods as diversion ditches, sediment traps, vegetative filters, and sediment basins. Preventing erosion is of course the most efficient way to control sediment runoff. The 2.6 acre project site consists of two lots located along the south shore of Buena Vista Lagoon, west of the AT&SF Railroad and north of Mountain View Drive in northern Carlsbad. The project site is covered with disturbed shrub habitat. There are no steep slopes or native vegetation on the project site. Fresh water marsh occurs on the northwest and eastern boundaries of the site below the rip-rap line. In recognition of the sensitive nature of the project area, the City approved the project with several conditions regarding the protection of coastal resources. The City found that the project was consistent with the certified Mello I1 Coastal Resource Protection Overlay Zone (Chapter 21.203 of the zoning ordinance) in that the project would adhere to the City’s Master Drainage and Storm Water Quality Management Plan and Grading Ordinance to avoid increased runoff and soil erosion, no steep slopes or native vegetation is located on the subject property and, the site is not located in an area prone to landslides, or susceptible to accelerated erosion, floods or liquefaction. The adjacent Buena Vista Lagoon wetlands have been delineated and the project has been designed to include a minimum 100 foot setback between the wetlands and all structures. The City’s approval required the applicant to record an open space deed restriction over the entire wetland buffer setback area and to make an irrevocable offer of dedication of the wetlands buffer to the California Department of Fish and Game. Although the existing vegetation on the site consists primarily of non-native grasses and weeds, two regionally significant habitats, a coastal lagoon and fieshwater marsh community, do occur near the subject property. Thus, activities on the property could affect the quality of these habitats. Buena Vista Lagoon provides nesting and foraging habitat for the California least tern and other avian species; although the quality of this habitat is decreasing due to continuous development along the edge of the lagoon. The City approved a sedimentation catch basin on the southeast corner of the site which will A-6-CII-98-98 Page 13 direct surface runoff to the east of the site within the freshwater marsh which is part of Buena Vista Lagoon. Policy 3-2 provides that no direct discharges to the lagoon can occur without approval of the Department of Fish and Game. That permission has not been obtained from the Department in writing. Urban runoff and pollutants at this location could endanger plants and animals that reside in the marsh, including the endangered clapper rails. Therefore, the City's decision cannot be found consistent with Policy 3-2 of the Mello I1 LCP and substantial issue must be found. STAFF RECOMMENDATION ON THE COASTAL PERMIT: The staff recommends the Commission adopt the following resolution: I. Approval with Conditions. The Commission hereby grants a permit for the proposed development, subject to the conditions below, on the grounds that the development will be in conformity with the provisions of Chapter 3 of the California Coastal Act of 1976, will not prejudice the ability of the local government having jurisdiction over the area to prepare a Local Coastal Program conforming to the provisions of Chapter 3 of the Coastal Act, and will not have any significant adverse impacts on the environment within the meaning of the California Environmental Quality Act. II. Standard Conditions. See attached page. III. Special Conditions. The permit is subject to the following conditions: 1. Final Revised Plans. Prior to the issuance of the coastal development permit, the applicant shall submit for the review and written approval of the Executive Director, final, revised site, fencing and building plans approved by the City of Carlsbad which demonstrates compliance with the following requirements: a. The proposed residence and garage/second unit shall be redesigned to not exceed 25 feet in height. b. No fencing shall be located along the south buffer area as shown on Exhibit 7 (attached). No fencing shall be located along the access drive turnaround on the east side of the site such that it precludes continued public access in its current A-6-CII-98-98 Page 14 location. No fencing of the access drive is permitted. c. The proposed off-site electric gate off Mountain View Drive is not approved. 2. Future Development/Deed Restriction. Prior to the issuance of the coastal development permit, the applicant shall execute and record a restriction in a form and content acceptable to the Executive Director against the subject 2.6 acre property. The deed restriction shall reflect the following: (1) The subject permit is only for the development described in CDP #A-6-CII-98-98. Pursuant to Title 14 California Code of Regulations Section 13250(b)(6), the exemptions otherwise provided in Public Resources Code Section 306 1 O(a) shall not apply to the area governed by this coastal development permit. (2) This approval limits the height of the residences to no higher than 25 feet. (3) No copper roof or concrete block materials are permitted. (4) Residential structures and garagehecond units shall be painted with earth tone colors (deep shades of green brown and gray with no white or light shades, and no bright tones) to minimize the development’s contrast with the surrounding scenic area. (5) The south buffer area shall not be fenced. (6) Fencing along the access drive turnaround on the site shall not preclude continued public access in its current location, along the eastern side of the site. The document shall run with the land, binding all successors and assigns, and shall be recorded free of prior liens that the Executive Director determines may affect the enforceability of the restriction. This deed restriction shall not be removed or changed without a Coastal Commission-approved amendment to this coastal development permit unless the Executive Director determines that no amendment is required. 3. Open Space Deed Restriction. Prior to the issuance of the coastal development permit, the applicant shall record a restriction against the subject property. The restriction shall prohibit any alteration of landforms, erection of structures of any type and removal of vegetation, except as permitted herein, for any purposes in the proposed habitat buffer areas as shown on the site plan dated 7/17/98 (Exhibit 8) and generalIy described as the area between the water’s edge of Buena Vista Lagoon and the 42” high chain link fence on the west side of the project site and the area between the freshwater marsh habitat and the 72” high chain link fence on the east side of the project site. Native drought-resistant vegetation required herein, public access and the existing public trail shall be permitted within the buffer. Construction of the permitted development shall not be used or construed to interfere with any public prescriptive rights or public trust rights that may exist on the property. The document shall include legal descriptions of both the applicant’s entire parcel(s) and the easement area. The document shall run with the land, binding all successors and assigns, and shall be recorded free of prior liens that the Executive Director determines may affect the enforceability of the restriction. This deed restriction shall not be removed or changed without a Coastal Commission-approved amendment to A-6-CII-98-98 Page 15 this coastal development permit unless the Executive Director determines that no amendment is required. 4. Lateral Public Access. Prior to the issuance of the coastal development permit, the applicant shall execute and record a document, in a form and content acceptable to the Executive Director, irrevocably offering to dedicate to a public agency or private association approved by the Executive Director an easement for lateral public access and passive recreational use along the lagoon shoreline. The easement shall be located along the entire width of the property along the Buena Vista Lagoon shoreline and shall be a minimum of 25-feet wide over the public access trail shown on the site plan dated 7/17/98 (Exhibit 2) The document shall provide that the offer of dedication shall not be used or construed to allow anyone, prior to acceptance of the offer, to interfere with any rights of public access acquired through use which may exist on the property. It shall be recorded free of prior liens which the Executive Director determines may affect the interest being conveyed, and free of any other encumbrances which may affect said interest. The offer shall run with the land in favor of the People of the State of California, binding all successors and assignees, and shall be irrevocable for a period of 21 years, such period running from the date of recording. The recording document shall include legal descriptions of both the applicant's entire parcel(s) and the easement area. 5. Drainane/RunofVSedimentation Control. Prior to the issuance of the coastal development permit, the applicant shall submit for the review and written approval of the Executive Director, final drainage and runoff control plans for the project, approved by the City of Carlsbad and reviewed in consultation with the Department of Fish and Game and designed by a licensed engineer qualified in hydrology and hydraulics, which would assure no increase in peak runoff rate from the developed site over runoff from the natural site, as a result of a ten-year frequency storm over a six-hour duration (10 year, 6 hour rainstorm). The plan shall document that runoff from the impervious surfaces of the site will be collected and discharged at a non-erosive velocity and elevation. Energy dissipating measures at the terminus of any proposed outflow drains shall be constructed. Any vegetation removed to install such measures shall be replanted with native vegetation.. The applicant shall also submit a written commitment indicating that all devices shall be installed and maintained by the applicant in accordance with the approved plan. 6. Grading; and Erosion Control. Prior to the issuance of the coastal development permit, the applicant shall submit, for the review and written approval of the Executive Director, final grading plans, approved by the City of Carlsbad which shall be subsequently implemented and conform to the following requirements: A-6-CII-98-98 Page 16 a) No grading activities shall be allowed during the rainy season (the period from November 15 to March 3 1st of each year). All disturbed areas will be replanted immediately following grading and prior to the beginning of the rainy season. The applicant shall undertake the development in accordance with the approved grading and erosion control plan. Prior to commencement of any grading activity, the applicant shall submit a grading schedule to the Executive Director. b) The installation of temporary and permanent runoff and erosion control devices shall be developed and installed prior to or concurrent with any on-site grading activities. c) All areas disturbed, but not completed, during the construction season, including graded pads, shall be stabilized in advance of the rainy season. The use of temporary erosion control measures, such as berms, interceptor ditches, sandbagging, filtered inlets, debris basins, and silt traps shall be utilized in conjunction with plantings to minimize soil loss from the construction site. 7. Clapper Rail Protection Plan. Prior to the issuance of the coastal development permit, the applicant shall submit for the review and written approval of the Executive Director, a clapper rail protection plan which has been developed in consultation with the Department of Fish and Game. The plan shall document that no construction activities shall be allowed during the breeding season of the light-footed clapper rail within the wetlands adjacent to the project site. Project construction shall be prohibited during the breeding season, March 1 through August 1, unless a focused survey for the clapper rail is conducted immediately prior to project construction and determines that no clapper rails were observed during the study. The wetlands buffer area shall be staked and flagged in the field by a licensed surveyor and shall be shown on the submitted clapper rail protection plan. A minimum of three notices shall be posted within this area to specifl that this area is off-limits to construction activity. 8. Final LandscaueLightingExterior Treatment Plan. Prior to the issuance of the coastal development permit, the applicant shall submit for the review and written approval of the Executive Director, in consultation with the Department of Fish and Game, a revised landscape/lighting/exterior treatment plan, approved by the City of Carlsbad, which shall incorporate the following: a. Building - Materials/Colors. No copper roof or concrete block materials are permitted. The proposed residence and garage/second unit shall utilize colors and building materials with earth tone colors (deep shades of green brown and gray A-6-CII-98-98 Page 17 with no white or light shades, and no bright tones) to minimize the development’s contrast with the surrounding scenic area. b. Lighting. An exterior lighting plan shall be submitted, developed in consultation with the Department of Fish and Game, which indicates all exterior lighting shall include a combination of low-level lights and shields to minimize the amount of light entering the adjacent wetlands and wetland buffer area. c. Revised Landscapinq Plans. The plan shall indicate the type, size, extent and location of all plant materials, the proposed irrigation system and other landscape features and be subject to review by the Department of Fish and Game. The landscaping plan shall consist of native, drought-resistant landscaping acceptable to the Executive Director in consultation with the Department of Fish and Game. 1. The revised landscape plan shall indicate the placement of a minimum of one specimen size tree (24-inch box minimum) for every 10 feet of pad area lagoonward of the proposed building sites and arranged to maximize screening of the structures from views from Buena Vista Lagoon, its public trail, Old Highway 101 and the railroad. A minimum of 8-trees shall be provided lagoonward of the building pad for Parcel A. 2. At maturity the trees shall approximate the height of the roofline of the residences. 3. The required trees shall be planted within 60 days of completion of residential construction and be maintained in good growing condition for the life of the residences. Maintenance requirements to assure no blockage of public views must be incorporated into the approved plan. 4. The plan must also indicate non-native plant species shall be removed from the wetland buffer area and the wetland buffer area shall be revegetated with a hydro-mulched coastal sage scrub seed mix. The permittee shall undertake development in accordance with the approved final plans. Any proposed changes to the approved final plans shall be reported to the Executive Director. Proposed changes to the approved final plans shall not occur without a Coastal Commission-approved amendment to this coastal development permit unless the Executive Director determines that no amendment is required. V. Findings and Declarations. The Commission finds and declares as follows: A-6-(211-98-98 Page 18 1. Detailed Pro-iect Description. Proposed is the construction of a 2,713 sq.ft. residence, consisting of two-stories over 30 feet tall, and features a copper-colored metal roof and concrete block walls. Also proposed is a 1,633 sq.ft., 35-foot high garage with a 577 sq.ft. second unit above. Estimated grading quantities include 75 cubic yards of cut and 75 cubic yards of fill to be balanced on-site. Also proposed is off-site private access improvements, the replacement of gate and fencing on the site. The proposed project site is made up of two lots comprising 2.6 acres located along the south shore of Buena Vista Lagoon, west of the AT&SF Railroad and north of Mountain View Drive in northern Carlsbad. The project site is covered with disturbed shrub habitat. There are no steep slopes or native vegetation on the project site. Fresh water marsh occurs on the northwest and eastern boundaries of the site below the rip-rap line. The property is vacant and an existing unimproved lagoon trail is located along its western edge and continues to circle the site like a loop. The AT&SF railroad right-of-way lies to the east of the site, and multi-family housing is located to the south of the project site. The site is designated Residential Low (RL, 0-1.5 ddac) and zoned R-1-30,000 in the certified Mello I1 LCP. 2. Visual Resources. The previously cited visual resource policies of the Mello 11 LUP provide for the protection of scenic coastal areas and for the compatibility of existing and new development. The project site is in an area of scenic beauty as it lies at approximately 12 MSL adjacent to the Pacific Ocean, Buena Vista Lagoon and its associated open water and freshwater marsh habitats. The project site is an approximately 2.6-acre vacant and flat parcel that sits in the lowlands near the mouth of the south shore of Buena Vista Lagoon. It is bordered by the lagoon to the north and west and a freshwater marsh to the east with residential development to the south at higher elevations. While existing apartment and condominium structures located south of the subject site present an urban backdrop, when looking west from old highway 10 1 across the project site to the ocean, the unique setting of this area was not considered by the City in its approval. Although ocean views would not be significantly altered by this project (except from passenger trains on the adjacent rail line), the City approved residential structures that are large and as such will “stand out”at this location. The bulk and scale of the proposed 30 - 35 foot high structures is out of character with this unique, low-lying site given its proximity to the lagoon and ocean. In addition, the proposed development includes a copper colored roof and a concrete block wall facade. Policies 3-2 and 8-1 of the Mello I1 LUP require that new development be visually subordinate to its setting. The Commission finds that the project, as proposed, is out of character with its setting and is inconsistent with the policies. It would be visible Erom a number of public locations (beach, railroad, and Old Highway 101 from City of Oceanside and near the Carlsbad pump station to the east of the site) and is not appropriate for its lagoon setting. In that regard, the Commission finds the proposed residence and A-6-CII-98-98 Page 19 garagelsecond unit must be redesigned to be no higher than 25 feet high. This height is consistent with the San Malo residential project, located immediately north of the project site across the lagoon in the City of Oceanside, which is known not only for its French Normandy architecture but for its modest scale which makes it subordinate to the oceadlagoon setting. In several other permit decisions in Carlsbad, the Commission has also required a 25-foot height limit to reduce the visual impacts of new development. These actions primarily concerned larger residential subdivisions in the Aviara and Sammis Property projects on Batiquitos Lagoon in southern Carlsbad. While this project is of less intensity, it nonetheless has a great visual impact on the surrounding environs of Buena Vista Lagoon. For that reason, the Commission finds the height reduction is warranted, As such, Special Condition #1 requires revised plans that limit project height to 25 feet high. Additionally, Special Condition #8 requires building materials/colors to be subordinate to the lagoon setting by requiring the proposed residence and garagehecond unit shall be painted with earth tone colors (deep shades of green brown and gray with no white or light shades, and no bright tones) to minimize the development’s contrast with the surrounding scenic area. The height reduction and color changes will result in a smaller, less visually obtrusive project that is compatible with its setting. Special Condition #2 requires the entirety of the property - which includes the other .72 acre adjacent lot under the applicant’s ownership - to be subject to the above provisions in the form of a deed restriction. This restriction is necessary to insure fkture property owners are aware of condition requirements. The applicant has submitted a landscaping plan that indicates a number of non-native trees and shrubs would be planted. These trees and shrubs may be noxious or invasive to the existing sensitive habitat area surrounding the project site. Special Condition #8 requires that a landscaping plan be developed in consultation with the Department of Fish and Game. The Commission hrther finds that landscaping upland of the buffer shall be designed to mitigate the visual impact of the structures as viewed from the lagoon and public access trail, while preserving views from the homes. the natural character of the surrounding environment (i.e., non-invasive or noxious). The revised landscape plan shall indicate the placement of a minimum of one specimen size tree (24-inch box minimum) for every 10 feet of pad area lagoonward of the proposed building sites and arranged to maximize screening of the structures from views from Buena Vista Lagoon and its public trail and Old Highway 101 and the railroad. A minimum of 8-trees shall be provided lagoonward of the building pad and be compatible with the existing lagoon environment. At maturity the trees must approximate the height of the roofline of the residences. The revised landscape plan must include provisions requiring the trees to be planted within 60 days of completion of residential construction and be maintained in good growing condition for the life of the residences . Maintenance requirements must also be provided to assure no blockage of public views. A-6-C1I-98-98 Page 20 In summary, as required to redesign proposed residential development to be subordinate to its lagoon setting to be no higher than 25 feet in height and that building materials and colors be earth-tone colors, and that appropriate screening vegetation is provided to hrther reduce the visual impact of the proposed project, the Commission finds the proposed project can be found consistent with the visual resource protection policies of the certified LCP. 3. Public Access/Recreation. Both the certified LCP and the Coastal Act contain policies protecting physical access to the beach and ocean. Policies 7-3 and 7-6 of the LUP and Section 30212 of the Coastal Act require that access to and along the shoreline be maintained. The subject site is located between the first public roadway and the sea at the ocean entrance to Buena Vista Lagoon. There is evidence of use of a trail on the site. There is a system of trails on the applicant’s property which together form a loop around the subject property. These trails are well-worn footpaths which appear on numerous aerial photographs dating back to 1972. Presently, based on these existing paths, it appears that access to this loop trail is fiom the ocean and from an informal path to the east through the fresh water marsh from Carlsbad Blvd and next to tennis courts on Mountain View Drive. In CDP #6-83-51, the Commission approved the subdivision of the property immediately adjacent to and south of the subject site. The permit allowed subdivision of a 7.65 acre parcel into three lots and construction of 14 condominiums (ref. exhibit #6). In its approval of CDP #6-83-51, the Commission required Lot 3, the lot over which the applicant must take access to get to the project site, to be reserved as open space through an offer to dedicate an open space easement. In its open space easement condition, the Commission prohibited all development except for development needed to allow for vehicle access across Lot 3 to the lagoon weir and for public projects that were planned on this low-lying area, including wetland restoration and possibly as a depository site for beach replenishment projects. The condition did not recognize any private vehicular access across Lot 3 which is needed for the applicant to get to the project site. However, the applicant has demonstrated the right of private vehicular access across Lot 3 to the project site through an easement that was initially granted in 1971 and then recorded again n 1984. In its approval of CDP 6-83-51, the Commission also required a public access easement over the entirety of Lot 3. Neither the offer to dedicate an easement for public access nor the offer to dedicate an open space easement have been accepted by a public agency or private association. The City’s decision on this project formalizes lateral access along the lagoon but does not address how the public will access the trail, lagoon and ocean from Mountain View Drive. Section 30212 of the Coastal Act and Policy 7-6 of the LUP require that vertical access to and along the shoreline be provided where appropriate. The City’s action failed to provide public vertical access fiom Mountain View Drive to the ocean and the shore of the lagoon which is inconsistent with these provisions. As such, the Commission finds that replacement of the existing manual gate A-6-CII-98-98 Page 21 with a new electric gate will give the impression that this area is private which could hrther limit access by the public, inconsistent with Coastal Act and LCP policies. As stated the policies of the Coastal Act and the Mello II LCP protect public access both to and along the shoreline, including the shoreline of Buena Vista Lagoon. Policies 7-3 and 7-6 specifically provide that access shall be provided along and near Buena Vista Lagoon on the applicant’s property. The City’s approval secured the access path identified in Policy 7-6 by requiring the applicant to dedicate an easement over the existing trail near the water’s edge. The Commission’s requirement mirrors that approved by the City in Special Condition #4 and provides that the easement shall be located along the entire width of the property along the Buena Vista Lagoon shoreline as shown on the site plan dated 7/17/98. In addition, the Commission finds additional steps must be taken to preserve and protect existing public access opportunities consistent with the above LUP policies. For example, the applicant is proposing the installation of 42’’ high chain link fencing across the required 100 foot setback (exhibit 7). The applicant is also proposing the installation of a time-lock gate within this fence which would extend across the existing trail and be open from dawn to dusk. In two recent decisions by the Commissian in Carlsbad (CDP 6-96-159, Cade/ and LCPA 1-984 Poinsettia Properties Specific Plan), the Commission found that time lock gates were inappropriate. In its action to prohibit them, the Commission found that unrestricted public access was warranted for coastal visitors to be able to access coastal resources. Time lock gates are also subject to mechanical failures and vandalism which limit their effectiveness. In the former decision, the Commission allowed the applicant security fencing at the upper limit of a habitat buffer to protect against vandalism. In this way both public access and private security was maintained. This case is similar in that the Commission is allowing the applicant to fence the site for security reasons but is not allowing fencing or gates that would preclude existing public access. Special Condition #1 requires that the gate and fence be deleted so that the public access trail will remain open at all times along the shoreline of Buena Vista Lagoon. The applicant is also proposing the installation of 6’ high chain link fencing and vegetation on the eastern portion of the site around the access turnaround. Again, fencing at this location could preclude continued movement by the public. Presently, there is a foot path that provides access along the eastern portion of the project site in the 100-foot habitat setback. While the Commission recognizes the need for the setback, it also recognizes that historic public use has occurred along this portion of the trail. Policy 7-3 of the Mello I1 LUP requires that access be maintained in this area consistent with resource protection. For this reason the Commission is requiring in Special Condition #1 that the applicant submit a fence plan which provides fencing such that the public will not be precluded from using this area as they have in the past. Implementation of this condition will require that Ad-CII-98-98 Page 22 passage through a portion of the fence be provided so that the trail in the eastern buffer will remain accessible for public use. As noted, access to the project site must come over a lot which is not under the applicant’s ownership (Lot 3). Presently, a gate precludes public access over this lot fi-om Mountain View Drive. In 1983, the Commission approved a public access easement over this lot. Thus, the present situation is inconsistent with the Commission’s previous approval. The applicant desires to replace this gate with an electric gate, but does not include a provision for public pedestrian access. The Commission finds that replacement of the existing manual fence with a new electric gate will give the impression that this area is private and would hrther limit access by the public, inconsistent with the public access policies of the Coastal Act and the LCP. In summary, as required to revise fencing and gating plans and record a lateral access easement? the Commission finds the project will not have adverse public access impacts. Only as conditioned, can the Commission find the proposed project in conformance with the access policies of the certified Mello I1 LCP and the Coastal Act. 4. Environmentallv Sensitive Habitat Areas. The project site is an approximately 2.6- acre vacant and flat parcel that sits in the lowlands near the mouth of the south shore of Buena Vista Lagoon. It is bordered by the lagoon to the north and west and a fieshwater marsh to the east. Coastal lagoons offer habitat and a resting place for many sensitive plants and animals, including the endangered light footed clapper rail which resides in the freshwater marsh immediately adjacent to the applicant’s site. In recoption of these resources? the certified LCP establishes development setbacks from the resource and requires these setbacks to be reserved as open space. Special Condition #3 requires development setbacks from both the open waters of Buena Vista Lagoon and its associated fieshwater marsh. In its findings for approval, the City found that the project was consistent with the certified Mello I1 Coastal Resource Protection Overlay Zone (Chapter 2 1.203 of the zoning ordinance) in that the project would adhere to the City’s Master Drainage and Storm Water Quality Management Plan and Grading Ordinance to avoid increased runoff and soil erosion, no steep slopes or native vegetation is located on the subject property and the site is not located in an area prone to landslides, or susceptible to accelerated erosion, floods or liquefaction. The adjacent Buena Vista Lagoon wetlands have been delineated and the project has been designed to include a minimum 100 foot setback between the wetlands and all structures. The developer has been conditioned to record an open space deed restriction over the entire wetland buffer setback area and to make an irrevocable offer of dedication of the wetlands buffer to the California Department of Fish and Game. A-6-CII-98-98 Page 23 The Commission finds that similar provisions are necessary as part of this coastal development permit. That is, the Commission finds an open space deed restriction over sensitive areas of the site is warranted. Special Condition #3 requires the restriction shall prohibit any alteration of landforms, erection of structures of any type and removal of vegetation, except as permitted herein, for any purposes in the proposed buffer areas as shown on the site plan dated 7/17/98 (Exhibit 8). Also, removal of the fence within the buffer is necessary because it could limit wildlife movement and provide a predator perch. Several policies of the certified LCP also require that project construction not indirectly adversely impact coastal resources by way of erosion and sedimentation. The Commission finds in Special Condition #5 that final drainage and runoff control plans must be submitted to assure no increase in peak runoff rate from the developed site over runoff from the natural site, as a result of a ten-year frequency storm over a six-hour duration (10 year, 6 hour rainstorm). The plan shall document that runoff from the impervious surfaces of the site will be collected and discharged at a non-erosive velocity and elevation. A sedimentation catch basin is proposed on the southeast corner of the site to direct surface runoff to the east of the site within the freshwater marsh which is part of Buena Vista Lagoon. Policy 3-2 of the Mello II LUP provides that no direct discharges to the lagoon can occur without approval of the Department of Fish and Game. Therefore, Special Condition #5 requires the applicant to consult with the Department of Fish and Game to ensure drainage in this sensitive area can be found consistent with Policy 3-2 of the Mello II LCP. Also, in Special Condition #6 the Commission finds that although there is only minor grading being proposed @e., 75 cubic yards of balanced grading) based on the location and the surrounding resources, final grading plans must be submitted which indicate no grading activities shall be allowed during the rainy season (the period from November 15 to March 3 1st of each year). Typically, the rainy season begins on October 1 of any year; however, because of wildlife concerns, the rainy season restriction can be extended to November 15 in this case. Also, all disturbed areas will be replanted immediately following grading and prior to the beginning of the rainy season. The installation of temporary and permanent runoff and erosion control devices shall be developed and installed prior to or concurrent with any on-site grading activities. Finally, as noted, a nesting pair of clapper rails is known to exist within the freshwater marsh area located immediately east of the project site. The Commission is requiring that development be setback 100-feet from this marsh and that this setback be secured through an open space deed restriction. Additionally, as hrther protection to this endangered species and as requested by the Department of Fish and Game, the Commission is requiring in Special Condition #7 that no construction activities be allowed during the breeding season of the light-footed clapper rail within the wetlands adjacent to Ad-(211-98-98 Page 24 the project site. Thus, project construction shall be prohibited during the breeding season, March 1 through August 1, unless a focused survey for the clapper rail is conducted immediately prior to project construction and determines that no clapper rails were observed during the study. Special Condition #8 requires an exterior lighting plan shall also be submitted which indicates all exterior lighting will include a combination of low- level lights and shields to minimize the amount of light entering the adjacent wetlands and wetland buffer area. Further, the wetlands buffer area shall be staked and flagged in the field by a licensed surveyor. A minimum of three notices shall be posted within this area to specifjr that this area is off-limits to construction activity. In summary, as conditioned to mitigate project related impacts to surrounding resources through the provision of habitat buffers preserved as open space and an appropriate location for project drainage, the Commission finds the project consistent with the resource protection policies of the Coastal Act and the Mello II LCP. In summary, the Commission finds that with 100-foot habitat setbacks on the east and west sides of the site to be secured through an open space condition, a public access easement on the south side of Buena Vista Lagoon, revised plans that indicate the proposed residential development will be redesigned to be subordinate to its lagoon setting by being no higher than 25-feet high and that building materials and colors be earth-tone colors, that existing public trails on the site be preserved so as to not preclude existing public rights, that fencing and gating plans be revised to not adversely affect public access, that grading, drainage and runoff control plans be submitted to ensure that downstream resources will not be indirectly affected from proposed development and that a clapper rail protection plan be implemented which ensures this endangered avian will not be adversely affected from residential development in this scenic and sensitive area the project can be found consistent with all applicable Coastal Act and Mello I1 LCP provisions. Only as conditioned above is the proposed project consistent with the resource protection policies of the certified LCP. 5. Local Coastal Planning. Section 30604(a) also requires that a coastal development permit shall be issued only if the Commission finds that the permitted development will not prejudice the ability of the local government to prepare a Local Coastal Program (LCP) in conformity with the provisions of Chapter 3 of the Coastal Act. In this case, only as conditioned, can such a finding be made. As noted above, the project as submitted has been found inconsistent with a number of Coastal Act and LCP policies. As conditioned, the project will establish open space and public access easements to protect existing coastal resources and public trails, control runoff to mitigate any potential sedimentation of the adjacent lagoon, and provide adequate landscaping and design revisions to preserve the scenic amenities of the area. The proposed project is also consistent with the land use designation and density Ad-CII-98-98 Page 25 permitted in the LCP. Therefore, the Commission finds project approval, as conditioned, will not seriously prejudice the implementation of the Carlsbad LCP. 6. Consistency with the California Environmental Ouality Act (CEOA). Section 13096 of the Commission’s Code of Regulations requires Commission approval of Coastal Development Permits to be supported by a finding showing the permit, as conditioned, to be consistent with any applicable requirements of the California Environmental Quality Act (CEQA). Section 21080.5(d)(Z)(A) of CEQA prohibits a proposed development from being approved if there are feasible alternatives or feasible mitigation measures available which would substantially lessen any significant adverse effect which the activity may have on the environment. The proposed project has been conditioned in order to be found consistent with the visual resource, public access and environmentally sensitive habitat policies of the Coastal Act and the certified LCP. In this case, there are no feasible alternatives available which can lessen the significant adverse impact the project will have on public views, public access and the environment. The proposed conditions addressing landscaping, fencing, gating , building design and protection of public access and environmentally sensitive habitat, will minimize all adverse environmental impacts. As conditioned, there are no feasible alternatives or feasible mitigation measures available which would substantially lessen any significant adverse impact which the activity may have on the environment. Therefore, the Commission finds that the proposed project is the least environmentally-damaging feasible alternative and can be found consistent with the requirements of the Coastal Act to conform to CEQA. STANDARD CONDITIONS: 1. 2. 3. Notice of Receipt and Acknowledgment. The permit is not valid and development shall not commence until a copy of the permit, signed by the permittee or authorized agent, acknowledging receipt of the permit and acceptance of the terms and conditions, is returned to the Commission office. Expiration. If development has not commenced, the permit will expire two years from the date on which the Commission voted on the application. Development shall be pursued in a diligent manner and completed in a reasonable period of time. Application for extension of the permit must be made prior to the expiration date. Compliance. All development must occur in strict compliance with the proposal as set forth below. Any deviation from the approved plans must be reviewed and approved by the staff and may require Commission approval. A-6-CII-98-98 Page 26 4. Interpretation. Any questions of intent or interpretation of any condition will be resolved by the Executive Director or the Commission. 5. Inspections. The Commission staff shall be allowed to inspect the site and the development during construction, subject to 24-hour advance notice. 6. Assinnment. The permit may be assigned to any qualified person, provided assignee files with the Commission an affidavit accepting all terms and conditions of the permit. 7. Terms and Conditions Run with the Land. These terms and conditions shall be perpetual, and it is the intention of the Commission and the permittee to bind all kture owners and possessors of the subject property to the terms and conditions. (9898R.doc) I . JUL-22-98 WED 14:01 CITY OF CARLSBAD COtlfl DE FAX NO. 4380894 -. - - APPLICATION NO. A-6-CI 1-98-98 Location Maps P. 15 __. LEVY RESIDENCE CDP 97-59 STATE OF CALIFORNIA-THE RESOURCES AGENCY PETE WILSON, &=mor CALIFORNIA COASTAL COMMISSION SAN DlEGO COAST AREA 3111 CAMINO DEL RIO NORTH, SUITE 200 APPEAL FROM COASTAL PERMIT DECISION OF LOCAL GOVERNMENT SAN DIEGO, CA 92108-1725 (619) 521-8036 P1 ease Rev! ew Attached Appeal Informati on Sheet Prior To Compl eti ng This Form. SECTION I. ADD^^ 1 ant Name, mailing address and telephone number of appellant: Commi ssioner Christine Kehoe Citv of San Dieao 202 "C" s treet. S an Dieuo 9 2101 61 9 236-6633 Zip Area Code Phone No. SECTION 11. Deci sion Bei nu ADueal ed 1. 2. Brief description of development being appealed: Construction of a Name of local /port government: Ci tv o f Carlsbad ~ two-s or sa.ft. second dwell ins unit over a detached uaraue won a 1.9 acre lot. 3. no., cross street.etc.1: South Shore of Buena Vista Laqoon. west of the AT&SF Railroad. north of Mountain View Drive. Ca rlsbad. San Dieao Cou ntv Development's location (street address, assessor's parcel 4. Description of decision being appealed: a. Approval ; no speci a1 condi ti ons : b. Approval with special conditions: xxx c. Denial: decisions by a local government cannot be appealed unless the development is a major energy or public works project. Deni a1 deci si ons by port governments are not appeal ab1 e. Note: For jurisdictions with a total LCP, denial TO BE COMPLETED BY COMMISSION: DATE FILED: 7/27/g% 3 EXHIBITNO. 3 APPLICATION NO. A-6-C I I -9 8 -98 2 5 Appeal Form 4 Appeal Summary Page 2 APPEAL FROM COASTAL PERMIT DECISION OF LOCAL GOVERNMENT (Paae 2) 5. Decision being appealed was made by (check one): a. -Planning DirectorIZoning c. JPlanning Commission Admi ni strator b. -City Council/Board of d. Other Supervisors 6. Date of local government's decision: Julv 1. 1998 7. Local government's file number (if any): CDP 97-59 SECTION 111. Identification of Other Interested Persons Give the names and addresses of the following parties. (Use additional paper as necessary. 1 a. Name and mailing address of permit applicant: 1825 Aston Ave. Carlsbad. Ca lifornia 9 2008 b. Names and mailing addresses as available of those who testified (either verbally or in writing) at the ci ty/county/port hearing(s1. Include other parties which you know to be interested and should receive notice of this appeal . SECTION IV. Reasons SUDDO rtina Thi s ADDeal Note: Appeals of local government coastal permit decisions are limited by a variety of factors and requirements of the Coastal ct. Please review the appeal information sheet for assistance in completing this section, which continues on the next page. Appeal Summary Page 3 APPEAL FROM COASTAL PERMIT DECISION OF LOCAL GOVERNMENT (Paqe 3) State briefly your reasons for this aooeal. description of Local Coastal Program, Land Use Plan, or Port Master Plan policies and requirements in which you believe the project is inconsistent and the reasons the decision warrants a new hearing. (Use additional paper as necessary.) Include a summary The Droiect includes co nstruction of a residence and second dwelling unit on a 1 proiect reauires an access road to the subiect uarcel which extends across a 1 access in a De rmit for subdivision of the adjacent parcels (CDP #6-83-51). That oermit has not vet been amended to allow the access road in the ouen space. of the road in the least environmentally damaains alianment and public use of the road within the pub lic access looen soace lot. A second co ncern is the leaalitv o f the lot on which the Drouosed residence is located. It amears that redivision of two lots was required to reach the current confiquration of lots on which the residence was aooroved: however. the City did not Drocess a rthe time the Commission approved the adiacent subdivision, the number of existins legal lots on this site and the aourouriate intensity of use on this site was auestioned due to concerns associated with a develoDment's oroximitv to wetlands, visual impact and the effects on public access to the laaoon. All of these issue s should have been addressed at the subdivision staae throush cdo review bv the Citv. AUDrOVal of a permit for an sfr on this lot which has > bccess road which has not been authorized bv the Commission throuah an 1 Issues which must be addressed in that amendment review include siting Concerns related to the residential oroiect include the sitina and desisn to greserve existins Dublic views from Carlsbad Blvd.. the railroad and the the laaoon: and the Droximitv of the develooment to wetlands. Therefore. the B r 0.1 e c t raises auestion reaardina consistency with the uublic access and recreation oolicies of the Coastal Act. and aoulicable LCP eolicies which include address develooment ad. iacent to Buena Vista lasoon. protect oublic vistas. environmentallv sensitive habitat areas and oublic access. 1 Note: statement of your reasons of appeal; however, there must be sufficient discussion for staff to determine that the appeal is allowed by law. The appellant, subsequent to filing the appeal, may submit additional information to the staff and/or Commission to support the appeal request. The above description need not be a complete or exhaustive SECTION V. Certification The information and facts stated above are correct to the best of my Appellant or Agent PETE WILSON, Gommr STATE OF CALIFORNIA-THE RESOURCES AGENCY CALI FORNl A COASTAL COMMISSION SAN DIEGO COAST AREA APPEAL FROM COASTAL PERMIT 3111 CAMINO DEL RIO NORTH, SUITE 200 DECISION OF LOCAL GOVERNMENT SAN DIEGO, CA 92108-1725 (619) 521-8036 P1 ease Rev! ew Attached Appeal Information Sheet Prior To Completing This Form. SECTION I. ADDellant Name, mai 1 i ng address and telephone number of appel lant: Commissioner Pedro Nava Bauer. Harris. McEvov & C 1 i nkenbeard 925 De La Vina Street Santa Barbara, CA 93101 805 965-0043 Zip Area Code Phone No. SECTION 11. Decision Beina Appealed 1. Name of local/port government: Citv of Carlsbad 2. two-storv. 33 -feet hish and 2.713 sa .ft. sinsle family residence and 577 sa.ft. seco nd dwellina unit over a detac hed sa raae UDO n a 1.9 acre lot. Brief description of development being appealed: Co nstruction of 3 3. Development's location (street address, assessor's parcel no., cross street,etc.): Sbf Mountain View Drive. Ca rlsbad. Sa n Dieso Cou ntv 4. Description of decision being appealed: a. Approval ; no special conditions: b. Approval wi th speci a1 condi ti ons : xxx c. Denial: Note: For jurisdictions with a total LCP, denial decisions by a local government cannot be appealed unless the development is a major energy or public works project. Denial decisions by port governments are not appeal TO BE COMPLETED BY COMMISSION: Bc F0 _. DATE FILED: 7h 01 STRICT : 5& Appeal Summary Page 2 APPEAL FROM COASTAL PERMIT DECISION OF LOCAL GOVERNMENT (Paae 2) 5. Decision being appealed was made by (check one): a. -Planning Director/Zoning b. -City Counci 1 /Board of c. XPlanning Commission d. Other Administrator Supervisors 6. Date of local government's decision: Julv 1. 1998 7. Local government's file number (if any): CDP 97-59 SECTION 111. Pers n Give the names and addresses of the following parties. (Use additional paper as necessary. 1 a. Name and mailing address of permit applicant: 1825 Aston Ave. Carl sbad. Cal i forni a 92008 b. Names and mailing addresses as available of those who testified (either verbally or in writing) at the ci ty/county/port hearing(s1. Include other parties which you know to be interested and should receive notice of this appeal. SECTION IV. R/ Note: Appeals of local government coastal permit decis limited by a variety of factors and requirements of the ct. Please review the appeal information sheet for ass in completing this section, which continues on the next ons are Coastal stance Page * APPEAL FROM COASTAL PERMIT DECISION OF LOCAL GOVERNMENT (Paqe 31 State briefly your reasons for this amea 1. description of Local Coastal Program, Land Use Plan, or Port Master Plan policies and requirements in which you believe the project is inconsistent and the reasons the decision warrants a new hearing. (Use additional paper as necessary.) Include a summary Note: statement of your reasons of appeal; however, there must be sufficient discussion for staff to determine that the appeal is a1 lowed by law. The appellant, subsequent to filing the appeal, may submi t additional information to the staff and/or Commission to support the appeal request. The above description need not be a complete or exhaustive SECTION V. Certification The information and facts stated above are correct to the best of my know1 edge. Signed Date 1 Aaent Authorization: act as my agent in a1 1 matters pertaining to this appeal. I designate the above identified person(s1 to Signed Appel 1 ant Date 001 6F I I I I I I , _- 8 . I I' i 1 I . . .- _. . r , .. : 1. .. . . , - -. - - _. . . . . - . - . - . . . . . .. . FROM -/ .. / UH-LPYH Utl:LYcIPl IU x YlOlYSLlYOlL - - L. . .1 -.., : i ' ": .. . , EXHIBIT 6 AERIAL IMAGE: 2003 AERIAL IMAGE: 2024