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HomeMy WebLinkAboutCT 93-09; Ocean Bluff; Tentative Map (CT) (25)STATE OF CALIFORNIA—THE RESOURCES AGENCY PETE WILSON, Governor CALIFORNIA COASTAL COMMISSION SAN DIEGO COAST AREA 3111 CAMINO DEL RIO NORTH, SUITE 200 SAN DIEGO, CA 92108-1725 (619) 521-8036 December 21, 1995 Ann Hysong City of Carlsbad Planning Department 2075 Las Palmas Drive Carlsbad, CA 92009-1576 Re: Notice of Prior Environmental Compliance/Ocean Bluff I apologize for the lateness of these comments. Staff has reviewed the subject document and has the following comments. The proposed subdivision consists of 92 single family lots and one multiple family lot (16 apartment units) on 32 acres of previously disturbed farmland resulting in no on-site disturbance to biological resources. The document indicates that biological impacts to one pair of gnatcatchers and to approximately 4 acres of coastal sage habitat will result from the off-site extension of Poinsettia Lane from its existing terminus at Alga Road to the southwestern corner of the Ocean Bluff site. Other off-site improvements that are proposed to serve the project include Street "A" from the southwest corner of the project south to the intersection of future Poinsettia Lane extension and Blackrail Road from its existing northern terminus to the northeast corner of the project. On-site grading results in 320,000 cubic yards of balanced cut and fill and involves a terraced hillside design. Prior environmental compliance for this project is based on the Zone 20 Specific Plan Program EIR. The project also consists of a local coastal program amendment and zone change from L-C to R-l the single family zone. The draft document adequately assesses and provides for the agricultural conversion of the historic farmlands present on the property. In addition, the proposed use, as well as its intensity, appears consistent with the certified LCP direction. The environmental document (Notice of Prior Environmental Compliance with the Zone 20 Program EIR) identifying project impacts states that off-site access improvements will impact a nesting pair of gnatcatchers and encroach into 4 acres of sensitive resources, including dual criteria areas protected by the Mello II LUP. The document states the dual criteria policy does not apply to the construction of Circulation Element roads. While the LCP provides for limited resource impacts for such roads, Policy 5-5 of the certified Mello II LCP provides that Poinsettia Lane should be completed as a major arterial as indicated on the Local Coastal Program Map by 1995. The document under review does not acknowledge this provision or provide an exhibit that depicts the alignment of Poinsettia Lane as approved on the LCP map. Any proposed alignment change from that approved on the LCP map must be submitted to the Commission for approval as a LCP amendment. The LCPA must be submitted prior Ann Hysong December 21, 1995 Page 2 to the Commission's action on the coastal development permit for the subject tentative map. In addition, the environmental document and any proposed LCPA should evidence how the recommended alignment represents the least environmen- tally-damaging alternative. The environmental document identifies that .28 acres of coastal sage scrub will be impacted to construct Street "A" from the southwestern corner of the Oceanbluff parcel to the proposed Poinsettia Lane extension. The document indicates that this impact will be mitigated "in-kind" at an off-site >• location. Street "A" is not a circulation element road and resource impacts associated with it can only be considered if it is found that it provides access to flatter, more developable areas and there is no less environmentally- damaging alternative. The document does not acknowledge this requirement and fails to provide the required analysis. Regarding conformance with the Natural Communities Conservation Planning (NCCP) program, the document states that, although disturbance to approximately 4 acres of coastal sage scrub and southern mixed chaparral habitat and a nearby nest of gnatcatchers will result from construction of Poinsettia Lane and Street "A", it will not preclude connectivity between Preserve Planning Areas (PPA) nor preclude the preservation of 50% of the habitat in PPA 4 (the subject preserve planning area). The document thus concludes the impacts can be accepted as consistent with the NCCP and the City's Habitat Management Program as mitigated. However, the environmental /• document fails to indicate whether the proposed off-site road alignments have been accepted by the resource agencies so as to not preclude long-range planning options with regard to coastal sage scrub and gnatcatcher protection. Additionally, as mentioned above, possible LCP prejudice concerns exist with these alignments and the pattern of development they may support. Finally, the City has used the Zone 20 Specific Plan as the standard of review for this project. The specific plan has been approved at the local level but has not been submitted to the Commission as an LCPA for review and certification. As you know, the circulation system in the Zone 20 area has not been analyzed by the Commission with respect to determining the least environmentally-damaging road design in Zone 20. We encourage the City to submit the specific plan as an LCP amendment to address these issues now. These comments have been based on the information currently available. Ultimately, the Coastal Commission is the decisionmaking body and these comments are drafted to give guidance. Please contact me if you have any questions. Sincerely /tiff.Bill Ponder Coastal Planner BP:bp(0787A)