HomeMy WebLinkAboutCDP 97-25; Carlsbad Municipal Golf Course; Coastal Development Permit (CDP) (4)+ - '. L.
City of Carlsbad
June 14,2000
Bill Ponder
California Coastal Commission
31 11 Caminito Del Rio North, Suite 200
San Diego, CA 921 08-1 725
SUBJECT: Carlsbad Municipal Golf Course
Dear Mr. Ponder:
On June 6, 2000 we received a letter from you stating that Commission staff would seek
a Commission appeal of the project if approved by the Planning Commission as it is
currently proposed. Your letter was distributed to the Planning Commission prior to its
decision to approve the project. For your information the project has been revised to
eliminate all impacts to the isolated fresh water marsh. Additionally we are redesigning
hole #12 to eliminate any impact to the mixed riparian habitat in Macario Canyon. The
redesign of hole #12 is a substantial conformance matter that will not require an
amendment to the City's coastal permit. Instead it is being processed as an addendum
to the construction bid package.
On June 12, 2000 the City filed a Notice of Final Action for the golf course project. It is
my understanding that the appeal period will end on June 26, 2000 if a valid appeal is
not filed. As you know, that notice indicated that the project is within the Commission's
appeal jurisdiction. Please note however, that the Post LCP Certification Map that was
submitted as part of the City's "Effective Certification" package did not identify any area
covered by the golf course project as being within the Commission's appeal jurisdiction.
The Macario Canyon riparian area has developed over the last several years through
mitigation efforts by the City combined with a more predictable source of water from
urban runoff and irrigation related to the adjacent agricultural operations. Without this
source of water, the mixed riparian habitat would be reduced in size and it would
migrate to the Cannon Road bridge area. In other words, it's not really a natural riparian
habitat. This is probably why it was not included within the Commission appeal
jurisdiction on the Post LCP Certification Map.
Your letter also identifies the issue of encroachment into "dual criteria" steep slopes
covered be Policy 4-3 of the City's LCP. The golf course project encroaches into 8.5
acres of dual criteria steep slopes out of 24.9 acres contained on the Huntington Beach
property and Macario Canyon. This calculates to approximately a 34% encroachment.
I'd like to remind you that, the permit issued by the Coastal Commission for the
industrial subdivision of the Huntington Beach property also used the Policy 4-3 as a
standard of review and allowed for more than 50% encroachment without any mitigation.
1635 Faraday Avenue - Carlsbad, CA 92008-7314 (760) 602-2710 - FAX (760) 602-8560
- ,. . Carlsbad Municipal df Course
June 14,2000
Page 2
The golf course project will preserve 13.1 acres of unprotected dual criteria slopes on-
site but located outside of the coastal zone. Additionally, the project will preserve 42.3
acres of coastal zone non-protected non-steep slopes that contain higher quality habitat
than the dual criteria slopes. Finally, the project includes a re-vegetation program that
will restore 1.04 acres of steep coastal slopes. The golf course project follows the
example of slope and habitat preservation established by the Pacific Rim (Aviara)
project approved by the Coastal Commission.
We believe that the golf course project is superior in so many ways to the approved and
final industrial subdivisions that it replaces. We also believe that the project was
designed to protect and enhance coastal resources to the greatest extent feasible.
While we recognize that an amendment to the LCP might be a means to reconcile the
apparent inconsistencies between the objectives of the City’s HMP and some of the
outdated habitat protection policies contained in the LCP, we believe that the
Commission, based on past actions, has the authority to approve the golf course project
without a LCP amendment. If the Commission has that authority, then the City must
have that same authority. Based on the above, we believe that a fair argument can be
made that the Commission does not have appeal jurisdiction in this matter. Therefore,
we request that you reconsider your intent to appeal the CDP for the project.
We would like to provide any additional information to assist you in your decision. Also,
we will make time to meet with you at your convenience. If we meet, we would request
that the same people be involved as our previous meeting with you on June gth.
Thank you for your attention to this very important matter.
Sincerely, *e Community Develo ent Director
C: City Manager
City Attorney
Planning Director
Assistant Planning Director
Municipal Projects Manager
Chuck Damm
Deborah Lee
Sherilyn Sarb