HomeMy WebLinkAboutLCPA 00-13; Redeemer By The Sea Lutheran Church; Local Coastal Program Amendment (LCPA) (10)STATE OF CNIFC+WLA -“E R€SXJRC!3 AWN-
CALIFORNIA COASTAL COMMISSION
SAN DIEM ARU
7575 MFTROFQUTAN DRlVP SUlTE 103
SAN DIE42 CA 92108402
(619) 767-2370
October 17,2002
Thu 14a
TO:
FROM:
SUBJECT:
COMMISSIONERS AND INTERESTED PARTIES
PETER DOUGLAS, EXECUTIVE DIRECTOR
EXECUTIVE DIRECTOR’S DETERMINATION that the City of Carlbad’s
actions, certifying the City’s Local Coastal Program Amendment
# 1-20323, C xd D (C2rMad Promenade, Rdeemer by the Sezr; and Thompson-
Tabata Rezones), is adequate to effectively certify its local coastal program (for
Commission review at its meeting of November 5-8,2002)
BACKGROUND
At its meeting of July 9,2002, the Coastal Commission certified, with suggested modifications, the
City of Carlsbad Local Coastal Program Amendment #1-2002B and C (Carlsbad Promenade, Redeemer
by the Sea). At its meeting of August 7,2002, the Commission certified, with suggested modifications,
the City of Carlsbad Local Coastal Program Amendment #1-2002D (Thompson-Tabata Rezone).
The Carlsbad Promenade rezone changed the 30.9-acre site from Limited Control (L-C) and Residential
One-Family with a 10,000 square foot minimum lot size and qualified development overlay (R-l-
10,000-Q) to Residential One-Family with a 7,500 square foot lot size and qualified development
overlay (R-1-7,500-Q). The Redeemer by the Sea rezone changed a 10.26-acre parcel from Limited
Control (L-C) to One-Family Residential (R-1). The Thompson-Tabata rezone changed an 82.2-acre
site from Limited Control (L-C) to One Family Residential (R-1) and Residential Density Multiple
(DW.
By their actions adopting Resolutions No. 2002-264,2002-262, and 2002-26 1 respectively for the
Carlsbad Promenade, Redeemer by the Sea, and Thompson-Tabata rezones on September 10,2002, the
City Czmcil hzs actncwledged zicd accep?ec! a!! ofthe Commission’s suggested modifications. The
modifications addressed required preservation for native vegetated habitat and permitted uses within
habitat, buffer requirements, brush management, and wetland protection. The City has also provided
the Commission with a copy of the revised zoning map, which has been updated to incorporate the
Commission’s suggested modifications for these rezones. The City already has coastal development
permit authority over this geographic area and will continue issuing permits consistent with the local
coastal program as amended.
As provided for in Section 13544 of the Commission’s Code of Regulations, the Executive Director
must determine if the action of the City of Carlsbad is legally sufficient to finalize Commission review
of the LCP amendment. The City’s actions have been reviewed and determined to be adequate by the
Executive Director. Section 13554 of the Commission’s Code of Regulations then requires this
determination be reported to the Commission for its concurrence.
RECOMMENDATION
Staff recommends that the Commission CONCUR with the Executive Director’s determination as set
forth in the attached letter (to be sent after Commission endorsement).
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STATE OT CALPORNM-THE WSiXRCES MWCY ORAY DAVIS.
CALIFORNIA COASTAL COMMISSION
SAN DIE00 AREA
7575 METROPOLITAN DIU= SUITE ID3
SAN DIEGO, CA 921084402
(619) 767-2370
\
November 12,2002
Mayor Claude A. Lewis
City of Carlsbad
1200 Carlsbad Village Drive
Carlsbad, CA 92008
RE: Certification of the City of Carlsbad Local Coastal Program Amendment
#1-2002B, C and D (Carlsbad Promenade, Redeemer by the Sea, and Thompson-Tabata
Rezones)
Dear Mayor Lewis:
The California Coastal Commission has reviewed the City’s Resolution Nos. 2002-264,2002-262, and
2002-261 together with the Commission’s actions of July 9,2002, and August 7,2002, certifylng City
of Carlsbad Local Coastal Program Amendment #1-2002BY C and D (Carlsbad Promenade, Redeemer
by the Sea, and Thompson-Tabata Rezones). The Carlsbad Promenade rezone changed the 30.9-acre
site from Limited Control (L-C) and Residential One-Family with a 10,000 square foot minimum lot
size and qualified development overlay (R-1-10,000-Q) to Residential One-Family with a 7,500 square
foot lot size and qualified development overlay (R-1-7,500-Q). The Redeemer by the Sea rezone
changed a 10.26-acre parcel fi-om Limited Control (L-C) to One-Family Residential (R-1). The
Thompson-Tabata rezone changed an 82.2-acre site from Limited Control (L-C) to One Family
Residential (R-1) and Residential Density Multiple (RDM). 1
In accordance with Section 13544 of the Commission’s Code of Regulations, I have made the
determination that the City’s actions are legally adequate, and the Commission has concurred at its
meeting of November 7,2002.
By its action on September 10,2002, the City has formally acknowledged and accepted the
Commission’s certification of the Local Coastal Program Amendment including all suggested
modifications. The modifications addressed required preservation for native vegetated habitat and
permitted uses within habitat, buffer requirements, brush management, and wetland protection The
City is already issuing coastal development permits in conformance with the certified local coastal
program for this area.
In conclusion, I would like to congratulate you and all other elected or appointed officials, staff and
concerned citizens for continuing to work towards full implementation of the Coastal Act. We remain
available to assist you and your staff in any way possible as you continue to develop and implement
the City’s local coastal program.
Sincerely,
Peter Douglas
Executive Director
(HAProject Files\Carlsbad HMP\LCPA 1 -2002\CAR LCPA 1 -2002.All.ED Checkoff.doc)
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AB# 16,875 TITLE:
CARLSBAD PROMENADE
LCPA 0048(A)
MTG. 9-10-02 COASTAL COMMISSIONSUGGESTED MODIFICATIONS
DEPT. PLN&
DEPT. HD.
CITY ATTY.
CITYMGR
That the City Council ADOPT Resolution No. 2002-264 , APPROVING LCPA 00-OS(A)
which is an amendment to LCPA 00-08 to acknowledge the receipt of and incorporate the California
Coastal Commission suggested modifications to add language to the Mello I1 segment zoning map of
the Carlsbad Local Coastal Program.
ITEM EXPLANATION:
The Cartsbad Promenade Local Coastal Program Amendment (LCPA 00-08) was approved by the
City Council in February 19,2002. Subsequently the amendment was submitted to and reviewed by
the California Coastal Commission (CCC) in July 2002. The CCC approved the City's requested
amendment with modifications. In order for the amendment to become effective, the City must
accept the CCC suggested modifications and incorporate them into the appropriate segment of the
Local Coastal Program.
Adoption of the suggested modifications will affect only the Carlsbad Promenade property by adding
language to require a habitat buffer between structures and the native habitat and to record an open space conservation easement in favor of the City or other conservation agency. These modifications
nil1 not affect the approved tentative tract map and the project has already been conditioned with
respect to the open space easement requirement.
ENVIRONMENTAL:
The program of the California Coastal Commission involving the preparation, approval, and
xrtification of Local Coastal Programs as provided in Sections 30500 through 30522 of the Public
qesources Code has been certified by the Secretary for Resources as meeting the requirements of
Section 21 080.5, Acknowledgement and adoption of the Coastal Commission suggested
nodifications is exempt from the California Environmental Quality Act and no environmental analysis
s necessary.
FISCAL IMPACT:
4doption of the suggested modifications will not have a fiscal impact on the City.
ZH I BITS:
1. ?. Location Map
3. Attachment "A"
City Council Resolution No. 2002 - 264
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RESOLUTION NO. 2002-264
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF CARLSBAD, CALIFORNIA, APPROVING A LOCAL
LEDGE AND ADOPT THE CALIFORNIA COASTAL
COMMISSION SUGGESTED MODIFICATIONS FOR
CASE NAME: CARLSBAD PROMENADE
COASTAL PROGRAM AMENDMENT, TO ACKNOW-
LCPA 00-08.
CASE NO.: LCPA 00-08(A)
The City Council of the City of Carlsbad, California, does hereby resolve as
follows:
WHEREAS, the Planning Commission did on January 16, 2002, hold a duly
noticed public hearing as prescribed by law to consider Local Coastal Program Amendment 00-
08 and adopted Planning Commission Resolution No. 5136 recommending to the City Council
that it be approved; and
'- WHEREAS, the City Council did on the 19th day of February, 2002 hold a duly
noticed public hearing as prescribed by law to consider an amendment to the Local Coasta
Program and acted to approve the amendment; and i L
WHEREAS, the California Coastal Commission did on the 9th day of July, 2002
hold a duly noticed public hearing as prescribed by law to consider an amendment to the Local
Coastal Program and acted to certify the amendment with suggested modifications; and
WHEREAS, on the 10 th day of SEPTEMBER , 2002 the Carlsbad
City Council formallv acknowledged receipt of the Coastal Commission's resolution of
certification, including the suggested modifications.
The City Council of the City of Carlsbad, California does hereby resolve as
follows:
1.
2.
That the above recitations are true and correct.
That the suggested modifications will meet the requirements of and
conform with the policies of Chapter 3 (commencing with Section 30200) of the California
Coastal Act to the extent necessary to achieve the basic state goals specified in Section
30001.5 of the Coastal Act.
3. That the suggested modjfications to Local Coastal Program Amendment
LCPA 00-08, are approved substantially as shown in Attachment "A" on file in the Planning Department and'attached hereto.
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4.
Attachment "A."
That staff is directed to modify the LCP zoning map in accordance with
5. That the City agrees to issue coastal development permits in accordance
with Attachment "A."
PASSED AND ADOPTED at a regular meeting of the City Council of the City of
Carlsbad on the 10 th day of SlTCEMBER , 2002, by the following vote, to wit:
AYES: Council Members Lewis, Kulchin, Finnila, Hall
NOES: None
ABSENT: Council Member Nygaard
NE M. WOOD, City Clerk
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Page 2 of 2 of Resolution No. 2002-264
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- EXHIBIT 3 -
Attachment “A
LCPA 00-08(A) - Carlsbad Promenade - Suclqested Modification Lanquaqe:
The City shall incorporate the following requirements onto the certified LCP Zoning Map,
to apply to the subject parcels (APN 21 5-070-1 3-00, 21 5-070-36-00,214-550-01-00):
a) The onsite areas of native vegetated habitat (approximately 10.34 acres),
including coastal sage scrub, southern maritime chaparral, southem willow scrub
and wetland areas, shall be protected as a condition of development approval,
and secured through recordation of an open space conservation easement in
favor of the City of Carlsbad or other conservation agency, or other appropriate
preservation method. Use of the open space areas containing native vegetation-
shall be restricted to habitat conservation, restoration and enhancement. !
b) A5 a condition of development approval, a minimum 20-foot buffer area shall be
required between structures and delineated native vegetation. The buffer area
shall be secured through an easement or deed restriction that prohibits structures and/or non-native plantings in the habitat buffer area. A reduction to the 20-foot
habitat buffer requirement may be allowed in order to obtain access to the
property from Camino de las Ondas, where the maximum feasible habitat buffer
shall be provided. Zone 3 brush management for fire protection may extend up
to 20 feet into the habitat buffer area.
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EXHIBIT 2
CARLSBAD PROMENADE
LCPA 00=08(A)
AB# 16,873
MTG. 9-10-02
DEPT. PLN #
RECOMMENDED ACTION:
u: DEPT. HD.
REDEEMER BY THE SEA
COASTAL COMMISSION SUGGESTED MODIFICATIONS CITY ATTY.
I LCPA 00-1 3(A)
CITYMGR
That the City Council ADOPT Resolution No. 2002-262 , APPROVING LCPA OO-l3(A)
which is an amendment to LCPA 00-13 to acknowledge the receipt of and incorporate the California
Coastal Commission suggested modifications to add language to the Mello I1 segment land use map
of the Carlsbad Local Coastal Program.
ITEM EXPLANATION:
The Redeemer by the Sea Local Coastal Program Amendment (LCPA 00-13) was approved by the
City Council in January 2002. Subsequently the amendment was submitted to and reviewed by the
California Coastal Commission (CCC) in July 2002. The CCC approved the City's requested
amendment with modifications. In order for the amendment to become effective, the City must
accept the CCC suggested modifications and incorporate them into the appropriate segment of the
Local Coastal Program.
Adoption of the suggested modifications will affect only the Redeemer by the Sea property and will
cause several tentative tract map lot lines to be adjusted within the subdivision boundaries. The
adjustment will add approximately 200 square feet to Open Space lot number 13,.and it can be
accomplished through a substantial conformance determination.
ENVIRONMENTAL: I
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The program of the California Coastal Commission involving the preparation, approval, and
certification of Local Coastal Programs as provided in Sections 30500 through 30522 of the Public
Resources Code has been certified by the Secretary for Resources as meeting the requirements of
Section 21 080.5. Acknowledgement and adoption of the Coastal Commission suggested
modifications is exempt from the California Environmental Quality Act and no environmental analysis
is necessary.
FISCAL IMPACT:
Adoption of the suggested modifications will not have a fiscal impact on the City.
EXHIBITS:
1. City Council Resolution No. 2002-262
2. Location Map
3. Attachment "A" Coastal Commission Suggested Modifications.
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RESOLUTION NO. 2002-262
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF CARLSBAD, CALIFORNIA, APPROVING A LOCAL
LEDGE AND ADOPT THE CALIFORNIA COASTAL
COMMISSION SUGGESTED MODIFICATIONS FOR
CASE NAME:
COASTAL PROGRAM AMENDMENT, TO ACKNOW-
LCPA 00-1 3.
CASE NO.: LCPA 00-1 3(A)
REDEEMER BY THE SEA
The City Council of the City of Carlsbad, California, does hereby resolve as
follows:
WHEREAS, the Planning Commission did on January 2, 2002, hold a duly
noticed public hearing as prescribed by law to consider Local Coastal Program Amendment 00-
13 and adopted Planning Commission Resolution No. 5121 recommending to the City Council
that it be approved; and
WHEREAS, the City Council did on the 12th day of February, 2002 hold a duly
noticed public hearing as prescribed by law to consider an amendment to the Local Coastal
1
& Program and acted to approve the amendment; and I
WHEREAS, the California Coastal Commission did on the 9th day of July, 2002
hold a duly noticed public hearing as prescribed by law to consider an amendment to the Local
Coastal Program and acted to certify the amendment with suggested modifications; and
WHEREAS, on the 10 th day of SEPTEMBER , 2002 the Carlsbad
City Council formally acknowledged receipt of the Coastal Commission's resolution of
certification, including the suggested modifications.
The City Council of the City of Carlsbad, California does hereby resolve as
follows:
1. That the above recitations are true and correct.
2. That the suggested modifications will meet the requirements of and
conform with the policies of Chapter 3 (commencing with Section 30200) of the California
Coastal Act to the extent necessary to achieve the basic state goals specified in Section
30001.5 of the Coastal Act.
3. That the suggested modifications to Local Coastal Program Amendment
LCPA 00-13, are approved substantially as shown in Attachment "A on file in the Planning
Department and attached hereto. &\Sbd WA*kW'
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vith 4.
Attachment "A."
That staff is directed to modify the LCP zoning map in accordance
5. That the Redeemer by the Sea Tentative Map previously approved by the
Planning Commission shall be modified as necessary to comply with the applicable segments of
the Carlsbad Local Coastal Program as amended by this action.
6. That the City agrees to issue coastal permits in accordance with
Attachment "A."
PASSED AND ADOPTED at a regular meeting of the City Council of the City of
Carlsbad OR the 10 th day of SEPTEMBER , 2002, by the following vote, to wit:
AYES: Council Members Lewis , Kulchin, Finnila, Hall
NOES: None
ABSENT: Council Member Nygaard
ATTEST:
&h7?4d- . WOOD, City Clerk
(SEAL) 1
Page 2 of 2 of Resolution No. 2002-262
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EXHIBIT 3
Attachment “A”
0
LCPA 00-1 3(A) Suaaested Modification Lanquaqe:
The City shall incorporate the following requirements onto the certified LCP Zoning Map,
to apply to the subject parcel(APN 21 5-080-22-00):
a) The onsite areas of native vegetated habitat (approximately 0.37 acres),
including southern maritime chaparral, shall be protected as a condition of
development approval, and secured through recordation of an open space
conservation easement in favor of the City of Carlsbad or other conservation
agency, or other appropriate preservation method. Use of the open space areas
containing native vegetation shall be restricted to habitat conservation,
restoration and enhancement, and operation and maintenance of existing storm
water facilities as necessary to sewe future development.
b) , As a condition of development approval, a minimum 20-foot buffer area shall be
required between structures and delineated native vegetation. The buffer area
shall be secured through an easement or deed restriction that prohibits structures
and/or non-native plantings in the habitat buffer area. Zone 3 brush
management for fire protection may extend up to 20 feet into the habitat buffer
area.
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REDEEMER BY THE SEA
LCPA 00-1 3(A)
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AB# 16,872
MTG. 9-10-02
DEPT. PLN &
DEPT. HD.
CITY ATTY.
CITY MGR
TITLE:
THOM PS ON/TABATA SU BDlVlSlON
COASTAL COMMISSION SUGGESTED MODIFICATIONS
LCPA 98-04(A)
That the Council ADOPT Resolution No. 2002-261 , APPROVING the Local Coastal Program
Amendment to incorporate the California Coastal Commission’s Suggested Modifications into the
Land Use Map for the Mello II segment of the Local Coastal Program.
ITEM EXPLANATION:
On February 5 and February 12, 2002, the City Council approved the ThompsonlTabata residential
subdivision. One of the actions included in that approval was a Zone Change and Local Coastal Program to change the zoning of the property from Limited Control (L-C) to One Family Residential
(R-1-Q) and Residential Density Multiple (RD-M-Q). As required by the Coastal Act, the Local
Coastal Program was referred to the California Coastal Commission for their review and approval.
On August 7, 2002, the Coastal Commission approved the Thompsonmabata Local Coastai
Program Amendment; this approval included suggested modifications to the zoning map for the
Mello I1 segment ofthe Local Coastal Program. These modifications, shown in Attachment “A”, must
be accepted by the City for the Local Coastal Program Amendment to be effectuated.
The suggested modifications deal with habitat preservation concerns and raise no issues to staff.
They include preservation of the onsite southern wwow scrub habitat and buffer areas for both the willow scrub habitat and the coastal sage scrub habitat onsite. Implementation of the suggested
modifications would necessitate the adjustment of several tentative map lot -lines within the
subdivision boundary and the restriction of residential development on three lots. These adjustments
are minor in nature and can be accomplished through the City’s Substantial Conformance
Determination process.
ENVIRONMENTAL:
The proposed modifications do not affect the previous environmental determinations. The potential
impacts of the previously approved actions were already evaluated in the Zone 20 EIR and the
Mitigated Negative Declaration for the ihornpson/Tabata resideritial subdivision. No Public
Resource Code 21081 findings are required.
FISCAL IMPACT:
The modificztions suggested by the Coastal Commission deal only with habitat preservation features
if the Thompsonflabata subdivision and do not cause any fiscal impacts.
EXHIBITS:
1. City Council Resolution No. 2002-261
2. Location Map
3. Attachment “A, Coastal Commission Suggested Modifications (1 -2002D).
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RESOLUTION NO. 2002-261
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CARLSBAD, CALIFORNIA, TO ACKNOWLEDGE AND ADOPT
THE COASTAL COMMISSION’S SUGGESTED MODIFICATIONS
INTO THE LOCAL COASTAL PROGRAM ZONING MAP FOR
THE THOMPSONlTABATA RESIDENTIAL SUBDIVISION,
LOCATED IN THE SOUTHWEST QUADRANT.
CASE NAME: THOMPSONlTABATA
CASE NO.: LCPA 98-04(A)
WHEREAS, on February 5 and February 12, 2002, the City Council held duly
noticed public hearings as prescribed by law to consider Local Coastal Program Amendment
(LCPA 98-04) for the Thompsonflabata residential subdivision; and I
WHEREAS, the California Coastal Commission did on the 7th day of August
2002, hold a duly noticed public hearing as prescribed by law to consider an amendment to the
Local Coastal Program and acted to certify the amendment with suggested modifications; and
WHEREAS, these Coastal Commission Suggested Modifeations must be
incorporated into the Local Coastal Program Zoning Map to become effectuated;, and
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WHEREAS, on the 10 th dayof SEPTENBER , 2002, the
Carlsbad City Council formally acknowledged receipt of the Coastal Commission’s resolution of
certification, including the suggested modifications.
NOW, THEREFORE, BE IT HEREBY RESOLVED by the City Council of the City
of Carlsbad, California, as follows:
1.
2.
That the above recitations are true and correct.
That the proposed Suggested Modifications will meet the requirements of
and conform with the policies of Chapter 3 (commencing with Section 30200) of the California
Coastal Act to the extent necessary to achieve the basic state goals specified in Section
30001.5 of the Coastal Act.
3. That the Suggested Modifications to the Mello II segment of the Local
Coastal Program are approved substantially as shown in Attachment “A” on file in the Planning
Department and attached hereto.
4. That the Thompsonnabata Tentative Map and Site Plan previously
approved by the City of Carlsbad be modified as necessary to comply with the applicable
segments of the Carlsbad Local Coastal Program, as amended by this action.
5, That staff is directed to modify the LCP zoning map in accordance with
Attachment “A. CW\sU I-m
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6. That the City agrees to issue coastal permits in accordance with
PASSED AND ADOPTED at a regular meeting of the City Council of the City of
Attachment "A".
Carlsbad on the 10thday of SEPTEMBER 2002, by the following vote, to wit:
AYES: Council Members Lewis, Kulchin, Finnila, Hall
NOES: None
ABSENT: Coun. Mernber Nygaarh
C.
ATTEST:
Page 2 of 2 of Resolution No. 2002-261
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EXHl BLT - -
Attach men t “A
LCPA 98-04(A) - Suqgested Modification Lanquaqe
The City shall incorporate the following requirements onto the certified Local
Coastal Program Zoning Map to apply to the subject parcels (APNs 214-140-44,
214-170-09, -36, -58, -59, -73, -77):
a. The. onsite areas of native vegetated habitat (approximately 2 acres),
including coastal sage scrub, southern. willow scrub and riparian area,
shall be protected as a condition of development approval, and secured
through a recordation of an open space conservation easement in favor of
the City of Carlsbad or other conservation agency, or through other
appropriate preservation method. Use of the open space area containing
native vegetated habitat shall he restricted to habitat conservation,
restoration and enhancement, and operation and maintenance of existing
storm water facilities in the riparian area as necessary to serve existing
and future development.
b. As a condition of development approval, the onsite coastal sage scrub
shall be protected by a buffer which shall include the slope upland of the
habitat and a six foot high, solid barrier wall permanently located at the top
of the slope, to separate the coastal sage scrub from the adjacent
residential development. No gates; openings, or- access .to the habitat .; .
shall be provided through the barrier wall from the residential lot to the
open space; however, the upper two feet of the wall may be plexiglass.
The wall and its function as a habitat protection barrier shall be maintained
by the Home Owners Association. All brush management for fire
protection shall occur on the residential side of the habitat barrier wall. No
clearing of coastal sage scrub habitat shall be permitted. The buffer area
shall be secured through an easement or deed restriction that prohibits
structures, grading and/or non-native plantings in the habitat buffer area.
Revegetation of the disturbed area adjacent to the wall shall occur utilizing
native, non-invasive species to reduce erosion potential, enhance habitat
value and to screen the wall from views toward the residential
development from the east. The development shail direct controllable
noise and light sources away from the habitat areas and, if plexiglass is
utilized, no lighting shall be permitted within 20 feet of the barrier wall.
c. As a condition of development approval, the onsite areas of southern
willow scrub, riparian and wetland area shall be protected by a minimum
50-foot buffer area, to the extent that the buffer can be physically
accommodated on the subject site. Where the distance between the
riparian area and existing adjacent development to the west is less than
50 feet, the buffer shall be provided to the maximum extent feasible.
Remedial grading activities are allowed within the buffer area to the
minimum extent necessary to stabilize adjacent soil conditions for safety
and environmental protection purposes. The buffer area shall be secured
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through an easement or deed restriction that prohibits structures and/or
non-native plantings in the habitat buffer area. The buffer surrounding the
riparian habitat shall be enhanced through planting native vegetation
determined in consultation with the California Department of Fish and
Game and the US. Fish and Wildlife Service. Brush management for fire
protection is not allowed in the buffer area. Passive recreational uses
such as sidewalks and seating areas are allowable in the upper half of the
buffer zone.
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EXHIBIT T
THOMPSONITABATA
LCPA 98=04(A)