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Development and Public Services

Coastal Act Policies

Chapter Three of the California Coastal Act establishes clear parameters for the location, intensity, type, and design of new development in the coastal zone. First and foremost, Section 30250(a) requires that new development be concentrated in and around existing developed areas with adequate development capacities. Where such areas are not available, development must be located where adequate public services exist, and where the development will not have significant adverse effects, either individually or cumulatively, on coastal resources. Generally, public works such as water, roads and sewer systems, must be sized to serve planned development. Highway 1, though, must remain a two lane scenic road in rural areas under section 30254. Significant resources that must be protected from new development include environmentally sensitive habitat, the marine environment, agricultural land uses, scenic and recreational resources, public access to and along the shoreline, and archeological resources. New development must also be located and designed to minimize risks from flooding, fire, and geologic risks (see other Hazards Findings for more detail).

There are only limited exceptions to the general development requirements of the Coastal Act. Hazardous industrial development may be located away from developed areas (Section 30250(b)); and coastal-dependent industry may be permitted outside developed areas if other locations are infeasible or environmentally damaging, and the effects of such development are mitigated (Section 30260). Under Section 30250(c), visitor-serving facilities may also be located outside of urbanized areas, but only if urban locations are infeasible for such development. Visitor-serving facilities must also be located in existing isolated development nodes or at select points of attraction for visitors. Overall, these requirements reflect a fundamental goal of the Coastal Act: to protect coastal resources by limiting new development to existing developed areas.

Finally, the Coastal Act establishes a set of priority uses that operate within the locational and resource constraints for new coastal development. For example, if public services are adequate to support only a limited amount of urban growth, land use potential must be first allocated to coastal dependent uses, essential public services and vital industry, public and commercial recreation, and visitor serving development (Section 30254). The Coastal Act also requires that public recreational uses take precedence over private residential and general industrial or commercial development, but not at the expense of agriculture or coastal-dependent industry (Section 30222).

Beyond the new development policies found in Chapter Three of the Coastal Act, Chapter Five of the Coastal Act also defines the relationship between the Coastal Commission and other state agencies, in order to avoid duplication of efforts and conflicts (Section 30400). These policies are particularly relevant to the review of planning provisions for public works facilities (water supply, sewage treatment, etc.) Section 30401 states that the chapter should not be interpreted to limit the Commission’s ability to regulate new development so long as it does not set standards that duplicate those already established by another state agency. For example, the Commission may not set standards for the quality of drinking water because these are more properly set by the State Water Quality Control Board. Likewise, the Commission may not allocate water rights as this is within the purview of the State Water Resources Control Board. The Commission, however, may limit development, because of limited water supplies, if necessary to comply with Chapter 3 Coastal Act policies, thus reducing the ability of any holder of a water allocation permit to fully exercise it.

Finally, Section 30412 specifically discusses the relationship between the Commission and the State Water Quality Control Board and the Regional Water Quality Control Boards. It also limits the Commission’s jurisdiction over the construction of wastewater treatment plants to siting, sizing, service area and appearance of these facilities.

Overview of Existing and Planned Development for the North Coast

The North Coast Area covered by this segment of the San Luis Obispo County LCP is large (+100,943 acres), isolated from population centers and overwhelmingly rural in character, with only 2% of the land area committed to urban uses (Cambria is 1,935 acres, San Simeon Acres, 80 acres). The small town of Cambria (population 5,623) and the much smaller village of San Simeon Acres are the only urbanized portions of the planning area. Highway One, a two lane road for most of its alignment, is the only north-south route linking the North Coast to the urban centers of the Monterey Peninsula some 70 miles north, and Morro Bay to the south. Highway 46 provides the only link to the inland population centers of the County. Because of its isolation, the North Coast must depend on its own resources for such services as sewage disposal and water.

The Rural North Coast

Most of the land in the rural portion of the planning area is designated for agricultural use (+96,410 acres, including most of the 48,000 acres of that part of the Hearst Ranch in the Coastal Zone). Much of land designated for agriculture is used for cattle grazing. Other agricultural activities include orchards, row crops and dry farming (see Agriculture findings for detail). Although the certified LCP permits numerous non-agricultural uses on land zoned for agriculture, there has been little development approved since certification in 1983. Due to the many permitted and existing uses, as well as the uncertainty as to how many legal parcels actual exist in the rural lands, it is virtually impossible to quantify build-out of the rural area, although the County estimates a potential build-out equivalent to 1400 single family dwellings. Certified zoning limits minimum parcel sizes to a range between 20 and 320 acres, depending on the agricultural use of any given holding (see Agricultural Findings).

The other primary rural land use designation is "Rural Lands". This designation makes up only a small portion of the rural area (about 1%) and is basically a 1200 acre, large parcel low density residential zone north of Cambria. Finally, another 1,100 acres is designated recreation and commercial retail. The County estimates that 300 residential units could be accommodated on these sites (pg. 2-12).

The only intensive development proposed for the rural portion of the North Coast is the construction of three resorts and a golf course on the Hearst Ranch. Cumulatively, these resorts would add 650 market rate hotel units, a 100 bed youth hostel or 50 space campground, a variety of accessory uses and an unknown number of housing units for employees to the rural area in the vicinity of San Simeon Point, the Staging Area for Hearst Castle and near San Simeon Acres.

Urban Areas of North Coast

The urban portion of the North Coast is small, only +2% of the planning area. Land use in Cambria is mostly single family residential development. Other commercial uses provide goods and services to the population of the planning area as well as to the many tourists who visit the North Coast. Of note is the changing pattern of residential development and use. Until recently, homes constructed in Cambria were generally small and many were occupied for only part of the year as "vacation homes". This pattern has been replaced by a trend towards larger homes which are occupied year round. Demographics affecting household size have also changed over the last fifteen years. There are now proportionately more "family" households and fewer single or two person households than in the past, when the Cambria population contained a higher percentage of retired people. The impacts of this new pattern is relevant to the allocation of scarce urban services -- particularly water. New development since certification has progressed steadily, limited only by the County’s growth management plan and scarce water hook-ups.

The principal problem facing Cambria is the dramatic disparity between the ability to provide urban services and the number of vacant, legal lots within the urban boundary. Services, particularly roads and water, are already greatly stretched and yet Cambria is only 20% build-out. The proposed amendments to the North Coast plan acknowledges this problem but other than proposing a small reduction in residential density offer no meaningful solutions.

San Simeon Acres, a few miles north of Cambria was developed to provide support services for visitors to near-by Hearst Castle. As such, it is designated for visitor services including overnight accommodations and multi-family residential uses generally geared towards employees of the Castle and visitor-serving facilities. Similar to Cambria, the amount of development permitted by the plan is poorly matched with the infrastructure needed to support build-out. The plan update exacerbates this problem because it provides for additional residential density by allowing multi-family housing on portions of parcels designated for commercial and visitor serving uses. Permitted density is 26 units per acre and could potentially increase residential build-out by 500 units (pg. 7-117-18).

Issues and Analysis

1. Location, Type and Intensity of Hearst Resort Development

With 48,000 acres of its total holding in the coastal zone, the Hearst Ranch makes up about half of the North Coast planning area. The entire ranch includes some 13 miles of shoreline and extends beyond the planning area into the upper reaches of the Santa Lucia Mountains. The Hearst Ranch is lightly developed with 23 miscellaneous dwelling units, including residences for ranch workers and the Hearst family and guests, as well as typical farm buildings and a road network to serve ranch activities. The primary land use is cattle grazing with some acreage in row crops. The Ranch has been used for cattle grazing since 1865 and its rural agricultural character has remained essentially unchanged for over 130 years.

As discussed in more detail in the Agriculture findings, non-agricultural development has been an issue on the Ranch since at least the 1960s. The first proposal for development in fact was for some 20,000 homes at Piedras Blancas. In the 1970s, though, the County of San Luis Obispo reevaluated the plan for the Hearst Ranch. In conjunction with the passage of the Coastal Act, a new planning process began which eventually took the form of the Hearst Resort Plan in the certified LCP.

The presently certified North Coast Plan provides for intensive resort development in four areas of the ranch:

The remainder of the ranch is in the agriculture land use category. As discussed in greater detail in the finding on agriculture, a wide variety of agricultural and non-agricultural uses are permitted in this designation.

The County's comprehensive update process for the North Coast Area Plan examined a wide variety of resource planning issues for the Hearst Ranch, including the appropriate location and density of future resort development. In December of 1996, the Board of Supervisors limited the ultimate buildout of the resort to 500 units. The Board also moved the proposed development off of San Simeon Point, limited the number of units on the west side of Highway One to 150; and deleted the 250 units envisioned for the Pine Forest. In addition, the Board revised the planning standards for development timing, circulation improvements, traffic capacity, water and wastewater capacities, drainage and nonpoint runoff control, biological assessment, employee housing, public access, design standards, habitat protection, etc.

In June of 1997, the Board of Supervisors again addressed the Hearst Resort proposed development, which resulted in the current plan before the Commission as a comprehensive LCP Amendment. Generally, the proposed updated North Coast Plan provides for all of the development in the certified plan, and adds a cultural center and 50 unit hotel at Old San Simeon and an equestrian facility at the Pine Forest and the Staging Area for a total of 700 lodging units and a variety of accessory and other commercial uses. The amount of development allocated to each geographic area reflect maximums for each location and the total hotel/resort rooms must not exceed 650 units. An unspecified amount of housing for employees is also permitted (7-17) and is not included in the maximum unit count for hotel units (4-12). Employee housing has been added as a permitted use and may now be located on the hotel/golf course site (7-25), in Old San Simeon Village (7-24) at the Staging Area (7-20) and at the Pine Forest Resort (7-32).

The proposed update also redesignates approximately seventy acres of land presently designated "Agriculture" to resort use. The Staging Area site is expanded from 18 acres to 28 acres and approximately 60 acres are being added at the Golf Course/Hotel site. In conjunction with the anticipated development in Old San Simeon Village, a total of 265 acres will be developed in the vicinity of San Simeon Point. In addition to this presently proposed expansion, the updated plan encourages the Hearst Corporation to apply for a future amendment for an additional 300 acres of agricultural land to be converted for expanded golf course use (4-11).

Conformance with Coastal Act

As discussed above, the Coastal Act sets a demanding standard for the location, intensity, type, and design of new development in the coastal zone. Development must be located in and around urban areas or, if such locations are not available, where adequate public services exist. Development outside of existing urban areas also must not have any significant impacts, either individually or cumulatively, on coastal resources.

The rural North Coast is precisely the type of coastal area envisioned for protection by the development policies of the Coastal Act. The northern end of the County's planning area rivals Big Sur in its relatively untouched beauty. To be sure, one of the great advantages of the very large Hearst Ranch holding, committed as it has been to the stewardship of agricultural resources, has been the protection of a magnificent rural landscape for over 130 years. Outside of Cambria and San Simeon Acres, there is little development in the coastal zone of the North Coast.

As will be discussed in detail in these findings, the Coastal Act does not allow for the location and intensity of development currently proposed for the Hearst Ranch. Section 30250 clearly demands that new development be directed into the urban areas of Cambria and San Simeon Acres. In addition, as discussed in the Visual Resource findings, the protection of viewsheds under section 30251 limits development in areas visible from Highway One, such as the Staging Area and the proposed Pine Forest location. As detailed in the Agricultural findings, new development at the Pine Forest, the Staging Area, and on most of the land surrounding the immediate site of Old San Simeon is inconsistent with section 30242, because these areas are currently viable as agricultural grazing land. And when the other various resource constraints protected by the Coastal Act are considered, particularly the availability of water, the need to protect environmentally sensitive habitat, and the capacity of Highway One, it becomes more difficult still to contemplate intensive, relatively unconsolidated resort development on the rural North Coast. More detail on all of these problematic aspects of the proposed Hearst Resort development is presented in later findings.

Nonetheless, as mentioned earlier, the Coastal Act does make a limited exception for visitor-serving development such as that proposed by the Hearst Corporation. Under section 30250(c) such development may be located in "existing isolated developments or at selected points of attraction for visitors" if it cannot be feasibly located in existing developed areas. As discussed in more detail in the Recreation findings, the California State Parks Hearst Castle Facility has been a major visitor attraction since that late 1950s. In addition, while Old Simeon is certainly not a bustling commercial center, there is some commercial development activity there, and Old San Simeon has existed as an "isolated" albeit tiny development since the late 19th century. It was platted earlier this century, at a time when it was being more intensively used, first as a whaling port; and then as a staging area for the construction of Hearst Castle. In short, there is at least some Coastal Act basis for locating new visitor-serving development either in the vicinity of the State Parks facility, or within Old San Simeon.

To do so, however, requires a finding that locating such development in existing urban areas is not feasible. As discussed in the Recreation findings, there is considerable undeveloped land in both San Simeon Acres and Cambria that could conceivably accommodate much of the type of development anticipated at the Hearst Resorts, particularly the hotel and motel units that would serve middle and lower income visitors. There are not, however any large parcels in either Cambria or San Simeon Acres that could support the resort recreational opportunity proposed for the Hearst Ranch near San Simeon Point. This type of more comprehensive visitor serving attraction is not currently available on the North Coast or, for that matter, on any part of the San Luis Obispo County coastline. The Hearst Ranch site is also the closest to the primary visitor destination in this area -- Hearst Castle. New visitor-serving development for this point of attraction is best located near the attraction itself. Finally, new visitor-serving development in Old San Simeon would have the potential to significantly augment visitors’ enjoyment and understanding of this section of the coast by virtue of its historic values and coastal resources, consistent with the Coastal Act's goal to protect and enhance visitor-serving development. (see Recreation Findings).

However, as discussed at length in the Agriculture Findings, allowing significant visitor-serving development at Old San Simeon would require the conversion of significant amounts of viable grazing lands, inconsistent with Coastal Act Section 30242. Therefore, the only appropriate potential development envelope for Hearst Resorts, with one limited exception discussed below, is within the developed node of Old San Simeon -- approximately 17 acres of land currently designated commercial retail. Within this node, the maximum number of hotel/motel units allowable is approximately 100, given the limited acreage, the need to protect the viewshed, and the need to maintain the historic character, including existing structures such as Sebastian’s store and the historic warehouses, of Old San Simeon. Such a density (approximately 6 units/acre) is consistent with other low intensity visitor-serving developments approved by the Commission in sensitive resource areas, such as the Marina Dunes Resort; as well as in Big Sur, where there are no visitor-serving facilities over 60 units outside of urbanized areas.

The exception to Section 30242 that would allow new visitor-serving development to move beyond the Old San Simeon envelope is discussed in detail in the Agriculture findings. To summarize this discussion, the conversion of agricultural lands may be found consistent with the Coastal Act if the visitor-serving development concentrates development that might otherwise impact agricultural lands. Based on the analysis of the Agriculture findings under this policy, a total of 275 visitor-serving units, which approximates the development potential of Hearst Ranch beyond Old San Simeon, are appropriate to site in and around Old San Simeon, but only if non-agricultural uses are prohibited on the remainder of the Ranch; and a 1000 foot agricultural easement surrounding the allowable development is put in place. Coupled with the 100 units allowable at Old San Simeon, the total allowable intensity at Old San Simeon, then, is 375 units. As will be shown, this number is an absolute maximum, based as it is on conservative assumptions (biased in favor of development) about future development potential on the Hearst Ranch.

As detailed in the Recreation findings, this more limited intensity of resort development is also consistent with Coastal Act section 30221, which requires that recreational demand be examined prior to allocating agricultural land to new visitor-serving development. Thus, at least some of the proposed Hearst Resort units should be discounted as more appropriately located in Cambria or San Simeon Acres. Moreover, the intensity of new visitor-serving at Old San Simeon should also be constrained by the lack of services, as detailed in Issues 3 and 4 below. Section 30250(c) does not exempt rural visitor development from the other applicable requirements of the policy, namely, the concentration of development and the need to provide adequate services to support new development. Visitor-serving development is a preferred use when public services are limited; but in this case the availability of even basic water and sewer services is a question that must be addressed prior to any development outside of existing urban areas. Indeed, since the Commission last took a comprehensive look at the North Coast LCP (when the LUP was certified in 1983), the lack of reliable water resources for new development that would not infringe on agricultural and sensitive habitat uses, has become increasingly apparent.

Nor does visitor-serving development enjoy any special treatment with respect to its potential impact on sensitive coastal resources. Thus, the findings on Scenic Resources recommend that new development in the viewshed between the County Line and San Simeon Acres should be strictly limited to avoid degrading public views of this highly scenic coast, consistent with Coastal Act Section 30251. The findings for "Environmentally Sensitive Habitats" recommend that new development must be subordinate to the protection of riparian habitats in order to be found consistent with section 30240, particularly given the listing of at least two new species under the Endangered Species Act;; as well as avoid sensitive forests and other species. Finally, the Hazards and Archeological findings also limit the appropriate location of new development. Most significantly, since the Commission last evaluated the North Coast Area Plan, the State Geologist has designate the San Simeon Fault as active -- a significant new constraint on proposed resort development (see Hazards Findings).

It is clear, then, that the location, type and intensity of the new proposal for Hearst Resorts development in the NCAP is inconsistent with the Coastal Act. Overall, the Pine Forest facility is not located at an existing node of development and is thus inconsistent with section 30250. Similarly, the resort facility currently proposed at the base of San Simeon Point should be located in, contiguous to, or in close proximity to Old San Simeon. Finally, the development proposed at the Staging Area is inconsistent with the visual resource and agriculture policies of the Coastal Act and should be pulled into the envelope in and around Old San Simeon Village. Figure 1 illustrates the proposed land use designations for the Hearst Ranch in light of these constraints.

Recognizing the Coastal Act exception for visitor-serving development, but also keeping in mind the tremendous resource constraints and other policy requirements of the Coastal Act, a more concentrated development envelope encompassing the immediate area around Old San Simeon is necessary for future visitor-serving development to be consistent with the Coastal Act. In particular, the golf course -- which is not a coastal-dependent or coastal type of recreation -- should be eliminated from the proposal as detailed in the Visual and Recreation findings, and the water supply discussion later in this finding.

Table 1 summarizes the recommended modifications to the Hearst Resort development proposal. Detailed standards and other relevant language are presented in the modifications. Figures 1 and 2 show the appropriate development locations for new development. The development envelope represents the necessary conclusions of all the findings of this report, including these development findings, as well as the geological hazards findings and visual resource findings.

Overall, new visitor-serving development on the Hearst Ranch can only be found consistent with the Coastal Act if:

  1. new development is concentrated around the existing development node at Old San Simeon, and is constrained as shown in Figure 1;
  2. the total number of visitor-serving units is limited to 375; non-agricultural uses are prohibited on the remainder of the Hearst Ranch, and a 1000 foot agricultural easement is put in place around the Old San Simeon development envelope;
  3. development is sited to stay out of critical viewsheds; and
  4. the intensity of uses, the square footage allowed, is limited to account for limited services; resource impacts, and the minimization of coastal hazards.

Consistent with the County’s current approach, any development also should be phased, to allow for more systematic evaluation of the likely resource constraints at various intensities of development. Again, more detail on the supporting findings for these requirements is presented in the other sections of this report.

Table 1. Hearst Resorts Phasing Plan

SUMMARY - PHASING, LOCATION AND DEVELOPMENT PLAN

FOR HEARST RESORT DEVELOPMENT

PHASE

ACTIVITY

LOCATION / SIZE

DESCRIPTION

1

A. OLD SAN SIMEON HOTEL/MOTEL DEVELOPMENT 100 ACRE DEVELOPMENT ENVELOPE AT OLD SAN SIMEON AS SHOWN IN FIGURE 7-3 100-250 UNITS HOTEL/MOTEL; RESTAURANT, COMMERCIAL SHOPS, AND OTHER ACCESSORY USES.
  B. YOUTH HOSTEL OR CAMPGROUND HOSTEL IN SAN SIMEON VILLAGE ENVELOPE. CAMPGROUND LOCATION TO BE DETERMINED WITH PHASE 1(A) DEVELOPMENT. 60 BED YOUTH HOSTEL OR 50 SITE CAMPGROUND TO BE BUILT WITHIN ONE YEAR OF OCCUPANCY OF PHASE 1 UNITS.
  C. AGRICULTURAL BUFFER 1000 FOOT AGRICULTURAL EASEMENT AROUND OLD SAN SIMEON PERMANENT BUFFER AROUND DEVELOPMENT ENVELOPE; AGRICULTURAL USES ONLY
  D. PUBLIC ACCESS IMPROVEMENTS FROM SAN SIMEON VILLAGE TO ADOBE CREEK, WEST OF HIGHWAY ONE; VILLAGE TO STATE PARKS VISITOR CENTER (SEE STANDARD 7) MASTER PLAN PREPARED; BLUFFTOP TRAIL SSV TO SSP TO ADOBE CREEK; PEDESTRIAN TRAIL FROM SSV TO STATE PARKS VISITOR CENTER; VERTICAL ACCESS TO SANDY BEACHES (SEE STD 7---)

2

A. OLD SAN SIMEON HOTEL/MOTEL DEVELOPMENT 100 ACRE COMM.RETAIL CATEGORY AS SHOWN IN FIGURE 7--3 100 - 275 UNITS HOTEL/MOTEL; RESTAURANTS/COMMERCIAL STORES; AND OTHER ACCESSORY USES
  B. PUBLIC ACCESS IMPROVEMENTS BETWEEN PICO CREEK AND W.R. HEARST MEMORIAL STATE BEACH (SEE STANDARD 8) AS REQUIRED BY IMPACT ANALYSIS AT MASTER PLAN AND DEVELOPMENT STAGES.

3

A. OLD SAN SIMEON HOTEL/MOTEL DEVELOPMENT 100 ACRE REC CATEGORY AS SHOWN IN FIGURE 7--3 100 - 175 UNITS HOTEL/MOTEL; RESTAURANTS/COMMERCIAL STORES; AND OTHER ACCESSORY USES
  B. PUBLIC ACCESS IMPROVEMENTS BETWEEN OAK KNOLL CREEK AND PIEDRAS BLANCAS LIGHTHOUSE (SEE STANDARD 9) AS REQUIRED BY IMPACT ANALYSIS AT MASTER PLAN AND DEVELOPMENT STAGES.

4

A. OLD SAN SIMEON HOTEL/MOTEL DEVELOPMENT 100 ACRE COMM.RETAIL CATEGORY AS SHOWN IN FIGURE 7--3 75 UNITS HOTEL/MOTEL; RESTAURANTS/COMMERCIAL STORES; AND OTHER ACCESSORY USES
  B. PUBLIC ACCESS IMPROVEMENTS BETWEEN PIEDRAS BLANCAS LIGHTHOUSE AND RANCH NORTHERN BOUNDARY (SEE STANDARD 10) AS REQUIRED BY IMPACT ANALYSIS AT MASTER PLAN AND DEVELOPMENT STAGES.
  • NOTES: (1) All Acreage approximate. See Figure 7-3 for location.

    (2) Time between phases to be according to the approved phasing plan.

    (3) In no case shall the total OLD SAN SIMEON DEVELOPMENT exceed 535 units, INCLUDING YOUTH HOSTEL AND/OR CAMPGROUND, AND 100 UNITS OF EMPLOYEE HOUSING.

  • Finally, the square footage allowances in the Table below reflect the Commission’s best judgment as to appropriate room size and ratios to associated uses, in light of the resource constraints of the North Coast, particularly water (see Issue 3 below). The table summarizes the estimated coverage needs of 375 units at approximately 20.5 acres, assuming a mix of one and two-story structures and a significant amount of parking. This would result in an overall coverage of 25% of the allowable envelope, exclusive of roads, which are allowed an additional 20% of the envelope. This is also without factoring in the use of the existing warehouse structures as functional components of the resort development. Given the conservative assumptions factored into this analysis, the allowable density and intensity of uses at Old San Simeon would appear to be essentially compatible with the rural character and other resource constraints of Old San Simeon.

    Table 2. Allowable Coverage of Development at Old San Simeon

    Resort Component

    Square Feet

    Acres

    375 Overnight Units @ 800 sq. ft/unit + 20% aux.space

    360,000

    8.3

    Accessory Uses @ 50% of overnight units + 20% aux.spc.

    180,000

    4.1

    100 Employee Housing Units @ 1000 sq. ft./unit + 20%

    120,000

    2.8

    60 Unit Youth Hostel

    15,000

    0.3

    Additional Commercial Uses

    75,000

    1.8

    Total Building Coverage At One Story

    750,000

    17.2

    Total Building Coverage Assuming 50/50 One/Two Story

    500, 250

    11.5

    Parking (1200 spaces at 300 sq. ft/space)

    360,000

    8.3

    TOTAL SITE COVERAGE

    860,250

    19.7

    Approximate Development Envelope (less 20% roads)

    3,484,800

    80

         
    Percent Coverage in Old San Simeon Envelope:  

    25%

    For comparison sake, Staff notes that the 265 unit Inn at Spanish Bay, which also contains a variety of shops, recreational activities, meeting rooms and restaurants is located on a 20 acre site. The Spanish Bay site is, however, located in an urban area and served by public utilities. The intensity of development is thus greater than would be appropriate in a more rural setting. Indeed, as mentioned earlier, a more recent Commission action limited the Marina Dunes Resort to just 63 rooms on about 18 acres or, in the alternative, 9 acres of developable land less sensitive habitats. This equates to a density range of 3.5 to 7 units per acre. In the Hearst development envelope of about 100 acres, the density with 375 units would be no less than 3.75 units/acre for total site, and closer to five or six units/acre given likely site constraints, ag buffers, and other open space requirements. Similarly, the Marina Dunes allowed a total coverage of about 5.5 acres or 30% of the site.

    In conclusion, as modified by these findings, new visitor-serving development on the Hearst Ranch may be found consistent with section 30250 of the Coastal Act.

     

    2. New Development in Cambria

    With a population of 5623, the town of Cambria is the only significant urban area in the North Coast. Approximately 75% of the existing development is residential; the remaining 25% consists of a variety of commercial, visitor-serving and urban uses. The urban service line which defines the town is drawn fairly tightly. And because Cambria is only 25% built-out, this line appears to offer plenty of opportunity to expand development within it for many years. Unfortunately it is very unlikely that the amount of growth permitted within the urban service line can be accommodated. Currently, there are 3,408 dwelling units in Cambria and a population of 5,800. The plan allows build out of another +8,290 dwelling units with a population increase from 19,000 to 26,000. As detailed in later sections of this finding, water and road constraints exist now and it is uncertain that they can be overcome to the point of being able to ever support the anticipated build-out of the plan.

    The seeds of Cambria’s current planning dilemma were planted in the 1920’s when huge tracts of land were subdivided into very small (+1700 sq. ft.) lots. Please see Exhibit 2. Oblivious to slope, the need for services and effects on the natural environment, this grid of precise, tiny rectangles was created and lots sold to individual owners many years ago. Thousands of these lots remain vacant and available for future development. Final build-out of Cambria would be even higher than that anticipated in the plan were it not for the fact that at least 10% of these lots are not suitable for development. In addition there is a clear trend for homeowners to acquire two or three lots for each house.

    Finally, there are few areas remaining in Cambria for significant new subdivisions. The East-West Ranch, which is located between Park Hill and Lodge Hill, is the most important site. It currently contains 18 parcels. The update envisions a maximum of 265 lots on the west portion of the Ranch.

    Conformance with Coastal Act Policies

    As discussed at the beginning of this Development finding, Coastal Act Section 30250 limits development to already developed areas that have the capacity to accommodate such growth. Although Cambria is an existing developed area, it is also severely constrained by the lack of services for the potential buildout of its many small lots. As such, new development is problematic under the Coastal Act.

    The County has certainly made efforts to encourage the merger of small lots into single building sites and to voluntarily retire lots, but further reductions are still needed. One promising method to reduce the number of lots has recently been proposed by the County and is described in detail in Exhibit 3. This analysis proposes to reduce the number of lots by establishing an assessment district to provide the funding to acquire them. Four levels of lot retirement are studied, including a 17%, 29%, 37% and 56% reduction in lots. Any reduction would, of course, narrow the disparity between development and services. However, selection of Level III or IV would be the best matches given the severity of constraints discussed later in these findings.

    This proposal has been favorably received both in the community ( see Exhibit 4) and by the Board of Supervisors. The Cambria Community Services District Board also supports the plan and has stated they would be prepared to implement it if approved by the Cambria voters. Notwithstanding this support, the current updated NCAP provides inadequate policies and planning standards for addressing the buildout problem of Cambria. As discussed in more detail in the Water Supply findings, for example, there is no policy to avoid the de facto creation of new lots, let alone the retirement of substandard small lots. Without such a planning requirement, new development in Cambria is not consistent with section 30250, which requires that adequate urban services be available for new coastal development. Therefore, the County's lot reduction program should be added as an area standard for Cambria because it provides a method, if approved by the voters, to bring build-out of the town much more in line with available (and potentially available) services as required by Section 30250 of the Coastal Act. (see Suggested Modification 107).

    As a corollary to lot reduction, it is also important to ensure that there is no net increase in development through new subdivisions. There are few areas remaining in Cambria for significant new subdivisions. However as mentioned earlier there is some potential for a maximum of 265 lots on the west portion of the East/West Ranch. The West Ranch currently contains 18 parcels, thus the plan allows a maximum of 247 new lots. To reduce the impact of creating these new lots, the North Coast Plan provides for a mandatory lot retirement plan on a 1:1 basis for all lots created on the Ranch after 35 if the land is annexed to the Cambria Community Service District. The plan provisions raise numerous questions. For example, it is unclear why 18 additional lots should be permitted without a retirement requirement, or why only the East/West Ranch, as opposed to other areas of Cambria, must retire lots in exchange for creating new ones. It is also unclear as to what kind of lot must be retired to mitigate the creation of a new one. Simply retiring lots that are already unbuildable does little to effectively avoid new development.

    To be consistent with Section 30250, planning standards are needed that require all new residential subdivisions to retire an equivalent number of lots based on the impact of the new lots being proposed. This would be more consistent with the goal of avoiding a net increase in building potential. (see Suggested Modification 109). However, one-to-one retirement for new lots is insufficient in and of itself to meet the demands for new development in Cambria. Indeed, in a context like Cambria, it is important to ensure that the lot or lots retired truly mitigate the impacts on public services attributable to the newly created lot. If, for example, a new lot was 7500 square feet, a fairly typical modern lot size, the anticipated development, consistent with current trends toward larger homes in Cambria, would be a residence of over 3000 square feet. A review of permits over the last 8 years show that houses are generally ranging between 3000-4000 sq. ft. on lots of this size. A home of this size is more likely to be occupied year round and by a larger household than a home constructed on one of the existing substandard parcels which is typically 1750 square feet in size. Homes on these small sites are limited to 1000 square feet or less in size (pg. 7-103). Virtually no space on these small sites will remain for landscaping after the house and driveway are constructed. In contrast, significant garden areas would remain on the hypothetical 7500 sq. ft. lot even after construction of a +3500 sq. ft. house and double driveway. Considering the anticipated larger house, greater number of occupants and landscaping, more water, sewage service and greater traffic generation can be expected from the development of the larger lot than a project on the smaller one. A simple trade of one small lot for one, new large lot would, therefore only partially mitigate the impacts of new lot. Likewise the retirement of a small lot with low development potential because it is located on a steep hillside with no road access does not mitigate the creation of a new lot on a flat or reasonable slope served by road and utilities. The new lot will, in all likelihood develop. The old lot will, in all likelihood never develop because construction costs would be prohibitive. (In fact, the North Coast Plan and the 1997 Hausrath Economic Analysis assume that 10% of the small lots will not develop because of their location).

    A program that required the retirement of an area equivalent to the area of the new lot would be simple to administer and result in more effective mitigation for new, standard size (up to 7500 sq. ft.) residential lots. The impacts of new residential lots over 7500 square feet in size would not ordinarily be significantly greater than those of a 7500 sq. ft. lot and thus would not be required to retire lots for any area over 7500 sq. ft. unless the County finds that, for a particular subdivision, additional mitigation through lot retirement is needed. Finally, a limitation on the number of small lots on steep slopes that could be used in any retirement transactions will ensure that most of the lots retired are truly developable thus providing adequate mitigation for the new lot. (Please see Suggested Modification 109.)

    3. Water Supply

    A reliable water supply is the single most critical constraint on new development in the North Coast. Separated from population centers by distance and rugged topography, the North Coast must rely on local streams for water. Unfortunately, the streams are small, their water storage basins are limited, and the effects of significant withdrawals on habitat values and the integrity of the aquifers are poorly documented. In addition, there is tight competition for scarce water supplies between agricultural and municipal users and the maintenance of riparian/wetland species. With Cambria only 25% built-out, San Simeon Acres only 54% built-out, and with intensive visitor-serving at Hearst Ranch as yet unbuilt, this competition can be expected to intensify.

    This situation is exacerbated by the characteristics of the aquifers that supply water for urban and agricultural uses in the North Coast planning area. With the exception of Phelan and Chisholm Springs on the Hearst Ranch, water is supplied by wells that pump the underflow of the local creeks. Wells are presently located on Pico, San Simeon and Santa Rosa Creeks. Wells are planned on Arroyo de la Cruz to serve the proposed Hearst Resorts. The water is extracted from gravel and sand areas which underly portions of the creeks -- generally the lower reaches of these water courses. The water bearing gravel and sand areas range in depth from a few feet to as much as 80’ and do not extend any great distance beyond the creek channels.

    During the wet portion of the year, when the creeks are visibly flowing, these acquifers fill up with water. The maximum amount of water that can be absorbed into the acquifer is expressed as "usable storage." The filling up of a depleted or partially depleted aquifer is called "recharge". Typically, aquifers like these are recharged fairly quickly by the winter rains because they are not very large. If, however, winter rains are below average, the acquifer may not recharge fully. Also, if storm flows down the creek are too rapid, the surface water may discharge into the sea before the acquifer is fully recharged. In any event, once surface flows terminate for the year, there is no further recharge of the aquifer.

    Recharge of the north coast streams, of course, is influenced by the amount and timing of rainfall. Rainfall and the annual flow of the creeks vary greatly over time. For example, in 1983, the annual flow at the upper gauge on Santa Rosa Creek was 21,300 AF, in 1985 it was 3,593 AF. According to a preliminary study done by USGS, in 1994 annual stream flows at this upstream gauge ranged from 244 AF to 27,800 AF for the thirty year period between 1959 and 1989. On San Simeon Creek, annual discharge between 1971 and 1989 ranged from 475 AF to 42,600 AF (page 100). The authors of the USGS report state that the relationship between flows and rainfall is linear. Rainfall in the planning area varies greatly from year to year, ranging from 10" per year to 40" for the period between July 1974 to the present.

    Because the North Coast aquifers are small and annual flows vary widely, reliance on "average" flows to determine water availability for a given year or years is not appropriate. For example, there were two straight years of drought in 1975 and 1976 when the aquifers did not fully recharge and water was simply not available. Efforts to pump the depleted aquifer on the Santa Rosa Creek resulted in subsidence and seawater intrusion as well as a de-watering of the lagoon. To avoid such overpumping, it is more prudent to base anticipated extractions from both acquifers on low flow data to ensure a reliable water supply.

    Finally, all water in storage in an aquifer is not available for use. Storage is a term which quantifies the total amount of water that can be physically absorbed into the geologic structure of an aquifer. The amount that can be removed without causing damage is termed the "safe yield". This amount will always be less than total storage. Some water must remain in the aquifer to support riparian and wetland habitat, to provide a barrier against salt-water intrusion and to avoid irreparable damage to the aquifer due to subsidence. Subsidence occurs when the aquifer is significantly overdrafted. When an aquifer subsides, the geologic structure (gravels, sands, fines) is compressed, thus reducing the ability of the aquifer to store water. This process is irreversible. (Please see Exhibit 5 for a brief over-view of groundwater hydrology).

    In summary, the North Coast Creeks accommodate vastly different flow levels, and have small aquifers which recharge quickly but can also be depleted quickly. Safe yield figures presently available are estimates based on an average rain year, and they have not fully considered impacts of such withdrawals on riparian and wetland habitats -- particularly during dry periods and drought years.

    Cambria

    Water for the unincorporated town is supplied by the Cambria Community Services District (CCSD). The District boundaries include most of the land within the urban boundary defined in the LUP with the exception of a major portion of the 450 acre East-West Ranch. The District also serves (approximately 300 to 500) acres outside the urban boundary. Cambria Community Services District’s water is supplied from five wells which tap the underflow of San Simeon and Santa Rosa Creeks.

    Santa Rosa Creek

    Santa Rosa Creek winds through the town of Cambria, extending +13 miles from its headwaters in the Santa Lucia Mountains to the Pacific Ocean. The estimated safe yield of this creek is given in the North Coast update as 2260 acre feet (AF) per year based on a 1994 preliminary study by the United States Geologic Survey. A review of this document does not, however, provide a definitive safe yield figure and although it includes information regarding existing water demand for agricultural and municipal uses, it does not factor in the water needs for the preservation of riparian and wetland habitats.

    CCSD has a permit from the State Water Resources Control Board to extract a maximum of 518 AF per year from Santa Rosa Creek. Of this total, only 260 AF a year can be extracted between May 1 and October 31. This summer limit has never been reached for two reasons, in times of plentiful streamflow, the District prefers to use water from San Simeon Creek because it is of much better quality and requires less treatment. In dry years, Santa Rosa Creek is incapable of supplying this amount of water. As an example, in the drought of 1976-77, less water than allocated by the State Water Resources Control Board could be withdrawn before the wells went dry. Overpumping during that period also caused significant subsidence, potentially damaging the ability of the aquifer to recharge. The water production table attached as Exhibit 6 demonstrates the preference for water from San Simeon Creek.

    Thus, in summary, while the Santa Rosa Creek safe yield of 2260 AF given on pg. 3-12 of the plan implies an adequate water supply to serve Cambria’s needs, a closer look reveals that the basis for that number is not well grounded, does not consider impacts on habitat values, does not factor in the ability of the aquifer to actually produce water during a drought nor the potentially damaging effects of attempting to do so on the aquifer structure. Since development uses water on a year round basis and, in fact, water use in Cambria is up by 40% during the summer months, it is imperative that the water supply is sufficient to meet urban needs during these months and during periods of drought. Likewise, the protection of riparian and wetland habitat depends on a reliable and sustainable water supply (Please see ESHA Finding).

    San Simeon Creek

    San Simeon Creek, located two miles north of Cambria, is the preferred source of municipal water. This creek too has its headwaters in the Santa Lucia Range and flows westward for over nine miles to the Pacific Ocean. Safe yield for San Simeon Creek is estimated to be 900 acre feet in the North Coast Update. Similar to the figure for Santa Rosa Creek, this estimate relies on the 1994 USGS report and is subject to the same flaws. Riparian agricultural users in the basin consume approximately 450 AF per year. CCSD has a permit from the State Water Resources Control Board which allows the District to withdraw a maximum of 1230 AF per year. Of this total, only 370 AF may be withdrawn during the dry period which, in this case, is defined as that time between the cessation of surface run-off at the Palmer Flats Gaging Station and October 31, 1997. Typically this is a six or seven month period. The permit also requires the District to supply riparian users when municipal pumping lowers the aquifer to the point where riparian users pumps run dry (Board Order WR 88-14, October 1988).

    Several uncertainties exist with respect to the reliable, long term amount of water which can be supplied by San Simeon Creek. The first issue is the soundness of the 900 AF safe yield figure. It is unclear how this figure was determined and whether it was calculated to include a reservation of water for the preservation of riparian and wetland habitat. The changing water needs of senior, riparian users must also be addressed. These users have priority over appropriators such as CCSD and are thus entitled to be served before the District. They may also divert additional water if fallow, riparian fields are brought into production. Finally, the multiple disparities between estimated safe yield, water board allocations and current production are also of concern. One apparent conflict is that even if one one accepts an estimated safe yield of 900 acre feet, the existing State Water Resources Control Board permit allows one of the users, CCSD, to withdraw a maximum of 1230 AF a year, 330 AF over safe yield not including existing riparian withdrawals. Another concern is that with the exception of 1991 extractions, the combined riparian and CCSD withdrawals have exceeded the estimated safe yield figure since 1980. In 1996, for example, CCSD withdrew 717 AF from San Simeon, riparian users withdrew +450 AF for a total of 1167 AF, 267 AF in excess of the estimated safe yield of 900 AF given in the plan. (Please see Exhibit 6, Water Production Records, CCSD.)

    Alternative Water Sources and Management Options

    Due to the constraints and uncertainties which surround expanded water withdrawals or even continuation of existing levels of extraction from the Santa Rosa and San Simeon Creek basins, it is relevant to review alternative water sources for urban uses and planning tools for water management. Practically speaking, alternatives include construction of desalinization facilities, increased storage, water conservation and efficient water delivery systems. Reservoirs and imported water are also theoretical possibilities but due to potential environmental effects and costs are, in reality, less viable.

    Desalinization

    CCSD currently has a valid Coastal Permit to construct a desalinization plant capable of producing 1307 AF of water a year. According to a May 1997 fiscal analysis of plan alternatives and infrastructure costs, approximately 36% (412 AF) of Cambria’s share of the new desalinization plant production is needed to cure existing service deficiencies. The District has agreed to share up to 161 AF a year of water with the San Simeon Community Services District to support new development in San Simeon Acres. A pipeline to transport this water has also been granted a Coastal Development Permit. Thus a balance of 724 AF would be available for new development in Cambria. The approved desalinization facility will be very expensive to build and operate, and the District has not begun construction. CCSD is currently looking into plan modifications which could significantlly reduce the cost of construction. It is anticipated that a decision on whether to proceed with the project will be made within the next year. Desalinization thus appears to offer an achievable alternative to the existing water source particularly if construction costs can be reduced. Costs per acre foot of water are also comparable at $1500.00 an AF for desalinization and $1300.00 an AF for water extracted from the creeks.

    A privately owned and operated desalinization plant is proposed in the North Coast update to serve the planned subdivision on the East/West Ranch with water as an option to annexation and service by the Cambria Community Services District. County staff has indicated that the following planning standard provides for this method of water supply:

    Technology: Employ progressive measures that utilize new technology, are resource efficient and environmentally sound (Standard K, 7-59).

    Only a portion of the East/West Ranch is located within the Urban Service Line (USL) of Cambria. Most of the property, the West Ranch, is not in the USL and has not been annexed into the Cambria Community Services District. Development of the Ranch for residential use is considered urban infill because it is surrounded on all three land sides by existing urban uses.

    Increased Storage

    Storing water during times of plenty is another way to augment supply. As previously discussed, reliable withdrawal from the creeks is most problematic during the dry period of the year -- generally between May and October and during cyclical droughts. At the same time water use jumps by 40% during the summer months. In the winter, however, most years, thousands of acre feet of water course down San Simeon and Santa Rosa Creeks to empty into the sea. A substantial amount of this water could be diverted to urban use, at no harm to habitat values, if adequate storage was available. Currently, CCSD has the ability to store only one million gallons (+3 AF) for operating flexibility and fire protection, barely enough to satisfy one days use during the summer peak periods.

    Water Conservation

    A method to stretch an existing, finite water supply is to initiate an aggressive, comprehensive water conservation program. Beginning in 1990, CCSD fielded a retrofit program to replace old plumbing fixtures with lower use modern ones. As stated in the January 1997 report to the CCSD Board:

    The purpose of the Program is to allow for additional new construction, but at the same time reduce overall water use in the District. This is done by installing low flow plumbing devices in existing homes, installing water saving agricultural irrigation systems, entering into water exchange agreements and constructing new water supply projects. By doing so existing water supplies are utilized more efficiently allowing for the surplus to be used for new construction. In adopting the Retrofit Program the Board of Directors established a savings goal of 2 to 1. This means that each applicant wishing to construct a new house is required to save enough water to cover his or her house plus one other. For example, under the existing ordinance an applicant constructing a new home on a large lot (more than 8000 square feet) must provide water savings equivalent to the retrofitting of at least 17 two bathroom homes in order to meet the current 2 to 1 requirement, or pay a corresponding in-lieu fee of 17 times $550.00, or, $9,350.

    As of January 1, 1997, 1,693 residential structures have had low flow plumbing fixtures installed under the District’s Retrofit Program. An additional 472 houses have been retrofitted under the District’s Retrofit on Resale Program and 299 houses under the provisions for New Construction and Remodeling. There are 2,410 homes that have been retrofitted and it is estimated that there are approximately 1,100 existing houses still available for retrofit in Cambria.

    A more conservative retrofit to new construction formula is suggested in the report to the CCSD Board (pg. 6) as follows:

    Table 3: Modified Retrofitted Residential Water Usage Comparison*

    Average Number of Units Used Per Household (Bi-Monthly):

    1989/90 12.5 Units ** (A unit of water

    is 748 gallons)

    1995/96 11.01 Units

  • * Excludes users who consume two or less units and 41 or more units per billing period and all homes not known to be retrofitted to District retrofit standards.

    ** 1989/90 Base Year Average (i.e., all users)

    As a result there is a 0.5 unit (+370 gallons) per residential household difference between a retrofitted and non-retrofitted home based on 1995/96 data. The 0.5 units can be established as the amount of water saved for each Equivalent Dwelling Unit (EDU) retrofitted. In taking the most conservative approach to determine the required 2 to 1 ratio established in the District Ordinance the following formula could be used:

    (Estimated New Use divided by Units Saved) x 2 = Savings Goal of 2 to 1

    (11.01 Units divided by 0.5 Units) x 2 = 44 Units

    Thus, the equivalent of 44 houses (EDU’s) would need to be retrofitted to save twice the amount of water a new house would require under this formula. In 1996 the average number of points required under the Program is equivalent to 13.5 houses.

  • Given either of these figures, 44 retrofits of existing homes to allow one new home, or 17 retrofits to allow one new home, it appears that the life of the program is limited due to the finite (1100) number of non-retrofitted homes. At the 44:1 ratio, 25 new homes could be accommodated. At a 17:1 ratio, 64 new homes could be built. The effectiveness of the program to actually result in no net gain of water demand is also greatly limited by the option of the potential new home builder to pay an in-lieu fee of $550.00 a point rather than negotiate the retrofitting of existing homes. Since the institution of the in-lieu option in 1994, 85% of the applicants have opted to pay the fee rather than retrofit. According to the January 1997 report to the CCSD Board, most of this money collected in 1996 was used to pay expenses associated with designing the desalinization facilities and obtaining permits for its construction. The District is currently re-assessing the in-lieu fee program and may decide not to continue it. The net effect of this program to date seems to be at least a slowing down of increased water use rather than maintenance (or reduction) of the status quo.

    The District also has completed a program to repair and replace aged, leaking pipes. Prior to completion of this program in 1987, up to 30% of water produced had been lost to leakage. This remedial work is, however, a one time event in that it does not lower demand, it simply reduced waste between production and delivery. Post-1988 production figures are by comparison much more likely to relate closely to actual use.

    CCSD has, as can be seen from the preceding discussion, attempted to augment and conserve the existing water supplies. The leak detection and repair program has been quite successful in saving water, the retrofit program less so -- particularly since the introduction of the in-lieu fee option in 1994. Construction of the desalinization plant is stalled but offers a potential for a meaningful addition to existing supplies. (Please see Exhibit 7, correspondence from CCSD describing existing and proposed programs.)

    In the meantime, the January 1997 report to the District notes that water use in both conventionally plumbed and retrofitted homes is on the rise as is water use for commercial activities. The report notes that even so, water use (based apparently on production figures) is still lower than it was in 1988.

    Management

    Another method to address limited water supplies is to manage new urban growth so that development does not outstrip available services. San Luis Obispo County has chosen two traditional planning methods to limit urban growth -- a Growth Management Ordinance which limits the number of new residential units in Cambria to 125 a year and a Resource Management System which monitors essential services and can theoretically halt development when defined thresholds of severity are reached. (NCAP pg. 3-7 et seq.)

    The Growth Management limitations on the number of new units which can be constructed in Cambria in a given year is insufficient to address the problem of a very limited and unreliable water supply. The program simply slows down the effects of the increasing disparity between water supply and demand, but does not address the root problem presented by a scarce but essential service.

    The Resource Management System (RMS) offers a better tool for phasing new development with adequate services because it provides an objective standard for determining when services and development are poorly matched. The RMS has three levels of Resource Severity constraints relative to water, sewer, roads, schools and air quality. Level One is an "early warning" threshold that indicates a particular service or resource will be inadequate to support a specific, planned level of development in the future. Level Two warns that an identified service or resource will be depleted before more capacity can be obtained. Level Two calls for fairly immediate action to increase capacity or slow down additional demands on the service. Level Three is the most severe situation. This level occurs when the capacity of an identified service or resource to serve development has been met or is exceeded. At this level, the LUP states that action may be needed to protect basic public health and safety.

    In Cambria, water is one of the services listed as having already-passed Level Three severity by 1995 when the chart was last updated. The reason water is shown as a Level Three constraint is because there is not now an adequate, reliable water supply sufficient to serve the development that presently exists during a dry or drought year. Indeed, some local observers believe there is inadequate water to accommodate a normal rainfall year. (Please see Exhibit 8, correspondence to Commission from William Bianchi, received November 24, 1997.) In any event, the County acknowledges that the water supply is problematic existing levels of development. This level of constraint of an essential service might seem to imply that it would be prudent to stop new development until additional capacity could be obtained. The RMS program allows, but does not require, the County to reduce or eliminate new development in this situation. The County has thus far not taken this step.

    Conformance with Coastal Act Policies

    As the preceding analysis suggests, the proposed amendment is inconsistent with Coastal Act policies because it provides for continued urban development that cannot be supported by existing water supplies. Estimates of available water to serve new development are based on incomplete information and do not analyze the impacts of water withdrawals on riparian/wetland habitats or agricultural activities as required by the Coastal Act (Sections 30240, 30241(e) and 30231). Programs, like the RMS, which could ensure that new development is allowed only when adequate services are available to support it, are not mandatory and have not been voluntarily implemented.

    In order to find the proposed updated LUP consistent with the Coastal Act, the updated water section must be re-written to more accurately describe the nature of the aquifer and the need for a more thorough study to determine safe yield. To ensure that additional water withdrawals for municipal uses will not adversely impact the coastal resources of riparian/wetland habitats and agriculture, a planning standard must be added to Chapter 7,C, Cambria Urban Area Standards (pg. 7-47 et seq.) which provides for a moratorium on all new development which would be served with water from either of these sources unless a variety of performance standards are met over the next three years to ensure that coastal resources are adequately protected.

    As specified in Suggested Modification 107, basic performance standards that should be met include the preparation of an Instream Flow Management Study to determine the water needs of riparian and wetland species living in Santa Rosa and San Simeon Creeks; and the development and implementation of a water production strategy that is capable of serving the development provided for in the plan. This standard includes re-use of wastewater, water supply other than from the creeks and reduction of build-out.

    Finally, the County has a reasonably effective set of policies for water management for existing lots. However, the provision of water for the East-West Ranch is unsatisfactory, particularly the proposal for a private desalination plant. In previous actions, the Commission has found that the provision of essential services in urban areas should be undertaken by public (or private) utility purveyors for an entire service area rather than individualized utilities constructed to serve a single project. The following excerpt from the adopted Findings for the 1995 LCP amendment to the Santa Barbara Coastal Plan outlines the rationale for this determination:

    Private desalination facilities also raise the basic policy question of the effect of allowing the proliferation of privately owned and operated water supply facilities on the ability to comprehensively plan for the provision and essential public services.

    Additional questions raised by private desalination facilities include the ability of a private homeowners association to operate and be accountable for complex desalination operations to mitigate impacts, adequately respond to and cleanup potential spills of hazardous chemicals, enforce operation limitations and in general maintain control and long-term operation of the facilities. These include concerns about the homeowners capability over the long term to successfully operate the facility without the need for an established water purveyor to step in and operate the system or provide alternative water supplies should the association facilities fail. The Commission has developed a discussion paper which addresses these and other coastal issues related to the development of desalination facilities.

    Two of the fundamental questions raised by the proposal to use private desalination facilities are: the potential precedent such a facility generates for inducing unlimited growth based upon a technically unlimited supply of water; and the further fragmentation of public utility services, and related tendency toward scattering public work facilities, and their related impacts, rather than consolidating them as stipulated in Coastal Act Section 30260. Proliferation of desal facilities where consolidation is feasible, whether private or public, is inconsistent with the requirements of PRC Section 30260.

    Consolidation and expansion of existing public desalination facilities will help to successfully operate the complex technology and reduce or mitigate potential impacts resulting from such facilities. The success of desalination facilities is also more likely when operated by established water purveyors serving large geographic bases and a larger rate-paying pool as compared to a private homeowners association with limited funds and expertise to manage such complex operations. The experience of small private water purveyors depending upon small industrial desalination facilities and water wells in the Goleta/Santa Barbara area and other areas in the coastal zone has demonstrated the difficulties of sustained operation of such facilities.

    Since the GWD’s service district boundaries include the Goleta Community Plan planning area and a desalination facility is available to provide desalinated water to the GWD by contract, private desalination facilities are not currently appropriate. Region-wide provision of desalination facilities, prevents proliferation of smaller individual desalination facilities, thereby reducing cumulative impacts on coastal resources, including marine resources, created by individual facilities. A region-wide approach supports the Commission’s consolidation policy, Section 30260, which encourages coastal-dependent industrial facilities, such as portions of desalination facilities, as determined on a case by case basis. These facilities are encouraged to expand within existing sites so long as they are designed to permit reasonable long term growth consistent with the Coastal Act and certified LCP.

    It should be noted that the Commission has allowed a private desal facility on Santa Catalina Island. That facility, however, was consolidated with an Edison electrical power facility and there is no municipal or public water system at that location. The circumstances on Santa Catalina Island were thus different in important respects from those in the Goleta Planning Area."

    As discussed earlier, in addition to the area already within the Cambria Urban Services Line (USL), there are approximately 300 acres (18 parcels) of the East/West Ranch that are not within the USL but are surrounded by urban development. (Please see Exhibit 9.) This site is a logical urban infill area and is currently designated for a maximum of 340 residential units in the Certified North Coast Plan. The plan update reduces the maximum unit count to 265. If this site develops at an urban density as anticipated by its’ owners, it will require urban services and must be included within the urban service line. The creation of isolated pockets of urban level development outside of the urban boundary is inconsistent with Coastal Act Policy 30250 which supports the location of urban uses in urban areas. The North Coast update requires that this site be brought into the urban service area if it is subdivided into more than 35 lots. (Standard 11B, page 7-60) Subsequent annexation into the Cambria Community Services District is, however, optional for any development scenario on the West Ranch (Standards 11B, C, D, pg. 7-60).

    The Plan anticipates that if the CCSD does not annex the West Ranch it could obtain its water supply from a private desalinization plant. This proposal is inconsistent with Coastal Act policies and the Commission’s action in similar planning situations in the past. Therefore, the NCAP should be modified to prohibit the use of single project desalinization plants (see Modification 109). An alternative method of water supply, other than CCSD, is by new wells on the lower reaches of Santa Rosa Creek which curves through the north-east corner of the West Ranch. Correspondence from representatives of the East/West Ranch state that they hold a pre-1914 appropriative right to the creek waters and would be entitled to 186 AF a year based on past ranch use. The letter goes on to say that while this appropriative right exists, they would prefer to be served by water from a desalinization plant and not exercise their appropriative right.

    Based on the discussion and conclusions reached in the earlier analysis of the productivity of Santa Rosa Creek, additional withdrawals from this creek are problematic. The use of water from Santa Rosa Creek to serve the domestic needs of development on the East/West Ranch is simply not a realistic option at this time. Therefore, if the West Ranch is to be subdivided and developed as proposed in the North Coast Update, the plan must be modified to require inclusion within the Urban Service Line and annexation to Cambria Community Services District so that water service and wastewater treatment service can be provided to accommodate the urban development. (Please see Suggested Modification 115.)

    Finally, in order to achieve consistency with Coastal Act Sections 30260 and 30250, a new, areawide standard is needed that requires that desalinization plants serve urban intensity development within or in close proximity to existing urban areas must be owned and operated by a public agency. (see Suggested Modification 109.) Planning standard 9K (pg. 7-59) for development on the East/West Ranch also should be clarified to preclude private desalinization facilities (see Suggested Modification 114) and Standard 10B, C and D (pg. 7-59) must be revised to require annexation to Cambria Community Services District prior to approval of further subdivision of the property (Please see Suggested Modification 115.) Companion changes to Standard 11 B, C and D relevant to CCSD annexation and the table on pg. 7-64 are also required (pg. 7-60). (see Suggested Modification 116).

    San Simeon Acres

    San Simeon Acres is a small satellite community located approximately 1.5 miles north of Cambria. The current population is 250 and the land area within the urban boundary is 80 acres. Land use in San Simeon Acres is about evenly divided between visitor serving commercial retail and multi-family residential designations. According to County estimates, the village is approximately 50% built out. San Simeon Acres provides services for visitors to nearby Hearst Castle and thus a variety of motels, restaurants and other retail ventures geared toward the coastal visitor have developed over the years since the land was split off the Hearst Ranch for this purpose in the 1940’s.

    San Simeon Community Services District (SSCSD) provides domestic water to San Simeon Acres (pg. 3-34). This district obtains its water from two wells which tap the under-flow of Pico Creek, located on the north edge of town. The safe yield of Pico Creek is estimated at 130 acre feet (AF) a year based on preliminary studies undertaken by the Department of Water Resources in the 1950’s. The North Coast Plan acknowledges the uncertainty of this figure because it requires that a study to determine safe yield must be undertaken when water extractions reach 140 AF a year (pg. 7-114). Given the preliminary quality of these studies, their age and the fact that effects on habitat were not considered, the resulting safe yield must be viewed with caution. Current withdrawals from Pico Creek total 102 AF (86 AF for urban use, 16 AF for agricultural demand). According to the North Coast update, San Simeon Acres water supply was adequate through 1985 (pg. 3-35). Since that time a moratorium on new construction that required water service has been in effect. Conservation and a prohibition on outdoor water use has also been necessary to maintain existing levels of development. Buildout of San Simeon Acres proposes a population of +1229 people, an increase of +500% over the existing number of residents. An additional 349 motel units for a total of 1055 is also contemplated. At current motel occupancy rates (approximately 55%) and residential water use rates (120 gpd per capita), 240 AF of water would be needed for buildout according to the North Coast plan.

    Pico Creek

    Pico Creek is a small coastal water course which flows from its headwaters in the Santa Lucia Mountains to the Pacific Ocean. As stated earlier, a safe yield of 130 AF a year has been estimated for this creek but that figure should be viewed with caution. The SSCSD has a permit from the County to extract 140 AF a year from the creek underflow but this figure is above the safe yield and probably above the true ability of the aquifer to reliably supply water. The maximum amount withdrawn by the district has been 100 AF annually (1997). During the summer months, extractions have not exceeded +12 AF per month. The effects of this withdrawal on coastal resources has not been addressed. The changing demand for water by senior, riparian users has also not been considered. Riparian users have priority for water over appropriations like SSCSD and thus are entitled to have their allocations filled before the district. Currently, the riparian user, Hearst Ranch, withdraws only 16 AF a year for stockwatering but if ranch plans changed -- additional cattle or the initiation of row crop production -- greater amounts of water could be needed.

    Alternative Water Sources, Management and Conservation

    Given the constraints and uncertainties relevant to increased water withdrawals or, even continuation of the existing level of extraction from Pico Creek, it is important to review alternative water sources and planning management tools for San Simeon Acres. As with Cambria, the most practical alternatives include the construction of desalinization facilities, increased storage, water conservation and mandatory phasing of new development consistent with the capacity of essential public services.

    Desalinization

    As discussed earlier in the section about Cambria, CCSD has a plan to construct a desalinization plant capable of producing 1307 AF of water a year. The CCSD has agreed to share up to 161 AF of desalinization water with the San Simeon Community Services District. A pipeline to transport this water to San Simeon Acres has already been approved. Depending on the ultimate figure for safe yield from Pico Creek, the desalinization water and creek withdrawal could potentially meet, or at least come closer to, the 240 AF needed for buildout of the village. At this time, however, it is unclear whether the CCSD desalinization plant will ever be constructed.

    Increased Storage

    As discussed under this topic for Cambria, increased water storage is another method that can augment water supplies, particularly for use during the higher use summer months and during drought. SSCSD has virtually no storage tanks other than a 150,000 gallon facility for fire protection.

     

    Water Conservation

    San Simeon Acres has practiced strict water conservation for the past decade. No new construction or remodelling which would require additional water service has been permitted since 1986. All bathrooms have been reftrofitted with low flow fixtures. All outdoor water use for landscaping has been prohibited since 1989. Water use per capita is significantly lower than the norm. It appears that all the methods available to reduce water use have been implemented and no further reductions due to conservation can be expected.

    Management

    The Resource Management System (RMS) discussed for Cambria also applies to San Simeon Acres. The chart on page 3-9 of the North Coast update shows that water supplies for San Simeon Acres are already constrained to Level III, the most severe level of constraint. As in the case of Cambria, the County could halt new development when a Level 3 constraint is reached. This action has not been taken by the County, however SSCSD, the water provider, has declared a moritorium on new development. The decision to continue the moratorium is of course, solely at the discretion of the district.

    Conformance with Coastal Act Policies

    The proposed amendment is inconsistent with Coastal Act policies because it provides for continued urban development that cannot be supported by existing water supplies. This situation is further exacerbated in San Simeon Acres by allowing additional residential development beyond that permitted in the existing certified North Coast Plan. San Simeon Acres planning standard II (pg. 7-117 NCU) add high density residential use (26 d.u. per acre) to the rear half or upper story of commercial development on all land designated for commercial retail use (approximately half the acreage of San Simeon Acres). This residential use may be built in advance of, or in concert with, the Commercial use and has the potential to add at least a few hundred units to the housing stock. As in Cambria, estimates of the safe yield of the water source are sketchy and do not consider impacts on riparian and wetland habitat or agricultural activities. Finally, programs, like the RMS, which have the effect of phasing new development to be matched with the availability of essential services, are not mandatory and have not been voluntarily implemented.

    In order for the proposed updated LUP to be consistent with the Coastal Act development policies, the water section discussing supply for San Simeon Acres must be revised to more accurately describe the nature of the aquifer and the need for a more thorough study to determine safe yield. To ensure that additional water withdrawals will not adversely impact riparian and wetland habitats or agricultural activities, a planning standard must be added to Chapter 7, D. San Simeon Acres Village Standards, (pg. 7-113 et seq.) which provides for a continued moratorium on all new development which would be served with water from Pico Creek until such time that an Instream Flow Management Study (ISFM) which shows additional withdrawals are consistent with applicable Coastal Act policies has been completed, approved by the County, and incorporated into the LCP (see Suggested Modification 133). New development served by water from the CCSD desalinization plant would not be precluded. Finally, denial of the increase in residential use proposed by allowing high density, multi-family development in the Commercial district is required at this time because of the uncertainties associated with the ability of the water purveyor to serve the amount of development already permitted in the plan. (see Suggested Modification 134.)

    Rural Areas

    The rural portion of the North Coast Coastal Zone encompasses over 100,000 acres, most of which is designated for agricultural use. Agricultural uses typically include cow/calf operations, with the Hearst Ranch as the largest operator in the area running an average of 2100 head over the +48,000 acres of their holdings in the Coastal Zone. Other agricultural activities include row crops, dry farming and some orchard development. According to Table 3-2 (pg. 3-12), agricultural uses that rely on water from Santa Rosa, San Simeon and Pico Creeks withdraw a total of 1356 AF for irrigation and stockwatering. Table 3-2 does not offer any agricultural use figures for the two creeks, San Carpoforo and Arroyo de la Cruz, which are located on the Hearst Ranch and presumably are water sources for the various ranch activities.

    Water is also needed to support a variety of other rural land uses -- scattered residential development and a gravel operation on San Simeon Creek for example. The County estimates that the rural area is only about 13% builtout and that additional residential units can be constructed as well as a variety of other types of development permitted in the agricultural and rural lands districts.

    Plan goals for the development of the rural North Coast include protection of coastal natural resources (wetland/riparian habitat, marine habitat, threatened or endangered species) and balancing growth with the sustained availability of resources (presumably resources, like water, needed to accommodate development). (pg. 1-3 NCU) Another goal of the North Coast update is to maintain a clear distinction between urban and rural scale development. (pg. 1-4)

    Of the five main creeks that provide water to the rural areas, San Simeon, Santa Rosa, and Pico Creeks have already been discussed. That leaves San Carpoforo Creek, and Arroyo de la Cruz. Another, minor, source, not discussed in the North Coast update, is Villa Creek.

    San Carpoforo

    This creek in the northern end of the planning area flows from its headwaters in the Santa Lucia Mountains through the Hearst Ranch to its outlet in the Pacific Ocean at Ragged Point. The Hearst Ranch has never filed for a permit from the State Water Resources Control Board to extract water from this creek. With the exception of a preliminary study done by the Department of Water Resources in the 1950’s, no further hydrological or biological analysis has been undertaken for San Carpoforo Creek. Thus, little is known about storage capacity and even an estimated safe yield figure is unavailable.

     

    Arroyo de la Cruz

    Arroyo de la Cruz Creek also has its headwaters in the Santa Lucia Mountains. It flows through the Hearst Ranch to the sea between Ragged Point and Piedras Blancas. The safe yield of Arroyo de la Cruz is estimated in the Plan as 470 AF based on early preliminary studies by Department of Water Resources. The Hearst Ranch draws water from Arroyo de la Cruz and its tributary springs (Phelan and Chisolm Springs) to serve the needs of the current ranching operation. Hearst also has permits from the SWQCB for withdrawals in anticipation of the future construction of the proposed Hearst Resorts. Existing permits are summarized as follows:

    1. Application 20026A: Hearst Corporation has a license to take water from Chisolm and Phelan Springs in the following amounts:

  • (a) .06 CFS/Year for domestic and stockwatering purposes from April 1 to October 31

    (b) .21 CFS/Year for irrigation from April 1 to October 31

    (c) 70 AF, maximum withdrawal annually

    (d) 27 acres, maximum area irrigated

    2. Application 25881: Hearst Corporation has a permit for Arroyo de la Cruz underflow. A "permit" means approval for the withdrawal has been granted, but either the underlying project has not been completed or the full amount of water has not been taken (or both situations). This particular permit was scheduled to expire in December 1995 if construction was not completed and in December 1997 if water was not taken. In response to an extension request, the State Water Resources Control Board extended this permit to expire in December 2006 (construction) and December 2008 (water use).

    A public trust complaint against this application has recently been lodged with the State Water Resources Control Board by the Environmental Defense Center on behalf of Friends of the Ranchland. The complaint alleges that the Hearst Corp. is in violation of several of the conditions attached to this permit.

    3. Application 27126: Hearst Corporation has a 1995 permit (expires in 1998) to withdraw the following additional amounts from Chisolm and Phelan Springs.

    (a) .24 CFS/year for stock, irrigation and domestic use from November 1 to March 31

    (b) 72 AF maximum

    (c) 35 acres, maximum area irrigated

    (d) water may be used to supply 49 AF reservoir

     

    4. Application 27212: Hearst Corporation was granted a permit in March 1997 (expires December 31, 2006) to withdraw the following amounts of water from Phelan and Chisolm Springs:

    (a) .07 CFS/Year for domestic and stock-watering uses (domestic use is for Hearst Castle, Hearst Castle Staging Area, Ranch Headquarters and village of San Simeon) from December through April

    (b) .34 CFS/Year for irrigation from December through March

    (c) .65 AF maximum withdrawal annually

    (d) 46 acres, maximum area irrigated

    Water allocated under this permit can only be taken from the springs when there is visible surface flow for 100 yards down stream from Phelan Springs.

  • Permit 25881 allows for 1607 AF withdrawal per year from Arroyo de la Cruz. Municipal uses are entitled to 25% of the total or 401 AF per year. The remaining 75% (1206 AF) is for irrigation use. Maximum area to be irrigated is 300 acres. The permit includes a variety of other conditions which could serve to reduce the 1607 AF allocation and protect coastal resources. (Please note conditions 6, 12, 18, 19, 20, 23, 28, 29). Condition 16 of the permit also requires the applicant to undertake a monitoring program as follows:

    16. The Permittee shall conduct the Monitoring Program as described in Appendix 5, beginning at page 332, of Appendix I, Comments and Responses to the State Environmental Impact Report, Hearst Ranch Visitor Services Development Plan, Water Supply Project. The program report shall (1) analyze the previous year; (2) project water withdrawal during the forthcoming year as a result of further development; (3) project water withdrawal effects assuming (a) an average flow year and (b) the 1976 and 1977 drought years, and (c) those droughts years of historical record which are deemed appropriate at the time of the analysis, and compare the anticipated effects to the conclusions of the Staged EIR; (4) proposed additional monitoring or scientific studies of the hydrology or biological resources which would be appropriate given the projected hydrological effects of the projected pumping; and (5) propose mitigation measures in response to the effects of project pumping on underflow water and the surface flow. The Board reserves jurisdiction to require Permittee to initiate additional scientific studies and monitoring programs and enact specific mitigation measures for the protection of the fisheries, riparian vegetation, or other biological resources dependent on the waters of the Arroyo de la Cruz. Such studies and monitoring programs shall meet the specifications of the Board.

    17. The Monitoring Program as described in Term 16 shall be conducted until the Permittee is instructed by the Board to discontinue the Monitoring Program.

    The applicant is required by the terms of the permit to develop a water conservation program (Condition 14) and maintain all gauges and measurement devices described in the permit (Condition 21).

    Finally, the permit provides an estimate of water use for the various resorts as follows:

    1. The Staging Area Development 82 AF

    2. San Simeon Village Commercial 11 AF

    3. San Simeon Village Resort and Golf Course 613 AF

    4. Pine Forest Resort and Golf Course 703 AF

    5. San Carpoforo Point Resort 178 AF

    TOTAL: 1587 AF22

    Development based on this permit from the State Water Resources Control Board would seem to raise some rather basic questions and appears premature. The major discrepancy between even the estimated safe yield of 430 AF, from Arroyo de la Cruz and the proposed allocation of 1607 AF from that stream by this permit alone is certainly an issue. Moreover, with the acknowledgement that the current proposal for the Hearst Resorts will not require as much water as itemized in the 1982 SWRCB decision, major concerns are still raised by the permit. For example, the permit requirement that only 25% of the 1607 AF can be allotted to municipal use seems thwarted by Condition 19 which contemplates 1587 AF -- or virtually all of the allocation -- going to what is generally considered a "municipal" use -- that is, urban level development. Furthermore, the allocation of 75% of the permitted withdrawal for "irrigation" could mean the water must be used for typical agricultural irrigation of crops, or, because it is not clear in the permit, it could stretch the meaning to include watering the golf course and resort landscaping.

    Another issue of concern is the content of the information gathered over the last fourteen years in the monitoring reports required by condition 16 of the permit. A review of the reports reveals they offer primarily uninterpreted, raw data regarding water flows past identified stream gauges. This data could have potential value in understanding water supply capabilities but is flawed by the fact that various measuring gauges were broken at frequent intervals over the years. Moreover, the reports are of virtually no value regarding the minimum flows needed to support riparian/wetland species.

    In response to an inquiry from the Environmental Defense Center regarding these reports, staff of the SWRCB offered the following comments:

    We also discussed the quality of the data. The surface flow gages don’t seem to be too reliable. Damage appears to be repaired very slowly and the information in the files indicates that these are relatively poor quality gages due to highly unstable "controls". Even though the Lagoon gage was providing suspect data for several years, no changes were made until complete failure occurred. Well data is not complete. A recent report indicates that notable storms occurred in the middle of May which denied access to some of the wells during the spring. This indicates that the data collectors were not extremely motivated to obtain the data. Also, collecting data from or adjacent to operational wells may provide faulty data. Drawndown due to recent pumping could skew the data considerably; especially if the fact that the wells were recently pumped is not known to the data collector.

    Brian asked if we would be willing to provide the data or compilations of the data to the Coastal Commission. I stated that we try to cooperate with other State agencies as much as possible. However, we have serious shortages of available staff and no one has really been working on this project for many years. Consequently, unless there is a pressing need for staff to prepare compilations for inhouse use, we might let the Coastal Commission pay for copying by an outside source or let their staff go through the files.

    Brian stated that a recent document indicated safe yield from the stream to be about 400 afa. He wasn’t sure who prepared the document or exactly what type of document is involved although he thought it was related to an environmental review document; possibly for a staged document. I indicated that I would be surprised if there was enough information in the monitoring reports to reach this conclusion. This could mean that additional data has been collected by someone but not submitted to the SWRCB. (Please see Exhibit 10 for full text.)

    Water Planning Standards for the North Coast

    Planning standards for the North Coast rural lands are found in Chapter 7 of the North Coast update. General standards for all rural lands include the following requirements: (1) Proposed tourist-recreation projects, detailed studies of water availability and use, as well as assessments of water withdrawal impacts on fish and wildlife. (Standard #24 pg. 7-09); and (2) New non-agricultural development proposals shall demonstrate that there is sufficient water availability for both domestic use and fire suppression prior to issuance of a land use permit. (pg. 7-10, Standard #25)

    Arroyo de la Cruz also has a specific prohibition on development except for water diversion projects, wildlife and natural resource protection, coastal accessways, water wells and impoundments, and agriculturally related uses. In addition, no development or other activities shall be allowed if significant unavoidable adverse impacts on the natural resources will result. (pg. 7-11, Standard #9)

    The NCAP update also includes specific water standards for the Hearst Resort development. First, the phasing plan for Hearst must insure that water is available (pg. 7-16, Standard #2C). Second, each phase of development has certain requirements. These include: a review to determine adequacy of services, including impacts on local water supplies; and to determine impacts (both individually and cumulatively) on coastal resources, including fish and wildlife resources and plant communities. These reviews must also include an analysis of impacts on coastal resources generated by water withdrawals from the Arroyo de la Cruz or San Carpoforo watersheds including the preparation of a hydrological monitoring program which projects the availability of water for out-of-stream uses consistent with the protection of in-stream uses such as anadromous fish; an analysis of the effect of the water extraction on the biological resources which are dependent on the waters of Arroyo de la Cruz Creek (or San Carpoforo Creek if this creek or its groundwater basin is used as a water source) (7-16, Standard 3A-B).

    The NCAP also requires that these water reviews be conducted by a qualified aquatic biologist, and include examination of the stream and (lagoon) habitat characteristics, the biological and coastal resources dependent of the creek and lagoon (e.g., anadromous fish, including spawning and rearing areas, migration corridors; pool and riffles; water quality and flow in conjunction with the hydrological monitoring program; population characteristics and levels of smolt and adults) and hatching requirements for anadromous fish. Any approval of water utilizing development on the Hearst Ranch must also be based on a finding that such development will not result in water extractions which will adversely impact recognized instream beneficial uses, or that such impacts can and shall be effectively mitigated.

    Third, the NCAP encourages water reclamation to reduce total water consumption, but also allows the State Water Resources Control Board to be petitioned to adjust the maximum amount of water which may be extracted from the Arroyo de la Cruz watershed to a level consistent with the amount necessary to service the level and type of development permitted for the Hearst Ranch holdings. Finally, Hearst Ranch development proposals are to include the provision of organized services, of which the most critical are water supply, sewage disposal, and solid waste disposal.

    The update plan also includes "programs" relevant to water use and water supply for the Hearst Resorts. Again, programs are not mandatory and, according to the plan, are implemented only on consideration of community needs, community support and cost (pg. 3-39). Programs related to water include a call for more detailed studies of the groundwater basins on Hearst Ranch to determine safe yields for proposed tourist recreation developments; and a program to explore possibilities for using treated wastewater from sewage treatment plants for park irrigation or golf courses. (3-40)

    Conformance with Coastal Act

    As discussed in Issue 1 of this finding, the general location of the proposed Hearst Resorts development is problematic under Coastal Act section 30250. However, section 30250 also requires that essential public services must be available to support development without adversely affecting coastal natural resources. It is entirely unclear at this time how much water can be reliably produced to serve any significant amount of visitor serving development on the Hearst Ranch. It is also unknown what effects a given level of water production from any of the North Coast streams likely to be used would have on habitat values. Mandatory standards therefore, are needed that clearly state that any quantified amount of development represents an absolute maximum that may be reduced substantially or denied altogether based on service capacity and adverse impacts on coastal resources (see Suggested Modification 79).

    At the same time, the intensity of proposed development must also be more sharply defined. Currently, the proposed update allows a great variety of accessory and other uses in addition to the overnight accommodations. Better definition of the size and number of these uses relative to the size and number of hotel units must be included in the plan. The Commission’s recent adopted findings for the Marina Dunes Resort plainly address the need for specificity in this area. For example, hotel units of 1200 square feet in size and "accessory" facilities which consume more square footage than the overnight accommodations would have significantly greater service needs than a smaller facility of the same gross number of units. It is therefore necessary to define what the baseline is for a unit and what the ratio of accessory uses to units would be to avoid an intensity that effectively goes beyond even the maximum permitted by the plan. (see Suggested Modification 97(2B).

    For the number of visitors accommodated (a maximum of 165 per day on average), golf courses use a significant amount of water per capita. Although the Hearst E.I.R. quotes a significantly greater water use for their proposed golf course, +500 AF, typical coastal golf courses require 240 AF of water in a dry year (+190 AF in a normal year). When, as in the case of the North Coast, a needed service such as water, is scarce, its use should be carefully husbanded to provide for Coastal Act priority uses which serve a broader spectrum of visitors such as overnight accommodations, restaurants, etc. Therefore, the golf course must be eliminated to find consistency with Coastal Act policies (see Suggested Modification 97).

    In addition, as discussed in the agricultural findings, the proposed amendment also allocates a greater amount of land area to the Hearst Resorts -- seventy acres of agricultural land would be redesignated to Commercial Recreation and Recreational Use. Furthermore, the Hearst Corporation is encouraged to request an amendment for additional amounts of agricultural land -- up to 300 acres -- for the golf course. Aside from the fact that no findings have been made by the County to support this conversion of agricultural land, the uncertainties of water availability to support existing planned development surely preclude any additional increase in area or new water intensive uses at this time. Therefore, it is recommended that these provisions in the plan (pages 4-11 and 4-14), be deleted. (See Suggested Modifications 10 and 14.)

    Standard 3F on page 7-17 also requires the development of employee housing to serve the Hearst Resorts. This housing may be provided on the site of the resorts or elsewhere in other "appropriately designated" areas. The amount of employee housing required to support the resorts could be significant and require substantial amounts of water. It is, therefore, important to identify where this new development would be located to ensure consistency with Coastal Act policies relevant to new, intensive development. Please see Suggested Modification 89 which defines the maximum number of units for San Simeon and directs this development to be located on the resort site or in existing urban areas.

    Finally, as discussed earlier in this finding, the issue of the safe yield of Arroyo de la Cruz to support the proposed level of development on the Hearst Ranch is still unresolved. An instream flow management study, undertaken by qualified professionals over an appropriate time period is required before it can be determined what level of resort development can be served by water from this creek consistent with the development and habitat protection policies of the Coastal Act (30250, 30240, 30231). Although the North Coast Plan includes standards directed towards gaining a better understanding of the creek, they fall short because (1) they allow development to proceed before the studies are finished (3c pg. 7-16); (2) do not adequately define study parameters (3c); (3) appear to rely in part on an on-going study that, thus far, has provided little useable information (3A, pg. 7-16) and do not relate the findings of the study to approval of a project. In order to be consistent with Section 30250, which requires that services be available for new development, and with Sections 30251 and 30240, which require the protection of sensitive habitats. These standards must be revised to result in a study that will more accurately define impacts on coastal resources that can be used as criteria to determine the appropriate level of resort development. (Please see Suggested Modifications 67, 72, 83, 84, 85, 86, 87).

    Rural Area Other Than the Hearst Ranch

    Neither the existing certified North Coast LUP or the proposed update provide for any other nodes of new, intensive visitor serving or other non-agricultural development in the remainder of the rural area. Continued water supply for Hearst Castle and staging area should however be discussed. This popular visitor destination is owned and operated by the State Department of Parks and Recreation as a result of a gift from the Hearst family. In the recent past, annual visitor counts of one million people have been reached. More recent visitation has diminished somewhat, but the state monument still attracts upwards of 700,000 people a year. Water for the Castle and Staging Area is supplied from Phelan and Chisolm Springs- tributaries of Arroyo de la Cruz (Water Permit 27212 and 10924B). License 10924B allocates 60 AF of water to Department of Parks and Recreation and an unknown share of the 65 AF under Permit 27212.

    The proposed North Coast update requires the preparation of a State Parks General Plan if substantial new development is contemplated (7-39, Standard 14). Standard 14B and G require that the plan adequately address infrastructure needs as follows:

    B. Infrastructure. Plans for utility service, including water supply, sewage disposal, and other infrastructure, showing sufficient ability to serve the anticipated number of visitors and other needs of the facility.

    G. Mitigation of impacts from the facility. Full mitigation of environmental impacts from traffic, air quality, water use, sewage disposal, and visual impacts on Highway One is required.

    Planning standard 15 (pg. 7-40) also requires the Department of Parks and Recreation to coordinate their new development with the Hearst Resort proposed for the Staging Area.

    In order to maintain consistency with Coastal Act policies that require new development to be limited to that which can be adequately served with essential services without damaging coastal resources., Standard 14B must be revised to ensure that the impacts of additional water withdrawals will not adversely affect riparian and wetland resources (see Suggested Modification 101).

    As mentioned earlier, Standard 24 (7-9) provides for studies of water availability for tourist facilities such as the Hearst Resorts. The standard does not however relate the findings of the studies to the approvability of the project. In order for new development to be consistent with Coastal Act Section 30250, it must be able to adequately be served by appropriate infrastructure and not adversely affect coastal resources. Standard 24 must, therefore, be revised to state that development will be limited, or denied, based on the results of these studies (see Suggested Modification 63).

    Similarly, Standard 25 (7-10) requires that, prior to the issuance of a land use permit, new, non-agricultural development must demonstrate an adequate water supply. Water supply, consistent with the protection of coastal resources, is a critical component of any development and should be ascertained prior to approval of a project so that public comments and appropriate conditions can be factored into the final, approved project. (Please see Suggested Modification 64.)

    Finally, Standard 9 (pg. 7-11) provides general criteria for development, including water wells and diversions, on or near Arroyo de la Cruz. The standard states that development must not result in significant, adverse impacts on natural resources. In order to maintain consistency with Coastal Act requirements to protect agriculture (Sections 30240 and 30241), the standard must be revised to state that development (water wells) which serve non-agricultural uses also must not adversely affect agricultural productivity (see Suggested Modification 72).

    4. Roads and Circulation

    Road access into the Planning area is limited to Highway One and Highway 46. Highway One provides the only through, north-south coastal route between the Monterey Peninsula and Morro Bay. Highway 46 connects the North Coast with the inland portion of San Luis Obispo County. Both the town of Cambria and the village of San Simeon Acres are bisected by Highway One and it is used extensively for local circulation as well as an increasingly popular visitor route.

    The following sections of this finding discuss the effects of the proposed amendment on circulation, analyze those effects relative to the controlling Coastal Act policies and suggest modifications to the plan as appropriate.

    Highway One

    Highway One runs the entire length of the planning area and, outside of Cambria is generally a two lane road. The current Level of Service (LOS) between the southern boundary of the planning area and the entrance to Hearst Castle is LOS D. This level of service is considered "marginally acceptable and maneuverability and speed selection is restricted for most drivers." The E.I.R. prepared for the North Coast update states that a LOS of C or better is considered acceptable (pg. 5-1-3). The North Coast update does not identify a specific LOS as being acceptable, but it can be inferred from the discussion on page 5-4 that a LOS of D is probably adequate while a LOS of F is clearly not acceptable. The acceptability of LOS E is unknown. Projections in the plan indicate that levels of service between Cayucos and Hearst Castle will deteriorate to LOS D and F at buildout. These figures assume a 140% increase in traffic volumes at buildout between Cayucos and Cambria. Cambria, however, is only about 25% built-out, it can be expected to expand four times by build-out unless a way can be found to reduce the number of existing, vacant lots. The projected traffic volumes may, therefore, be rather low. Similarly, the traffic volumes between Cambria and Hearst Castle may also be understated. The plan projects a doubling of traffic (1000 more trips) but a review of the traffic estimates for the Hearst Resorts alone suggest a rather low estimate of 370 to 1102 trips, development of rural land between Cambria and Hearst Castle can also be expected to add trips to this section of Highway One. Finally, San Simeon Acres is only +54 built-out and will generate additional traffic volumes.

    Understated or not, it is clear that given the current planning scenarios, traffic volumes on Highway between Cayucos and Hearst Castle can be expected to increase to Levels of Service which are generally thought to be unacceptable. Levels of Service between Hearst Castle and the County line in Big Sur are however projected to be maintained at LOS C. Highway One is also prone to operational problems along its route, particularly north of Hearst Castle. An eroding shoreline threatens sections of the road between Piedras Blancas and Arroyo de la Cruz. Narrow lanes, sharp curves and the absence of shoulder parking have caused safety problems. The resurgence of elephant seal populations has also added a new peril for drivers. These issues and suggested revisions to address them are more thoroughly discussed in the Findings for Hazards and Environmentally Sensitive Habitats.

    The North Coast update contains several goals related to Highway One, including managing diminishing resources such as traffic capacity; ensuring that development demands will not exceed existing and planned capacities; and locating new public service facilities as close as possible to the users. Along with the other goals of the NCAP, these goals are considered criteria for consideration when new development is proposed (pg. 1-6).

    The Circulation Chapter of the plan also provides non-mandatory recommendations for improvement to Highway One. First, the NCAP defines "Principal Arterial Highways" as freeways and State Highways, such as Highways 1 and 46 in the North Coast Planning Area (pg. 5-10). At the same time, because Highway One carries substantial local traffic, "the installation of passing lanes, where possible, is recommended in the North Coast Circulation Plan." (5-10)

    The most important programmatic statements in the NCAP for Highway One concern exceptions to the policy to maintain the Highway as a two-lane road in the rural areas of the North Coast. As amended by the County, the NCAP calls for further studies of Highway One use patterns, as a basis for appropriating fair shares of assessments to fund improvements, or other programs that will offset the impact on the highway (p. 5-14, 3A). The improvements contemplated include:

  • (1) Two passing lanes, one northbound, one southbound from Cayucos to Cambria; and possibly full left and right turn channelization of San Geronimo Road, Villa Creek Road, and Harmony Valley Road (5-14, 3B);

    (2) Signalization and channelization of the southerly section of Main Street - Ardath Drive, and Cambria Drive intersections in Cambria (5-14, 3C);

    (3) Two passing lanes, one northbound, one southbound; and full left and right turn channelization of major local road intersections such as at Vista Del Mar and Pico Avenue in San Simeon Acres between Cambria and Hearst Castle Staging Area (5-14, 3D);

    (4) Developing paved turnouts; and improving shoulders to provide paved area usable as a Class II Bike Lane north of Hearst Castle Staging Area (5-4,3E); and

    (5) Developing transit opportunities such as bus service between Hearst castle and motel areas in San Simeon/Cambria, and Cambria's downtown (5-14, 3F).

  • The NCAP does limit the expansion of Highway One in Cambria until traffic levels warrant the installation of passing lanes, and until other management methods are found not to be feasible or effective (5-16).

    Finally, the NCAP includes a program to consider a safer and more convenient pedestrian crossing to link residential and motel areas east of the highway with the beach areas in San Simeon Acres. This may include channelization for left turn lanes and also a street light on Highway One to stop high-speed traffic (5-17).

    The NCAP Update also modifies the mandatory planning standards for Highway One. A new areawide standard addresses traffic mitigation and requires that development plan and subdivision proposals be reviewed to determine the adequacy of services, including the impacts on the carrying capacity of Highway One. It further states that inadequate road capacity may be grounds for denial unless adequate mitigation measures are incorporated. Increasing traffic levels to an extent that is found to detract from the rural, scenic nature of Highway One shall not be permitted (7-4, #5).

    The standards for Hearst Resort development are also updated. Similar to the assessment required for water supply, the phasing of Hearst development must "Time phases to correspond to transit improvements in and traffic capacity planned for Highway One and other affected roads;" and (7-15, 2A) "Insure that ... traffic capacity or transit system alternatives and safety improvements are in place (7-15, 2C)." Each phase must also be reviewed to determine adequacy of services, including impacts on the carrying capacity of Highway 1. And although inadequate road capacity may be grounds for denial, the County has removed a prohibition on increasing the number of traffic lanes or the placement of full stop signals on Highway 1. Finally, the NCAP requires appropriate participation, including funding for mitigation of traffic impacts on Highway One and other areas affected by Hearst development. (7-19, 3K)

    With respect to other development proposed in the North Coast, the NCAP includes a Standard requiring State Parks to plan for infrastructure and mitigate any traffic impact, including controlling ticket sales at Hearst Castle to encourage more visitors during the off season. (7-39, 14B; 7-40, 14E,F,G). It also requires development proposals for the East-West Ranch to be reviewed to determine the adequacy of services including the impacts on carrying capacity of Highway One. Similar to Hearst Resorts, inadequate road capacity may be grounds for denial unless mitigation measures are incorporated to ensure that adequate capacity can be provided (7-67, #23). Discretionary projects must be reviewed to determine the adequacy of services including the impacts on carrying capacity of Highway One (7-114, #4).

    Conformance with Coastal Act

    Coastal Act Section 30254 requires that Highway One be maintained as a scenic, two lane road in rural areas. With the exception of Cambria and San Simeon Acres, all of the North Coast planning area is rural. The proposed amendment, however, clearly provides for the expansion of Highway One from a two lane road to a four lane road from Cayucos to Hearst Castle. Planning program 5-10 redesignates Highway One from an arterial road to a principal arterial -- principal arterials are defined as freeways. Freeways are typically four lanes or more. Various programs recommend the installation of passing lanes where possible through Cambria (5-10) and contemplate additional lanes near the Hearst Resorts (5-14, 3). Programs 3A and 3B provide for north and southbound passing lanes between Cayucos and Cambria and Cambria and Hearst Castle (4 lanes -- one northbound travel lane, one northbound "passing lane", one southbound travel lane, one southbound "passing" lane.) It may be argued that the occasional passing lane could be found consistent with the spirit at least of Section 30254. However, as articulated in the North Coast Plan, the "passing" lanes could be continuous, thus defeating the purpose of the Coastal Act policy. If the Programs were revised to limit the location and number or total length of the three or four lane portion of the Highway, then these provisions could be found consistent with Section 30254 to an insignificant expansion. Suggested Modifications 25, 33, and 34, therefore, limit the use of passing lanes to no more than 10% of the total length of the existing rural segments of Highway One This is comparable to other rural coastline in California, such as the San Mateo Coast and northern Santa Cruz County.

    Likewise, Planning Standard 2A (7-15), must be modified to clearly state that additional lanes on Highway One will not be permitted as mitigation for the traffic impacts of new development. (See Suggested Modification 81.)

    The Coastal Act also requires that new development must be able to be adequately supported by essential services, including roads. Although the Plan includes standards for the Hearst Resorts, East-West Ranch and San Simeon Acres that state that development can be denied if there is inadequate road capacity, it does not define what constitutes inadequate road capacity. The LOS system is a well accepted formula for determining adequate levels of road service. Levels of Service A through C are considered acceptable. LOS D is marginally acceptable. LOS E and F are generally considered unacceptable. In order to provide greater certainty in the review of development proposals and ensure that the requirements of Section 30250 of the Coastal Act are met, an acceptable Service Level must be identified. A service level of D is acceptable between Cayucos and the Hearst Castle Staging Area because, although it is a scenic drive, this portion of the road is inland and is the primary access route for Castle visitors and residents of the North Coast from inland San Luis Obispo County. The portion of Highway One which leads north to Big Sur from Hearst Castle offers almost continuous views of the sea and as it continues through to the Monterey Peninsula, this drive is seen by many to be a recreational activity in itself. The Big Sur LCP, in recognition of the recreational value of the drive, requires that an LOS of C shall be maintained. The same LOS for the remainder of this highly scenic route in northern San Luis Obispo County is, therefore, also appropriate. (See Suggested Modifications 52 and 81 which add such a planning standard).

    Cambria Internal Circulation

    Traffic on the streets and roads in Cambria, especially Main Street, is frequently congested, particularly in the summer. Regardless of the land use designation of a site, approval of any future development must take into account the limitations imposed on development by congested traffic.

    As mentioned above, traffic conditions on local streets are a major concern in Cambria. One way of determining traffic conditions is by ranking them according to Level of Service. Level of Service D, which the County has determined is the minimum acceptable LOS for streets and roads in Cambria, is characterized by near-unstable traffic flow where small increases in volume could create substantial delays and where maneuverability and selection of speed are restricted. Although the main roads and streets currently are at or better than the minimum acceptable level established by the County, at buildout unacceptable levels of service will exist. Without road improvements, at buildout, the County projects increased congestion at, for example, Main Street east of Pine Knolls Drive and west of Cambria Drive operating at LOS E.

    Conformance with Coastal Act

    The County proposes to mitigate for impacts to traffic from future development by several means, including Transportation Demand Management (TDM) programs and policies intended to reduce travel demands and congestion. These TDM programs and policies include construction of left turn lanes and new streets, use of public transit and other alternative transportation means, locating development so that necessity for travel is reduced, and requiring developments to mitigate their effects on the transportation system.

    The Coastal Act intends that circulation not inhibit coastal access, but also that roads be constructed or expanded only when necessary. New development should maintain and enhance public access to the coast by providing for public transit and nonautomobile circulation (Section 30252) and new roads must be designed and limited to accommodate the needs generated by development that is consistent with the Coastal Act (Section 30254).

    The County is proposing all of these kinds of measures. Most of these are consistent with the Coastal Act. The area where inconsistencies occur is in the construction of new streets. The new streets proposed to be constructed to help maintain LOS at acceptable levels are shown on Exhibit #10. They include extension of Piney Way, construction of new Fiscalini Ranch Road and new Creekside Drive, extension of Cambria Dive, extension of Windsor Boulevard, and extension of Tipton Street. Of these, the existing area plan considers only the Fiscalini Ranch Road - Creekside Drive new construction.

    Piney Way

    The Piney Way extension would provide another access besides Burton Drive between West Lodge Hill and Main Street. Extending this street would require construction on steep slopes, removal of an unknown number of Monterey pine trees, and a new crossing over Santa Rosa Creek. The Update states that "this is a much longer term alternative, and the need should be fully justified prior to implementation." This proposed street extension, as a planning issue, is not inappropriate in a land use plan document. However, the premise on which planning for the extension is based is that Cambria will grow by 200 percent at buildout. At the present time and for the foreseeable future, it is unlikely that the community will be able to grow as it has because of the lack of water. It is questionable if this street extension is necessary to serve vague future development. Because of this, the potential impacts from construction on steep slopes and in the pine forest, and because the County itself considers this to be a longer term alternative whose need is not now justified, it is not appropriate at this time to consider this extension in the Update. Development or uses that can be permitted consistent with the Coastal Act are very limited. Therefore, these proposed streets are inconsistent with Coastal Act section 30254. (See Modification 30.)

    Fiscalini Ranch Road, Windsor Boulevard, and Creekside Drive

    All three of these proposed streets would be on East - West Ranch property. The Fiscalini Ranch Road would provide a connection between West Lodge Hill and Highway One and potentially West Lodge Hill and Park Hill. The connection with Highway One would traverse steep slopes in view of the highway and could impact recorded archaeological sites. Creekside Drive would connect the East Village at Rodeo Grounds Drive with Highway One, opposite the Fiscalini Ranch Road - Highway One connection. Creekside Drive would be constructed in the Santa Rosa Creek floodplain and would be highly visible from Highway One. Windsor Boulevard extension would connect the existing sections of Windsor Boulevard on West Lodge Hill and Park Hill. Both Fiscalini Ranch Road and the Windsor Boulevard extension would probably be constructed in conjunction with development of the East - West Ranch. The Windsor Boulevard extension would be relatively straight across the property and would be for emergency access between West Lodge Hill and Park Hill. Fiscalini Ranch Road would be an open through street across the property inland of Windsor Boulevard, but would be more sinuous to follow contours and serve clustered development.

    If the West Ranch is developed, a street across the property connecting West Lodge Hill and Park Hill would be appropriate as an additional access route. Existing access roads may be inadequate, depending on the ultimate density of development on the Ranch. The connection with Highway One, though, could have potential significant adverse impacts to archaeological sites and the scenic views of the hillside from Highway One. However, if it is sited and constructed to avoid archaeological sites to the greatest degree feasible and to adequately mitigate for unavoidable impacts to archaeological sites and if it will not detract from the scenic hillside views to the greatest degree feasible, then the connection will be consistent with Coastal Act sections 30244 and 30251, which require protection of visual and archaeological resources. Windsor Road is not as problematic and would be a logical in-road to the West Ranch development. Assessing appropriate design and siting at the development stage, this road is also consistent with the Coastal Act. Therefore, Fiscalini Ranch Road, if the connection with Highway is deleted, and Windsor Boulevard, as conceptual planning issues, are consistent with Coastal Act sections 30251 and 30252.

    Finally, Creekside Drive would have potential significant adverse impacts to views from Highway One across the floodplain meadows and would be subject to flooding and could exacerbate flooding by further limiting the area over which flood waters could spread. Further, construction of Creekside Drive is, according to the County, a long term, low priority development. As with the Piney Way extension, Creekside Drive would be needed to serve vague future development which is unlikely to materialize in the near future due to lack of water. Therefore, Creekside Drive is inconsistent with Coastal Act sections 30251 and 30253, which requires that hazards, in this case development in a floodplain, be minimized. Such a road would also have negative impacts on the Santa Rosa Creek riparian zone, inconsistent with Section 30240 and 30231. (See Modifications 28 and 29.)

    Cambria Drive

    The Update states that "[t]his extension is also located in West Village and is planned to link the west side of Cambria by a fourth access point to Highway One and the downtown areas." However, this street extension is not shown on the circulation map and the description gives no clear indication of where it would be located. As with the Piney Way extension, there is only vague future development that would necessitate this street. Therefore, the proposed extension is inconsistent with Coastal Act section 30254. (See Modification 137, Map Changes.)

    Tipton Street

    The proposed Tipton Street extension would enter the West portion of the East - West Ranch at its southerly boundary. This would provide a second open access into the Ranch from the south. The Update states that "Extension of this street into The Ranch is not anticipated at this time." Since it is not anticipated at this time, there is no reason for it to be included in the Update. No planning purposes or issues are furthered by including this in the Update. The extension of this street during the 20 year lifetime of the Update is highly unlikely. Even if the Ranch is developed to the maximum proposed there would be no need for this extension. Therefore the proposed Tipton Street extension is inconsistent with Coastal Act section 30254, and should be removed from the NCAP. (See Modification 137.)

    5. Wastewater Treatment

    The two principal issues presented by the North Coast Plan relevant to sewage disposal are the provision of adequate capacity to serve the urban areas of Cambria and San Simeon Acres and the method of serving the proposed Hearst Resorts. The following sections of this finding discuss each of these issues in turn.

     

    Urban Areas

    CAMBRIA: Cambria is served by a one million gallon per day (1 MGD) sewage treatment plant operated by the Cambria Community Services District (CCSD). The plant is currently running at about 50% of its capacity, treating +490,000 gpd of sewage. Wastewater from the treatment plant is discharged through a spray irrigation system and surface discharge into ponds located near the mouth of Van Gordon Creek. The sludge is spread on fields located on the CT Ranch north of Cambria. A condition attached by the Coastal Commission to the 1977 permit for the new plant reserves 200,000 gallons a day of capacity for Coastal Act priority issues and limits residential hook-ups to 125 per year. The existing 1 MGD plant will not be able to serve build-out of the plan. A 2.2 MGD plant will be needed. The Resource Management System projects that the current plant can accommodate Cambria’s growth until 2022. It thus appears that there is sufficient capacity for the twenty year duration of the North Coast Plan.

    The primary issue associated with the Sewage Treatment System for Cambria is not therefore related to capacity but more towards the environmental effects of the method of discharging the treated wastewater. This issue is discussed in the finding on Environmentally Sensitive Habitats.

    SAN SIMEON ACRES: San Simeon Acres is served by a 200,000 gpd plant located near the shoreline in the southern part of the village. The site is presently designated for multi-family development but the proposed update recommends changing that to a more appropriate, Public Facilities designation. The plant is operated by the San Simeon Community Services District (SSCSD) which provides wastewater treatment to the small town of San Simeon Acres and to the Department of Parks and Recreation facility at Hearst Castle. State Parks is entitled to 50,000 gpd of the plant’s capacity and is currently using 15,000 gpd. Existing development in San Simeon Acres uses +65,000 gpd capacity for a total average use of 80,000 gpd. Wastewater is discharged from an ocean outfall near the treatment plant.

    The North Coast LUP states that the SSCSD treatment plant will have to be expanded to 300,000 gallons per day capacity to serve build-out of San Simeon Acres and maintain the 50,000 gpd reservation for State Parks use at Hearst Castle and the Visitor Center at the castle Staging Area. Discussions with Department of Parks and Recreation staff indicate that the 50,000 gpd reservation will be sufficient for their needs well into the foreseeable future as all major development projects have been completed for this facility. A review of current use figures for San Simeon Acres, presently about 50% built out, shows average 65,000 gpd. The average dry weather flows (June-October) coincide with peak use because this is the time period most popular with visitors to the area and thus the period of highest occupancy and use of San Simeon Acres extensive visitor accommodation facilities. If the present demand at 50% built-out is 73,000 gpd, then it would seem that only another +75,000 gpd would be needed for a total of a 180,000 gpd plant (50,000 gpd for Department of Parks and Recreation, 65,000 for existing uses, 65,000 for planned, but yet unbuilt development -- +180,000 gpd). Sewage Treatment plants are, however, ordinarily built with slightly greater capacity than is anticipated to provide a safety cushion in the event of malfunction and to accommodate normal maintenance. Also, if occupancy rates increase for motels in San Simeon Acres flow rates could increase. The Regional Water Quality Control Board regulates the operation of Sewage Treatment Plants and usually requires a moritoria on new hook-ups when a plant reaches 80-85% of its rated capacity. Adding this safety factor into the final plant size would, then, result in the need for at least +225,000 gpd plant.

    In order to maintain consistency with Coastal Act Section 30254, which limits public works to the size needed to accommodate planned development, the text of page 3-37 must be revised and a new planning standard for San Simeon Acres must be added to limit plant capacity accordingly. (See Suggested Modification 8.)

    The text on page 3-37 also suggests that the District’s service area may be expanded beyond its present boundaries to serve land in "the immediate vicinity." Depending on the definition of "immediate vicinity", this statement could mean that the proposed Hearst Resorts could be annexed to the District. Given the uncertainties regarding the final sizing of these developments and the lack of analysis of the effects of extending urban services into rural areas, it is inconsistent with Coastal Act Policies to allow extension of urban services outside existing urban boundaries. The text must therefore be revised to more clearly identify the service area for San Simeon Community Service District and a planning standard added to maintain current District boundaries. (see Suggested Modification 9.)

    Finally, the Coastal Act requires that Coastal Act priority uses -- visitor-serving and recreation -- shall not be precluded by limited infrastructure. Although it appears that sewage capacity is reasonably available for most of plan build-out, the North Coast update includes several standards to reserve capacity for priority uses. In particular, the San Simeon Acres Community Services District (SSACSD) must reserve 75% of available water and sewer capacity for visitor serving uses, and 25% for affordable housing, although if consistent with other permits, this 25% may be taken from the Visitor Serving category (p. 7-113, #1).

    Even with the potential to divert some of the reserved water to affordable housing, much of the potential buildout in San Simeon Acres is already available for visitor-serving uses. In addition, there is not a real sewage capacity problem here at this time. Finally, given the current development moratoria on the basis of lack of water, little development is anticipated in the near future. Therefore, the NCAP policies maintain consistency with Coastal Act Section 30250.

    Rural Areas/Hearst Resorts

    Planned densities for the rural portion of the North Coast are, with the exception of the Hearst Resorts, so low that any needed wastewater treatment can be achieved on site by septic systems. This section of the Finding will therefore focus on wastewater treatment and disposal for the planned development at the Staging Area, San Simeon and the Pine Forest resorts.

    As discussed earlier, the North Coast Plan provides for a substantial amount of intensive visitor serving, recreational and residential (employee housing) at three rural locations on the Hearst Ranch. None of these sites are presently within any public service district that provides wastewater treatment and disposal. The North Coast update does not discuss sewage generation that would be anticipated by this level of development nor does it provide any explicit policy direction on how to accommodate it.

    The E.I.R. prepared in 1982 by Envicom Corporation to support the water supply project on Arroyo de la Cruz before the State Water Quality Control Board (Water permit application #25881) does, however, include a discussion on anticipated wastewater treatment needs and potential methods of treatment and disposal.

    Table 12, on page 97 of the E.I.R. depicts estimated wastewater flows for the projects as proposed in 1982. Adjusting the figures for some of the development currently proposed in the North Coast update, a total flow of 157,000 gpd would be required as shown on the following table.

    TABLE 4. ADJUSTED ESTIMATED WASTEWATER FLOWS

    LOCATION/TYPE SIZE GENERATION RATE USE AT 100%
           
    1. Staging Area      
    a) Motel 150 units 180 gpd per unit 27,000 gpd
    b) Restaurant 250 seat 32 gpd per seat 8,000 gpd
    c) Commercial 10,000 sq. ft.   650 gpd
    d) Day Use 200 people 7 gpd per person 1,400 gpd
    e) Youth Hostel 100 units or 50 site camping (no figure given in EIR)  
          37,050 gpd
    2. San Simeon Village -- Resort
    a) Hotel 250 units 180 gpd per unit 47,000 gpd
    b) Restaurant 150 seat 32 gpd per seat 4,800 gpd
          49,800 gpd
    3. San Simeon Village - Commercial
    a) Hotel 50 units 180 gpd per unit 9,000 gpd
    b) Commercial 10,000 sq. ft. 650 gpd  
    c) Day Use Recreation 1,000 people/day 7 gpd per seat 7,000 gpd
          16,650 gpd
    4. Pine Forest      
    a) Hotel 250 units 180 gpd per unit 45,000 gpd
    b) Restaurant 250 seat 32 gpd per seat 8,000 gpd
          53,000 gpd
           
    Total Sewage Generation Based on Development Estimates in the E.I.R. as Specifically Reduced by the North Coast Plan 156,500 gpd
           
           
           

    This figure of +160,000 gpd should however be considered quite low. It does not reflect any capacity for the youth hostel, campground or employee housing required by the plan, nor does it reflect other uses permitted on these sites (meeting rooms, caretaker units, cultural center, rural recreation, convention facilities, bars, and equestrian centers). In addition, the commercial uses contemplated in the E.I.R. are quite modest. The addition of 100 units of employee housing alone would, for example, add 21,000 gallons per day for a total of 180,000 gpd. Reservations of 15-20% of the rated capacity as required by the Regional Water Quality Control Board would bring the plant size to +207,000 to 221,000 gpd. A Sewage Treatment plant slightly larger than the size of the one currently serving San Simeon Acres would be needed to accommodate this level of development. Any additional development permitted in the plan would of course increase demand.

    Although the Coastal Act Section 30250 requires that new development must have access to adequate services -- like wastewater treatment -- the North Coast Plan does not offer a specific strategy for providing this essential support for the Hearst Resorts. The updated plan does however suggest that wastewater disposal services for the resorts may have to be supplied by a public agency:

    Future special districts may be needed to provide services in the planning area. For example, a forest management district is needed to provide local solutions to problems with the Cambria Pine Forest. In addition, proposed resort developments on the Hearst Ranch, may necessitate the provision of water, sewage disposal, fire and police protection, additional schools, and other facilities managed by an public agency. (Standards - Paragraph On 3-4)

    Moreover, Planning Standard 2C (pg. 7-16) simply requires that wastewater systems shall "be in place" to serve the Hearst projects; while Planning Standard 2H (pg. 7-17) requires that development proposals include the "provision of organized services."

    At bottom, there are only two strategies for wastewater treatment and disposal for the proposed Hearst Resorts development -- treatment at a public plant or construction of an on-site package plant. Both strategies present practical problems and potential conflicts with Coastal Act policies.

    Treatment at a public plant, the most convenient being the one located in San Simeon Acres, would require the extension of a sewer line beyond the urban boundary of the village. The extension of urban services into rural areas tends to blur the boundaries between urban and rural areas and thus induce growth that is inconsistent with the protection of coastal resources. Section 30241 for example requires the establishment of stable urban and rural boundaries to protect agricultural land. This section also precludes public service expansion that would impair agricultural viability. Section 30250 requires new, urban level development to locate within areas already served by public services. Visitor serving development may be located outside urban areas, but it must be able to accommodate its own service needs as there are no provisions in the Coastal Act to extend public services for these uses. Finally, Section 30254 limits the expansion of public works to that needed to serve development that is otherwise consistent with the Coastal Act. Clearly, the extension of services through several miles of rural land, much of which is designated for agricultural uses, to serve what will be essentially a new urban area, is inconsistent with these Coastal Act policies.

    There is also a practical problem associated with using the plant at San Simeon Acres. According to the North Coast update (pg. 3-37) the ultimate capacity of the plant is limited to 300,000 gpd. The plan states that this amount of capacity is needed to serve build-out of San Simeon Acres and provide service to Hearst Castle. As discussed in an earlier section of this finding, this figure may be somewhat high, by perhaps as much as 50,000 gpd. However, estimated flows from the Hearst Resorts of at least 200,000 gpd could clearly not be accommodated as well. If for example build-out of San Simeon Acres and Hearst Castle require +250,000 gpd sewer capacity and the maximum size plant that could be located on the current SSCSD site is 300,000 gpd, only 50,000 gpd, at most, would be available for the Resorts -- a significant shortfall. A new site would have to be found and the discharge permit for the ocean outfall would have to be amended to allow the greater discharge. The SSCSD outfall is located in the Monterey Bay Sanctuary and increased discharges must also be approved by the Monterey Bay National Marine Sanctuary. Currently, new or increased discharges into the Sanctuary are viewed with caution. (See also ESHA findings.)

    The other method of disposing of this amount of sewage is to treat it on-site with a package plant constructed and sized to accommodate only the Hearst Resorts. Package plants are owned and operated by the private developer. Due to operational problems, they are not allowed by all Regional Water Quality Control Boards. The Oakland Board for example does not permit them in the counties subject to their jurisdiction. The San Luis Obispo Board does, however, allow them and thus a package plant is an option for the Hearst Resorts.

    Conversations with Hearst Ranch representatives and a review of the 1982 E.I.R. prepared for this development conclude that a package plant is the most likely alternative, as follows:

    The principal alternative for sewage disposal will be on-site treatment, with the effluent being reclaimed for either golf course watering, agricultural irrigation, or both, The sites and characteristics of treatment plants have not been specifically identified, but the applicant states that golf course and/or spray field locations have been planned to minimize any effects of runoff to sensitive riparian or coastal marsh habitats. Sewage disposal will be subject to the requirements of the Regional Water Quality Control Board.

    The technology of package plants -- and indeed all sewage treatment plants -- has greatly improved over the years. Package plants can now produce an effluent that can be used for irrigation of agricultural land. Other improvements are available which dramatically reduce the amount of sludge which must either be spread on land or transported out of the area. Thus the operational requirements of modern plants do not have the adverse impacts on agricultural land that the older style treatment facilities did. This is important in this situation because absent the new technology, acres of agricultural land would have to be taken out of production to provide the spray and sludge fields. It thus appears that a properly designed and operated package plant sited within the allowable development envelope, would be the most appropriate choice to serve allowable development. Plan standards to ensure this are however needed to provide consistency with Coastal Act policies relevant to the protection of agriculture and to adequately size the facility to avoid inappropriate growth. (See Suggested Modification 83.)

    6. Miscellaneous Land Use Designation Changes

    The North Coast update proposes a variety of changes to existing land use designations in both the urban and rural areas. The changes involving the conversion of agricultural lands are discussed in the agricultural findings. This section discusses all other proposed land use designation changes. The County proposes to change the land use designations at 14 urban locations, as follows:

    Cambria Urban Area (NCAP Map 8: Cambria, Land Use Categories)

    1. Cambria Community Services District: residential to commercial retail.
    2. Connelly & Childs: residential and office/professional to commercial retail.
    3. Kauffman/Swauger: residential to commercial service.
    4. Kreps/Meltzer: commercial retail to residential.
    5. Cambria CSD: commercial retail to public facility.
    6. Rhoades/Crawford: agriculture to commercial retail (1 acre)
    7. Lynch/Strong: residential to recreation.
    8. State Parks: open space to recreation.
    9. East Ranch Floodplain: commercial retail to recreation and residential to recreation
    10. Newman/Londonderry: multi-family residential to single family residential.
    11. South Cambria: Residential Suburban to Rural Lands and remove from Urban Rural Line.
    12. School Site: open space to residential.
    13. Mid-State Bank: recreation to commercial retail and removal of Visitor-Serving designation

    San Simeon Acres Urban Area (NCAP Map 5: San Simeon, Land Use Categories)

    1. San Simeon Community Services District: residential to public facility.

    Conformance with Coastal Act

    The nature of particular land use designation changes determines which Coastal Act policies are relevant. Appropriate policies are cited in the individual discussions of each proposed change below.

    1. Cambria Community Services District: residential to commercial retail.

    Located in the West Village of Cambria, this vacant 1.4 acre site is currently designated Residential Single Family (RSF). The Cambria Community Services District (CCSD) requested that the County change the land use designation to Commercial Retail (CR) which is consistent with the land use designation of the parcels immediately to the south on the same side of the street. The site is now used as informal parking by the general public when shopping or doing business in the West Village. The site is bounded on the south by vacant commercial land, on the north by vacant residential land, on the east by vacant residential land on steep slopes, and on the west by Main Street and public facilities (Veteran’s Hall, Senior Center) on the opposite side of the street.

    Any development on the site will add traffic to Main Street and potentially increases the need for parking and/or displace the existing informal parking. The site is subject to flooding and potential geologic hazard from the steep slopes on the easterly part of the site and behind it. The one category in which commercial uses on this site could potentially overburden infrastructure is in traffic generation. The change to commercial retail could, according to the County, result in approximately 12 times as many daily trips as residential uses would generate (1,700 versus 140). As discussed above in the Roads findings, streets in the West Village of Cambria are frequently congested. Highway One is congested through Cambria. Currently, Main Street in front of this site operates at LOS C, while to the east of this site, it is LOS D. According to the EIR for the Update, at buildout, and with mitigations (widening Main Street to three lanes, etc.). Main Street in front of the site would operate at LOS E -- an unacceptable level.

    The site is also in the mapped flood hazard area where further new development should be prohibited until a comprehensive flood management plan is developed and implemented (see Hazards findings). Any development on the site, regardless of its land use designation would displace informal parking, be subject to flooding and potential geologic hazard from the steep slopes at the rear of the site, and have potential adverse impacts to views from public roads.

    Because of these constraints it is not appropriate to change the land use designation on this parcel at this time. Therefore, the change in land use designation is inconsistent with Coastal Act sections 30250 and 30253, and should be denied.

    2. Connelly & Childs: Residential and Office/Professional to Commercial Retail.

    This three acre site is located on the south side of Main Street just east of the Cambria Elementary School in the East Village. The topography is flat to gently rolling and slopes from Main Street to Santa Rosa Creek. The easterly one-third is designated Office/Professional; the westerly two-thirds is designated Residential. An 18 unit mobile home park is located on the southern part of the westerly two-thirds. The property owners requested that the County redesignate the entire site to Commercial Retail which would be consistent with the designations across Main Street and along Main Street to the east. The main issues here include future building in a flood hazard area and increasing traffic on Main Street.

    As with the previous land use designation request, traffic is a major concern here. The potential daily trips under the existing designation is 835; Commercial Retail use could generate up to 5,167 daily trips. This site is east of the previous site; according to the EIR, after buildout with mitigations, this section of Main Street would operate at LOS D, the minimum acceptable to the County. Please see the previous analysis for further discussion of traffic.

    In terms of the existing pattern of development and in location, it makes most sense that the current Office/Professional designation be changed to Commercial Retail. The Multi-Family Residential designation should be retained for that portion of the property where the mobile home park is located. However, in order to reduce water use and traffic, no Multi-Family Residential use should be allowed on the Commercial Retail part of the site. The site is in a developed area where there are services and the proposed change will not change the existing standards dealing with flooding, etc. Although the change in land use designation could allow a fairly large increase in trips, the EIR describes Main Street operating at LOS D after buildout, with mitigations. No new development would occur on this site in the flood hazard area, since that part of the site is already developed with the mobile home park. Therefore, the change in land use designation for a portion of this area is consistent with Coastal Act sections 30250, 30251, and 30253. (Please see Modification 137.)

    3. Kauffman/Swauger: Residential to Commercial Service.

    Steep to gently rolling slopes with grassland and Monterey pine forest characterize this vacant 3.85 acre parcel. It is currently designated Residential Suburban, although it is within the Urban Services Line, is across a street from the existing Commercial Service-designated property, and is separated from other residential land by steep, heavily forested slopes. The site is at the intersection of Burton Drive and Village Lane just southeast of the heart of the East Village.

    The main issue is the geologic hazard presented by the steep slopes on the rear of the parcel and the potential for increased traffic on Burton Drive and other streets in the vicinity. About 60 percent of the site is covered by a geologic study overlay, recognizing the potential hazard to development below the steep slopes and requiring geologic study before development may be approved. The most level, useable part of the site is across Village Lane from an existing Commercial Service property. The steep slopes adjoin existing residential uses. Burton Drive, a two-lane collector street, currently operates at LOS D. Although this proposed change would potentially increase traffic generation from an estimated 20 cars under the current designation to an estimated 145 under the proposed designation; Burton Drive is forecast to still operate at LOS D at buildout. Water use could potentially increase from 0.68 acre feet per year to 2.49 acre feet per year. This proposal could allow development that, overall, would be more intensive than that under the existing land use designation. This is not appropriate given the constraints on development in Cambria, and it is also inconsistent with Coastal Act 30250 because it could contribute to cumulative adverse impacts on coastal resources. Therefore, this land use change is denied (see Suggested Modification 137).

    4. Kreps/Meltzer: Commercial Retail to Residential Multi-Family

    Located on MacCleod Way between Wood Drive and Evensong Way on East Lodge Hill, this flat to gently rolling, vacant four acre site is surrounded by residential areas and Highway One. It is currently subdivided into 33 parcels, each approximately 25 feet by 90 feet, and one large common area parcel.

    The County identified circulation and traffic as an issue with commercial development. That kind of development could potentially generate about 15,000 trips per day as compared to a little over 700 trips per day for multi-family residential use. Water demand for multi-family residential would be about three and one-half times that of commercial.

    Cambria is only about 25% built out; it has about 3,400 dwelling units with a potential of over 11,000. The potential number of multi-family residential units on this four acre site with the proposed change is 104, with a potential of 225 persons. The 340 acre East-West Ranch, as proposed in the Update, has the potential to add up to 325 dwellings (265 on West Ranch + 60 Multi-family units on East Ranch) and well over 500 persons. As discussed in the Development section of this report, Cambria cannot sustain much, if any, new residential development; new lot creation is not appropriate at this time. In addition, commercial use of this site is probably not realistic given its location in an otherwise completely residential area, and being less than one-half mile from the commercial core of the East Village.

    Given the service and infrastructure constraints in Cambria, perhaps a more suitable residential use of the site would be single family dwellings. In its present configuration, if the designation was single family residential, the site could be developed with 33 units with about 71 persons, compared to 104 units and 225 persons that residential multi-family could potentially allow. Another option would be to change the land use designation to residential single family and encourage the resubdivision of the property. At the minimum parcel size of 6,000 square feet, there would be about 29 lots and 63 persons. With this modification to require resubdivision and redesignation to RSF, the site can be changed from a very inappropriate use to an appropriate one that will reduce the number of lots in Cambria.

    As detailed in the Development section of this report, Cambria does not need and cannot sustain much additional residential development. There are options other than that proposed for this site which would not add as much residential development, and possibly would reduce the total number of residential lots. Therefore, if modified the proposal is consistent with Coastal Act sections 30250, 30251, and 30253 and should be denied (see Modification 137).

    5. Cambria CSD: Commercial Retail to Public Facility

    CCSD currently uses and for many years has used this 1.15 acre parcel for a corporation yard and pumping and water treatment plant. The site is flat to gently sloping and lies along Santa Rosa Creek in the East Village. The site is on the opposite side of the creek from the East Village commercial core, in the floodplain.

    Potential flooding and preservation of riparian habitat are the main issues on this site. Although it would be prudent for CCSD to relocate the functions that this site performs to a site out of the floodplain, or at least some distance away from the creek bank to decrease the risk of flood damage to the pumping and water treatment plant, the proposed change simply recognizes the legal, existing use, and, since no new development is expected on the site, the proposed change raises no significant issues with respect to the development policies of the Coastal Act .

    6. Rhoades/Crawford: Agriculture to Commercial Retail (see Agriculture Findings).

     

    7. Lynch/Strong: Multi-Family Residential to Recreation.

    An eight unit bed and breakfast inn, the J. Patrick House, is currently in operation on this 0.14 acre site. It is located on East Lodge Hill on Burton Drive between Eton Road and Patterson Place. The site is moderately sloping with lines and landscaping. The primary issue is the previous illegal enlargement of a five unit bed and breakfast to eight units.

    The proposed change from Residential Multi-Family to Recreation would effectively legalize the eight room bed and breakfast. The room increase would create about a 50 percent increase in trips per day, from 44 to 70 and a 50 percent increase in water demand, from 0.40 acre feet per year (afy) to 0.64 afy. Both of the resulting figures are relatively small.

    The site is across Burton Drive from the Cambria Pines Lodge, which currently is designated Recreation. The proposed change will allow for the correction of the violation of illegally increasing the number of units by three. This is a very small increase in the number of Cambria’s existing motel units (about 0.45 percent). The proposed change is in a developed area, has no visual impacts, is not in a flood hazard area, and is a very minor user of water. Therefore, the proposed change is consistent with Coastal Act sections 30250, 30251, 30253, and 30254.

    8. State Parks: Open Space to Recreation.

    This proposed change would apply to a five acre site used as a parking lot and overlook on the north side of the Santa Rosa Creek lagoon, on the west side of Moonstone Beach Drive. The site is a vacant coastal terrace with coastal scrub vegetation. This proposed change would recognize the long-time use of this site as a parking area and overlook and place it in the more appropriate Recreation land use category. The change is consistent with Coastal Act sections 30212.5 and 30221.

    9. East Ranch Floodplain: Commercial Retail to Recreation and Residential to Recreation and removal of Visitor-Serving Designation from easterly 10 acres.

    This is a mostly level 20 acre site south of Santa Rosa Creek and east of Highway One, mostly in the floodplain. A portion of the East part of the East-West Ranch, this site is proposed to have its land use designation changed to limit new residential lots and units. Currently, the Residential Multi-Family designation would potentially allow up to 364 units. The Recreation designation would potentially allow up to four houses. The County also proposes removing the Visitor-Serving Designation which exists on the easterly 10 acres.

    Floodplain development, additional residential units, and removal of the Visitor-Serving designation are the primary issues. This proposal will remove a large amount of potential residential and commercial development from the Santa Rosa Creek floodplain. The potential would still exist for 60 multi-family units on four acres that are not a part of this proposed change, outside of the floodplain. The proposed change is a positive one in that it removes the potential for a very large number of units in the floodplain. That part of the proposal is consistent with Coastal Act section 30254. However, as with item number 13, Mid-State Bank, below, there is no particular reason given or information provided which would support removal of the Visitor-Serving designation. Therefore, the removal of the Visitor-Serving designation is not consistent with Coastal Act section 30222. As modified to retain the visitor-serving designation, this change is consistent the Coastal Act (see Suggested Modification 137).

    10. Newman/Londonderry: Multi-Family Residential to Single Family Residential.

    This is a 2.4 acre site comprised of 17 small lots on West Lodge Hill near the southern edge of Cambria and less than one-tenth of a mile from proposed change number 7, Rhoades. There are currently eight units on the site. The main issue is the change to neighborhood character that would come with a change from attached units to detached units. The proposed change would occur on a site currently designated multi-family residential which is across a street from single family residential. There would be a slight reduction in total potential number of building sites and dwellings from 24 to 20. Because of this decrease in intensity, the proposal is consistent with Coastal Act section 30250.

    11. South Cambria: Residential Suburban to Rural Lands and remove from Urban Rural Line.

    This site is a 135 acre property along Cambria’s southern edge. The site is mostly covered with pines. The site is currently designated Residential Suburban; the proposed change is to Rural Lands. Rural Lands reflects the removal of this site from within the Urban Rural Line. That line marks the planned edge of urban development for approximately the next 20 years. As part of the Update the County examined three potential alternatives or levels of development that would increasingly limit population growth in the North Coast Planning Area. The second level included the redesignation of this 135 acre property from Residential Suburban to Rural Lands along with redrawing the Urban Rural Line to exclude this site.

    Under the Residential Suburban designation, minimum parcel size ranges from one to five acres, which could result in from 135 to 27 parcels. Under the Rural Lands designation, the minimum parcel size is from 20 to 320 acres, which could result in from six parcels to one parcel. At a minimum, this proposed change will reduce the number of potential new lots in Cambria by 21 (fewest RS parcels = 27; most RL parcels = 6; 27 - 6 = 21). Therefore, the proposed land use designation change is consistent with Coastal Act section 30250. However, three modifications must be made to the Update for internal consistency and to accurately reflect the designation change.

    1. Delete the second paragraph under Rural Lands on page 4-8 and modify the last paragraph on that page to read "Areas of Rural Lands are designated to the south and to the north and east of the Urban Reserve Line for Cambria."
    2. Modify Figure 4-4, page 4-20, to show changes to the Urban Rural Line,
    3. Delete the last paragraph on page 4-21 to reflect the deletion of the Residential Suburban designation. (See Modification 18.)

    12. School Site: Open Space to Residential.

    The owners of the East-West Ranch have offered this site to the school district. It is a gently sloping, approximately seven acre site about 100 yards inland from the coastal bluff near the southwestern corner of the West portion of the ranch. The main issues are the loss of open space and increased traffic. This would be a change from a designation that allows extremely little development and does not allow schools, to one that allows for intensive development, including schools. While there have been no approvals for any development on the East-West Ranch, the most up-to-date proposed circulation elements for that area include a new cross-site extension of Windsor Boulevard to connect the two existing but separate parts of that street (see Roads findings). The connection would be roughly parallel to the ocean bluffs along the bluffward edge of the proposed school site.

    There is no doubt that the community needs another school. The other land use designation on the site, Single Family Residential, occupies higher and more steeply sloping parts of the site. The proposed school site is a much less sloping site. A school serving West Lodge Hill and Park Hill, two areas that currently have no school site, could be located here. Being inland of Windsor Boulevard, future development of the site would not adversely affect public coastal views. The West Ranch is proposed to have clustered development with much open space, both seaward of the site and farther inland, up the slope.

    Overall, the change from Open Space has no adverse impacts on coastal resources, particularly in light the proposed public access dedications along the bluff of the West Ranch site. However, a more appropriate designation for the site than Residential is Public Facility, which also allows schools and caretakers’ residences but does not allow general residential use. This would better ensure that other uses, including residential, do not occur on the site and that it is set aside for public school use. If modified to change the designation to Public Facility, the proposal will be consistent with Coastal Act section 30251 and 30254 (see Modification 137).

    13. Mid-State Bank: Recreation to Commercial Retail (portion) and removal of Visitor-Serving combining designation

    This 13.12 acre site lies between Main Street and Highway One, and Cambria Drive and Santa Rosa Creek. The property slopes down moderately steeply from Main Street on the eastern side of the site; most of the site is flat to gently rolling. Most of the site is in the creek floodplain. The proposed change would result in four acres of Commercial Retail designation and 9.12 acres of Recreation designation. Currently, a small bank occupies the north corner at the intersection of Main Street and Cambria Drive.

    Flooding on the site and the potential to exacerbate flooding in the West Village are major issues with any development on the site. The removal of the visitor-serving combining designation on four acres of the site is also an issue.

    This site has been the subject of controversy in the past. In 1987 the Commission approved a small bank at the intersection of Main Street and Cambria Drive. The County, in 1990, approved a commercial development that utilized the full extent of the site. That approval was appealed to the Commission. The Commission found that no substantial issue existed. In 1994, the owner proposed grading to place an earth berm along the north bank of Santa Rosa Creek and to alter the streambed under the Highway One bridge to confine floodwaters to the creek, in association with Phase I of the 1990 approval. The grading proposal was approved by the County, appealed to the Commission, and denied, in part because the 1990 approval had expired and because there were other alternatives to the proposed grading.

    The current proposed designation change would result in a much smaller development than originally proposed with no alteration to the Santa Rosa Creek streambed. Approximately one-third of the site, nearest Main Street, would be redesignated to Commercial Retail, which could include development that would serve both visitors and residents.Although there is no hard data supporting the County’s proposed removal of the Visitor-Serving combining designation, Cambria does currently provide a wide range of visitor-serving uses, from bed and breakfasts to motels of varying price ranges (there are approximately 670 motel rooms in Cambria), and from delis to formal restaurants. Nevertheless, no information has been produced showing that the Visitor-Serving Designation is no longer necessary. Until that occurs, that designation cannot be removed because it would be inconsistent with Section 30222 of the Coastal Act, which requires that lands suitable for visitor-serving commercial facilties have priority over private residential uses.

    Most of the site is in the floodplain and development potential is limited there. Development on this site could seriously exacerbate flooding in West Village by displacing floodwaters. This property is located at the east end of the West Village and at the west end of the East Village. Floodwaters overtopping the bank of Santa Rosa Creek are funneled across this site between Highway One and Main Street, both of which are elevated above the site.

    Any development on this site must address that flooding issue. As discussed in the Hazards findings, any development in the flood hazard area anywhere in Cambria along Santa Rosa Creek must address the overall flooding issue.

    The County proposes adding a requirement that proposed development on the site include submittal of a geologic report, drainage plan, and flood hazard analysis. Another new requirement would be that development in and adjacent to Santa Rosa Creek shall not be approved unless a finding is made that historic stream flows will be maintained or enhanced. However, neither of these requirements will address the overall flooding situation on this site and in the West Village when floodwaters overtop the creek banks. Further, there is no evidence that the visitor serving priority designation is not needed. No evidence has been provided to show that there is an overabundance of visitor-serving sites and uses. Therefore, the proposed change is inconsistent with Coastal Act sections 30222, 30250, and 30253, and should therefore be denied (see Suggested Modification 137).

    San Simeon Acres Urban Area (Refer to Map 5: San Simeon, Land Use Categories):

    San Simeon Community Services District: residential to public facility.

    This 20,000 square foot site is the location of San Simeon Community Services District’s (SSCSD) existing sewage treatment plant, between San Simeon and Balboa Avenues at the mouth of Arroyo del Padre Juan Creek in the community of San Simeon Acres. The proposed change will recognize the use that has existed on the site for many years and is consistent with Coastal Act section 30250.

    7. Proposed Combining Designation Changes

    Combining Designations are overlays that prescribe further investigation or certain development standards in addition to the basic land use category requirements. For example, a development site with a sensitive habitat combining designation overlay is subject to additional standards in the NCAP, as well as the Coastal Zone Land Use Ordinances. Each proposed change is discussed below.

    Cambria Urban Area (Maps 9 and 10: Cambria, Combining Designations)

    1. Sensitive Resource Area (SRA) and Terrestrial Habitat (TH) Adjustment - Pine Forest Location.

    This proposed change would affect the boundaries of the TH combining designation in the Park Hill and Happy Hill areas of Cambria. The County is requesting that the TH boundaries be expanded to reflect the on-the-ground extent of the pine forest. A previous mapping error incorrectly delineated the boundary of the pine forest in the Happy Hill area and on Park Hill. The proposed new boundary would encompass virtually all of Park Hill and all of Happy Hill. By extending the protection afforded by the TH combining designation, the proposal is consistent with Coastal Act section 30240, which requires the protection of environmentally sensitive habitat (see also ESHA findings).

    2. Historical Designations in East Village

    This change would apply the Historical Combining Designation (H) to 22 buildings and places in the East Village and add the Archaeologically Sensitive Combining Designation (ARCH-SEN) to four of the sites. The East Village is considered a "Special Community" by the LCP, partly because of its historical nature. This change would recognize that fact and require that major remodels and additions will be required to respect the historical character of the particular building in design. The change would also clarify that sensitive archaeological sites exist in the East Village. Therefore, the proposed change is consistent with Coastal Act section 30244, which addresses the protection of archaeological resources; and section 30253, which addresses community character.

    3. Cambria Community Steering Committee: Remove Visitor-Serving Designation from the Mid-State Bank property

    Please refer to item 13 under Cambria Urban Area Land Use Designation Changes, above.

    4. Hume Property: Remove Visitor-Serving Designation

    Please refer to item 9 under Cambria Urban Area Land Use Designation changes, above.

    5-9. Removal of Elementary School and Park Designation from East Lodge Hill and addition of four park designations in and near Cambria.

    The elementary school designation is proposed to be removed because the site is developed with residential uses and is therefore no longer under consideration as a school site. The park designation is proposed to be removed for the same reason. The addition of new park sites are intended to meet the need of the community for additional parks.

    These proposed combining designation changes will encourage the provision of adequate park facilities for the community, which now are very limited. This will benefit both the residents and the visitors by providing additional recreational areas. The proposed changes are consistent with Coastal Act section 30252 which, among other things requires that:

    the location and amount of new development should maintain and enhance public access to the coast by. . . (6) assuring that the recreational needs of new residents will not overload nearby coastal recreation areas by correlating the amount of development with local park acquisition and development plans with the provision of onsite recreational facilities to serve the new development.

    10. Map Leffingwell Creek and a portion of Santa Rosa Creek and San Simeon Creek to clearly show as Sensitive Resource Areas: Coastal Streams and Riparian Vegetation.

    These features in and near Cambria have not before been clearly mapped in the area plan document. This mapping addition clarifies that these streams are sensitive resource areas and thereby clearly extends the protection given those resources to these features. The proposed mapping is consistent with Coastal Act sections 30231 and 30240 (See ESHA findings for more detail).

    San Simeon Acres Urban Area (Map 6: San Simeon Acres, Combining Designations)

    1. Sensitive Resource Area Adjustment Between Balboa, Vista del Mar and Arroyo del Padre Juan

    This action would simply remove the Sensitive Resource Area designation from already developed lots. This area is bounded on the east by Arroyo del Padre Juan. The area to the southwest was considered a sensitive resource area because of the proximity of the arroyo. However, the lots which abut the arroyo were developed many years ago and there is no longer any reason to have the sensitive resource designation on the lots. The arroyo would still retain its SRA designation. The proposed change is consistent with Coastal Act section 30240.

    2. Add a park designation in the vicinity of the former gas station site at the north end of the community between Highway One, Pico Avenue, and Pico Creek.

    This would provide for a future community park on this mostly level site which formerly was occupied by a gas station. The site is vacant. Currently, San Simeon Acres has no park facility. The nearest developed park is at San Simeon State Park, about a mile to the south. The nearest park with play fields and play equipment is Shamel County Park about three miles south in Cambria. The proposed change is consistent with Coastal Act section 30252, which addresses the adequacy of local and regional park facilities.

     

     

    Public Recreation and Visitor-Serving Facilities

    Applicable Policies

    The Coastal Act sets clear priorities for public recreation and visitor-serving facilities. Section 30001.5(c) expresses the Legislature’s fundamental goal to maximize "public recreational opportunities in the coastal zone." Section 30210, meanwhile, requires that recreational opportunities be provided for "all the people." Similarly, section 30213 states an uneqivocal preference for developments that provide public recreational opportunties; and Sections 30221 and 30222 both identify public recreation as a priority land use in the coastal zone. Section 30221 also establishes a general priority for commercial recreational activities, over any private residential or general industrial and commercial development. Finally, section 30250(c) allows the location of visitor-serving facilities at existing isolated developments or selected points of visitor attraction if they cannot be feasibly located in existing urbanized areas.

    Visitor-serving land uses are not given the highest preference in the Coastal Act, though. Section 30222 clearly subordinates visitor-serving uses that enhance coastal recreation to agriculture and coastal-dependent industry. In addition, section 30221 requires the protection of oceanfront land suitable for visitor-serving uses, but only if the demand for such uses is not being met elsewhere. Visitor-serving development must also be consistent with the other resource policies of the Coastal Act. For example, visitor-serving facilities that might qualify for the siting exception of section 30250(c) must still be consolidated as much as possible to minimize impacts to coastal resources.

    Overview of North Coast Recreation

    Coastal recreation is one of the most important resources of the North Coast. Although Hearst Castle is often highlighted, the relatively undeveloped rural coastline and pleasant climate of the North Coast rivals other rural and scenic areas of the California Coast (see Visual Resource Findings). The tourist economy is generally strong, and a wide range of coastal resources is available between Hearst Castle and Cambria.

    There are two state beach parks in the North Coast planning area. WR Hearst Memorial is an eight acre beach providing day use only. It is located on San Simeon Bay, just below Old San Simeon. San Simeon State Beach is an important camping and day use beach for visitors to the North Coast, including Hearst Castle visitor traffic. The campground currently has 233 campsites, which are heavily used in the summer months. Recent figures for July and August show occupancy of 80% and 90% respectively; and State Parks has stated that visitors are being turned away on the weekends between Memorial Day and Labor Day. As dicussed in the Access findings, San Simeon State Beach provides excellent shoreline access from just south of San Simeon Acres to Cambria and Shamel Park.

    There are also a variety of overnight accommodations in the North Coast Area. There are at least 20 motels in San Simeon Acres, with a total of 706 units. Cambria has 28 motels with 669 units, in addition to many Bed and Breakfast and house rentals. There are currently only 43 total motel units in the rural area of the North Coast. Table 5 presents the trends, including future buildout, of overnight visitor accommodations. As shown, the number of overnight units has more than doubled in the last fifteen years. A similar doubling is anticipated over the next twenty years. The County also estimates a current average annual occupancy rate of 55% in the North Coast planning area.

    Table 5. North Coast Overnight Visitor Accommodation Trends

    Year

    Rural Area

    San Simeon Acres & Cambria

    TOTAL

    Increase

    1982

    34

    642

    676

     

    1997

    43

    1375

    1418

    110%

    New

    700*

    1049

    1749

     

    Total

    743

    2424

    3167

    123%

  • * 650 of these new units are proposed on the Hearst Ranch. As modifed herein to allow 375 units, the actual increase at buildout would be 100% for the Planning Area.

  • Visitor trends for the North Coast are well-indicated by the attendance at Hearst Castle. As shown in Figure below, visitors peaked in the late 1980s at over a million visits a year. According to Department of Parks and Recreation, this number represents the end of a fairly regular upward trend since the opening of Hearst Castle in 1958. However, attendance has since dropped significantly, and only more recently has it begun to level off. The same general trend is apparent in visitor data for WR Hearst Memorial State Beach.

    Issues and Analysis

    1. Location, Scale, and Character of Hearst Resort Development

    As discussed in the Development Findings, visitor-serving development on Hearst Ranch has been proposed since the late 1970s. Originally, the Hearst Corporation proposed a five phase development which, in addition to the four phases currently envisioned, also included a resort development at Ragged Point/San Carpoforo, at the northern end of the planning area. The total number of units proposed was 900; and two golf courses were planned. In its initial review, the Commission staff originally recommended that both the Ragged Point and the Pine Forest facility, as well as both golf courses, be deleted as inconsistent with the Coastal Act. In addition, staff analysis indicated that 900 additional rooms was not warranted in the North Coast planning area, given that this would bring the total number of overnight accommodations to 2,162 for the 35 miles between Cayucos and Monterey County. After a series of negotiations, between the County and the Commission, the Hearst resort proposal was zoned down to 650 units; the San Carpoforo resort was deleted, and the Golf course at the Pine Forest was deleted.

    In the most recent round of planning at the County level, the San Luis Obispo County Board of Supervisors initially downzoned the Hearst proposal again, reducing the total number of units to 500. The Board also moved the San Simeon Point resort complex off of San Simeon Point, and once again eliminated the Pine Forest facility. This action took place in December of 1996. In June of 1997, a reconfigured Board of Supervisors revisited the planning decisions of the North Coast Update, and changed the total number of allowable visitor-serving units back to 650 (150 to 350 at the Staging Area; 50 at Old San Simeon; 250 near San Simeon Point; and 250 at the Pine Forest Location; in no case exceeding 650 total). More detail is provided in the Development findings.

    Conformance with Coastal Act

    As discussed above, the Coastal Act expresses a clear preference for visitor-serving development that maximizes recreational opportunities for "all the people" (section 30210). Section 30213 protects and provides for lower-cost visitor-serving facilities and it states a clear preference for public recreational opportunities. Section 30222 also states a preference for visitor-serving facilities that enhance public opportunities for coastal recreation. In other words, section 30222 gives some preference to those commercial uses that support the public’s enjoyment of coastal recreational activities. Examples of this type of visitor serving use might include a scube rental/supply near a popular diving area, or overnight accommodations near an area with many coastal trails attractive to hikers and beachcombers.

    At the same time, the Coastal Act requires careful balancing of recreational and visitor-serving development with other coastal resources. Thus, section 30221 requires the reservation of oceanfront land for recreational uses, unless the demand for such activities is already being met in the area. Visitor-serving facilities must also be concentrated consistent with section 30250, and subordinated to agricultural and coastal-dependent uses.

    From a recreational policy perspective, the County’s proposed location and intensity of visitor-serving development on the Hearst Resort is not consistent with the Coastal Act. First and most apparent, as discussed in the Development Findings, the Pine Forest resort proposal is not consistent with section 30250(c), which limits visitor-serving facilities to isolated nodes of development or points of attraction such as Old San Simeon or San Simeon Acres. A more appropriate location for such a facility for example would be immediately adjacent to and inland of San Simeon Acres, assuming that agricultural land could be converted,and all other resource constraints could be overcome.

    Second, although it is appropriate to site new visitor-serving development within the vicinity of Old San Simeon, this siting must be consistent with other resource protection policies of the Coastal Act. Thus, the Coastal Act’s preference for visitor-serving facilties does not equate to a carte blanche exemption of such development from the policies that protect viewsheds and environmentally-sensitive habitat, agricultural land uses, and archeological sites; or that require the minimization of geological hazards. Once again, as discussed in the Development and other resource findings of this report, the collective operation of the resource protection policies of the Coastal Act limit the appropriate development envelope around Old San Simeon to the 100 acres shown in Figure S1 and 2.

    Third, given the necessary concentration of resort development at Old San Simeon under sections 30250 and 30242, the total number of units allowed by the County’s plan is inconsistent with the Coastal Act, and should be reduced to a total of 375 visitor-serving units (see Development and Agriculture findings), Moreover, similar to the need to balance various land uses, the Coastal Act also requires the carefully balancing of visitor-serving impacts with the protection of other coastal resources. In Big Sur, for example, the Commission struck a necessary balance to protect the scenic resources (similar in nature and quality to those of the rural North Coast) and the unique visitor-serving experience, by limiting the total number of visitor-serving units to 300. This was for the entire 70 mile Big Sur coastline, roughly double the length of the North Coast. A similar balance is implicit in the section 30254 requirement that Highway One remain a scenic two lane road in rural areas. In short, visitor-serving development is to be encouraged, protected, preferred, etc., but not at the expense of other important coastal resources.

    In the case of Hearst Resorts, as described in the ESHA, Visual, and Public Access resource findings, too much development at Old San Simeon risks overwhelming the sensitive resources of San Simeon Point, including a relatively undeveloped cove at San Simeon, the low intensity character of Old San Simeon, critical viewsheds, dune habitats north of the Point and so forth. Ultimately, too much development would risk negative impacts from increased visitation to sensitive resources north of San Simeon, such as the elephant seal habitat at Piedras Blancas, and the various lagoons of the north coast. In addition, as discussed in the Agriculture findings, visitor-serving facilities will inevitably bring conflicts with the surrounding grazing uses as well. For a variety of reasons, then, the 375 units allowed under the Agriculture and Development findings is more in keeping with the balance between visitor-serving uses and resource protection struck by the Coastal Act.

    It should also be pointed out that limiting the number of Hearst resort units is not inconsistent with the mandate of section 30221, which requires the reservation of land for other, non-visitor- serving uses if recreational demands are being met elsewhere. As the data presented earlier suggests, it is by no means clear that certain types of middle range visitor-serving development is needed along the North Coast. As mentioned, the current annual occupancy rate for overnight accommodations in the North Coast is estimated by the County to be 55%. Although there are no doubt some higher occupancy rates which result in fewer available rooms on short notice at peak times during the summer peak seasons, the overall rate of 55% is generally considered to be low by hotel and motel industry standards. By comparison, the County of Santa Cruz enjoyed an average annual occupancy of 65% last year.

    Further evidence for the uncertain demand for visitor-serving facilities is found in the visitation data for Hearst Castle, which is no doubt ebbing and flowing with the more general trends of the economy. In addition, as the County’s buildout analysis shows, both San Simeon Acres and Cambria anticipate significant amounts of hotel and motel development that would likely compete with or be similar to the development proposed for the staging area. If a choice were to be made between new overnight accommodations currently planned for the Staging Area or additional rooms in San Simeon Acres and Cambria, the Coastal Act would clearly establish a preference for new visitor-serving in the existing developed areas without the viewshed impacts which wuld occur at the staging area. Of course, as discussed in the Development Findings, the overall type of resort development envisioned for the Hearst Ranch -- a higher end resort providing a wide range of recreational amenities, including significant public access to San Simeon Point -- is not really feasible in these locations. Thus, only some of the planned development, is more appropriately located elsewhere.

    Finally, apart from the other findings of this recommendation that restrict the Hearst Resort Development to the Old San Simeon development envelope, a more limited resort development, with lower-cost facilities mixed in (see below), is more in keeping with the preferences of the Coastal Act for public visitor-serving experiences. Rather than promoting the exclusivity of the separate private resort, the recommended modifications of this report would encourage the development of a more vital public visitor-serving destination in Old San Simeon. This site, on the shores of San Simeon Bay, one of the largest protected anchorages between Carmel and Morro Bay, is an ideal location for such a visitor-serving destination. Various user groups, facilities, and a range of accommodations would be more closely mingled. The Village concept would both consolidate, and thus limit the impact of new development at San Simeon; and also enhance the visitor-serving experience for all citizens to the maximum extent possible within the other resource constraints of the Coastal Act.

    Overall, to bring the updated NCAP into conformance with the recreational policies of the Coastal Act, the location of the Hearst Resort development, and its concomitant design, should be limited as required by other findings in this report. In addition, the County should amend its goal statements in Chapters One and Two concerning visitor-serving development, to clarify that the clear Coastal Act preference is for public recreational facilities (1-5; 2-19). In order to ensure that visitor-serving facilties allowed outside urban areas remain available to the general public and do not convert to private uses (residential, private clubs, time shares, etc.) a standard must be added to this effect for development on the Hearst Ranch. This is consistent with other Commission actions throughout the state, whereby the conversion of hotels and motels to private vacation or timeshare arrangements has been limited to promote public visitor-serving goals.

    Finally, in light of other findings in this report (Development, Viewshed) and given the wide range of uses allowable within the recreation category, San Simeon Point should be rezoned to Open Space. This zoning allows for the passive recreation and public access uses envisioned for the Point, but eliminates any uncertainty about the appropriateness of any future intensive development at this location, consistent with Coastal Act's preference for permanent protection of sensitive coastal areas.

    2. Lower Cost Visitor-Serving Facilities at Hearst Resorts

    The existing NCAP contains a requirement that low-cost visitor-serving development be provided with the Hearst Resort development within four years of the occupancy of the phase one Staging Area development. This low-cost facility must be either a 100 bed hostel, or a 50 unit campground. The updated NCAP has changed the delivery commitment of the low-cost facility to any time prior to approval of any additional phase of development. It has also prohibited the location of such facility at Piedras Blancas, which was previously indicated as an appropriate site (7-20).

    Conformance with Coastal Act

    Coastal Act Section 30213 requires that lower cost visitor and recreational facilities be protected, encouraged, and, where feasible, provided. The updated NCAP currently requires that with Phase 1 of the Hearst Resort development, a 100 bed Youth Hostel or a campground of 50 sites be constructed "prior to the approval any additional phase" of development. Generally, this requirement is an important component of the Hearst Resort development proposal. However, section 30213 clearly anticipates that where feasible, lower-cost facilities should be provided as a condition of development. As currently structured, there is no guarantee that such a facility will be provided, unless the Hearst Resort development moves beyond Phase 1. Given the economic uncertainties of resort development, as well as the multitude of resource constraints that may be anticipated with the proposed development, it is possible that an initial higher cost phase of development would be completed and established without a lower-cost facility ever being realized. In such a scenario, the Hearst development would effectively preclude lower-cost visitors from enjoying the benefits of visitor-serving development in the Old San Simeon area. This is inconsistent with the Coastal Act section 30213.

    In order to be fully consistent with section 30213, a lower-cost facility should be provided concurrent with any development in Old San Simeon. Therefore, standard 3 for the Hearst Resort Phase 1 must be modified to require the establishment of the campground or youth hostel, within one year of occupancy of any other development in the Resort envelope. Other references to the timing of the lower-cost facility should be amended as well. However, recognizing the reduction in the allowable intensity of development at Old San Simeon required by these findings, it is also appropriate to reduce the number of required Youth hostel units to 60. The allowable "footprint" for such a development -- 15,000 sq.ft. -- should be more than adequate for such a facility.

    Finally, in order to be consistent with the other development and resource findings of this report, the NCAP should be modified to require that the Youth Hostel, if built, should be sited within the Old San Simeon development envelope. This will also support the larger public visitor-serving enhancement goals of the Coastal Act.

    3. Golf Courses

    The current NCAP envisions an 18 hole resort style golf course located to the immediate north of Old San Simeon. However, the updated NCAP includes the conversion of an additional 60 acres of agricultural grazing lands to accommodate a larger development envelope for the golf course. Apparently more recent assessment of other resource constraints, versus the needed acreage for a fully-competitive 18-hole golf course, has dictated such a request.

    The NCAP update, though, also encourages the Hearst Corporation to come back for an additional LCP amendment that would allow an even larger conversion of agricultural lands to accommodate a 27 hole, "world class" golf course. Since the submittal of the NCAP Update to the Commission, the Hearst Corporation has submitted an application to the County to change approximately 300 acres immediately north of the current proposed golf course from Agriculture to Recreation, for use as future proposed golf course. The intent is to process this submittal as a separate amendment to the County's LCP.

     

    Conformance with Coastal Act

    Visitor-serving development is a high priority under the Coastal Act. Section 30210 states that public recreational opportunities shall be maxmized. Section 30213 also expresses a clear preference for developments that provide public recreational opportunities. Coastal Act Section 30222 evinces a clear preference for public visitor-serving development that enhances coastal recreation over private residential, industrial, or general commercial development. However, it also very clearly subordinates such development to agriculture and coastal-dependent uses. In addition, the Coastal Act provides no particular mandate for private visitor-serving developments.

    The proposal for an 18 hole golf course associated with a resort is not a priority use in this clear policy hierarchy and does not serve to enhance coastal recreation. First, as discussed in other sections, the golf course will require the conversion of approximately 250 acres of agricultural grazing lands that have not been shown to be infeasible for continued agricultural use (see Agricultural findings for more detail). Second, the golf course use itself is inconsistent with the visual resource protection policies of the Coastal Act (Visual Resource findings). Third, according to the 1982 Hearst EIR, it may use almost as much water as currently supplies the entire town of Cambria in an area of very limited and uncertain water supplies (see Development findings). Fourth, it is unlikely that the type of golf course envisioned by the Hearst Corporation would approximate a public recreational facility that serves a wide range of visitors. Nor can it be said that a golf course enhances coastal recreation, although a coastal location may enhance the golf course. Thus, a golf course cannot be considered a type of commercial visitor serving use given limited priority under section 30222. As discussed in other sections, therefore, the golf course should be deleted as inconsistent with the broad goals and specific resource protection policies of the Coastal Act.

    Similarly, as mentioned, the County has encouraged the Hearst Corporation to come forward with an additional LCP amendment that would convert some 300 acres of agricultural land to recreational use. This change would allow for the construction of much larger, 27 hole golf course facility. In light of the findings made in this staff recommendation, references to this additional land use change and potential golf course, as well as any other references that imply support for a golf course facility, must be deleted from the NCAP.

    4. Miscellaneous Recreational Land Use Changes

    This section briefly analyzes several miscellaneous recreational land use changes for conformance with the Coastal Act.

    Camping Facilities - Location criteria.

    The County has proposed that no new camping, including non-recreational vehicle camping, occur on the west side of Highway One north of Cambria. Although the restriction on recreational vehicles is appropriate, particularly given the visual resource findings of this report, low-intensity, non-vehicle camping may be appropriate between the Highway and the shoreline. To preclude such opportunities for low-intensity, low-cost visitor-serving activities would not be consistent with the Coastal Act. Accordingly, these standards should be revised to prohibit only recreational vehicles west of Highway One (see Modification 99).

    Former Cambria Air Force Station.

    Non-recreational uses should be deleted from the standard for the Cambria Air Force Base. No findings have been made to support such a change, inconsistent with the Coastal Act's preference for visitor-serving development. The Base has previously been a target for public acquisition, and recreational visitor-serving uses should continue to be a policy goal of the NCAP. This is particularly true given the lack of any visitor serving uses on the Harmony coast. In addition, it is not clear that allowing such uses as single family dwellings is appropriate land use in this location. Such potential changes in land use are more appropriately accomplished through a zoning change, not through a spot amendment of the allowable uses on a given site. (see Modification 104)

    Piedras Blancas Lighthouse Limitations on Use.

    The NCAP has eliminated a wide range of low intensity public recreational uses as well as the possibility of a Youth Hostel being located at Piedras Blancas Lighthouse. Although the removal of the Hostel is consistent with other findings in this report, particularly the visual resource and Development findings, the removal of low intensity visitor-serving uses is not consistent with the recreational and public access policies of the Act. Accordingly, low intensity, passive recreation and camping should be allowed at this site. In addition, as detailed in the ESHA findings regarding the Elephant seal, this is the best location on the coast for a public observation and interpretive facility with repect to this resource--and should e considered as a gateway public contact station for the Monterey Bay National Marine Sanctuary. Therefore, this specialized, resource-dependent kind of use needs to be clearly allowable (see ESHA findings and Modification 105).

    Moonstone Beach.

    Non-recreational land uses such as Multi-family and single-family dwellings should be deleted from the limitation standard for Moonstone Beach. Such potential changes in land use are more appropriately accomplished through a zoning change, not through an spot amendment of the allowable uses on a given site. In addition, given the resource constraints in Cambria, particularly water, such changes are not consistent with the development policies of the Coastal Act at this time. Visitor-serving recreation is also a priority use under the recreational policies of the Coastal Act(see Modification 130).

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     Suggested Modifications to LCP Amendment