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Scenic Resources

Applicable Coastal Act Policies

Coastal Act Section 30251 provides for the protection of the scenic and visual qualities of coastal areas. Permitted development shall be sited and designed to protect views of and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the character of surrounding areas, and, where feasible, to restore and enhance visual quality in visually degraded areas. New development in highly scenic areas shall be subordinate to the character of its setting.

Additionally, Coastal Act Section 30253(5) requires that new development be protective of special coastal communities which, because of their unique characteristics, are popular destination points for visitors.

Overview of the Principal Visual Attractions

By almost any standard, the North Coast Planning Area of San Luis Obispo County would have to be regarded as a scenic resource of great public importance. An unspoiled shoreline with hundreds of coves, dozens of uncrowded beaches, rocky headlands and clean blue water stretching to a far horizon unmarked by oil rigs or air pollution, together comprise one of California’s premier natural wonders. This spectacular shoreline is backed by a series of coastal terraces, rising to the foothills and then the high ridges of the Santa Lucia Range.

Open rangelands, including coastal prairie grasslands, oak savannas, pine forest meadows and grassland-covered upland slopes, are the predominant vegetative cover. In spring, these areas are mantled in the lush green of new growth, followed by massed displays of California poppy, lupine and other native wildflowers. Later, these same grasslands are toasted to a golden brown, providing rich contrast to the somber, dark, ever-green forests around Cambria. The town of Cambria itself is an attraction: its many cottages, artistic roots, small-scale architecture, low-key lifestyle, all in the woodsy context of Monterey pine forest, remind many (who are old enough to remember) of Carmel before crowding, congestion and commercialism all took their toll.

In recognition of the scenic values of this part of San Luis Obispo County, the State Legislature, pursuant to the 1976 Coastal Act, placed the coastal zone boundary a full 5 miles inland from the shoreline. Especially noteworthy features include the southern tip of the Big Sur Coast landform and the wide open spaces of the Hearst Ranch. Threaded together by Highway 1 as it reaches out from Cambria, these areas are indeed "The Gateway to Big Sur." More subtle, but still important as scenic resources are the Cambria Pine Forest (including the landmark Scott Rock), the rural Harmony Coast, and the rural vistas seen along State Highway 46 as it descends from its jump across the Santa Lucia Range.

These scenic delights, most fortunately, can be enjoyed from the comfort of a tour bus or one’s personal automobile -- or for the more vigorously inclined, by bicycle. The favored vantage point is State Highway Route 1, which runs the length of the planning area (a distance of 34 miles). It features numerous unimproved turnouts, various improved vista points, and several beach accessways for more leisurely viewing. Public beach areas are another important vantage point, as are the connecting arterial State Highway 46, local public roads such as Santa Rosa Creek Road, and the ridgetop perch of Hearst Castle itself.

Big Sur Gateway

The southern approach to Big Sur follows the low coastal bluffs northwards from Cambria, past native pine groves, San Simeon Acres, then through the Hearst Ranch, past the existing Piedras Blancas Motel and on to Ragged Point. Key portions of this highly scenic 27 mile drive are highlighted below.

Ragged Point Area

The highly scenic Big Sur Coast is an internationally known visitor attraction. As Highway 1 makes its way through the rural countryside northwards from Cambria, for a good many miles it approaches the Big Sur Coast by way of the gently rolling coastal terraces which characterize the seaward perimeter of the Hearst Ranch. Finally reaching and crossing the canyon of San Carpoforo Creek, the highway abruptly departs the Hearst Ranch. Simultaneously, the visitor encounters a much bolder landform, which suddenly requires the road to execute a series of short turns and steeper gradients.

This, then, is the isolated Ragged Pt. area -- which, from a landform perspective, is part of the 90-mile Big Sur Coast. What is not commonly appreciated, is that the southern 3 miles of the Big Sur Coast are located in San Luis Obispo County. Here, the continent seems tipped on edge. Highway 1 clings to cliffs high above the sea. All is steepness -- slopes of 30%, 60%, even 100% gradient predominate. Mountains rise without pause from the sea, soaring over 2,000 ft. to the heights of the Mt. Mars-Bald Top crest in surprisingly little horizontal distance.

In contrast to the Hearst Ranch, the land between San Carpoforo Creek and the Monterey County line is broken into a number of smaller holdings. A handful of small, relatively modern residential structures are sprinkled along the highway. Ragged Point Inn occupies an anamolous coastal terrace fragment, providing the last chance for gasoline, food, gift shop, restrooms and shoreline access for a good many miles. The inn provides 20 guest rooms, with 28 more permitted; its 32 seat restaurant can handle approximately 60 more with patio seating. Most of the surrounding slopes are in private ownership, although the recently-acquired Sur Sur Ranch will extend the lands administered by Los Padres National Forest a short distance into the San Luis Obispo County coastal zone.

Hearst Ranch

The vast de facto open spaces of the approximately 77,000 acre Hearst Ranch (approximately 48,000 acres in the coastal zone) constitute an important scenic resource of statewide significance in their own right, as well as comprising the southern approach to the more rugged Big Sur Coast landform. The typical west-east landform section on the Hearst Ranch commences at the shoreline, where a low coastal bluff marks the seaward edge of a gently rolling coastal terrace. Inland from the primary coastal terrace, increasingly steeper and more massive hills and ridges culminate at the crest of the Santa Lucia Range. This crest defines the watershed divide between the Salinas River watershed and the smaller canyons and drainages, which make their way down the westerly slope of the range.

This entire sweep of unspoiled landscape can be viewed by the public in a continuously unfolding panorama along Highway 1. About 16 miles of the highway fall within the Hearst Ranch. It can also be enjoyed from other public vantage points, including highway turn-outs starting at the Monterey County line and vistas seen by visitors to Hearst Castle.

These views are often said to illustrate what "Old California" looked like before it was developed and urbanized. Even a relatively small amount of visible modern development would under these circumstances be intrusive, and would significantly degrade the sense of an essentially innocent landscape. Therefore, having observed that vast areas of the Ranch comprise an outstanding scenic resource, it should also be noted that the Ranch has a great abundance of hidden canyons, as well as knolls, ridges and groves of trees, which could be employed to conceal any new development which might be approved in the future.

Current LCP Policies

Basically, these call for "minimizing" the visual impact of new development, through building site selection "where hills and slopes would shield development." The general Areawide Standard, for structures west of Highway 1, limits height to 22 ft. The Ragged Pt. area is currently designated Rural Lands, which would allow subdivision at a density of 20 acres per unit. There are roughly 1,800 acres of non-Hearst lands here.

On the Hearst Ranch most of the acreage is designated as Agriculture. However, 150 motel units are allowed at the Staging Area; and, resort developments are allowed on San Simeon Pt., and in front of the native pine forest near Pico Creek. An 18 hole golf course is allowed between Highway 1 and the sea, north of San Simeon Pt.

Proposed Amendment

Area-wide viewshed standards would apply; these call for minimizing visual intrusion, avoiding development which would obstruct views of the shoreline from public viewpoints, adapting structures to fit hillside sites (rather than altering the landform to create level sites), and prohibiting development and grading on slopes greater than 30%. A visual impact analysis is required for new development visible from Highway 1. Development "which would in any way degrade the scenic qualities of major views and vista points" would be prohibited.

However, the 14 ft. height limitation for additions to existing visitor serving development in the Ragged Pt. area is removed, as is the requirement that non-visitor serving development be located on the inland side of Highway 1. The land use designation for the Ragged Pt. area would be changed from Rural Lands to Agriculture. This means larger minimum parcel size (320 acres for grazing lands), but more kinds of uses allowed. At the Piedras Blancas area, the maximum site coverage standard (40%) is also deleted.

On the Hearst Ranch, resort development is shifted off San Simeon Pt., to the adjacent area. Substantial additional resort development is allowed at the Staging Area, seen in easterly views from Highway 1. Hotel/motel height limits are raised from the present 25 feet to 30 feet. Restaurant and retail height limits are raised from 16 ft. to 25 ft. Exceptions to the height limit are allowed for non-habitable structures such as clock towers.

At Old San Simeon, in the Commercial Retail designation, the height limit is raised from 18 to 25 ft. In the adjacent Recreation category, the hotel height limit is retained at 30 ft., but once again an exception to the height limit is allowed for non-habitable architectural elements such as a clock tower.

Issues and Analysis

1. Protecting the Critical Viewshed.

The 120 mile shoreline drive along State Highway Route 1, from Cambria to Carmel, is one of the nation’s most spectacular scenic treasures. Yet, because substantial portions of this cherished landscape are entrusted to private ownership, development-siting policies appropriate to the reality of private stewardship are needed.

Experience has shown the difficulty of applying view protection policies which only require that projects be designed to "minimize impacts on public views." What does "minimize" mean? What can regulatory agencies reasonably require by way of redesign? Can the developer be required to completely conceal his/her project? Can we trust future landscape screening to (hopefully if not reliably) screen the project? These questions are debated endlessly across the nation whenever local regulatory efforts are applied to the problem of public view protection.

Decision making bodies tend to become frustrated by such fuzzy-edged standards, conceding visual instrusions because there is no clear minimum performance criterion. Often as not, the result is further "cluttering" of public views. It is evident that such a standard is too subjective where preservation of public views is the overriding concern.

In contrast to this elsewhere-common experience, the Big Sur Coast Land Use Plan (Monterey County LCP) contains an objective standard: all new development must be hidden from public view. This standard is unambiguous - either you’ll see it, or you won’t. (Certain partly-developed locations and certain categories of development which require a location in public view are exempted.) This policy states:

3.2.1. Key Policy

Recognizing the Big Sur coast’s outstanding beauty and its great benefit to the people of the State and Nation, it is the County’s objective to preserve these scenic resources in perpetuity and to promote the restoration of the natural beauty of visually degraded areas wherever possible. To this end, it is the County’s policy to prohibit all future public or private development visible from Highway 1 and major public viewing areas (the critical viewshed)... This applies to all structures, the construction of public and private roads, utilities, lighting, grading and removal or extraction of natural materials.

3.2.2. Definitions

1. Critical viewshed: everything within sight of Highway 1 and major public viewing areas including turnouts, beaches and the following specific locations...

3.2.3. Critical Viewshed

A. Policies

1. In order to avoid creating further commitment to development within the critical viewshed all new parcels must contain building sites outside the critical viewshed...

State Highway Route 1, from the point where it is joined by Highway 46 in Cambria, comprises the highly scenic southern approach to the Big Sur Coast. Certain areas are already committed to, or suitable for, new development. These include Cambria, San Simeon Acres, and the Old San Simeon area. Certain types of development, such as agricultural improvements, public access facilities, and navigational aids can not be feasibly concealed from public view. However, if these conditions are taken into account (as they are in the Monterey County portion of the Big Sur Coast), it would be possible to preserve the existing rural character of this "critical viewshed" by banning all new developments which would be seen from Highway 1, improved vista points, and public beach areas.

Accordingly, it is concluded that the most appropriate, and most effective way to protect that portion of the Big Sur Coast landform within San Luis Obispo County -- together with the approach route northwards from Cambria -- is through the adoption of a "critical viewshed" policy, parallel to Monterey County’s.

Feasibility. Is it feasible to establish such a policy, consistent with Constitutional requirements with respect to the "takings" issue, in San Luis Obispo County? The answer depends, in part, on the possible problem of vacant "viewshed" lots. Because the total number of parcels is, as explained in the Development Findings, uncertain, only the following informed estimates are available.

At the southern end of the Big Sur Coast, between San Carpoforo Creek and the Monterey County line, an estimated maximum of 26 parcels are located on the seaward slope of Bald Top Mountain. An additional estimated maximum of six viewshed parcels are located between San Simeon Acres and Cambria. Scott Rock is located on a single parcel, on the north side of Santa Rosa Creek Road (old Highway 46) immediately east of Cambria. Although not yet field-verified, it is believed that all of these parcels are either already developed, or have suitable locations for concealing new development behind existing trees or landforms.

The only other rural area within the potential viewshed are the expansive ranchlands and shoreline between San Carpoforo Creek and San Simeon Acres (Pico Creek). Here, most of the land is in a single ownership: the Hearst Ranch. This approximately 77,000 acre ranch offers abundant opportunities for locating new development outside the public viewshed along Highway 1 and the shoreline. The parcel containing the old San Simeon townsite on the shoreline of San Simeon Bay, shown on the County Assessor’s Parcel map as "Town of San Simeon," would lie at the core of the area where future visitor serving development will be directed -- and is therefore not counted as a "viewshed parcel."

On a non-Hearst inholding located north of Piedras Blancas Point, an existing 14-unit motel is located on the west side of Highway 1. On the east side of the highway at this same location are four non-Hearst vacant parcels, each 5 acres in size, which may constitute "viewshed lots." However, it is likely that through consolidation and resubdivision, four residences could be located within this 20 acre area without impacting public views.

North of Hearst Ranch: Ragged Pt. Area. Protective policies for scenic resources are discontinuous and not coordinated at the San Luis Obispo-Monterey County line. North of the line, State Highway Route 1 is designated a State Scenic Highway, and is identified as "highly scenic" in the LCP. Monterey County’s "critical viewshed" policy prohibits new development which could be seen from Highway 1, and backs it up with a TDC compensatory program. Expansion of existing resorts and commercial development is limited.

San Luis Obispo County policies are not rigorous enough to protect public views towards and within the Big Sur Coast landform. Development on existing vacant lots as well as new/expanded replacement development on already-improved parcels could have severe impacts on the visitor experience of Big Sur Coast. Road and building site grading, advertising signs, residential development, and above-ground utility and antenna development are primary concerns. The LCP encourages, but would not in all cases require new development to locate out of view, to modify heights, or to screen with landscaping or berming. There are no specific limits on the size of "monster houses" in the viewshed. In contrast to the adjoining Big Sur Coast LUP, there is no specific requirement that the number of residential units per parcel be limited to one. There is no prohibition on adding to the existing inventory of "viewshed lots" (those which have no place to conceal new development). Nor, are there any special standards that would limit the number of additional resort units at Piedras Blancas Motel and Ragged Point Inn.

Issues Specific to Hearst Ranch. The LCP as it presently exists does not require new development to be hidden from public view. New development projects contemplated by the Hearst Corporation include resort structures, road construction, and a golf course, all in close proximity to the shoreline and in public view from Highway 1. The focus of resort development would be San Simeon Point, the forested headland comprising the best-known scenic highlight on the Hearst Ranch coast.

As originally certified, the LCP required that the undeveloped balance of the Hearst Ranch be placed in a scenic easement, upon development of the resorts allowed in the LCP. This measure was essentially a quid pro quo trade-off intended to mitigate the visual impacts of the allowed new development. This requirement was previously deleted from the LCP. (See Agriculture Findings).

Subsequently, in 1996 the Board of Supervisors adopted revised resort development standards for the Hearst Ranch which would reduce the maximum allowable units from 650 rooms to 500 rooms. They also required that the entire 60 acre peninsular projection of San Simeon Point be protected by requiring the resort development to be shifted closer to Highway 1, where it could be better screened by existing groves of planted pines, cypresses and eucalyptus. This LCP amendment request was further modified in June 1997, to once again allow a total of 650 units; to encourage the 250 units of the site of the proposed Pine Resort to be shifted to the Staging Area and Old San Simeon sites; and to restore the proposed San Simeon hotel from 100 units to 250 units.

The hotel at San Simeon, whether 100 units or the currently proposed 250 units, would likely protrude either above or beyond the existing trees, thereby impacting seaward views at this highly scenic location. The associated 18-hole golf course would compound this impact. Additionally, the two resort complexes on the east side of Highway 1 (downslope from the Hearst Castle staging area and at the Pico Creek pine grove) would also intrude on public views from Highway 1. Finally, the commercial complex planned for the Old San Simeon area could, if not carefully designed, significantly alter the existing charm of this historic "one-horse" outpost.

The potential harm to scenic resources is subtantial, particularly considering the presently unspoiled character of the Hearst Ranch landscape. No mitigation measures which would compensate for these impacts are offered in the LCP. Suitable mitigation measures would include a requirement that all new development be hidden from public view. Accordingly, the highly visible site of the proposed "Pine Resort" complex at the southern end of the Hearst Ranch should be deleted, as protection of the adjacent grove of native Monterey pine would not allow the project to be shifted into the forest.

In those areas such as Old San Simeon where there is already a commitment to develop in public view, but existing landforms or forest are not adequate for concealment, landscape screening should be installed and permanently maintained so as to hide any new development. Alternatively, unavoidable viewshed intrusions could be offset with a scenic easement which would prohibit all other new development in public view, except for necessary public benefit projects and needed agriculture facilities.

Hearst Ranch Scenic Resource Protection Alternatives. Beyond Old San Simeon, a variety of strategies are available for protecting the magnificence of public views enjoyed from Highway 1 and other locations within the Hearst Ranch. Those alternatives considered include the following:

a. Existing North Coast Area Plan (NCAP) text -- essentially, calls for minimizing visual impacts where feasible. No prohibition on creating new viewshed parcels. This alternative is not acceptable, because it does not assure that the critical viewshed is protected from further cluttering; and, because the existing problem could be exacerbated through the creation of more viewshed lots.

b. Submitted NCAP Update text, per this amendment -- no substantial improvement over existing NCAP text, except provides generalized Areawide Viewshed Protection Standards and moves resort development off San Simeon Pt. Relaxes height restrictions somewhat, and allows non-habitable components such as clock towers to extend above the height limit; therefore, not as protective as existing NCAP text in this respect. Overall, unacceptable because it fails to provide the strongest possible public viewshed protection measures for the Highway 1 corridor -- which would be the only appropriate response for this nationally-significant scenic resource.

c. Delete the "Pine Resort" development site -- each of the three Hearst Resort development sites shown in the NCAP Update will impact public views from Highway 1 and public beach areas. The Pine Resort is shown for a location elevated well above and inland from Highway 1. It would impose an extensive development cluster in the foreground of a highly scenic, completely unspoiled view from Highway 1 to the northernmost of the native Monterey pine groves in the Cambria stand. A new, unavoidably visible access road would be constructed for access from the highway. Therefore, this development is decidedly inconsistent with the protection of the critical viewshed, and has no place in an LCP which needs to rigorously protect the highly scenic southern approach to the Big Sur Coast (or from the perspective of the southbound traveler - the grand finale!)

d. Delete the "Staging Area Resort" development site -- once again, this resort would be elevated above and inland from Highway 1. It would impose an extensive development cluster on a second-tier marine terrace, located in the foreground of a view from Highway 1 and the coastal bluff at Old San Simeon towards the distant ridgeline surmounted by Hearst Castle.

A presently attractive, undeveloped area in public view would be converted into a built-up complex, which would require an exception to any "critical viewshed" protection policy and establish an uncomfortable precedent for other parts of the Big Sur Coast scenic corridor. Mitigating factors include: a) its immediate proximity to the already partly-visible, partly-screened staging area for the Hearst Castle State Historical Monument; b) no need for development of a new access road in the Highway 1 viewshed; and, c) ease of installing an earthen berm and/or landscape screening so as to make the project less visible from Highway 1 and the shoreline. But none of these considerations are sufficient to offset the objections listed above. Also, earthen berms could be considered an "alteration of natural landforms," which is discouraged by Coastal Act Section 30251. And, landscape screening is effective only if it is properly maintained, and if the temptation to excessively trim or thin for "improvement" of views from the resort can be resisted. Therefore, concentration of new resort development at a single, already partly-developed site -- i.e., Old San Simeon --is necessary to achieve to achieve conformance with Coastal Act Section 30251.

e. No new resort development -- this alternative would most clearly conform with Coastal Act requirements. This would eliminate all hotel development in the vicinity of Old San Simeon, in addition to the other two sites mentioned above. It has been previously established that no water supply with an environmentally safe yield has been identified for any of the resort developments. In view of the existing visitor-serving developments and development potential in Cambria and at San Simeon Acres, no need has been established for new, isolated resort developments. And, in terms of public view protection, this alternative would provide for maximum conformance with Coastal Act Section 30251’s mandate to protect the visual qualities of coastal areas, and in highly scenic areas, to insure that new development is subordinate to the character of its setting.

On the other hand, as discussed in the Development and Recreation Findings above, this alternative would mean that the opportunity to secure certain public benefits -- such as access improvements from Old San Simeon to the beach at San Simeon Bay, and blufftop public access around San Simeon Point -- would not be provided in conjunction with new development. Consideration must also be given to other factors for the Old San Simeon area, including: a) historic identification as a development site, starting with the "Town of San Simeon" plat; b) its existing partly developed character, with a scattering of existing structures and large amounts of introduced non-native windbreak vegetation (in contrast to the other resort sites, which remain in a natural condition); c) the relative ease of screening new development through installation of landscape screening; and, d) the limited exception for "selected points of attraction for visitors" as referenced by Coastal Act Section 30250(c) for visitor-serving facilities (see Development Findings above).

f. Delete golf course -- standard 18-hole golf courses comprise artificial landscapes with manicured tees and greens, turfed fairways, and man-made "hazards." A "links-land" course is similar, but the visual impact is moderated because more extensive areas along the fairways are left in a natural condition. In either case, the proposed golf course north of San Simeon Pt. will impose a jarring artificial component on seaward views from Highway 1, as well as from public beach areas nearby and public vista points further north. Above the Monterey County line, the Big Sur Coast LUP explicitly prohibits golf course development, as an inappropriate type of use. This protective standard should be consistent along the entire Big Sur Coast drive, Carmel to Cambria.

g. Extend Critical Viewshed policy -- the existing Critical Viewshed policy for the Big Sur Coast, in operation since 1987 north of the Monterey County line, would be extended southwards to Cambria. Under this objective standard, new development in view of Highway 1 and public areas along the shoreline, would be prohibited. Exceptions would be made for certain types or locations of development, particularly those which can not be feasibly located elsewhere. New viewshed lots could not be created.

This alternative is simply a locational and/or design standard for such development as could be accommodated on the Hearst Ranch consistent with other LCP policies. Because the Hearst Ranch has many canyons, knolls, ridges, swales and groves of trees to conceal new development, only an estimated maximum of 25% of its potential buildable acreage within the coastal zone would be affected by the adoption of such a Critical Viewshed policy. Existing ranch roads, barns, airport hangers and other existing development would be allowed to remain.

Conformance with Coastal Act

The optimum combination of measures for protecting the highly scenic landscapes of the Hearst Ranch, is to concentrate new resort development at one location -- the Old San Simeon area on the blufftop at San Simeon Bay. This would be coupled with deletion of the Pine Resort and Staging Area Resort complexes, relocation of the resort units adjacent to San Simeon Pt., deletion of a golf course seaward of Highway 1, and designation of San Simeon Pt. as Open Space (60 acres), limitation of uses in the Agriculture land use designation to actual agriculture and public benefit uses; deletion of the obsolete Recreation designation on the south side of San Carpoforo Creek (Ragged Pt. proper), and adoption of the Critical Viewshed policy (with agricultural and public access exceptions). The NCAP’s present height restrictions would be retained.

More broadly, the best policy for protecting the North County’s rural, highly scenic public views as seen from Highway 1 and the shoreline, is to require that all new development be completely hidden from view. This prohibition would not apply within those townsites already earmarked for development, nor to Coastal Act priority uses which would necessarily require a location in public view. This approach is feasible because: a) there are only a few (if any) vacant rural parcels which lack an obvious place to conceal a new residence; and, b) the majority of visible land is located within a single ownership (the Hearst Ranch) with a great many opportunities to concentrate development away from public view -- or at a suitable townsite. Implementation measures, including but not limited to resubdivision, transferred development credits and land exchanges, can be identified to address any situation where the owner of a developable property lacks a suitable means to conceal a reasonable economic use.

Therefore, in order to appropriately respond to the mandate of Coastal Act Section 30251 to protect the highly scenic areas of California’s coast, the San Luis Obispo County LCP needs to include this "critical viewshed" policy. Lacking such a prohibition on siting new development in public view, the North Coast Area’s most scenic visual resources are exposed to further encroachment and intrusion, and the LCP is not in compliance with Coastal Act Section 30251. The potential problem is greatly aggravated by the fact that the LCP currently does not prohibit divisions of land which would add to the inventory of vacant viewshed lots. These deficiencies can be corrected through adoption of the "critical viewshed" policies contained in the Suggested Modifications, attached.

2. Cambria Pine Forest

Extends from immediately north of Pico Creek, to just south of Cambria Air Force Station, and inland past a highly scenic geologic formation known as Scott Rock. The pine forest is partially subdivided; portions within Cambria are partially developed, on high density antiquated residential subdivisions. Continued development of these antiquated subdivisions, including an estimated 5,000 or more vacant miniature lots (typically, 25’x 70’), will collectively result in deforestation of substantial areas of Cambria. This will result in the loss of much of the pine forest context which presently defines Cambria’s unique community character.

The LCP presently contains a TDC program for the purpose of addressing the problem of too many existing small lots (which means no room for trees). However, this program is very limited in what can be achieved. The NCAP update contains a sophisticated suite of amendments, including a new "Monterey Pine Forest Habitat Combining Designation," and a proposal to create a communitywide "Forest Management Plan". These measures will substantially increase the odds in favor of protecting the urban forest as a visual resource - but only where the lots are large enough to support tree growth.

Apart from the shoreline and the pine forest, the most noteworthy scenic landmark around Cambria is Scott Rock, a dramatic natural rock formation which juts skyward from the surrounding Monterey pine forest. This vulnerable scenic highlight occupies a single privately-owned parcel immediately to the east of the Cambria urban limit (USL/URL) line. However, it is most prominent in views from Main Street (portions comprising old Highway 1, northward from its intersection with new Highway 1) and Santa Rosa Creek Road (old Highway 46).

Conformance with Coastal Act

Cambria is a special coastal community, which because of its unique character, comprises an increasing popular visitor destination. Preservation of the forest context is clearly vital to Cambria’s community character. The County has recognized that the LCP’s present policies in this regard are inadequate, and has proposed a comprehensive set of urban forestry standards in its North Coast Update submittal. These standards, contained in the Combining Designations section will provide the necessary basis for regulating future tree removal (and replacement) within the Cambria Urban area.

However, as detailed in the Environmentally Sensitive Habitat Areas (ESHA) section of these Findings, several shortcomings are evident. If corrected in accordance with the Suggested Modifications identified for the pine forest ESHA, the LCP will also appropriately protect the forest as a visual resource and therefore will protect Cambria’s community character as required by Coastal Act Section 30253(5). Additionally, proposals identified in the "Development" section of these Findings may result in the retirement of many of the tiny lots, thus reducing the effects of construction.

3. Protecting other scenic resources along the North Coast

Other scenic areas along the San Luis Obispo County North Coast include:

Harmony Coast

The open grazing lands along Highway 1, southward from Cambria, comprise a continuous scenic corridor with many unspoiled rural vistas, the occasional farmhouse, meandering Villa Creek, and the historic "village" of Harmony. While the foreground landscapes resemble those seen in easterly views from Highway 1 as it proceeds north from Cambria, the shoreline south of Cambria is hidden from view behind a ridge parallel to the highway. Also in contrast to the Highway 1 corridor north, easterly views are primarily of rolling hills and isolated groves, rather than the more dramatic mountain backdrop and pine forest north of Cambria.

Recent real estate and land division activity along the Harmony corridor, together with the revival of Harmony itself as a roadside tourist attraction, give cause for concern. The LCP contains no specific standards which would preclude the creation of "viewshed lots" (residentially-buildable parcels without a place to conceal future development), nor does it specifically require that new development on existing lots be screened from public view. Better standards are needed to prevent creeping urbanization. However, a strict critical viewshed policy is not recommended here because of the different, non-shoreline character of the landscape, and because screening in this area is more likely to succeed as a mitigation measure (in contrast to wind-exposed areas closer to the shoreline).

Highway 46 Corridor

This east-west connector provides sweeping ridgetop vistas of the coastal zone as it approaches Cambria. The character of the landscape is similar to that seen along the Harmony Coast. Similar standards with respect to land divisions and screening of new development are warranted for the protection of the scenic character of these rural ranchlands.

Conformance with Coastal Act

The LCP Update amendment provides much-needed new Areawide Standards for Site Planning, Design, and Building. These new standards require: a 100 ft. setback distance from Highway 1; site-specific visual impact analysis for developments visible from Highway 1; location of building sites to minimize landform alteration; design review process; shielding of night lighting; prohibition of buildings, fences, signs, landscaping which would obstruct views of the shoreline; utilization of landform features to "minimize visual intrusion"; shared driveways "where possible"; prohibition of development or grading on slopes over 30%; structural design to fit hillside sites (rather than creating level building pads); and other measures to encourage new development to be sited and designed to minimize visual impacts.

However, a few shortcomings have been noted. These standards do not prohibit the creation of more "viewshed parcels," so a specific requirement is needed to insure that all future lots have suitable development sites (and driveway locations) that are concealed from public view (or in the case of driveways, rely on existing road access). Nor, do the standards prohibit billboards or other large commercial signs. Therefore, neither the present LCP nor the proposed LCP amendments are wholly adequate to protect these important scenic resources. If modified to correct the noted deficiencies, however, the North Coast Area Plan will (upon incorporation of the Update’s amendments) represent a very substantial improvement over the present LCP standards, and will achieve conformance with the requirements of Coastal Act Section 30251.

Public Access To And Along The Shoreline

Applicable Policies

Public access to and along the shoreline is a fundamental value of the State of California. Article 10, section 4 of the California Constitution affirms the public right of way to the state's navigable waters and encourages the legislature to enact laws that give the most liberal construction to this provision. Consistent with this goal, Section 30210 of the California Coastal Act states that "maximum public access . . . shall be provided for all the people." Section 30211 states that development shall not interfere with existing public access rights to the sea; and Section 30212 requires new development to provide "public access from the nearest public roadway to the shoreline and along the coast." Section 30500 requires that all Local Coastal Programs include a specific public access component to meet these goals.

The public's right to shoreline access is not absolute, though. Coastal Act Sections 30210, 30212, and 30214 require that public access rights be balanced with other public and private concerns, including public safety needs, military security, private property rights, agricultural interests, and ecological concerns. More generally, Coastal Act Section 30001.5(c) states a basic goal of "maximiz[ing] public access . . . consistent with sound resources conservation principles and constitutionally protected rights of private property owners."

Overview of North Coast Public Access Resources

The North Coast segment of San Luis Obispo County provides a wide variety of public access opportunities, including two state beaches, numerous automobile pull-outs and vista points, and a variety of formal and informal accessways to the beach. The North Coast is also significant for its as yet unrealized public access resources. In addition, several access-related problems, including a serious conflict between public access, public safety, and management of the elephant seal population at Piedras Blancas, have developed since the County’s LCP was first approved. This section provides an overview of existing and potential public access resources in three subareas of the North Coast: the Rural North Coast/Hearst Ranch, San Simeon Acres to Cambria, and the Harmony Coast. Figures 7-1 and 7-2 present a more comprehensive inventory of existing and potential access along the North Coast. Specific access-related problems and opportunities, as well as the conformance of the North Coast Area Plan with the Public Access policies of the Coastal Act are also discussed in section C below. The Recreation/Visitor-Serving section of the staff report discusses additional recreational resources such as state parks, campgrounds, and other visitor-serving facilities, including the proposed Resort development at Hearst Ranch.

Rural North Coast/Hearst Ranch

The Rural North Coast extends approximately 16 miles, from the northern border of San Luis Obispo County south to the northern edge of the San Simeon Acres at Pico Creek . Except for the area around Ragged Point and several "in-holdings" near Piedras Blancas, the entire rural north coast is owned by the Hearst Corporation. Although this segment of the North Coast shoreline has tremendous potential as a public access resource, existing formalized access to and along the beach is limited. Developed vertical accessways exist only at the Ragged Point Inn, where a steep vertical trail, privately built and maintained, heads down to small pocket beach, and at Hearst Memorial State Beach some 16 miles south. Formal lateral access currently exists only at the state beach. There are also three developed automobile vista points on Highway One between Piedras Blancas Point and Oak Knolls/Arroyo Laguna Creek; and three pull-outs between Hearst Memorial State Beach and San Simeon Acres.

As mentioned, the rural north coast has great potential for enhanced public access. Similar to the Big Sur coastline, many feel that this area is a valuable statewide if not national resource, because of its essentially undeveloped, rural character. And while much of the rural north coast shoreline consists of steep bluffs and rocky beach, blufftop and shoreline lateral access along a significant portion of the rural North Coast would be possible were vertical accesses made available. As described by the County, "[m]ost of the coastline consists of low marine terraces with accessible beaches and coves interspersed with rocky shorelines and steep bluffs providing for a variety of passive recreation uses" (6-2). A lateral coastal trail system, similar to the coastal trail planned for in the Big Sur component of the Monterey County LCP, could also be developed for the North Coast. Such a trail would need to be inland of Highway One north of Ragged Point, and between the Highway and the edge of the bluffs from Ragged Point to San Simeon.

The potential for future formalized public access on the north coast is reflected in the numerous informal trails that currently extend from a variety of informal automobile pullouts along Highway One down to particularly attractive beaches. The legal status of these informal public accesses and associated recreational uses has not been determined, and the Hearst Corporation recorded a notice of permissive use in 1972. A wide variety of recreational uses are associated with these informal accesses, including windsurfing, fishing, hiking, kayaking, etc.. In addition, the Piedras Blancas Lighthouse facility may someday be open for public access, including low intensity recreational or interpretive facilities (see Recreation and ESHA findings) facility. Finally, the undeveloped San Simeon Point, which lies just north of Hearst Memorial State Beach, is another tremendous potential resource for low intensity, passive public access activities. Even a brief review of aerial photos reveals an extensive network of trails, including around and on San Simeon Point. Table 7 summarizes some of the major points of formal and informal access along the rural north coast. Exhibits 12 and 13 generally locate these points.

Figure 7. Formal and Informal Access along the Rural North Coast

San Simeon Acres to Cambria

This segment of the North Coast includes the village of San Simeon Acres, the town of Cambria, and the rural lands that lie in between these communities. In addition to San Simeon State Beach, which provides campgrounds, trails, and other public access amenities, existing and potential access in this segment consists of a variety of lateral and vertical accessways in the San Simeon Acres and Cambria. Recent staff field observations have determined that access along this segment is generally good. It is worth briefly discussing available access resources in eight segments along this stretch of coast. Exhibit 14 locates these access resources.

San Simeon Acres

Access in San Simeon Acres is good, the highlight is a broad beach with excellent access. The main accessway to the beach is at the end of Pico Avenue, where parking for approximately 10 cars and a stairway are located. There is a second accessway south of the Cavalier Inn. This accessway does need a conspicuous sign. There also two vertical offers-to-dedicate at the southern end of the beach which should be analyzed for future development opportunities.

San Simeon Creek north to San Simeon Acres

There is a small subdivision with a frontage road parallel to Highway One along this stretch of coast. No vertical access is available through the subdivision. There is informal (surfing) vertical access to the north of the subdivision; however, there are "no trespassing" signs posted and a fence blocks easy access.

San Simeon State Beach

State Park ownership extends from Santa Rosa Creek north to San Simeon Creek. This entire stretch is part of San Simeon State Beach, which has 201 inland camping sites, as well as trails to the beach and on the inland side of the Highway (see Recreation Findings for more detail).

Shamel County Park north to Leffingwell Landing

This contiguous sandy area is wide open for public use. It is clearly visible from Moonstone Beach Drive, and there are numerous opportunities to view the beach and ocean. Parking, trails, and boardwalks are also available; as are restrooms at Santa Rosa Creek and Leffingwell Landing. There is also a boat launch at Leffingwell Landing. The adjacent inland uses are primarily visitor-serving motels. Overall, this area provides excellent access because the beach and coast are easily accessible for the whole length via Moonstone Drive; there is good visual access; and it is adjacent to many commercial visitor-serving uses (motels).

Shamel County Park

This County facility provides a developed lawn area with picnic tables, barbeques, restrooms, parking, and direct beach access. There is a large sandy beach contiguous with the state park beach at Santa Rosa Creek. A creek crossing would be necessary at certain times of the year to cross from Shamel in order to continue on through north to Moonstone Beach and Leffingwell Landing.

Park Hill

As with Lodge Hill discussed below, this is primarily a residential enclave. The shoreline is generally reachable via cul-de-sac roads, but the coast is not visible from Highway One in this area until one is past the subdivision. The beaches here are small and seasonal, with little overall carrying capacity. Three southern street ends (Murray, Bryan, and DeVault) provide good visual overlooks, but no stairs. At the northern end of Park Hill (Worcester to just past Cambridge), a relatively new blufftop park has been built. Here there are trails and pocket beaches. The property is owned by State Parks. A blufftop trail north does ends at the top of a 25 foot bluff, which one must scramble down in order to access Shamel Beach. A stairway would be a beneficial improvement here.

West Ranch

As discussed in more detail below, lateral access along the West Ranch is currently provided by permission, with entrances at the south and north from the end of Windsor Boulevard. The Commission has received several hundred petitions concerning the informal, historic use of the trails on the West Ranch. Aerial photos also document a wide network of trails.

Lodge Hill

Access in Lodge Hill is good. Access primarily serves the neighborhood, given the configuration of this residential area. Generally, the public is not drawn to this area, in part because the shoreline is not visible from Highway One (although access is signed on the Highway). There is also a somewhat long, windy, and confusing rural road pattern to the get to the coast in Lodge Hill. Finally, the beaches here are small and seasonal, with very little capacity for public use. In Lodge Hill, 50% of the street ends are currently developed with stairways. Of these three, they are fairly well spaced laterally. One of the three is Lampton County Park, which has a parking lot, trails, bike rack, and stairway. The other stairways are located at Harvey and Wedgewood.

Rural Harmony Coast

There is little to no public access to the shoreline south of Cambria along the Harmony coast. The County's LCP describes this area as not appropriate for public access unless such use is consistent with protection of existing agricultural operations. In general, the Harmony coast shoreline is characterized by steep bluffs and few sandy beaches. The former Cambria Air Force Base is also located in this area. Although once a target for public acquisition, it is now in private ownership (see Recreation Findings for more detail) There are also three lateral access OTDs showing in official records. More research is required to determine the appropriateness of future development of these OTDs.

Issues and Analysis

1. Organization of North Coast Area Plan Access Components

Public access along the North Coast is provided for by a variety of policies and programs in four separate documents of the San Luis Obispo County LCP. The County's Framework for Planning provides general guidance on the purpose and objectives of the Coastal Accessway land use designation. The Coastal Plan Policies document contains an overview discussion of shoreline access issues; eleven public access policies to implement the Coastal Act; and an Appendix of Shoreline Access terms. The Coastal Zone Land Use Ordinances document specifies the public access requirements of the LCP through ordinance 23.04.420 and gives definitions for the terms "lateral" and "vertical" access. The current North Coast Area Plan discusses various public access goals, resource descriptions, development standards, and programs specific to the North Coast, including access dedications to be required with any future development on the Hearst and West Ranches. Finally, the official land use maps of the County's LCP identify, for planning purposes only, the general locations of existing and proposed public access along the North Coast.

The County's update proposes changes only to the North County Area Plan; the public access policies and ordinances of other LCP documents are unchanged. In the NCAP, the County has added a section of general policy goals to provide direction to coastal zone management in the North Coast Area for the "next 20 years." The goals are intended to function as "criteria to help determine consistency of a development proposal with the LUE/LCP" (NCAP 1-2). Under the general goal of preserving "open space" Goal 10(c) would "encourag[e] better access to the coast through the acquisition and development of coastal accessways, trails, and neighborhood parks, in appropriate locations" (1-7).

The County has also updated general background discussions of public access resources in Chapters Three and Four of the NCAP, including descriptions of the proposed Hearst Ranch development. NCAP Chapter Five concerning "Circulation" includes updated programmatic discussions of pedestrian, equestrian, and bike trails; recreational and coastal access signing; and general road and Highway One circulation issues. Chapter Six, which addresses the combining designations and public facilities components of the NCAP, updates the "Local Coastal Plan" designation that includes public access programs for such issues as improvement of automobile vista points, acquisition of Piedras Blancas Lighthouse, and other access improvements along the North Coast. Chapter Seven of the NCAP includes a variety of specific changes to the public access planning area standards for the North Coast. Finally, except for certain changes to road designations and new roads in the West Ranch area (see Roads findings) no changes to vertical and lateral access designations are proposed on the official circulation maps of the NCAP.

Conformance with Coastal Act Policies

Protecting and maximizing public shoreline access is a fundamental goal of the Coastal Act. To facilitate achievement of this goal, Coastal Act section 30500 requires that all Local Coastal Programs include a specific public access component. Although the current San Luis Obispo County LCP, including the North Coast Area Plan, contains a wide variety of policies, standards, ordinances, programs, and map designations, there is no single component that systematically and comprehensively organizes these public access elements. This lack of comprehensive organization is inconsistent with section 30500. More important, without a cohesive access component in the LCP or the North Coast area, it is difficult to identify and protect existing and potential access resources along the North Coast. It is also difficult to plan for future access resource development and management or understand the precise access policy requirements for new development in the coastal zone. This undermines and is inconsistent with the goal of section 30211 to provide maximum public access.

To address these inconsistencies, the NCAP should be modified to include a separate Public Access chapter. This chapter should include a discussion of public access goals, policies, standards, programs, and other relevant management objectives for the North Coast Area. It should also include a comprehensive inventory of existing and potential public shoreline access, including a map indicating such access resources. The County has previously produced a Coastal Access Inventory (October, 1991), which provides a framework for a public access resource inventory. Public access policies, programs, and ordinances are easily assembled from existing planning documents (see Modification 1).

2. Planning for Maximum Public Access

As mentioned above, the County’s NCAP update includes a variety of public access goals, policies, programs, designations, and background discussion. The larger LCP of which the NCAP is a part also includes policies and ordinances to address public access. In general, the public access policies of the LCP closely reflect Coastal Act access policies 30210-214 (see Coastal Plan Policies, Chap. 2). Implementation of the County’s public access policies under County Ordinance 23.04.420 also mirrors the Coastal Act. CZLUO 23.04.420(b) repeats Coastal Act section 30211 nearly verbatim. CZLUO 23.04.420(c) essentially reproduces the requirements of Coastal Act section 30212, with additional standards that specify when "adequate access" exists (for example, every quarter mile in urban areas and every mile in rural areas).

Similar to the proposed NCAP updates, the certified NCAP contains further access programs, standards, and combining map designations specific to the North Coast. For example, the "North Coast Shoreline" sensitive resource area is characterized as providing a variety of passive recreational uses; and as "a valuable natural resource which must be protected from excessive and unsightly development" (p. 50). Existing North Coast Access programs, which are non-mandatory actions or policy recommendations include: the improvement of Caltrans Vista Points; public acquisition of Piedras Blancas Point and the Cambria Air Force Station; access signage improvements; acceptance and maintenance of offers-to-dedicate; and various improvements to existing and potential public accessways. Some of these programs are no longer relevant, either because they have been achieved, or because of they have been mooted by other developments (e.g., the Cambria Air Force station is now in private ownership). Additional access planning is discussed in the development standards section of the existing NCAP (see Issue 4 below for more detail). Finally, as discussed earlier, the certified combining designation maps for the North Coast show general locations of existing and planned lateral and vertical access.

In addition to specific updates to North Coast development standards (see Issue 4), the County has made the following substantive changes related to Public Access planning:

„ In Chapter One, under the general goal of preserving "open space," the County has added Goal 10(c), which would "encourag[e] better access to the coast through the acquisition and development of coastal accessways, trails, and neighborhood parks, in appropriate locations" (1-7).

„ In Chapter Three addressing Public Services and Resources, the County has added a discussion of neighborhood, community, and regional park deficiencies, with recommended Park standards (3-19; 3-32-33; for detail see Recreation findings); and a brief discussion of traffic circulation problems related to existing and potential increasing visitor traffic.

„ In Chapter Four addressing Land Use, the County has updated and made editorial changes to descriptions of existing and planned recreational land uses, including public accessways, in the North Coast Planning Area; and future visitor-serving development on the Hearst Ranch. Most of this discussion is informational only. The County has also amended the Land Use Program section, which includes a Rural Area Program for retaining public lands in public ownership (4-29); a program encouraging residential parks plans in Cambria (4-30); and programs to improve views from Highway One and acquire a park in San Simeon Acres (4-31).

„ In Chapter Five addressing Circulation, the County has added new discussions of auto, pedestrian, equestrian, bike, and other modes of transportation. For purposes of public access planning, the most important updates in Chapter Five are discussions of circulation objectives and alternatives (5-2-3); pedestrian and bike trail planning (5-8-9); the importance of transportation demand management to facilitate maintaining Highway One as a two-lane road in rural areas (5-10); and additional Circulation Programs for improvements to Highway One and other modes of public access, such as directional signage, trail development, and bikepath development (5-14-18).

„ In Chapter Six addressing Combining Designations and Public Facilities, the County has updated various combining designation descriptions, including the "North Coast Shoreline" Sensitive Resource Area (SRA), the San Simeon Point SRA, and the Piedras Blancas Point SRA, each of which are described as important access-related scenic resources. The County has also added references to Community and Regional Parks combining designations (6-9), as well as to the Combining Designation maps. Most important in this Chapter, the County has updated the "Local Coastal Plan" combining designation Program, which serves as the main Public Access programmatic element in the current NCAP. It includes public access programs for such issues as improvement of automobile vista points, acquisition of Piedras Blancas Lighthouse, and improvement of over access points along the North Coast (6-10-12).

„ In Chapter Seven addressing Planning Area Standards, the County has made a variety of specific changes to the Public Access standards for the North Coast. These standards are mandatory requirements for new development and are discussed in Issue 4 below.

„ On the North Coast maps, except for changes to certain road designations and new roads in the West Ranch area (see Roads discussion), no changes to vertical and lateral access designations are proposed on the official circulation maps of the NCAP. Some Recreational lands are proposed for rezoning as well (see Development findings).

Conformance with Coastal Act Policies

Coastal Act Sections 30210-214 make clear that public agencies implementing the Coastal Act must make every possible effort to plan for and provide maximum public access to the shoreline, albeit in reasonable balance with other public, private, and ecological concerns. Section 30210 requires the provision of maximum public access. Section 30211 prohibits the interference of development with existing access; Section 30212 requires new development to provide public access; and Section 30214(c) requires public agencies to consider and encourage innovative access management techniques when implementing the Public Access policies of the Coastal Act. As mentioned earlier, Section 30500 requires each Local Coastal Program to "contain a specific public access component to assure that maximum public access to the coast and public recreation areas is provided."

Although the County's NCAP update contains many important public access descriptions and programs, it falls short of the goal of planning for maximum access. In addition to the organizational difficulties discussed under Issue 1, the NCAP update is deficient in three primary planning areas: Goals and Objectives; Resource Identification; and Public Access Programs.

Goals and Objectives

The NCAP Update is much improved by the new discussion of general policy goals for the North Coast. However, as currently drafted, there is insufficient recognition of perhaps the most significant goal of the California Coastal Act -- maximizing public access to the shoreline. The only reference to public access in Chapter One is under the heading "Open Space." Moreover, this reference merely "encourag[es] better access to the coast." There is no discussion of the variety of coastal access goals, such as establishing a continuous coastal trail and providing a regional coastal bike path system, that should be part of any comprehensive public access program. Given the County's intent that the goals of the North Coast Plan function as criteria to guide development proposals, the lack of such goals to pursue and provide maximum public access to the shoreline, in balance with private rights and ecological concerns, is inconsistent with Coastal Act sections 30210-214.

To bring the Updated NCAP into conformance with the Coastal Act, a comprehensive Public Access component should be added to the NCAP as a separate chapter. As discussed in Issue 1, this chapter should assemble relevant public access goals, policies, standards, programs, implementation plans and other relevant management measure for the North Coast Area. It should also include a comprehensive inventory of existing and potential public shoreline access, including a map indicating such access resources. The County has previously produced a Coastal Access Inventory (October, 1991) that provides a framework and baseline data for a public access resource inventory (see Modification 1).

As for the particular content of such an Access component, to provide for maximum access, the County should also delete goals 10(c) and 12(d) from the NCAP (see finding -- below for the rationale for the 12(d) deletion) and add Goals to the Public Access chapter that seek to maximize public access by, among other things, developing all feasible lateral and vertical pedestrian access, developing a through coastal trail the length of the planning area, and providing for conspicuous signage for all public access (see Modification 5 and 6)

Resource Identification

The NCAP Update contains important information on existing vertical and lateral access and other public access resources along the North Coast. It also provides generalized mapping of these resources of the circulation maps for the rural areas of the County, San Simeon Acres, and Cambria. However, as with any public resource, comprehensive planning, including the gathering of systematic resource information, is required to provide maximum public access. These findings, for example, provide overview information on both existing and potential public access resources for the North Coast. Tables and maps are useful tools for understanding the range of public access planning issues for the North Coast. They are particularly useful in helping the public to understand the resources available to it. Actual public access development must be accomplished, of course, in reasonable balance with other public policy goals, such as environmental resource protection and protection of private property rights. Nonetheless, it is important to have a comprehensive resource inventory for planning and general public policy purposes.

A comprehensive inventory is also important because of the many methods available for developing access resources. Although much of California's public access has been developed through specific exactions or dedications in the regulatory process, much has been provided through other means as well, including public and non-profit acquisitions and private donations. Experience with the California Coastal Management Program has shown that it is difficult to anticipate and provide maximum public access resource development without comprehensive inventories and mapping.

The updated NCAP provides insufficient comprehensive discussion and identification of existing and potential public access resources of the North Coast. Resource descriptions are spread throughout the NCAP. In addition, the official maps of the NCAP do not provide sufficient detail for understanding and communicating the existing and potential public access resources of the North Coast. Finally, and most important, the NCAP does not identify the maximum, or full range of access opportunities, for planning purposes. For example, the current circulation map does not show any lateral access between Arroyo de la Cruz and Piedras Blancas Point. Similarly, no potential access, such as a continous blufftop trail, is shown for the Harmony Coast (Cambria to the southern edge of the Planning Area). Because of the lack of a comprehensive access inventory, including more detailed mapping, the NCAP is inconsistent with Coastal Act Sections 30210-30214.

To facilitate planning for maximum access in the NCAP, the County should add a comprehensive resource inventory to the public access chapter that assembles all access identified in the NCAP text or maps. The inventory should begin to develop information on all major formal and informal access resources for the North Coast planning area. Similar to the Resource Management System that the County implements, the public access inventory should also be updated and evaluated periodically (see Modification 1).

Public Access Programs

The updated NCAP contains access-related programs in Chapters Four, Five, and Six. Additional access plans are presented in Chapter Seven concerning specific development standards. Similar to Resource Inventory discussion, the lack of a systematic presentation of access programs in a single location in the NCAP conflicts with the goal of maximizing access. Public access goals and objectives, policies, resource inventories, and programs should be presented together to facilitate access planning and provide for effective implementation of the public access policies of the Coastal Act and the NCAP (see Modification 1).

In general the County has developed a useful and important set of specific programs to plan for maximum access. However, there are a few inconsistencies with the following programs:

„ Directional Signing (5-14). As currently modified, this program may lead to inadequate signage for public vertical and lateral access because it allows for signage that may not be near accessways. This is inconsistent with Coastal Act Section 30210, which requires conspicuous posting of public access. This program should be modifed to guarantee maximum and conspicuous signing of coastal access (see Modification 31).

„ Trails (5-14). This program encouraging the County to pursue public trails development might be interpreted as being limited to those areas where "interest" in such development has been expressed, as opposed to a general program to pursue maximum trail development. This is inconsistent with Coastal Act Section 30210 and should be modified accordingly (see Modification 32).

„ Bicycle Improvements (5-15). Although an important addition, this program does not specify the range and quality of bicycle improvements that should be pursued, inconsistent with the goal of maximizing public access resources. Experience in other coastal jurisdictions has shown that without more specific anticipation of the types of desirable access improvements, opportunities for acquisition and development may be precluded. To address this need this program should be expanded to clarify the desirability of a regional bikeway system on the North Coast, including the provision of Class I or II bikeways where feasible (see Modification 39).

„ Shoreline Access -- Vista Points (6-10). This combining designation program fails to plan for maximum access, in balance with other public, private, and ecological concerns. It is geographically limited, and does not allow for the possibility that other organizations might improve and maintain automobile vista points. This is inconsistent with Coastal Act section 30210 and 30212. Modify this combining designation program to plan for maximum access, in balance with other public, private, and ecological concerns. Amend (see Modification 45).

„ County owned surplus lots (6-12). Although a valuable program to reduce the number of substandard lots in Cambria, as currently drafted, this program fails to recognize the importance of publicly-owned parcels as potential public access resources, inconsistent with section 30210. Recognize the importance of publicly-owned parcels as potential public access resources by indicating that use of such parcels for public access is the first priority (see Modification 48).

„ West Ranch Design Principles. To assure the provision of maximum public access at West Ranch, modify design principle D (pg. 7-59) to include public access opportunities (see Modification 112).

„ OTD Implementation Plan. The County has recently accepted nearly all the offers-to-dedicate. However, there is a lack of a clear implementation strategy for opening and managing these areas for public use. The County, therefore, should include a program to develop an implementation plan for any OTDs that they have or may accept in the future.

„ Public Lands Program. One method for maximizing public access is to pursue all feasible and desirable opportunities to convert existing public lands into public access and recreational resources. The original NCAP had a program to secure the Cambria Air Force station as a public resource. However, this program was not achieved and now the Station is in private ownership. The NCAP currently has a Public Lands program that fails to emphasize the importance of public lands and facilities for future access resources (see 4-29, #2). This program should be amended to also require that relevant public land holdings be retained in public ownership, or be acquired by the County, to be used as public access/recreational resources. Privatization of such lands should be pursued only after such opportunities have been pursued to the maximum extent possible and found to be infeasible or undesirable.

3. Interference with Existing Access

The County currently protects existing public access through Policy 1 of the Coastal Plan Policies Document, and CZLUO 23.04.420(b) and (d)(iii). As mentioned earlier, these policies are essentially the same as Coastal Act policies, and they require the protection of access where established by the legislature or by historic use.

The issue of historic use, which may give rise to prescriptive public access rights to and along the shoreline, has been an on-going issue for the North Coast. Prescriptive rights are judicially determined rights of access or public easements that require certain basic findings including that: (1) people have used the land for a five year period, without permission and without effective interference; (2) the use has been substantial; (3 the land has been used by members of the general public, not only neighbors or friends of the fee owner; and (4) the use of the area has been with the actual or presumed knowledge of the owner and without significant objection or attempts by the owner to prevent or halt such use.

In 1972, the Hearst Corporation recorded a Notice of Permissive Use that necessarily affected future claims of public access rights. The legislature has declared that such recorded notices are sufficient evidence to preclude a finding of prescriptive use for any time period after the filing of such a notice. However, some evidence exists that the public has used various areas along the North coast, including the Hearst Ranch, for at least 40 years, from 1957 onward (e.g., see Coastal Development Permit A-3-SLO-95-70). Evidence and arguments for historic uses have also been presented from time to time for the West ranch property in Cambria. Thus, historic access uses is an issue at various locations along the North Coast. While, prescriptive rights may only be established by a court of law, the Commission and the County by extension is required to protect any historic rights that they believe exist.

As discussed earlier, there is a considerable amount of informal recreational use of the rural North Coast shoreline. A survey of citizens collected during the public hearings for the County's NCAP update process documented all of the following uses in this area: fishing, diving, kayaking, windsurfing, surfing, boating, boat launching, picnicking, sitting on the beach, playing on dunes, walking, jogging, bonfires, walking dogs, collecting shells/driftwood, building sand castles, sunbathing, photography, painting, and watching marine mammals.

Existing public access also may be interfered with or lost through the process of managing public accessways within private holdings. For example, the NCAP has always contained combining designation programs that encourage Caltrans to maintain and improve automobile vista points in the vicinity of Piedras Blancas Lighthouse, on the Hearst Ranch. These vista points have also been the subject of multiple Commission actions related to Caltrans proposals to realign Highway One in this same vicinity. In 1982, the Commission required the creation of a vista point as mitigation for the loss of access due to Highway One realignment. However, in the most recent action by the Commission (an appeal of a Caltrans realignment project just south of the Lighthouse), the Commission allowed the closing down of the very same existing vista point in exchange for the improvement of two other existing informal vista points (see A-3-SLO-95-70).

Finally, the County has modified the Vista Points Combining Designation program (6-11) to allow the Department of Parks and Recreation to be involved in the maintenance of vista points north of Cambria. The County has not proposed any other explicit changes to the NCAP that would affect the policies concerning interference with public access.

Conformance with Coastal Act Policies

Section 30211 requires that new development not interfere with the public's right of access to the sea, whether acquired through use or legislative authorization, including, but not limited to, the use of dry sand and rocky coastal beaches to the first line of terrestrial vegetation. As amended by the County, the vista point program does not require the protection of existing access when new development is proposed. This is particularly important in light of the controversial history at Piedras Blancas discussed above. This program is therefore inconsistent with section 30211. To assure that future development does not interfere with existing access, the Vista Points program must be modified to clarify the need to maintain existing access resources by only allowing access to be lost if it its concurrently replaced with equal or better access (see Modification 47).

More generally, given the significant amount of informal and historic public access along the North Coast, the County should add a program to develop and carry out a program to systematically document potential public prescriptive rights. Similar to the discussion above concerning maximum planning, such a program is necessary to provide for maximum public access to the shoreline. The documentation of historic public access is also increasingly important for areas like the Hearst Ranch, where a notice of permissive use has been filed. The more time that passes, the more difficult it becomes to gather information that might provide evidence for such historic public use.

4. New Development Access Standards

The SLO County LCP contains general policies and ordinances that require new development between the first public road and the sea to provide public access from the nearest public roadway to the shoreline and along the coast (Policy 2; CZLUO 23.04.420(c) et seq.). As discussed above, the County has been successful at obtaining multiple vertical and lateral offers to dedicate public access through the development review process. More important, the County itself has recently accepted almost all of these OTDs so that they may be incorporated into the public access resource inventory before they expired.

The LCP also contains a policy intended to implement Coastal Act section 30213, which requires that lower cost visitor and recreational facilities be protected, encouraged, and provided where feasible (Recreational and Visitor-serving Facilities Policy 3). The policy is to be implemented as a "standard" and thus does not have a corresponding ordinance. The policy also differs somewhat from the Coastal Act section 30213, stating: "[l]arger visitor-serving projects shall make provisions for services which are geared to a range of costs, including low cost facilities."

Finally, the existing NCAP has a variety of areawide and specific development planning standards, including requirements for access dedications and development by the Hearst Resorts and West Ranch developments.

The County has made a variety of changes to Chapter Seven of the Updated NCAP, which includes public access development standards for the North Coast. These changes are summarized below.

„ Introductory language is added explaining, among other things, that "land dedications and all other exactions identified in [the] plan are designed to mitigate the impacts of specific development proposals." This language also refers to the possibility of conducting "nexus and proportionality" studies that may be used to justify exactions or dedications; and that a failure to require such dedications because of insufficient justification will not create an inconsistency with the LCP (7-2).

„ The LCP combining designation standard for all new development is modified to require that vertical and lateral access dedications be provided according to the CZLUO; and that such dedications may be off-site for major development and may include improvements and on-going maintenance. The County has deleted a description of the variety of public access resource types (7-10).

„ Sensitive Resource Area standards have been modified to make the provision of public access discretionary, even if such access is compatible with the protection of marine resources (7-10).

„ Various changes have been made to the Hearst Ranch Resorts Plan, including adjustments to the access dedications and development requirements for each phase of resort development (7-14 to 7-33). More detail is provided in the following section.

„ Miscellaneous changes have been made to public access development standards for the Recreation, Public Facility, Cambria Urban Area, and San Simeon Acres categories of Chapter Seven, including access requirements for the West Ranch. More detail is provided in the following section.

Conformance with Coastal Act Policies

Coastal Act section 30212 requires that new development provide public access from the nearest public roadway to the shoreline and along the coast, except where it is inconsistent with public safety, military security needs, or the protection of fragile coastal resources; adequate access exists nearby; or agriculture would be adversely affected. Section 30213 requires that lower cost visitor and recreational facilities be protected, encouraged, and provided where feasible. As Section 30210 recognizes, though, these policies must be balanced with private property rights. In addition, Coastal Act Section 30001.5(c) states a basic goal of "maximiz[ing] public access . . . consistent with sound resources conservation principles and constitutionally protected rights of private property owners." [Add 30010.]

In general, the updated NCAP provides strong, comprehensive development standards for public access. However, there are a few issues that raise inconsistencies with the Coastal Act.

Nexus and Proportionality

The County has added language referencing the specific legal concepts of "nexus" and "proportionality" that reflect current Constitutional Fifth Amendment takings clause jurisprudence (7-2). It is the County's intent that any exactions or dedications required through the development review process not infringe on Constitutionally-protected private property rights. However, to be effective in providing maximum access through the development review process, plans, policies and standards must be sufficiently broad to adapt to changes that inevitably occur through the evolution of judicial case law. References to specific legal concepts developed in particular judicial cases are not necessary for the reasonable balancing of public rights of access to the shoreline with private property rights; they may have the unintended affect of limiting the provision of public access that future legal interpretations of the Fifth Amendment might encourage.

The added language also unnecessarily suggests that if nexus and proportionality studies, done at the landowner's request, do not justify particular exactions, that failure to require public access will not be inconsistent with LCP. This unnecessarily implies an additional burden of the County, and by extension the public, which could have a chilling effect on the provision of maximum access. As such, these specific references are inconsistent with Coastal Act Sections 30210-214, and section 30001.5(c), and should be deleted from the NCAP (see Modification 51).

General Shoreline Access Requirements

The amended combining designation standard for new development shoreline access requirements (7-10, #2) may be construed as limiting the range of potential public access exaction requirements. Although it allows for off-site dedications where appropriate, it also deletes descriptions of the variety of public access amenities that may be appropriate. The standard also references the CZLUO implementing ordinance. Although reasonably thorough, this ordinance does not allow for the full range of potentially appropriate lateral access, particularly blufftop access. This standard is therefore inconsistent with Coastal Act sections 30210 and 30212. To bring it into conformance with the Coastal Act, it must be modified to to provide for appropriate access and associated amenities (see modification 66).

Sensitive Resource Areas

Sensitive Resource Area standard #4 (7-10) allows for discretionary access when marine resources are present, even if such access would be compatible with the protection of such resources. This is inconsistent with section 30212, which requires that public access be provided where such access would be consistent with the protection of marine resources. To be consistent with the Coastal Act, the word "shall" should be maintained and the added "may" should be deleted (see modification 70).

Hearst Ranch Resorts Plan Standards

The NCAP standards for the Hearst Ranch Resorts Plan include general standards for providing shoreline access (7-17) and master access planning (7-18); as well as specific access requirements for each phase of proposed resort development (7-19 to 7-29).

Similar to finding 2 above, the general standard for shoreline access is needlessly qualified by potentially limiting and unnecessary language. The modified language is also cumbersome, poorly edited, and potentially confusing, no doubt due to the multiple changes that have been made by the County in the last year. As such, the standard is inconsistent with sections 30210 and 30212, which require the maximum amount of access to be provided with new development. To bring this standard into conformance with the Coastal Act, it must be modified to more clearly state the expected performance criteria (see modification 90). The suggested modification appropriately allows for the provision of maximum access, consistent with Section 30210; and also does not preclude the adequate consideration of private property rights, consistent with Coastal Act Section 30007.5 and 30010.

The NCAP also requires the submittal of a Public Access Master Plan with Phase 1 of the Hearst Resort development. This requirement is an important standard, and is generally consistent with the access policies of the Coastal Act. As currently drafted, the NCAP references two figures that show areas of access that should be addressed in the Master Plan (Figures 7-4 and 7-6). Although not necessarily inconsistent with the Coastal Act, to be consistent with other findings in this evaluation, these figures should also be incorporated into the new access component of the NCAP or superceded by a more general integrated resource inventory that identifies potential access opportunities. If maintained as separate figures specific to Hearst Resort development, the figures should also be modified to reflect the changes to each phase as discussed below. (see modification 91)

Finally, and most important, the NCAP requires various access dedications and improvements for each of four anticipated phases of Hearst Resort development. These exactions range from lateral and vertical access at San Carpoforo Creek at the northern end of the ranch, to an overlook at Pico Creek -- the southern edge of the Hearst Ranch. The administrative record for the update of the NCAP reveals a great deal of controversy over the nature and scope of these access dedications, particularly concerning their appropriateness under more recently developed concepts of "nexus" and "rough proportionality." To better understand this issue, and to evaluate the consistency of this section of the NCAP with the Coastal Act, closer examination of the proposed dedications, as well as potential impacts related to the proposed Hearst development is necessary.

The County's proposed exactions essentially cover four areas of the rural coast from Pico Creek to Ragged Point. From south to north these are:

„ Between Pico Creek to W.R. Hearst Memorial State Beach: Lateral and vertical access, including two vertical accessways at the existing Caltrans turn-out areas, and a small overlook park at Pico Creek. Lateral access is limited to the immediate shoreline (toe of the bluff to mean high tide). The state also already owns about two-thirds of this shoreline. Further research is being conducted on this ownership.

„ From San Simeon Point to the Caltrans Turnout at Adobe Creek (formally Vista Point #1): lateral access along the shoreline; a vertical accessway at Oak Knoll Creek; a small parking area and interpretive facility just north of Old San Simeon; a bluff top pedestrian trail to San Simeon Point and from the Point to Oak Knoll Beach, as well as vertical access to the sandy beach areas near the Point; a public parking area at the resort; a pedestrian/bicycle path to other resort areas; a picnic area; and other support facilities, such as trash receptacles, signs, and restrooms.

„ From Vista Point #1 to Piedras Blancas Lighthouse: Lateral access along the shoreline and one vertical access in the vicinity of Piedras Blancas Dunes, consistent with habitat protection (Elephant Seals).

„ From Piedras Blancas to Ragged Point: Vertical and lateral access paths to the Arroyo de la Cruz creek lagoon; three vista points and parking areas south of San Carpoforo Creek; vertical access from these vista points to the corresponding sandy beaches, and lateral access along these beaches; and support facilities for the San Carpoforo improvements.

Although the range and scale of these proposed exactions would seem to be quite extensive, a few limitations that are not immediately obvious should be highlighted. First, except for the blufftop lateral trail required at San Simeon Point, the lateral access required with each phase is limited to the land between mean high tide and the toe of the bluff -- little more than what many already consider to be Public Trust lands, particularly given the narrow beaches and rocky shoreline typical of the north coast.

Second, at least three of the required vertical accessways (two between Pico Creek and the Piedras Blancas Dunes accessway) are essentially already available, but for physical improvements. Thus, the State already owns the land along the shoreline at the two turnouts; and the access at the Piedras Blancas Dunes is being developed pursuant to the Coastal Commission permit for Caltrans Vista Point #3 and #4. A fourth vertical access at Oak Knoll Creek is in the vicinity of Vista Point #1 which, as described above, was an existing area of public access required by an earlier Commission permit for the realignment of Highway One.

Finally, much of the access required by the County, particularly that at Arroyo de la Cruz Lagoon and San Carpoforo, reflects historic use patterns that at one time may have been found to be prescriptive. The filing of a notice of permissive use in 1972 however cuts off any claims from that year forward. As each year passes, the potential for securing sufficient testimony regarding pre 1972 public use decreases, but for the filing of a permissive use notice by the Hearst Corporation, might be eventually recognizable as prescriptive public rights. So, although the County's exactions would represent a fairly dramatic shift in the formal legal landscape for public access on the Hearst Ranch, they would not necessarily move much beyond existing informal public access practices along the North Coast.

Nevertheless, regardless of current terms and legal concepts, any access dedications must be of reasonable scale and relationship to the impacts of particular coastal developments. In the case of Hearst Resorts, there will no doubt be significant impacts to the existing access resources of the rural North Coast, especially in the vicinity of San Simeon Point, even with the more limited development approved by these findings.

As outlined earlier, existing formal public access is extremely limited along this 16 mile section of coast. Currently, formally-recognized beach access only exists at W.R. Hearst State Beach and San Simeon State Beach. Moreover, the informal access points and trails between Ragged Point and Pico Creek "exist" only with the permission of the Hearst Corporation. Nor are they readily available to the visitor that is unfamiliar with local area -- for all intents and purposes the rural north coast is perceived as fenced, inaccessible private rangeland, except for the Caltrans vista points. In short, there are no obvious opportunities for public visitors to make their way down to the shoreline between the Ragged Point Inn and W.R. Hearst Memorial State Beach.

To put this relative lack of shoreline access in perspective, it is helpful to consider available access for other rural sections of the Central Coast. For example, along the Northern Santa Cruz -San Mateo Coast, (approximately 50 miles) there are no less than 24 formally acknowledged points of access, including numerous State and County beach parks. Even along the Big Sur Coast, with its dramatic topography and sheer cliffs, there are no less than 23 access points to the shoreline, albeit a 70 mile segment.

Overall, the limited existing supply of secured shoreline public access on the rural North Coast is important to acknowledge because it represents a limited capacity to receive any new visitor impacts. Indeed, in order for the public access resources in this area even to be maintained, to say nothing of maximized, visitors will need to be directed to new accessways, beaches, trails, etc. This is particularly true given the concentration of development required by other sections of this report. It will be important that any future development at Old San Simeon not overwhelm the cove and beach at San Simeon Point. In other words, whereas the Coastal Act requires that new physical development and infrastructure be concentrated, it also requires that the relatively low intensity of public access be distributed, for the precise reason that the public’s enjoyment of the beach will be maximized as the density of users decreases (section 30212.5).

Still, the need for additional acccess will ultimately be driven by the scale and intensity of new development at Old San Simeon. As modified by these findings, the Hearst Resort development could add as many as 375 new overnight rooms to the rural area of the North Coast. This would be a 50% increase over the existing overnight room stock at San Simeon Acres and in the rural area of the North Coast. Even with Cambria rooms included in the mix, the Hearst Resort would still increase overnight room accommodations by over 26%. In addition, this one simple measure also does not reflect the increased visitor traffic that will be drawn to area by the new commercial development at the resort, apart from the new overnight accommodations. Nor does it reflect the additional residents that will be drawn to the area as employees of the resort. Finally, with additional visitor-serving amenities in the area, it is likely that more people will be staying in the North Coast area for a longer period. Indeed, if all goes according to the Hearst Corporation plan, the resort at Old San Simeon will become a true visitor-serving destination, where visitors enjoy a variety of recreational resources for multiple days. This will represent a significant departure from the current dominant visitor traffic pattern of travel into the San Simeon area for a limited period of time to see Hearst Castle.

Overall, it is likely that new development at Old San Simeon will dramatically change the character of the public access experience along the rural north coast. What is now an essentially low intensity rural shoreline environment will become more crowded and intense, even if additional access resources are made available. New visitor pressures will also increased conflicts with the sensitive ecological resources already at risk, such as the dunes at Piedras Blancas and the elephant seals and habitat at Twin Creeks beach. In short, simply to maintain existing access resources in the planning area, let alone maximize public access, extensive improvements will be needed with future resort development.

As described above, the County has required a variety of limited access dedications spanning the entire Hearst Ranch. As a general rule, the geographic scope is appropriate given the existing and anticipated visitor traffic patterns; the high intensity of the planned resort development relative to undeveloped character of the North Coast; and the Coastal Act requirement that public access facilities be distributed in a visitor-serving area, "to mitigate against the impacts . . . of overcrowding or overuse by the public of any single area (section 30212.5). Still, the impacts to access that might come with increased development at San Simeon are somewhat unpredictable, and precise resource needs are difficult to anticipate at the planning stage. In addition, the County’s exactions do not carry any particular logic in terms of their timing and location. Therefore, at this planning stage for the Hearst resort, it is more appropriate to identify a set of minimum requirements for public access in and around the development envelope, subject to future scaling, geographic expansion, and other modifications as warranted by more detailed impact analysis at each phase of development.

Accordingly, to bring the NCAP public access standards for the Hearst resort development into conformance with the Coastal Act, the standards should be modified generally as follows (see modifications for exact language): (see modification 97)

„ PHASE 1: San Simeon Point to the Caltrans Turnout at Adobe Creek (formally Vista Point #1). Prior to occupancy of any units developed in Phase 1, provide the following minimum access improvements:

• A bluff top pedestrian trial from Old San Simeon to San Simeon Point, and from the Point to Adobe Creek;
• A pedestrian trail from the Village to the State Parks Hearst Castle Visitor Center;
• Lateral access along the shoreline from W.R. Hearst Memorial Beach to Adobe Creek;
• A vertical accessway to the shoreline at Oak Knoll Creek;
• Vertical access to other sandy beaches or rocky shoreline;
• Public parking and interpretive facility at the base of the point, with support facilities such as trash receptacles, signs, and restrooms;

Trails should be designed to allow for future extension and connection to a through coastal trail north and south of this area. Additional access improvements as described for future phases shall be required if warranted by impact analysis at the Master Plan and development stages.

„ PHASE 2: Pico Creek to W.R. Hearst Memorial State Beach. As required by impact analysis at the Master Plan stage and Phase 2:

• Lateral access dedications to support, and development of, a bluff top coastal trail from Old San Simeon to Pico Creek. Appropriate signage and controls for the protection of sensitive habitat and/or to prevent bluff erosion shall be provided.
• Lateral access dedications from mean high tide to the toe of the bluff;
• Vertical accessways at the two Caltrans turn-out areas, Little Pico Creek, and Pico Creek.

„ PHASE 3: From Vista Point #1 to Piedras Blancas Lighthouse. As required by impact analysis at the Master Plan stage and Phase 2:

• Lateral access dedications to support, and development of, a bluff top coastal trail from Adobe Creek to Piedras Blancas Lighthouse.
• Lateral access dedications along the shoreline from the mean high tide line to the toe of the bluff.
• completion of already required vertical access in the vicinity of Piedras Blancas Dunes, consistent with habitat protection (Elephant Seals).

„ PHASE 4: From Piedras Blancas to Ragged Point. As required by impact analysis at the Master Plan stage and Phase 2:

• Vertical and lateral access paths to the Arroyo de la Cruz creek lagoon;
• Three vista points and parking areas south of San Carpoforo Creek;
• Vertical access from these vista points to the corresponding sandy beaches -- San Carpoforo, Driftwood Beach, and the beach between Breaker Point and Yellow Hill.
• Lateral access dedications to support, and development of, a through coastal trail in this area.
• Lateral access dedications from the mean high tide line to the toe of the bluff.
• Support facilities for the San Carpoforo improvements.

(Please see Exhibits 15 and 16)

Shoreline Access at West Ranch.

In general, the County has structured its standards for the West Ranch development to adequately address Coastal Act requirements. Similar to the findings for Hearst development standards, though, slight modifications are necessary to bring the standards into full conformance with section 30210 and 30212. First, public access should be made a specific goal or design principle for the Ranch. Accordingly, Principle D (7-59) should be amended to include public access. Second, the overarching standard for access dedications at the Ranch should be amended to provide for maximum access, consistent with the Coastal Plan Policies and ordinances of the LCP, as well as the public access policies of the Coastal Act. In addition, an access Master Plan, including identification of access improvements and management arrangments, should be submitted for approval by the County at the subdivision stage. Third, to maximize public access, standard 14(A) should be amended to require that vertical and lateral pedestrian trails be provided that approximate in scale and intensity as close as possible, the historic informal access on the Ranch. Finally, Standard 14(B) should be amended to require at minimum a Class II bike path (see modifications 112 and 122).

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 Suggested Modifications to LCP Amendment