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Coastal Act Section 30253 requires that new development minimize risks to life and property in areas of high geologic, flood, and fire hazard. New development must also be designed and sited in such a way that it won’t cause or add to "erosion, geologic instability, or destruction of the site or surrounding area or in any way require the construction of protective devices that would substantially alter natural landforms along bluffs and cliffs." At the same time, Section 30235 does allow revetments, seawalls, and other bluff and shore protection devices, but only when required to serve coastal-dependent uses or to protect existing structures or public beaches in danger from erosion. Structures must also be designed to eliminate or mitigate adverse impacts on local shoreline sand supply. In addition, while shoreline devices may extend onto the beach, any impacts that may have on public access or other coastal resources must be avoided or mitigated.
As for flooding hazards, the Coastal Act recognizes that coastal rivers and streams may be subject to various engineering projects for flood control. Section 30236 allows "channelizations, dams, or other substantial alterations of rivers and streams", but only if such develoment uses the best mitigation measures feasible. Scuh projects are also limited to necessary water supply projects; flood control where there is no other feasible method to protect existing structures or provide for public safety; or developments where the primary function of the development is fish and wildlife habitat improvement.
Overview of North Coast Hazards
The North Coast Planning Area is subject to a variety of hazards, including ocean bluff erosion, flooding, seismic hazards, landslides, and fires. Not all areas of the North Coast are exposed to the same hazards though.
The ocean bluffs of West Lodge Hill and Park Hill are subject to erosion, which can endanger the existing residential development there. In contrast, in the rural area, the development most subject to ocean bluff erosion is Highway One where, in several locations, it lies close to the bluff edge.
Seismic hazards, while harder for the untrained eye to detect, do occur in the area, especially in the vicinity of San Simeon where the San Simeon fault is onshore. Seismic hazards include groundshaking, surface rupture, liquefaction and tsunami runup. While the San Andreas fault, some 35 miles inland, is the fault most likely to affect the area with groundshaking, two nearer active faults could also cause major damage. These nearer active faults include the Nacimiento fault, about 10 miles inland from the coast, and the Hosgri-San Simeon fault which lies mostly a few miles offshore, but which is on the land for about 11 miles between San Simeon Cove and the Ragged Point area (see Exhibit 17).
Flooding is of concern primarily in Cambria along Santa Rosa Creek, especially in the West Village, the East portion of the East-West Ranch, and the Mid-State Bank site (see Exhibit 18). While flooding occurs elsewhere in the planning area, in comparison there is little development outside of Cambria that is endangered.
The most visible fire hazard areas are the pine forests, which is also where most of the development has occurred. Development in the pine forests is almost exclusively within the Cambria urban area and the boundaries of the Cambria Community Services District, which provides fire protection within the urban area. Rural fire protection is provided by the California Department of Forestry and Fire Protection/County Fire Department.
Finally, earth movement through landsliding and erosion from ground soaking winter rains falling on steep slopes and/or areas of improper drainage and grading also poses a hazard. Since much of the residential part of Cambria is on moderate to steep slopes, there is a high degree of such erosion hazards.
1. Ocean-fronting Bluff Erosion
Most bluff erosion that is considered a hazard occurs in Cambria at the ocean bluffs on the west side of Lodge and Park Hills as a result of wave action and/or uncontrolled runoff over the top of the bluffs. This area is also where most of the armoring of the coastline in the planning area has occurred. The existing development protected from continuing erosion is residential and extends for about 1.25 miles along the bluffs in two separate sections, each 1/2 to 3/4 mile long. According to the Assessor’s parcel maps, there are 86 blufftop parcels (all residential single-family; the only large subdividable property within the URL of Cambria is the East - West Ranch) on Lodge Hill and Park Hill combined. Approximately two-thirds to three-quarters of the parcels are developed with single family dwellings. Almost half of those developed parcels have some sort of bluff protection, typically a seawall or rock revetment.
The Hazards section of the LCP Policy document (not a part of this submittal) requires all new development in areas subject to beach erosion to minimize risks to life and property, and that shoreline development be designed so that shoreline protective devices that would substantially alter landforms or natural shoreline processes will not be needed for the life of the structure (Hazards Policy 1). Hazards Policy 3 requires detailed review of development proposed in the geologic study area combining designation as indicated on the LCP maps. Hazards Policies 4 and 5 provide policy direction on design and construction of shoreline structures. Policy 6 requires new development on blufftops to be set back adequately to assure that no shoreline protective structures will be necessary for 75 years. Policy 7 says that the geologic study area combining designation includes "all coastal bluffs and cliffs greater than 10 feet in vertical relief and that are identified in the Assessment and Atlas of Shoreline Erosion as being critical to future or present development."
Based on limited review of geologic reports in Cambria, the average bluff erosion rate is 2 to 3 inches per year. It must be kept in mind, though, that bluff erosion can be episodic, so that in any given year the amount of erosion could exceed the average or be less than the average.
The existing area plan contains a Bluff Erosion Geologic Study Area Combining Designation. It states:
[p]ortions of the coastline where bluff erosion poses a concern for siting new development have been noted. Development should be located so that it can withstand 75 years of bluff erosion without the need for a shoreline protection structure ... (p. 47).
The Update carries over the same language in standard B(11) (6-4). Both the existing area plan (page 8-22) and the Update (page 7-55) specifically address blufftop setbacks in the Park Hill and West Lodge Hill areas. In the existing area plan two distinct areas are called out: "Tract 159 and other lots with coastal bluffs on Park Hill;" and "West Sherwood Drive on Lodge Hill". If the "other lots with coastal bluffs" means all the other bluff top lots on Park Hill, then all developable blufftop lots in Cambria are included since the Sherwood Drive lots are all of the Lodge Hill blufftop lots. The bluff setback for those areas is "[t]o be determined by geologic report to withstand bluff erosion and wave action for a period of 75 years . . . ." The Update contains the same requirement. However, on Park Hill, the minimum setback is 20 feet. While on Lodge Hill, the minimum is 25 feet. Finally, San Simeon Acres Commercial Retail Standard 4 and Residential Multi-Family Standard 4 both state that the bluff setback is to be "a minimum of 25 feet unless a geologic report or the stringline method of setbacks in the Coastal Zone Land Use Ordinance requires a greater setback" (7-118).
Most of the blufftop requirements and regulations are in the Hazards section of the LCP Policy document, which is not part of the Update submittal. As discussed, the blufftop setback standards contained in the Update vary somewhat, depending on the type and location of development. For example, in Cambria the setback generally is to provide for 75 years of erosion (with a minimum of 20 or 25 feet) before a protection structure is needed; while in San Simeon Acres, there is a minimum of 25 feet which may be required to be greater, but there is no equating that to a specific number of years worth of erosion. For the sake of internal consistency, San Simeon Acres Commercial Retail Standard 4 and Residential Multi-Family Standard 4 must be modified to require that structures be sited to provide for 75 years of erosion, with an absolute minimum of 25 feet from the bluff edge, before a shoreline protective structure would be needed. At the estimated rate of an average of 2 to 3 inches per year for bluff erosion, a 75 year setback equals 12.5 to 18.75 feet. The absolute minimum required by the Update is 20 feet on the Park Hill blufftop lots. Therefore, with the modification to the San Simeon Acres standards, the standards regarding blufftop setbacks contained in the Update will be consistent with Coastal Act section 30253. (Please see suggested modification 135)
As with flood hazards, most bluff erosion as a hazard occurs in the urban area. However, there are a few houses (less than a dozen), a warehouse, two motels, two restaurants, a lighthouse, and Highway One in the rural area that are located on bluff top property and could conceivably be subject to hazards associated with bluff erosion. Only one of these developments, Highway One, is currently protected from bluff erosion by a bluff protection device. As existing development, all of these could conceivably be allowed some sort of bluff protection device, if no feasible, less environmentally-damaging alternative was available.
Highway One is the only road to and along the coast north of Cambria. It serves as an access to the coast and beaches of northwestern San Luis Obispo County and southern Monterey County and provides access to the Big Sur Coast. Because of this, the highway may be thought of as a recreational feature. Highway One is often closed temporarily along the Big Sur Coast after winter storms. Those closures typically are the result of sudden and catastrophic landslides. In contrast, bluff erosion is typically a relatively slow, steady process, although erosion can be episodic. Nonetheless, the highway is subject to damage and potential closure from bluff erosion in several areas north of Cambria.
Highway One is adjacent to coastal bluffs at the various stream crossings and from just north of Pico Creek to Broken Bridge Creek, just south of the village of San Simeon, and then intermittently from about 2.5 miles north of San Simeon to the Monterey County line. The old highway alignment about 1.5 to 2 miles north of San Simeon shows evidence of old cribbing used to stabilize the bluff. The current alignment has only one place where a bluff protection device exists. This is about one half mile north of the Piedras Blancas Motel, at post mile 65.7.
Erosion of the bluff along Highway One at post mile 65.7 had progressed by early 1997 to the point where the bluff edge was only about two feet away from the edge of the highway. The Commission and San Luis Obispo County approved the placement of a rock rip rap revetment to protect the highway from further erosion. The Commission permit (3-97-39) is conditioned to be an interim, five year permit, valid until August of 2002. At that time one of two things is required: either Caltrans removes the rock and returns the site to pre-construction conditions or Caltrans receives approval of an amendment to the permit for another five-year term. The permit is conditioned to require that if Caltrans applies for an amendment, then the application must include an alternatives analysis. The alternatives analysis must include all feasible measures to protect the highway while avoiding or minimizing encroachment onto the beach or tidal areas or elephant seal habitat. At a minimum, the analysis must consider road realignment, continued use of the rock revetment, removal of the revetment, and use of other bluff protection measures. Additionally, Caltrans must include a discussion of the cumulative impacts to coastal resources of continuing erosion in the vicinity of the revetment site where similar conditions exist or could reasonably be expected to occur.
In late November, 1997, Caltrans notified Commission staff that another area, approximately 0.3 mile south of the previously described site where rock slope protection was placed, had eroded to the edge of pavement. Caltrans proposed placing rock slope protection at this site. As of the time this report was written, Caltrans had not determined if the work would extend seaward of the mean high tide line, although the shoreline below the bluff is rather narrow in this vicinity. The preliminary plans indicate that rock would extend out about 15 feet from the edge of the highway but that no sandy beach would be covered.
Both the existing area plan and the Update discuss Highway One as the main route through the area along the scenic Big Sur Coast between the Monterey Peninsula and San Simeon and continuing south to San Luis Obispo. Possible widening of the highway is also discussed (see Roads Findings). The Update mentions developing paved turnouts and improved, paved shoulders suitable for a Class II bike lane. However, there is no discussion of the hazard of bluff erosion to the highway and the possibility of additional rock being placed at the base of bluffs or of having to move the highway inland in the near- to mid-future.
Conformance with the Coastal Act
As mentioned earlier, roads are considered structures under the Coastal Act (Section 30106). Section 30235 allows the construction of revetments and other bluff protection devices when required to protect existing structures. In other words, there must be no feasible alternative to the use of a shoreline structure. Shoreline structures can alter natural shoreline landforms such as shoreline bluffs. In addition, construction of the structure may destabilize parts of the bluff. Shoreline alteration can also occur through the long-term effect of greatly slowing erosion of bluffs which can deprive beaches of a source of sand. Erosion of ocean-fronting bluffs can be exacerbated at each end of a vertical seawall where wave energy can be directed at the bluff material. Vertical seawalls can also contribute to loss of beach when wave energy is transferred from the vertical face of the wall to its base. Whether the reason for a shoreline protection device is to prevent damage to or loss of a house or a road, such protective structures often have adverse consequences to shoreline landforms.
For the reasons just discussed and since bluff erosion is typically relatively slow, an opportunity exists to evaluate alternatives other than shoreline structures for the protection of Highway One from bluff erosion. This is especially important since bluff erosion has reached another section of the highway. One alternative is to realign the highway inland a sufficient distance so that it, like houses in Cambria, will not need any bluff protection structure for 75 years. Incorporating such an alternative into the Update is consistent with Coastal Act Section 30235.
It is prudent to consider realignment as a method of protecting the highway from continuing bluff erosion that will endanger the highway sooner or later. Given the time (about five years) it takes for a major highway project such as a realignment to move through the system until it is funded, planning for moving the highway inland, away from the bluffs, should begin as soon as possible. Without such planning and analysis additional requests for approval of shoreline protection devices are sure to occur. For reasons of cost and ease of construction, unless the highway is realigned inland, the preferred engineering method of protecting the highway from ocean bluff erosion is and will continue to be rock revetments. Some, if not all, of those will cover some or all of a beach and interfere with public use of the beach or with elephant seal habitat, contrary to Coastal Act Sections 30211 and 30240.
North of San Simeon Acres Highway One is within an 80 foot wide "floating" easement granted by the Hearst Corporation to the State in 1938. The location of the easement is not limited to a specific route through the Hearst Ranch properties. The highway easement has been relocated at least twice in the past 16 years. Caltrans has realigned sections of the highway between San Simeon and Piedras Blancas inland, both for straightening of sharp curves and to put a greater distance between the highway and the bluffs. The most recent example was the realignment in the Twin Creeks area, approved by the Commission in 1996 and just recently completed. Ultimately, realignment of the highway will be cheaper than installation of numerous shoreline protective structures. More important, as a feasbile alternative, realignment is a better strategy to meet the requirements of the Coastal Act. Section 30235 allows shoreline protective structures when there is no other feasible method of protecting existing structures. Section 30211 requires that development not interfere with the public’s right of access to the sea. Rock revetments can cover portions or all of a beach and thereby preclude public beach access.
In addition, and as detailed in the findings on environmentally sensitive habitats, the placement of riprap on Northern Elephant Seal haul outs is inconsistent with Section 30240 of the Coastal Act.
Without an analysis and policy response to the problem of Highway One erosion, the NCAP is inconsistent with section 30235 and 30240. Therefore it is necessary to modify the Update’s discussion of transportation alternatives on page 5-10 to include realignment of the highway inland as a means of preserving the highway. Realignment to avoid bluff erosion hazards also needs to be added to the Planning Area Circulation Programs on page 5-15, Combining Designation Programs on page 6-10, and to Areawide Standards, Circulation, on page 7-4. With those modifications, the Update will be consistent with Coastal Act sections 30211, 30240 and 30235. (Please see suggested modifications 36, 37 and 47.)
While flooding can affect both Cambria and San Simeon Acres, Cambria is more flood prone with Santa Rosa Creek flowing through or near the commercial areas of the East and West Villages. The mapped flood hazard area in Cambria includes portions of the East Village adjacent to the creek and all of the commercial area of the West Village; even though Santa Rosa Creek is on the opposite side of Highway One from the West Village. Flood waters overtopping the creek banks upstream of the Highway One bridge can flow across the Mid-State Bank property and into the West Village. One reason for this is that the Highway One bridge cannot pass a 100 year flood. Water backs up behind the bridge and flows over land into the West Village. Although there are four culverts from the West Village under the highway to the creek, with flap gates on the creek end to prevent creek water from flowing into the West Village, they are less than fully effective when the creek is flowing at high levels and volumes, and according to the Cambria Village Center 1990 EIR, the culverts can only pass about 300 cubic feet per second (cfs). According to the EIR, it has been estimated that during a 100-year storm approximately 2,700 cfs will flow from Santa Rosa Creek across the Mid-State Bank property and into West Village. Assuming each culvert can pass 300 cfs, for a total of 1200 cfs, the amount flowing into West Village is 1500 cfs more than the culverts can pass. Information in the EIR estimated the depth of inundation in the West Village would be as much as 6-7 feet at the northwesterly end of West Village (please see exhibit 18). These depths were in fact experienced during flooding in 1995, and may have been exceeded.
Since certification of the North Coast Area Plan in 1983, the West Village has flooded three times, once in 1986 and twice in 1995. The earliest flood date listed in the County’s application for federal funds for flood control program development is 1969. Since then the West Village has flooded seven times, twice in 1969, once in 1973, once in 1978, once in 1986, and twice in 1995. These records from the last 28 years indicate that the West Village has been flooded by Santa Rosa Creek, on average, about once every four to five years, although in some years there may be multiple flooding episodes.
Flooding in San Simeon Acres is typically not as severe as that experienced by the West Village of Cambria. Pico Creek, at the north end of the community, is confined in a floodplain sufficiently below the elevation of the community to not pose a threat; its bed is some 40 feet below the general elevation of the community. The mapped flood hazard area for Pico Creek is contained within the banks of the stream. Arroyo del Padre Juan, at the southwestern corner of the community, does not have the watershed area to collect and convey very large amounts of runoff and only a few parcels would be affected.
The existing NCAP is silent on the issue of flooding along Santa Rosa Creek, although the Combining Designation Maps do show the flood hazard area. The Update proposes to add urban area standards regarding development in and near Santa Rosa Creek (7-50, 51). One standard requires applications for new development in the Santa Rosa Creek watershed or in the West Village to include a drainage and erosion control plan and requires mitigation for significant adverse effects development may have on flooding and drainage problems. The other proposed new standards address maintenance of the biological viability of Santa Rosa Creek, monitoring of water levels and quality, and filling in the floodway and floodplain. In Chapter Six, the Update proposes a discretionary Combining Designation Program that includes the goals of preserving the natural flood plain and increasing the capacity of Santa Rosa Creek to handle flooding. (6-18)
Coastal Act Section 30253 requires new development to minimize risks to life and property in areas of high flood hazard. As mentioned above, the amended Update contains standards that require a drainage and erosion control plan for new development in the watershed of Santa Rosa Creek or in the West Village (7-52). The County is also proposing that development in and adjacent to the creek not be approved unless a finding is made that historic stream flows will be maintained or enhanced (7-51). More generally, flooding hazards in the North Coast area are covered by the LCP. Hazards Policy 1 requires that all new development "be located and designed to minimize risks to human life and property." Policy 3 requires a detailed geological review of development proposed in a flood hazard zone. This policy also prohibits new development within the 100 year floodplain, except for areas within the urban reserve line.
Overall, neither the NCAP as modified nor the general LCP provide adequate policies for minimizing flooding hazards in Cambria. As such, the NCAP is inconsistent with Coastal Act section 30253. In particular, there is no policy guarantee that flooding will not continue to jeopardize new development that is currently not prohibited from being located in the flood plain of Santa Rosa Creek. However, the County is currently investigating various possibilities for more comprehensive flood control, including the possibility of forming a flood control district. In addition, the County is focusing on other strategies to reduce the overall risks of flooding in the West Village, including:
Nevertheless, the Update does not require any mandatory actions by the County to deal with the overall issue of flooding in West Village. Cambria Urban Area Community-wide Standard number 6(B) (pg. 7-50), which requires a finding that historic stream flows will be maintained or enhanced, does not adequately address the overall flooding problem. In order to address the requirements of section 30253, a new standard needs to be added that requires that no development, except for public services, in the mapped flood hazard area within the Cambria Urban Services Line shall be approved until a comprehensive flood analysis and management plan for the mapped flood hazard area is certified as an amendment to the LCP and is implemented.
The purpose of the flood analysis and management plan should be to limit flooding of the West Village from Santa Rosa Creek at the southeasterly edge of the Mid-State Bank property to the Windsor Boulevard bridge. This plan should also be consistent with section 30236, which limits the alteration of rivers and streams. Finally, at a minimum, the flood analysis should assess the four strategies or alternatives described above and possible improvements to the existing drainage from West Village under Highway One to the creek; and it should include an implementation timeline and identify sources of funding for necessary work. (Please see suggested modification 110.)
As for San Simeon Acres, the Update does not contain standards dealing with flooding, even though flood hazard areas are mapped along Pico Creek and Arroyo del Padre Juan. However, since flooding poses a relatively small threat in San Simeon Acres, the policies and standards contained elsewhere in the LCP are sufficient to ensure that any development there will not pose threats to life or property because of flooding. Therefore, the Update is consistent with Coastal Act Section 30253 regarding flood hazards in San Simeon Acres.
Although the rural portion of the north has many areas subject to flooding, there is relatively little development at risk. The stream in the rural area with the most development adjacent to it is San Simeon Creek, which has the potential to flood some scattered residential and ranch structures; the Cambria Community Services District’s (CCSD) water wells; as well as the San Simeon State Park campground. Since the creek typically floods only during the rainy season, when campground use is lowest, the potential for loss of life at the campground is low. However, there could be substantial damage to park facilities. Damage did occur in the winter of 1996-97 when rock and earth were scoured from one of the abutments of a bridge over the creek in the State Park. Repair of that damage was approved by the Commission in November 1997. CCSD has recently installed a berm between the creek and its facilities just upstream from the campground in order to reduce the chance of flooding. Damage to the district’s water wells could severely impact Cambria’s potable water supply.
There is generally little development along the rest of the planning area’s streams. Most of the development is agricultural. North of San Simeon Creek, flooding along Pico Creek would likely affect only portions of the Hearst horse ranch. Little Pico Creek has no development in its floodplain, nor do Broken Bridge Creek, Oak Knoll/Arroyo de Laguna, Arroyo del Oso, Arroyo de la Cruz, Arroyo de los Chinos, or San Carpoforo Creek. Arroyo del Puerto flows through the village of Old San Simeon, just south of the most southerly structure in the village, but the only development likely to be flooded would be a parking lot with trash cans and picnic tables at the State Beach on the seaward side of the village.
South and east of Cambria, there is agricultural development along Santa Rosa Creek, Perry Creek, Ellysly Creek, and Villa Creek at the extreme southern end of the planning area. Perry Creek also flows through the village of Harmony and could affect the small commercial and residential development there. In addition, Highway One crosses or is adjacent to all of these streams and the ocean and is subject to flooding and potential culvert and bridge washouts.
Flood hazard also exists in low lying, ocean-fronting areas from tsunami and storm wave runup. San Simeon Creek and the State Park campground could be subject to this type of flooding, as could Pico Creek, and other low lying coastal areas. this could conceivably also affect the Piedras Blancas lighthouse and research station and the Piedras Blancas Motel north of the lighthouse. Of course, Highway One would also be subject to flooding from tsunami and storm wave runup.
The LCP Coastal Policies document and Coastal Zone Land Use Ordinance provide regulations on new development and expansion of existing development in flood hazard areas. Both the existing NCAP and the Update contain a flood hazard combining designation. In the existing plan text it applies only to Santa Rosa, Perry, San Simeon, Arroyo de la Cruz, and San Carpoforo Creeks, although the combining designation map shows other streams with the flood hazard combining designation. The Update text adds Arroyo del Puerto, Oak Knoll, Little Pico, and Villa Creek. The combining designation map also shows Ellysly Creek, although it is not referenced in the text.
Conformance with the Coastal Act
For the rural area, the Update has no specific flood hazard standards. Those are contained in other parts of the LCP which are not part of this submittal. In addition, and in contast to standards for Cambria, the LCP prohibits new development within the 100 year floodplain in the rural areas. This is consistent with Section 30253. The Update identifies additional streams as flood hazard areas. However, a listing and/or discussion of Ellysly Creek in the Update as a flood hazard is omitted. In order to be found consistent with Coastal Act Section 30253 relative to flooding in the rural area, the combining designation flood hazard text should be modified to add Ellysly Creek.
Unlike bluff erosion, where the ongoing erosion is evident, seismic hazards are not readily apparent. The entire North Coast planning area is subject to damage from earthquakes, mostly through ground shaking. Local faults include the Oceanic and Cambria faults, and the San Simeon-Hosgri fault zone. The Cambria fault extends from the vicinity of Cayucos on the south to the vicinity of the Cambria area on the north. It is not officially designated as an active fault. It lies generally about one mile inland from the coast, although it may extend into the ocean north of Cambria, and there has been speculation that it may connect with the San Simeon-Hosgri fault system. The Oceanic fault lies about three to five miles inland. This fault is not officially designated as an active fault, although some researchers think that there may be a basis for considering the possibility of recent fault activity.
The local fault of greatest concern for future development in the planning area is the San Simeon-Hosgri fault. This fault complex is considered active and has been so designated by the State Geologist, at least where the San Simeon Fault is located on the land. The San Simeon and Hosgri sections appear to be connected offshore of the area between Cambria and San Simeon. The San Simeon fault lies in the vicinity of Old San Simeon. It extends on land in a north and northwesterly direction near the base of San Simeon Point at San Simeon Bay to the vicinity of Ragged Point, about 11 miles.
Although future development anywhere in the planning area is subject to seismic hazards, the largest single potential future development subject to seismic hazards is the Hearst Resort hotel in the area from the base of San Simeon Point to Highway One. This is the same area through which the San Simeon fault runs.
The Update proposes no changes to the existing area plan relative to seismic hazards. Both the existing plan and the Update call out the San Simeon fault as a geologic study area and note that it is an active fault subject to the provisions of the Public Resources Code Section 2621 et seq -- the Alquist-Priolo Act. In addition, the CZLUO for San Luis Obispo County incorporates PRC 2621 which addresses seismic hazards and its associated regulations (California Administrative Code Title 14, Sections 3600 et seq.), including the requirement that no structure intended for human occupancy be located within 50 feet of an acitve fault trace such as the San Simeon-Hosgri fault. It should be noted that in 1983, the time of original certification of the NCAP, the San Simeon fault had not been officially designated as a Special Studies Zone. That official designation did not occur until 1986.
Neither the existing plan nor the Update discuss seismic hazards elsewhere in the planning area. This is not inappropriate since there are no other faults officially designated as active in the planning area. However, the combining designation maps in the documents do not indicate that there is a seismic hazard area along the San Simeon fault, nor even that it is a Geologic Study Area, the County’s general combining designation for areas of geologic hazard. Although the official maps on file at the Planning Department do show the San Simeon fault as a Geologic Study Area and fault zone, the maps in the existing area plan and in the Update do not give any indication of the fault zone.
As currently modified, the NCAP does not sufficiently recognize the risks posed by seismic hazards in the North Coast planning area. In particular, since the LCP was certified, the State Geologist has designated the San Simeon-Hosgri fault as an active fault, subject to the requirements of the Alquist-Priolo Act. Indeed, several recently published studies of the San Simeon-Hosgri fault zone indicate an average rate of slip along the San Simeon fault of from 0.4 mm to 11 mm/yr. However, the "best constrained" value appears to be from 1 mm to 4 mm/yr. (see Hall, Hunt, and Vaughan; and Hanson and Lettis in Seismotectonics). Maximum lateral movement in a single event has been estimated to be about 1 to 2 m. That kind of seismic event is estimated to occur within a range of from 265 to 2,000 years, with the "best constrained" values between 600 and 1,800 years (Hall, Hunt, and Vaughan).
Considered an active fault, i.e., having surface displacement in about the last 11,000 years, by the State Geologist, the San Simeon fault is therefore mapped as being an Alquist-Priolo Special Studies Zone. The Special Studies Zone is centered on the main fault trace and extends out for 500 feet on either side of the fault trace. In this zone a detailed geological report is required when structures for human occupancy are proposed. In any event, no structure intended for human occupancy may be located within 50 feet of an active fault trace, i.e., where the fault intersects the surface of the earth. This is a requirement of PRC 2621 and Title 14, section 3600 et seq. of the State Administrative Code. It is also found in the County’s land use ordinance at Section 23.07.086b.
The San Simeon-Hosgri fault trace is most problematic for the proposed Hearst Resort development. The NCAP does not contain any specific discussion of the prohibition of development within 50 feet of the fault zone in relation to the proposed building envelope. In addition, there are other features that may indicate the presence of other faults in the proposed hotel area. Some of these occur east of the Special Studies Zone, and there is speculation that they may be active and part of the Arroyo Laguna fault, which is associated with the San Simeon fault zone and which lies parallel to the San Simeon fault trace. In the area between Highway One and San Simeon Point, the two faults appear to be at most a few hundred feet apart and may come together. Envicom Corporation, under contract to the property owner, Hearst Corporation, in San Simeon Environmental Constraints Study, dated October 18, 1994, discusses the possibility of active faulting (Arroyo Laguna fault?) 600 to 700 feet northeast of and parallel to the San Simeon fault. That study also places the San Simeon fault approximately 400 feet east of where it is shown on the Alquist-Priolo Special Studies Zone map and with a trend more to the northwest. Other features not positively identified as faults are near the base of the Point and in the west central part of the site.
Quite obviously, any future development proposal will need to be based in part on the results of a comprehensive geologic investigation of the entire site. The Update states that the exact location of the building envelope for the hotel and accessory uses "shall be located within the preferred area (not on San Simeon Point) to be further determined during required Environmental Impact Report and Local Coastal Permit Processes." Still, in light of new information since certification concerning the San Simeon-Hosgri fault trace, more rigorous regulation of development is required to bring the NCAP into conformance with section 30253.
Based on the requirement of the Special Studies Zone that no structure for human occupancy is allowed within 50 feet of the fault trace, a line parallel to and 50 feet to the northeast of the San Simeon Fault trace defines the westerly extent of the building envelope for any structure intended for human occupancy in the proposed future Hearst resort at Old San Simeon. This building envelope is subject to revision based on detailed geological investigations but in no case shall this building envelope be expanded to the southwest beyond a line parallel to and 50 feet to the northeast of the San Simeon Fault trace. Other development, such as a parking lot, or building not intended for human occupancy could be located anywhere within the Special Studies Zone unless a geologic report indicated otherwise. Therefore, although no structure intended for human occupancy may be allowed closer than 50 feet from the fault trace, it would be appropriate to locate parking and support buildings westerly of any structures designed for human occupancy, i.e., from 50 feet northeast of the fault trace to 500 feet southwest of the trace. (Please refer to the Development Section of this report for further details of the building envelope.)
Unless otherwise prohibited by the development limits imposed by Public Resources Code Section 2621 et seq., due to the presence of the Special Studies Zone, the NCAP should be modified to limit development between a line 50 feet northeast of and parallel to the San Simeon Fault trace and the southwest boundary of the Special Studies Zone to parking areas, grazing, interpretive signing, public coastal access trails, landscaping, and other miscellaneous development associated with continued agricultural use or resort use, but not including structures for human occupancy.
It is clear from the Special Studies Zone requirements that a hotel or other structures proposed for human occupancy could not be sited in the near-vicinity of the San Simeon fault trace. Since it is unknown just what the potentially fault-indicative features elsewhere on the site are, any environmental impact report and coastal development permit will need to address the geology of the site in detail. Therefore, to maintain consistency with Coastal Act Section 30253, a Standard is needed to require that site selection for the proposed future development northwest of San Simeon shall also require, and be based on a detailed geological investigation and report conducted by a certified engineering geologist or other qualified professional. If the County modifies the Update to include this requirement, then the Commission can find the document consistent with Coastal Act Section 30253 relative to seismic hazards. (Please see suggested modification 97.)
The Update maps do not indicate that an Alquist-Priollo Special Studies Zone has been established for the San Simeon fault. The County should modify the Update maps to indicate the presence of the Alquist-Priollo Special Studies Zone.
4. Fire, Landslides, and Non-coastal bluff erosion
Fire, landsliding, and non-coastal bluff erosion hazards are addressed only obliquely, if at all, in the existing Area Plan and in the NCAP Update. However, these hazards are adequately addressed in other sections of the County's' LCP, primarily the Coastal Policies document and the Coastal Zone Land Use Ordinance (CZLUO). In general, the LCP requires the following:
There is no need for new or modified standards in the Update regarding fire, landsliding, or non-coastal bluff erosion. Policies and standards to minimize those hazards already exist in the LCP. No issues have been identified by staff that would suggest a need for additional area-specific standards or programs. Therefore, the NCAP is consistent with the Coastal Act with respect to fire, landslides, and non-coastal bluff erosion hazards.
Coastal Act Policies
Archeological resources are protected by Coastal Act Section 30244, which requires that development that would adversely impact archaeological resources provide mitigation for such impacts. In addition, section 30250 requires that new development not have significant adverse effects, individually or cumulatively, on coastal resources.
Overview of North Coast Archaeology
The North Coast of San Luis Obispo County is rich in archeological sites. The area marked the northern extent of the Chumash people and the southern extent of the Salinan people. While only about 10 percent of the North Coast Planning Area has been surveyed for archeological sites, at least 153 prehistoric sites have been identified and recorded.
Within the Cambria Urban Reserve Line there are at least 25 archaeological sites. Several of those are on the East-West Ranch, the single largest undeveloped property within the Cambria Urban Reserve Line, and total about three to four acres, or roughly one percent of the area of the East-West Ranch. In the rural area, sites located at or near the proposed Hearst resort and golf course northwest of San Simeon, excluding San Simeon Point, are estimated to cover from about 172 to over 225 acres or (about 39 percent to about 51% percent of the area). The sites on San Simeon Point cover about 13 acres, or about 20 percent of the area of the point.
The inventory of 153 recorded sites should by no means be considered complete, since only 10 percent of the planning area has been surveyed and the survey methodology for many of those sites would not be acceptable under current standards used by professional archaeologists. Furthermore, not all of the known sites have had subsurface investigations; for those sites there is incomplete information about their nature and significance.
1. Urban Areas: Cambria and San Simeon Acres
Numerous archeological sites exist in Cambria, with more than a dozen in the Lodge Hill area alone. On the single largest undeveloped property in Cambria, the East-West Ranch, numerous sites also have been identified. Much of the area along the lower reach of Santa Rosa Creek is developed and has been for decades. Areas along creeks are often likely locations of archeological sites. In the East Village, with its intensive development, any sites that may have been located on the north side of the creek, where most of the development is, have been subjected to great disturbance. The south side of the creek is less developed and could conceivably harbor additional archeological resources. This is especially the case where Santa Rosa Creek lies between the east part of the East-West Ranch and the Mid-State Bank property and between Highway One and the west part of the East-West Ranch. West Lodge Hill and the East-West Ranch have numerous sites.
San Simeon Acres currently is built out with almost one-half of its allowable residential units. In contrast, existing commercial use (which is the only other land use in San Simeon Acres other than the waste water treatment plant), has about 50 percent of the total potential buildout remaining. Nonetheless, most of the land area of San Simeon Acres has been disturbed. The two most likely locations for archeological sites are along the two creeks: Pico Creek and Arroyo del Padre Juan. Very little, if any, development could occur in the community on undisturbed land. New archeological discoveries, while not impossible, are unlikely in San Simeon Acres.
Conformance with Coastal Act
In the existing NCAP, Cambria Urban Area Communitywide standard 8A, which applies only to the East-West Ranch, requires that development not occur in areas of archaeological resources, except for crossing bridges and bicycle and pedestrian paths. This requirement is carried over in the Update on page 7-62, Standard 13.C.2, applicable only to East-West Ranch. Cambria Urban Area Recreation Standard 25 contains the same language as the previously mentioned standard, but applies only to the Recreation category in the East Village (Mid-State Bank site). That standard is carried over in the Update but under Cambria Urban Area Commercial Retail Standard 8 on page 7-81. This is because the Update, is also proposing that part of the Mid-State Bank site be redesignated Commercial Retail. Neither the existing Area Plan nor the Update contain an areawide standard protecting archaeological resources.
Archaeological policies and standards applicable throughout the Coastal Zone are found in other portions of the LCP, specifically in the Coastal Plan Policy document and in the Coastal Zone Land Use Ordinance (CZLUO). According to the Update EIR, two additional archeological mitigation measures, which the County would eventually apply county-wide, are being considered with the update of another, non-coastal area plan. One measure includes adding six existing policies from the Coastal Plan Policy document to the CZLUO or the Framework for Planning. It is unclear how this repetition of existing policies elsewhere in the LCP would afford any added protection to archaeological resources. In any event, they are not proposed to be included in the Update.
The second archaeological mitigation measure would extend the archeological protection and mitigation measures currently applied only to discretionary permits to all projects resulting in earth disturbance. These include (1) site-specific research surveys and inventory of site resources by archaeologists where existing information is not adequate or where database and professional experience suggest the presence of cultural resources; (2) implementation of a County-approval plan by the developer to avoid impacts or preserve important resources based on survey recommendations prior to project approval; and (3) protection of sites by designating them open space, by use of easements, or other means.
It must be emphasized that the mitigation measures from the EIR outlined above are not included in the Update, as standards (mandatory regulations) or as programs (non-mandatory County actions dependent on future funding, etc.). In order to be consistent with Coastal Act Section 30244, therefore, it is necessary to require systematic surveys of development sites. In particular, a new archaeological protection standard 26 should be added to the Update Areawide Standards that requires preliminary site surveys by professional archaeologists for sites proposed for development, with additional investigation if, in the professional opinion of the archaeologist conducting the survey, additional investigation is warranted (see Modification 65).
Similarly, the East-West Ranch is proposed for large scale development (265 units). It is known that this area has numerous archeological sites. Because of this, and to be consistent with Coastal Act section 30244, it is appropriate to modify East-west Ranch standard 10, Permit Requirements, to require that an application for any proposed development on any part of the East-West Ranch shall include an archaeological site survey by a professional archaeologist according to current professional and CEQA standards (see Modification 117). Standard 13.C.2 also must be modified to require that where artifacts or human remains are discovered, no development be allowed there unless there is no feasible alternative site for the development and after consultation with representatives of the Chumash as to disposition of artifacts or remains found. If the County so modifies the Update, relative to archaeology in the Cambria urban area, it can be found consistent with sections 30244 and 30250.
Finally, as discussed above, it is unlikely that new archaeological sites will be found within San Simeon Acres, where there are no large undeveloped areas such as the East-West Ranch in Cambria. Therefore, no site specific archaeology standards are needed in that area to ensure consistency with Coastal Act section 30244 and 30250.
The rural areas of the North Coast have a higher likelihood of containing undiscovered archeological sites than do the urban areas because of the prevalanece of large rural parcels with relatively little disturbance. However, there are disturbed sites in the rural area where little in the way of new archeological material will likely be found. These areas include San Simeon State Park campground (which contains recorded sites), Old San Simeon, the Hearst Castle visitor center-staging area, the Piedras Blancas Lighthouse, and the Piedras Blancas Motel. The Highway One right-of-way also contains relatively undisturbed areas outside of the actual road area where archeological sites could exist. In particular, archaeologic sites exist in and near the recent realignment of Highway One in the Twin Creeks vicinity. Other known locations and/or potential archeological sites are along the creeks in the rural area such as Pico, Little Pico, Arroyo del Puerto, Oak Knoll Creek, Arroyo Laguna, Arroyo de la Cruz, and San Carpoforo Creeks; and the area including and from San Simeon Point to Oak Knoll Creek, where the Hearst resort and golf course would be located.
Conformance with Coastal Act
In the existing NCAP, Rural Area Recreation Standard 24, which applies only to the Hearst Ranch, requires a preliminary site survey prior to completion of site plans for development, and requires mitigation measures whenever feasible. The County is not proposing to carry this standard over in the Update. Given the potential for archaeological sites in the vicinity of the Hearst Resort development, removing this requirement would not be consistent with Section 30244.
More important, though, in 1993 and 1994, an eminent local professional archaeologist, Robert O. Gibson, under contract to Envicom Corporation, conducted surface surveys of the area of the Hearst proposed golf course and resort and of San Simeon Point. According to the constraints studies, three new prehistoric archaeological sites were discovered on the 440 acre golf course and resort location, and one new prehistoric archaeological site and two historic sites were discovered on the Point.
As a result of these investigations, Gibson estimated that up to about 51 percent (225 acres) of the area of the proposed resort and golf course contains known archaeological sites. According to the constraints study, Envicom planimetered the sites on an engineered topographic base map and estimated that the known archaeological sites cover about 39 percent (172 acres) of the area of the proposed golf course and resort. Approximately 20 percent (13 acres) of the area of San Simeon Point, not proposed for development, contains known archaeological sites.
Since Gibson’s work was a surface survey and did not include detailed subsurface work, the exact extent and nature of the sites is unknown. However, it is clear that the sites are extensive.
Professional archaeologists have long urged avoidance of archaeologic disturbance through project re-siting or re-design as the preferred method of mitigation. Where avoidance is not feasible, other forms of mitigation including scientific excavation are called for. As submitted, the Update will not result in the necessary mitigation, and does not conform to Coastal Act policies.
Given the large area of the archaeological sites in this location, and to maintain consistency with Coastal Act section 30244, it is necessary not only to retain a requirement for preliminary site surveys, but also to modify Standard 3 on page 7-16 to include impacts to archaeological resources as one of the items to be reviewed before development; and to require that an application for any proposed development shall include a report of a detailed subsurface investigation by a professional archaeologist according to current professional and CEQA standards. For the same reasons, it is necessary to require that site selection shall also require and be based on a detailed subsurface archaeological investigation and report by a professional archaeologist according to current professional and CEQA standards and including consultation with and incorporation of comments from acknowledged representatives of the Chumash. (See Modification 97.)
California Environmental Quality Act (CEQA)
The Coastal Commission’s review and development process for LCPs and LCP amendments has been certified by the Secretary of Resources as being the functional equivalent of the environmental review required by CEQA. Therefore, local governments are not required to undertake environmental analysis on LCP amendments, although the Commission can and does use any environmental information the local government has developed. CEQA requires that alternatives to the proposed action be reviewed and considered for their potential impact on the environment and that the least damaging feasible alternative be chosen as the alternative to undertake.
The final Environmental Impact Report (EIR) for the North Coast Area Plan Update was released on March 20, 1996. It analyzed four alternative development scenarios: 1) no development, 2) existing plan buildout, 3) Area Plan Update plus owner requested land use changes, and 4) reduced project which would modify the Area Plan Update to reduce overall development. Ultimately, the County adopted alternative 4. The EIR identified significant, unavoidable adverse impacts to circulation and water, for which the Board of Supervisors issued a "statement of overriding considerations" under Section 15093 of the CEQA Guidelines. Subsequently, the Board made three revisions to the Update, each time issuing an EIR addendum finding that the revisions were minor. The revisions included increasing maximum development of the Hearst Ranch Resorts and the East West Ranch, and reducing the minimum parcel size on the east and north sides of Cambria, adjacent to the Urban Reserve Boundary.
The North Coast Area Plan (NCAP) Update amendment contains various policies which would strengthen visual resource protection standards, amplify tree removal criteria, moderately shift major development locations on the Hearst Ranch and East/West Ranch, and result in numerous other revisions to the certified LCP. However, in many instances these revisions are insufficient to adequately protect resources or to result in Coastal Act conformance. For example, some of the tree protection measures are not mandatory; the creation of new "viewshed" lots along Highway One would still be possible; and the amount of development allowed in the Hearst Ranch Resorts Plan section of the NCAP exceeds known water supplies. Accordingly, the NCAP Update as submitted does not represent the least environmentally damaging feasible alternative. However, these deficiencies can be corrected if the County adopts the Suggested Modifications attached as Appendix A to these Findings. If so modified, the NCAP as amended will not have significant environmental effects for which feasible mitigation measures have not been employed consistent with the California Environmental Quality Act.
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