State of California - The Resources Agency
California Coastal Commission
North Central Coast District
45 Fremont, Suite 2000
San Francisco, CA 94305-2219
Voice and TDD (415) 904-5260
FAX (415) 940-5490

February 25, 2004
Pat Fitzgerald
Wavecrest Village LLC
2450 South Cabrillo Highway, Suite 200
Half Moon Bay, CA 94019

SUBJECT: Wavecrest Village Project Wetland Delineation

Dear Mr. Fitzgerald:

As you know, in considering your coastal development permit application for the
proposed Wavecrest Village project, the Coastal Commission is required to
determine whether any of the proposed development is located within 100 feet of
a wetland as defined under the Half Moon Bay LCP. To aid the Commission in
addressing this issue, I have requested that Dr. Dixon prepare a map of the
project site depicting all LCP wetlands that have been delineated, and to
indicate any areas where we disagree about the interpretation of the wetland
delineation data. To facilitate this task, Dr. Dixon has requested that Dr.
Josselyn provide in digital format all mapping data associated with the wetland
delineations that Wavecrest Village LLC has conducted for the project.

To date, we have received wetland delineations for four areas on the project
site, including:

1. Polygons 18 and 19,
2. The drainage ditch
3. The former agricultural pond, and
4. The wetlands to the north of the ballfields.

I have marked these areas as numbers 1-4 on the enclosed copy of the June 26,
2003 Wavecrest Village Illustrative Plan.

As we discussed in our telephone conversation yesterday morning, we still have
not received a delineation of the wetlands in the Central Area. Although you
have provided a map depicting the boundaries of wetlands located in the Central
Area, this map alone does not comprise a wetland delineation as that term is
understood by the Commission. To be complete, the wetland delineation must
include in addition to a map, the analysis and data upon which the map is based.
The data and analysis are necessary to enable the Commission to independently
verify the wetland boundaries as depicted by the delineation map.

In addition, as we also discussed yesterday. we have not received delineations
for other areas of the site that appear to be shown as wetlands on the June 26,
2003 Illustrative Plan These areas are indicated with a question mark on the
enclosure. Please clarify whether it is your position that these areas are
wetlands. If this is your position, please provide the basis on which you have
determined that these areas are wetlands along with all available wetland
mapping and delineation data available for these areas.

Finally, I would like to clarify staff's position concerning the present state
of information related to the presence of wetlands on the Wavecrest Village
site. Based on the available information at this time, the Northern Area of the
site, where, as shown on the June 26, 2003 Illustrative Plan, the middle school,
affordable housing and a portion of the market-rate residential development are
currently proposed to be located, appears to be uplands. However, as noted in
the November 29, 2001 staff report for the project, the westernmost extent of
the residential subdivision proposed in the Northern Area is located within 100
feet of wetlands associated with the drainage ditch. Staff's position remains
unchanged from our recommendation in 2001 that no development may be located
within 100 feet of these wetlands.

The June 26, 2003 Illustrative Plan includes development in areas of the site
where development had not previously been located. This latest plan was first
provided to Commission staff on February 6, 2004 during our meeting concerning
wetland issues. Thus, we have only recently been able to begin considering the
substantial project changes indicated by this plan. Changes to the project plans
that propose development in areas of the site where no development has
previously been proposed may require additional information to enable staff to
review the modified plans for LCP consistency. In the future, we recommend that
you discuss proposed project changes with staff as early as possible in order to
avoid or at least minimize delays in the permitting process.

The Illustrative Plan shows a residential subdivision in the area of the site
where the ballfields are currently located and where the school was previously
proposed to be located. None of the previous project plans proposed development
in the area of the ballfields to the west of the former school site. As such,
staff has not previously evaluated whether or not wetlands are present in this
area. According to the July 28, 2000 Vegetation Study prepared for the project
site, it appears that the most of the ballfield area does not contain wetland
vegetation. However, some of the sampling points in this area, including Sample
Points 9.3 and 11.6 contain a preponderance of hydrophytic vegetation and
therefore appear to meet the LCP definition of wetlands. A complete wetland
delineation should be conducted for this area to determine the boundaries of any
wetlands present (as suggested by Sample Points 9.3. and 11.6), as well as any
other wetlands in this portion of the site so the Commission may assess whether
the current project plan to site development in the ballfield area would conform
to the LCP wetland protection policies.

The June 26, 2003 plan also shows a community garden in the western area of the
site where no development has previously been proposed to the Commission. The
plan also shows an apparent wetland just to the north of the community garden.
This apparent wetland is one of the areas indicated by a question mark on the
enclosure as an area for which no wetland delineation bas been provided. A
wetland delineation for this area of the site is necessary to enable the
Commission to determine if the proposed community garden is sited consistent
with the LCP wetland development and buffer standards. If this area has been the
subject of a wetland delineation study, please provide that study as soon as
possible so that staff may verify the wetland boundaries mapped for this area.
If a delineation has not been conducted, staff recommends that you eliminate the
community garden until such time that the information necessary to evaluate
development in the areas of the project site for conformity with the LCP is

Chris Kern
Coastal Program Manager
North Central Coast District