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 available. Sincerely, /s/ Chris Kern Coastal Program Manager North Central Coast District