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WHAT IS SCOPING???. First opportunity for public to define the issues that should be analyzed in the Environmental Impact Report or EIR. Christina McGinnis, Bioregional Planning Associates, mcginnis@peoplepc.com.

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what is scoping

First opportunity for public to define the issues that should be analyzed in the Environmental Impact Report or EIR

Christina McGinnis, Bioregional Planning Associates, mcginnis@peoplepc.com


Sprawl: The Threat to Gaviota“All that is constant about the Californiaof my childhood is the rate at which it disappears.” -The writer Joan Didio

will our eden lose its garden
Will Our Eden Lose its Garden?


A recent survey by the Pew Center found that suburbansprawl ties with crime as a top local concern for most Americans

what is our vision the rural natural character of the coast must be preserved
Avoid coastal bluffs, Highway 101 corridor, the public viewshed, and sensitive habitat areas.

Ocean and nearshore habitats, grasslands, wetlands, creeks and wildlife corridors are the primary areas that warrant protection.

What is our vision?The rural, natural character of the coast must be preserved.
background the south central coastal bioregion
Background: The south-central coastal bioregion

Naples is an important part of the south coast region, which is recognized as one of the top “hot” spots for biodiversity in the world, and is considered of national and international significance.

When you turn to the mountains, think of the sea……..

a sample of coastal act policies
A Sample of Coastal Act Policies

California ranks second in the country in the number of listed endangered and threatened species. 2/3 of the listed species depend on aquatic ecosystems during part of their life cycle.

The Coastal Act § 30251 requires the protection of views in the ocean and scenic coastal areas of Naples.

The Coastal Act § 30240 protects environmentally sensitive habitat areas from significant disruption.

The Coastal Act § 30231 requires the protection of coastal and marine ecosystems from development and its impacts, including watersheds, wetlands, and kelp areas and associated marine biodiversity…

important policy issues
Important Policy Issues
  • EIR should use a comprehensive baseline of constraints and existing policies to analyze impacts
  • A “worst-case” policy assessment should be undertaken that addresses cumulative impacts, policy precedents, and the long-term implications of policy decisions
environmentally sensitive habitats
EnvironmentallySensitive Habitats
  • Native vegetation, particularly grasslands, must be adequately buffered and protected.
  • All wetlands should be characterized according to County Thresholds and Guidelines
  • Maintain largest possible areas of contiguous open space to support habitat, wildlife corridors, and foraging areas.
  • Assess collective losses to several animal populations on site and identify impacts on an individual, species-by-species basis.

The sensitive intertidal wetland

visual resources
  • Changes in the scale, land use patterns, and visual character/compatibility
  • Alternatives considered in the EIR should protect views and the rural character (Highway 101 and R.R.)
  • 3-D simulations from the HWY 101 corridor (day/night). Design elements should be used to screen development.
  • Required fire clearance areas for homes and soundwalls
growth inducement
Growth Inducement
  • Growth inducement from a project of this urban density in a rural area
  • Extension of services (police, fire)
  • No potential for extension of public sewer services to the area and major policy inconsistencies with the proposed Sewage Treatment Plant in the coastal zone.

The project and associated zoning district must be crafted to prevent a precedent for converting agricultural lands

  • A thorough analysis of the project's and alternatives' consistency with agricultural protection policies and the Agricultural Preserve Program and Williamson Act must be undertaken.
  • Eliminating grazing from the project site without a careful management and restoration plan could be a problem
  • Cattle Removal and Weed Explosion should be analyzed
cultural resources

A full Phase I report should be prepared for the project site given the archaeological sensitivity of the western portion of the coastal side of the development.

health and safety concerns
  • Beachgoers and slides
  • Landslides from unstable soils
  • Protection for residents from fire hazards

Bluff Erosion

grading and erosion concerns
  • The proposed grading plan would include over 60,000 cubic yards of grading.
  • Currently proposing major grading across a drainage
  • Slope stability issues (landslides, mudslides, and erosion issues) associated with the Rincon formation and earthquake faults
geologic concerns
Geologic Concerns
  • 75 year setback with sea level rise and coastal erosion should be revisited by the County. (75 years not enough).
  • Erosion and sedimentation during construction activities
hydrologic concerns
  • State water allocations uncertain
  • No apparent stable water source for the project.
  • How much untreated water is available, and whether there is capacity to treat water on the site. In addition, there is the concern of the effluent-where will it go?
  • Groundwater impacts from septic tanks and on-site retention basins
  • Proposed inland dry wells may not percolate properly
  • Increased surface runoff into the ocean
  • Change in drainage patterns
public services
Public Services
  • Occupancy estimates
  • Which schools would serve the site? Do they have the capacity and how would students be bussed?
  • Student generation rates
  • Undergrounded utilties
  • Any changes to offramps/onramps leading to the site should be designed so the rural character of the area is maintained and grading is minimized.
recreation concerns
  • Access -Under the Coastal Act, recreation policies must be consistent with resource protection.
  • Proposed concrete stairway overconstructed and visually undesirable
  • Safety impacts of the public’s use of the beach-Rincon Shale
project alternatives
Project Alternatives
  • Support detailed study of alternatives that would transfer development to existing urban sites. (LCP Policy 2-13)
  • Many alternatives should be considered and addressed, assuming they have the potential to reduce impacts.
  • Alternatives should be based on real, “on the ground” development potential, using a baseline created by a full analysis of constraints.
  • Include alternatives in the EIR that do not rely on a package sewer plant.
  • Include a broad range of alternatives in the EIR with onsite alternatives that do not involve placing development on adjacent properties. 
  • Project Description (PD)

The PD should state what the intent is for the sale and development of the lots. Would it be designed as a “planned community” development? How would the impacts to visual resources change if the property was an individual “lot-sale”, rather than a planned development?

impacts on sensitive ecosystems
Impacts on Sensitive Ecosystems

Impacts from urban and agricultural development on sensitive coastal and marine ecosystems and creeks

Tomate Canada Creek

the importance of naples reef
The Importance of Naples Reef

Naples Reef, a reef wetland, is one of the few reef wetlands of this type found along the southern California coast.

Naples Reef contains the highest diversity of intertidal organisms within the County. The benthic algae on Naples reef are considered one of the best examples on the South Coast.

Total Area: 18.98 square n.m.

Total Shoreline length: 6.49 n.m.

Habitats: Rocky reef, kelp beds, sandy bottom.

Depth range 0 to 145 fathoms, or 0 to 265 meters.

top marine areas in southern california
Top marine areas in southern California

The Santa Barbara County Comprehensive Plan Conservation Element recommends that Naples Reef be preserved as a scientific research and educational area because of its unusual biological character.

Snowy Egrets

The reefs in this area are incredibly diverse, particularly the offshore Naples reef, and is home to a rich diversity of benthic invertebrates, fish and seaweeds that form a unique ecosystem in this area.

Naples Reef is one of the two most thoroughly studied rocky reefs in Southern California.

local coastal plan policies
Local Coastal Plan policies

CLUP Policy 7-19: In order to protect the marine resources of Naples Reef and the

adjacent beach as a hauling out area for harbor seals, intensive recreational use shall not be encouraged (emphasis added). Access to the site should continue to be by way of boats.

CLUP Policy 9-24: Recreational activities near or on areas used for marine mammal

hauling grounds shall be carefully monitored to ensure continued viability of these habitats.

CLUP Policy 9-25: Marine mammal rookeries shall not be altered or disturbed by

recreational, industrial, or any other uses during the times of the year when such areas are in use of reproductive activities, i.e., mating, pupping, and pup care.

CLUP Policy 9-31: Only light recreational use shall be permitted on public beaches which include or are adjacent to rocky points or intertidal areas.

CLUP Policy 9-33: Naples reef shall be maintained primarily as a site for scientific

research and education. Recreational and commercial uses shall be permitted as long as such uses do not result in depletion of marine resources (emphasis added).


Threats to the beach, nearshore and marine environments from urban development -Water quality impacts to intertidal, kelp and eelgrass habitats.

shorebirds raptors and marine mammal haulout
Shorebirds, raptors, and marine mammal haulout

Endangered Brown Pelicans

Black shouldered kite

Black shouldered kite

Dead new born harbor seal

The impacts from increased recreational use on the sensitive areas of the beach, particularly the marine mammal haul-out area and nearshore bird use of the intertidal area at low tide, should be analyzed.

Limited public access should be allowed given these concerns.

Blue Heron


Eel Grass