Wednesday, July 27, 2016

Two 10 August 2016 California Coastal Commission Agenda Items: City of Carmel-by-the-Sea LCP Amendment No. LCP-3-CML-16-0005-1 Part A (Affordable Housing Incentives) & Appeal No. A-3-CML-16-0057 (Henderson, Carmel-by-the-Sea)

ABSTRACT: Two 10 August 2016 California Coastal Commission Agenda Items, namely City of Carmel-by-the-Sea LCP Amendment No. LCP-3-CML-16-0005-1 Part A (Affordable Housing Incentives) and Appeal No. A-3-CML-16-0057 (Henderson, Carmel-by-the-Sea), are featured. Regarding City of Carmel-by-the-Sea LCP Amendment Number LCP-3-CML-16-0005-1-Part A (Carmel Affordable Housing Incentives), SUMMARY OF STAFF RECOMMENDATION is reproduced; the Staff Report document copy is embedded. And regarding Appeal No. A-3-CML-16-0057 (Henderson, Carmel-by-the-Sea), SUMMARY OF STAFF RECOMMENDATION is reproduced; the APPEAL STAFF REPORT: SUBSTANTIAL ISSUE DETERMINATION & DE NOVO HEARING document copy is embedded.


California Coastal Commission

Hilton Santa Cruz/Scotts Valley
6001 La Madrona Drive
Santa Cruz, CA 95060

Wednesday August 10, 2016 9:00 a.m.


CENTRAL COAST DISTRICT

15. LOCAL COASTAL PROGRAMS (LCPs).
See Agenda Categories 

Public hearing and action on request by City of Carmel-by-the-Sea to amend the Implementation Plan’s incentives for affordable housing, including by establishing new standards for density bonuses in areas with Core Commercial and Residential/Commercial land use designations, for "Bonus Density" allowances within the R-4 zoning district, and for "Floor Area Bonus" allowances for R-4 and Commercial zoning districts. (KK-SC)

City of Carmel-by-the-Sea LCP Amendment Number LCP-3-CML-16-0005-1-Part A (Carmel Affordable Housing Incentives)

SUMMARY OF STAFF RECOMMENDATION

The City of Carmel-by-the-Sea proposes to amend the Local Coastal Program’s (LCP) Implementation Plan (IP) by clarifying and adding to the incentives for the development of affordable housing. Specifically, the amendment modifies IP Section 17.64.190 by: (1) establishing new standards for granting Density Bonuses (as allowed by Government Code Section 65915); (2) clarifying that the IP’s “Bonus Density” incentives (a separate City program aimed at encouraging affordable housing construction) apply only to areas zoned multi-family residential (R-4) and when one of the existing standards specified in 17.64.190 is satisfied; and (3) specifying that affordable housing units produced pursuant to the Density Bonus, Bonus Density, or Floor Area Bonus incentives (another City program to encourage affordable housing) be administered by a City approved affordable housing agency. The amendment also adds definitions to “transitional housing” and “supportive housing”, and adds “Group Residential” as an allowable land use in the R-4 zone.

The LCP currently includes a series of policies and standards aimed at encouraging the creation of affordable housing, and offers a suite of incentives to do so. For example, the Land Use Plan (LUP) allows Density Bonuses of up to 35% above the otherwise LCP-specified density maximum in areas with Core Commercial and/or Residential/Commercial land use designations. The existing IP also includes a series of programs aimed at encouraging affordable housing, including “Floor Area Bonuses” for development within commercial and R-4 zoning districts that provide a specified amount of affordable housing (e.g., up to a five percent increase in floor area if 25% of the housing units are affordable to moderate income persons), and “Bonus Density” incentives of up to 44 units per acre (above the otherwise allowed 33 units per acre) specifically in R-4 zoning.

As set forth in the proposed amendment, Bonus Density is applicable only in the R-4 zoning district, and the findings in IP Section 17.64.190 have to be met, including that 20% of the units will be reserved for “lower-income households” (or 10% for “very-low income households” or 50% for “senior citizens”). For Density Bonus, the applicable findings of IP Section 17.64.190 have to be met, including: conformance with State Density Bonus Law and LCP policies (other than density); and restriction to Core Commercial and/or Residential/Commercial land use designations. Finally, affordable housing produced via any of the aforementioned incentives (Density Bonus, Bonus Density, or Floor Area Bonus) must be administered by a City-approved affordable housing agency. In essence, IP Section 17.64.190 serves as an implementing ordinance to ensure, in context of the LCP’s existing framework, that projects receiving incentives/modifications to development standards from the LCP’s numerous affordable housing incentives provide affordable housing in a clear, enforceable manner, while ensuring coastal resources are protected.

Commission staff has worked collaboratively and extensively with City staff to craft an amendment that incentivizes the construction of affordable housing within Carmel-by-the-Sea in a manner that clearly communicates the different incentives available to do so, and in a manner that respects and protects the City’s unique coastal resources. Therefore, staff recommends that the Commission find the proposed amendment consistent with and adequate to carry out the policies of the LUP, and that the Commission approve the amendment as submitted. The motion and resolution are found on page 4 below.
CALIFORNIA COASTAL COMMISSION
W15a
Prepared July 22, 2016 for August 10, 2016 Hearing
To: Commissioners and Interested Persons
From: Susan Craig, Central Coast District Manager
Kevin Kahn, Central Coast District Supervisor
Subject: City of Carmel-by-the-Sea LCP Amendment Number LCP-3-CML-16-0005-1-
Part A (Carmel Affordable Housing Incentives)


16. NEW APPEALS.

d. Appeal No. A-3-CML-16-0057 (Henderson, Carmel-by-the-Sea)
Appeal by Commissioners Shallenberger and Howell of decision by City of Carmel-by-the-Sea granting permit with conditions to Wellington Henderson Jr. for construction of 8-ft.-tall, 63-ft.-long upper bluff wall with faux bluff facing and drainage and landscaping improvements on bluffs fronting 26336 Scenic Rd., along Carmel Beach in Carmel-by-the-Sea, Monterey County. (MW-SC)

APPEAL STAFF REPORT: SUBSTANTIAL ISSUE DETERMINATION & DE NOVO HEARING
Appeal Number: A-3-CML-16-0057
Applicant: Wellington S. Henderson, Jr.
Appellants: Commissioners Mary Shallenberger and Erik Howell
Local Decision: Approved by the City of Carmel-by-the-Sea Planning Commission on April 13, 2016 (City application number DS 15-158).
Project Location: On the bluffs at the south end of Carmel Beach fronting 26336 Scenic Road, Carmel-by-the-Sea, Monterey County (APNs 009-423-001 and 002).
Project Description: Construction of shoreline protective device designed as an eight-foot tall and 63-foot long upper bluff retaining wall with faux bluff facing and related drainage and landscaping improvements.
Staff Recommendation: Substantial Issue Exists; Denial

SUMMARY OF STAFF RECOMMENDATION

The City of Carmel-by-the-Sea approved a coastal development permit (CDP) to construct a shoreline protective device designed as an eight-foot tall and 63-foot long upper bluff retaining wall with faux bluff facing and related development (i.e., drainage and landscaping improvements) on the bluffs fronting a residential site at the south end of Carmel Beach. The site is the location of a circa 1948 Frank Lloyd Wright-designed house, which is a notable historical residence in the City of Carmel. The residence is sited on a bedrock outcrop at the south end of Carmel Beach and is highly visible from most vantages along the beach and the Scenic Road recreation trail. The City’s CDP decision was appealed to the Commission based on questions regarding potential inconsistencies with the LCP’s policies and standards for shoreline protective devices.

Staff recommends that the Commission find that the appeal raises a substantial issue and that the Commission take jurisdiction over the CDP application. Staff further recommends that the Commission deny a CDP for the proposed seawall at the site.

The LCP requires a three-step process to allow for shoreline protective devices: 1) identify an existing structure in danger from erosion; 2) identify a range of alternatives and select the least environmentally damaging alternative to abate the identified threat; and 3) mitigate for all coastal resource impacts caused by the selected shoreline protective device. However, the City’s approval did not adequately identify an existing structure in danger from erosion, did not analyze any alternatives, and did not identify and mitigate for all resultant coastal resource impacts caused by the approved project. For all these reasons, the City’s approval raises substantial LCP conformance issues.

On de novo review, the Applicant’s stated purpose of the project is to protect the residence’s driveway and driveway gate from potential bluff failure due to future erosion and storm events. The proposed upper bluff retaining wall would extend along the upper bluff face fronting the existing driveway and driveway entrance gate, which are both located roughly six-and-a-half feet from the bluff edge. The project’s own technical reports indicate that the underlying bedrock bluffs are eroding very slowly at this location, approximately 0.1 feet annually. At this rate, it would be roughly 65 years before the driveway and gate are undercut by erosion. Accordingly, an existing structure in danger from erosion has not been established in such a way as to allow for a shoreline protective device at this location,1 and thus the proposed project is inconsistent with LCP requirements in this regard and must be denied.

Furthermore, even if the existing driveway and gate were shown to be in danger from erosion, danger, including but not limited to relocation or partial removal of the driveway and gate, both options which appear feasible at this location. The Applicant did not provide and the City did not analyze any other alternatives to the upper bluff retaining wall, inconsistent with the LCP. Finally, even if danger were conclusively established, and even if the upper bluff retaining wall were conclusively shown to be the least environmentally damaging feasible alternative to address and abate the danger, the LCP requires that all attendant coastal resource impacts, including impacts to shoreline sand supply, be eliminated and, if the impacts are not able to be eliminated, mitigated. The City did not evaluate sand supply impacts that are likely to result from the upper bluff retaining wall, and did not identify any mitigation for impacts associated with the project. Thus, the proposed shoreline protective device is inconsistent with the LCP.

In short, the proposed project is inconsistent with LCP shoreline protective device policies and standards, primarily because there is no identified erosion threat to an existing structure that would warrant and allow for such shoreline protective device. Furthermore, even if danger were established, there has been no evaluation of alternatives, such as driveway relocation (which appears to be feasible at this location). And finally, even if the proposed development satisfied those first two LCP requirements, the project lacks avoidance and mitigation measures for attendant coastal resource impacts. For all of these reasons, the proposed project fails to ensure LCP conformance with LUP Policies P5-5 and P5-6, as well as with IP Sections 17.20.190(C) and (F), and therefore must be denied.

For these reasons, staff recommends that the Commission deny a CDP for the proposed project. The motions are found on page 5 below.
CALIFORNIA COASTAL COMMISSION
Appeal Filed: 5/19/2016
49th Day: Waived
Staff: Mike Watson - SC
Staff Report: 7/22/2016
Hearing Date: 8/10/2016
APPEAL STAFF REPORT: SUBSTANTIAL ISSUE DETERMINATION & DE NOVO HEARING

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