STOLOSKI HMB APPEAL A-2-HMB Item 14A - May 15 Agenda

Orientation

Houses Within 50 Feet of the Ditch

Agencies Assume Species Present USFWS – – “Due to the presence of suitable upland habitat and the lack of survey data, it is reasonable for the Service to consider that the Pullman drainage, and potentially similar drainages throughout Half Moon Bay area, is occupied by both species.” CDFW – – “Based on the lack of site specific surveys for CRLF and SFGS in this area…one cannot biologically validate the absence of these species without further intensive surveys.”

Dr. Dixon Report “Pullman ditch is degraded habitat that is not appropriate breeding habitat for these sensitive species and may not be regularly inhabited, but it does provide dispersal and foraging habitat that may be periodically used by both species.”

Dr. Dixon Report It is difficult to assess the risk of “take” resulting from the proposed development because it is a joint function of the likelihood these species would be present in the ditch habitat, the likelihood that they would move into the upland area, and the likelihood that they would move onto the roadway and be killed, none of which is known.

Winter Protocol Surveys

Winter Protocol Survey Results

No Connectivity

Dr. Jennings Based on my long-term familiarity with this species along the Central Coast and my experience with known occupied CRLF habitats in Half Moon Bay, I find it impossible that CRLF would be able to move to and from the Pullman Ditch given the absence of sustained surface water, narrow strip of land available for frog overland movement, and the presence of so much urbanization nearby (with the resulting large population of domestic cats and raccoons). With the only potential movement corridor for CRLF adjacent to the Half Moon Bay Coastal Trail, which would certainly be regularly used by domestic cats and raccoons, no CRLF would be able to move overland without a high probability of being predated.

Dr. Jennings Agency (CDFW and USFWS) documents maintain that the site is within the known dispersal distance for CRLF and SFGS and, as a result, they hypothesize that Pullman Ditch could be occupied by CRLF and SFGS (Triffleman 2006, 2007; DeLeon 2012; Tattersall 2014). However, the agencies’ hypotheses have not been validated in the biological assessments conducted since 2005 by myself and other biologists who have examined the site and surrounding area in detail, and are familiar with CRLF and SFGS in Half Moon Bay, and have reviewed all of the known information (H.T. Harvey and Associates 2005, WRA 2010, Riggs 2013).

Dr. Jennings

The LCP Policies Don’t Apply

Map Must Be Amended

Amending the Map

LCP Amendment Required

Even if Pullman Ditch was designated as a sensitive habitat on the Overlay Map, the Buffers Do Not Apply

Riparian Corridor Buffers

Riparian Corridors Defined

Limited Riparian Vegetation in the Ditch

Zoning Code Buffer

Oliva City Staff Report – quoted in CCC Staff Report

Roadway Alternatives – Design Objectives 2 Basic Objectives – Avoid creating new intersections on Highway 1 per City policy – Avoid facilitating development of the Surf Beach Tract By avoiding installing infrastructure in the Surf Beach

Onsite Roadway Alternative

Knewing Avenue Alternative

Osborn Avenue Alternative

PD Zone Consistency The PD Designation was created to address to Surf Beach Tract lot density – The purpose of the specific plan requirement is to reduce the number of small lots in that tract The Soloski property is not part of the Surf Beach Tract The subdivision was designed to avoid any development of the Surf Beach Tract

Not Part of Surf Beach Tract

Paper Subdivision Concern in LCP

Purpose of PD District

PD District Intent Planned Development District was created to achieve a reduction in the density of the Surf Beach Tract – and to do so before development occurs within the tract that could foreclose the ability to reconfigure the existing small lots within that tract in the future.

City Findings

Upshot of City Findings The Stoloski subdivision is a distinct unit that is not part of the Surf Beach Tract. – It does not contain the small lots that require re- planning and reconfiguration, and – It does not entail the development of that tract. The Stoloski subdivision leaves the Surf Beach Tract in tact – It reserves the City’s ability to develop a plan that addresses the density of the Surf Beach Tract. – It does so in a manner that does not hasten the conversion of the Surf Beach Tract from agriculture to residential development.

A Specific Plan Does not Advance the PD District Objective It serves no useful purpose to require the Stoloski project to be part of a specific plan that would facilitate the development of the Surf Beach Tract when the Stoloski project can be developed in a manner that does not entail the development of the Surf Beach Tract, as it does now.