1. SOLANA BEACH LUPA Comments from Solana Beach Coastal Property Owners

2. Private Stairways There are 3 private beach stairs in Solana Beach serving 3 condominium projects. All Pre-Prop 20 and maintained in excellent condition entirely on private property. Quasi-public already serving almost 293 condominium units.

5. Key Problems “Phases out” quasi-public beach access without justification or compensation. Will diminish coastal access for 300 families, their guests and vacation renters. Precludes repair and maintenance once 50% of the stairs has been replaced, cumulatively. POLICY 2.60

6. Solution Delete “phase out” language. Delete restraints on repair and maintenance – treat like any other structure. POLICY 2.60

7. Key Problems Conversion to public use is not feasible (security, liability, privacy, insurance). Conversion to public use is a taking without compensation. Not necessary – there is sufficient coastal access utilizing existing public accessways. POLICY 2.60.5

8. Solution Delete this policy in its entirety. Require mitigation where appropriate. POLICY 2.60.5

9. Restraints on Home Additions Policies 4.25, 4.25.5, 4.25.6 Approximately 50 SFRs on the bluff top. Average lot depth is about 70 feet. Under the new set back rules, most SFR lots have a NEGATIVE building envelope. KEY FACTS

10. Source: City of Solana Beach 3/12 Presentation to CCC

11. Key Problems Bluff edge setback takes the whole property in many cases. Applies to any new construction – even where no impact. Not supported by any building code. Engineer must pretend existing seawall is not there when calculating erosion rate. POLICY 4.25

12. Solution Restore setback to the way CCC calculated it for more than 3 decades. Existing seawalls should be factored into the erosion rate. POLICY 4.25

13. Key Problems New development requires waiver of all future bluff retention devices Ignores meaning of “existing” Per CCC, “existing” means existing as of the application for a CDP. POLICY 4.25.5

14. Solution Delete waiver language POLICY 4.25.5

15. Key Problems Additions using caissons requires a 1:1 removal across entirely westerly frontage. Caisson use requires a seawall. Additions based on caissons requires waiver of seawall protection. POLICY 4.25.6

16. Solution Delete restrictions on use of caissons. Delete waiver language. POLICY 4.25.6