1. Brief Review of Bluff Road and Other ESHA Issues Robert A. Hamilton Hamilton Biological, Inc. Banning Ranch Conservancy

2. “Bluff Road” Entrance Entry Road off PCH passes through southeastern part of Newport Banning Ranch to reach parking area on City- owned land.

3. “Bluff Road” Entrance Pink polygons represent areas of unpermitted habitat removal between 2003 and 2006.

4. “Bluff Road” Entrance Pink polygons represent areas of unpermitted habitat removal between 2003 and 2006. This general area is regularly used by breeding California Gnatcatchers.

5. Critical Habitat for California Gnatcatcher California Gnatcatcher in Big Saltbush on Sunset Ridge site. Photo: June 3, 2010

6. Critical Habitat for California Gnatcatcher California Gnatcatcher in Big Saltbush on Sunset Ridge site. All of Banning Ranch and Sunset Ridge are designated Critical Habitat. Photo: June 3, 2010

7. Photo 1: Native Scrub Along PCH Native Big Saltbush, Mulefat, Coast Goldenbush. Photo: November 15, 2010

8. Photo 1: Native Scrub Along PCH Native Big Saltbush, Mulefat, Coast Goldenbush. Habitat for the California Gnatcatcher. Photo: November 15, 2010

9. Photo 1: Native Scrub Along PCH Native Big Saltbush, Mulefat, Coast Goldenbush. Habitat for the California Gnatcatcher. Entry road would remove this habitat. Photo: November 15, 2010

10. Photo 1: Native Scrub Along PCH Mapped as “ornamental” by BonTerra in Sunset Ridge EIR. Photo: November 15, 2010

11. Photo 1: Native Scrub Along PCH Mapped as “ornamental” by BonTerra in Sunset Ridge EIR. City asked BonTerra to review; BonTerra determined the mapping was “adequate.” Photo: November 15, 2010

12. Photo 2: Native Scrub at Parking Area Native Mulefat, California Encelia. Photo: November 15, 2010

13. Photo 2: Native Scrub at Parking Area Native Mulefat, California Encelia. City mows and sprays the encelia annually for weed abatement. Photo: November 15, 2010

14. Photo 2: Native Scrub at Parking Area Native Mulefat, California Encelia. City mows and sprays the encelia annually for weed abatement. Parking lot for Sunset Ridge would remove this habitat. Photo: November 15, 2010

15. Photo 2: Native Scrub at Parking Area California Gnatcatcher pair observed here on November 4, 2009 (top polygon).

16. Photo 2: Native Scrub at Parking Area Native habitat mapped as “ruderal” by BonTerra in Sunset Ridge EIR. Photo: November 15, 2010

17. Photo 2: Native Scrub at Parking Area Native habitat mapped as “ruderal” by BonTerra in Sunset Ridge EIR. City asked BonTerra to review; BonTerra determined the mapping was “adequate.” Photo: November 15, 2010

18. California Encelia Scrub Even with mowing and spraying in 2009, the encelia scrub looked like this in early spring 2010. Photo: March 20, 2010

19. California Encelia Scrub Even with mowing and spraying in 2009, the encelia scrub looked like this in early spring 2010. California Encelia is not a “weed” and is expressly allowed in all fuel modification zones. Photo: March 20, 2010

20. California Encelia Scrub The City has offered no coherent rationale for their annual mowing and spraying of encelia scrub. Photo: November 6, 2009

21. California Encelia Scrub It is Critical Habitat and potential ESHA. Photo: March 25, 2010

22. Coastal Wetlands The Sunset Ridge EIR identifies no wetlands on the site. Photo: November 6, 2009

23. Coastal Wetlands The Sunset Ridge EIR identifies no wetlands on the site. These cat-tails growing in standing water were mapped as “ornamental” by BonTerra in Sunset Ridge EIR. Photo: November 6, 2009

24. Coastal Wetlands The Sunset Ridge EIR identifies no wetlands on the site. These cat-tails growing in standing water were mapped as “ornamental” by BonTerra in Sunset Ridge EIR. City asked BonTerra to review; BonTerra determined the mapping was “adequate.” Photo: November 6, 2009

25. Coastal Wetlands The Sunset Ridge EIR identifies no wetlands on the site. These cat-tails growing in standing water were mapped as “ornamental” by BonTerra in Sunset Ridge EIR. City asked BonTerra to review; BonTerra determined the mapping was “adequate.” The EIR calls for grading of this area, but these wetlands should qualify as ESHA. Photo: November 6, 2009

26. Tip of the Iceberg Apparent violations of the Coastal Act already identified by staff are only the beginning.

27. Tip of the Iceberg Apparent violations of the Coastal Act already identified by staff are only the beginning. BonTerra’s mapping and survey results lack credibility.

28. Tip of the Iceberg Apparent violations of the Coastal Act already identified by staff are only the beginning. BonTerra’s mapping and survey results lack credibility. Many serious issues remain unresolved.

29. Tip of the Iceberg Apparent violations of the Coastal Act already identified by staff are only the beginning. BonTerra’s mapping and survey results lack credibility. Many serious issues remain unresolved. The City has shown no interest in working with the public to resolve problems.

30. Tip of the Iceberg Apparent violations of the Coastal Act already identified by staff are only the beginning. BonTerra’s mapping and survey results lack credibility. Many serious issues remain unresolved. The City has shown no interest in working with the public to resolve problems. Please see my letter to Karl Schwing dated May 25, 2010.

31. Thank You