April Vargas of the CGF Board of Directors submitted these comments to the Board of Supervisors concerning what method the Board uses to seek approval of the Amendments by the Coastal Commission, who needs to provide the final approval.
Committee for Green Foothills Comments on
Midcoast LCP Update Project
County Counsel Memo November 14, 2006
County Counsel has identified four alternative forms of the resolution submitting the proposed changes to the County’s Local Coastal Program (LCP) to the California Coastal Commission.
Committee for Green Foothills supports Resolution No. 4 (Separate Amendments, Modification Possible) for the following reasons:
* Resolution Nos. 1 and 2 would involve an “all or nothing” approach to certification of the LCP Amendments. The entire package would either be certified or denied. While it is likely that most of the proposed LCP Amendments will be certified by the Coastal Commission, some may not. It would not be in the county’s best interest to risk a denial of the entire LCP amendment package if this is the case.
* Resolution No. 3 would allow the Commission to certify each Amendment separately, which would not risk denial of the entire package. However, the Commission would be precluded from suggesting modifications. Assuming the county would want to revise the Amendment so it could be certified, it would be helpful to know what modifications would meet the Coastal Act requirements.
* Resolution No. 4 allows the separate certification of Amendments that meet the requirements of the Coastal Act, and gives the County the additional benefit of the Commission’s suggestions for modifications. The County does not have to adopt those suggested modifications, and can always suggest other revisions, or provide additional background information that supports the County’s Amendment as originally submitted. Resolution No 4 allows for a process of give and take, and collaboration between the county and the Coastal Commission which reflects the partnership between our local government and the Coastal Commission).
Resolution No. 4 provides the most flexible approach to the certification process and will honor the extensive, seven-year public process that produced the set of Amendments to be certified. Hundreds of county residents, numerous staff members, the Planning Commission and your Board have all devoted countless hours in good faith efforts to draft essential changes to our Local Coastal Plan. These revisions have been crafted to address current conditions within the Midcoast area. Underlying this whole process is the requirement that these revisions meet the standards of Chapter Three of the Coastal Act. Resolution 4 provides the most effective method for meeting these requirements and we urge the Board to adopt it.
We also encourage the Board to adopt modifications that will allow the Non-LCP items to become effective immediately. County staff has proposed a comprehensive and balanced process for implementation of the substandard lot merger program and there is no reason to delay on this or any of the other Non-LCP items.