The project is proposed on twenty sites within the Del Monte Forest. The major components of the project which are analyzed are:

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1 PROJECT CONSISTENCY WITH THE DEL MONTE FOREST LAND USE PLAN (LOCAL COASTAL PLAN), MONTEREY COUNTY GENERAL PLAN, AND GREATER MONTEREY PENINSULA AREA PLAN POLICIES This section analyses the Pebble Beach Company s Del Monte Forest Preservation and Development Plan s consistency with the Del Monte Forest Land Use Plan (LCP), General Plan policies which are not specifically included within the LCP, and specific policies of the Greater Monterey Peninsula Area Plan which are relevant to the portion of the project which is outside the Coastal Zone. 1 The project is proposed on twenty sites within the Del Monte Forest. The major components of the project which are analyzed are: GC EC SBI SBE SBDR PBL SUBS CY RD HWY Construction of a new 18-hole golf course with clubhouse and 11 visitor-serving suites on the existing Pebble Beach Equestrian Center site and adjacent undeveloped lands (Area MNOUV); Relocation of existing Equestrian Center to the Sawmill Borrow site Construction of 91 visitor-serving units, additional meeting space and a new underground parking lot at the Inn at Spanish Bay (also referred to as the Spanish Bay Resort) Construction of 12 units of employee housing adjacent to the Spanish Bay Resort (Area B) Construction of a new driving range and golf teaching facility at the Spanish Bay Resort (Area C) Construction of 63 visitor-serving units, additional meeting and hospitality space and new underground parking structure at the Lodge at Pebble Beach Creation of 33 residential single family lots (Areas F-2, F-3, I-2, K, and PQR) Construction of 48 units of employee housing at the Corporation Yard Road improvements within the Del Monte Forest Improvements to the Highway 1/ Highway 68 / 17-Mile Drive interchange; Abandonment, realignment, and improvements to certain internal roadways within the Del Monte Forest, sanitary sewer, potable water, and reclaimed water line extensions Relocation of existing equestrian/pedestrian trails segments and construction of new trails segments for a net increase of 3.6 miles of new trails Dedication and preservation of 492 acres within Areas B, C, D, F-3, G, H, I-1, J, K, L, MNOUV, PQR, and the Corporation Yard as open space On-going resource management activities 1 Some policies contain a number of specific issues which need consistency review. When this is the case each issue will be numbered in brackets, such as [1], in the policy and will then be referenced in the analysis. These numbers are not officially a part of the County policy but have been inserted as a means of making the analysis more direct and user friendly. An example of this procedure can be found in LUP Policy 1.

2 A key has also been added between the written policy and the analysis of consistency which indicates the relationship of that policy to each project area. The project areas are identified by the initials used in the above chart, such as GC = Golf Course and EC = Equestrian Center. The consistency of this project area is indicated with a symbol: The project within this area, as designed, is consistent with the policy. The project within this area, as conditioned or mitigated, is consistent with the policy. The project within this area is inconsistent with the policy. --- The policy does not apply to the project within this area. For example the below key, for DMF LUP Policy 1, indicates that the project within the golf course, Equestrian Center, the Lodge at Pebble Beach, residential subdivisions, and the Corporation Yard employee housing sites, as conditioned or mitigated, is consistent with Policy 1. Additionally, the policy is not applicable within the Inn at Spanish Bay, Spanish Bay employee housing, Spanish Bay driving range, and the Highway 1 / 68 / 17-Mile Drive interchange Policy consistency issues which relate to trail improvements are noted within the project area they impact or the nearest project area if the improvements are not within a specific project area. The dedication of preservation areas and management activities are not recorded on this key as they are consistent with all policies which apply. D-2

3 PROJECT CONSISTENCY WITH DEL MONTE FOREST LCP POLICIES RESOURCE MANAGEMENT ELEMENT Water and Marine Resources 1. New development in the Pescadero watershed, and the smaller unnamed watersheds of the Pebble Beach planning area which drain into the Carmel Bay Area of Special Biological Significance (ASBS), as well as the watersheds of Seal Rock Creek and Sawmill Gulch, shall be [1] sited and designed to minimize runoff, site disturbance, erosion, and sedimentation. [2] All new development shall be designed to conform to site topography. [3] New residential driveways and other road surfaces shall be kept to the minimum length and width to provide simple, direct access. [4] Other paved areas shall be limited to the minimum required to meet daily (not occasional) parking needs. This policy shall not be read to preclude safe bicycle lanes nor adequate parking for commercial visitor-serving development and access points Consistency Determination: The project components which are within the Carmel Bay ASBS are the Lodge at Pebble Beach facilities, the southern portion of the golf course site, the new residential lots within Area PQR, and the southern half of the I-2 subdivision. The residential subdivision sites within Area K, Area I-2 (northern half), Area F-2 (most of the area), and Area F-3 (most of the area) are within the Seal Rock Creek Watershed. The Sawmill Gulch watershed contains the relocated Equestrian Center, the Corporation Yard housing, and the northern tips of residential subdivisions in Areas F-2 and F-3. The majority of the proposed golf course site, the Spanish Bay developments, and the Highway 68/Highway 1 improvements are located outside of these named watersheds. [1] The Pebble Beach Company has included drainage and erosion control measures in the design of the proposed project. These measures include new controlled discharge outfalls, connections with existing stormwater drainage features, and localized and less formal discharge structures that flow to open space areas and existing swales. The development plans also depict a number of areas where detention basins will be created to reduce peak drainage flow rates during storm events and allow settling of sediment particles. The proposed project has been designed to cluster development onto the less-sloped areas of subdivision sites. Mitigation measures are recommended in Section 3.4, Hydrology and Water Quality (HWQ), and in Section 3.2, Geology, Seismicity, and Soils (GEO) to reduce and/or minimize runoff, erosion, and sedimentation. Mitigation Measure HWQ-A1-1 will require the implementation of permanent post-construction water quality Best Management Practices (BMP s) which may include the preservation of existing vegetation, concentrated D-3

4 flow systems, slope surface protection such as mulching, seeding, and planting, biofiltration buffer strips and grassy swales. Mitigation Measure GSS-C1-1 requires the preparation of an erosion and sediment control plan. [2] All new development is designed to conform to site topography. The golf course was designed to conform to site topography and has been specifically designed to respect existing drainage patterns. Those portions of the project which will be constructed on slopes in excess of 30%, including portions of the proposed golf course and Residential Subdivisions F-3 and PQR, will be required to conform with all of the development standards of the CIP and Mitigation Measure GSS-B1-1, GSS-B1-2, and GSS-B1-3. [3] Driveways proposed at the Spanish Bay and Corporation Yard employee housing sites provide direct access to the units and parking spaces while minimizing traffic congestion. Residential driveways will be required to be designed to the access standards of the County and the Pebble Beach Community Services District and provide direct access once development approvals are sought for these sites. None of the parcels have been designed in such a way as to require a lengthy access, such as flag lots. All lots have good street frontage to allow for access. [4] Residential parking is provided within this project for the employee housing sites at Spanish Bay and the Corporation Yard. At the Corporation Yard 113 parking spaces are proposed for 32 two-bedroom townhomes and 16 three-bedroom units which is consistent with the County standard. The County requirement for this site is a minimum of 111 parking spaces, based on the standard of 2 spaces per two-bedroom units, 2.2 spaces for each three-bedroom unit, and one guest parking space for every 4 units (Section of the Zoning Code). The Spanish Bay employee housing site provides 43 parking spaces for four two-bedroom units and 8 three-bedroom units. The Zoning Code minimum requirement for this development is 29 spaces. This number is almost 50% above the required number and is therefore excessive. While this project component is not in one of the applicable watersheds, a condition of project approval will be recommended that will require that the number of paved parking spaces available not exceed 32, which is 110% of the required number. Additional spaces can be provided only if the surface for these spaces meets the Department s standards for permeability. Proposals for parking at the 33 residential lots proposed will be designed when applications for the development of these lots are submitted to the County. These designs will be analyzed according to County standards at that time. With these mitigation measures and conditions of project approval, all portions of the proposed project will be consistent with this policy. 2. Non-point sources of pollution to the Carmel Bay ASBS, rocky intertidal areas, and wetlands shall be minimized through careful attention to drainage and runoff control D-4

5 systems. The criteria of the AMBAG 208 Water Quality Management Plan shall apply in watersheds affecting these resources Consistency Determination: The Lodge at Pebble Beach facilities, the southeastern portion of the golf course site, the proposed residential lots in Area PQR, and the southern half of Area I-2 are located within the Carmel Bay ASBS watershed. Additionally the golf course site, the new equestrian center, the Spanish Bay driving range, and the Spanish Bay employee housing site all contain mapped wetlands to which this policy applies. The applicant has incorporated drainage and erosion control measures into the project design and Best Management Practices (BMP) will be implemented during construction to reduce the potential of erosion and non-point source pollution. Design of the new golf course will re-route drainage near the existing equestrian center away from the Carmel Bay ASBS into drainage systems at the new golf course. Mitigation is proposed to reduce construction and operational impacts so that the project will be consistent with this policy. Related mitigation measures are those listed in the Hydrology & Water Quality (HWQ) section of the draft EIR. 3. [1] No land clearing operations greater than one acre per year per site or grading operations greater than 100 cubic yards may take place between October 15 and April 15 in water supply watersheds and high water erosion hazard areas. [2] Development on slopes exceeding 30% is prohibited unless this siting on a particular parcel better accomplishes other policies of this Plan. Utilizing the data of the Soil Conservation Service shall make determination of high water erosion hazard. Consistency Determination: [1] None of the project sites are located in water supply watersheds. However, some areas contain soils with moderate to high erosion potential, according to Soil Conservation Service data. Project sites that will involve the most grading are the: New golf course (318,000 CY cut / 377,000 CY fill); Relocated Equestrian Center (26,850 CY cut / 41,354 CY fill); Spanish Bay Resort, primarily underground parking facilities (44,252 CY cut / 0 CY fill)); Spanish Bay driving range (12,293 CY cut / 31,977 CY fill); Lodge at Pebble Beach, primarily underground parking facilities (26,929 CY cut / 5,030 CY fill); and Corporation Yard employee housing (38,577 CY cut / 25,019 CY fill). D-5

6 County policy allows controlled grading during the rain season (October 15 through April 15) if there is an approved Storm Water Pollution Prevention Plan (SWPPP). This SWPPP is in addition to the erosion control plan required as part of a grading permit application and generally describes proposed construction activities, receiving waters, stormwater discharge locations, and BMPs that will be used to reduce project construction effects on water quality. Prior to the rain season, the applicant will develop a SWPPP and submit it to the Regional Water Quality Control Board (RWQCB) for review and approval. [2] Several development areas contain or cross areas in excess of 30% slopes. Limited segments of roads, driveways and non-structural development are on, or cross, 30% slopes within the golf course (fairway 17 and golf cottages) and the Equestrian Center (upper equestrian center road). Mitigation measure GSS-B1-1 requires that the tentative maps for Residential Subdivisions F-3 and PQR be revised to exclude all areas with slopes of 30% or more from developable areas; conservation easements will be required for these areas. Mitigation Measures GSS-B1-2 and GSS-B1-3 require the applicant to implement the recommended design criteria of the geotechnical engineer of record for the commercial recreational areas where these slopes can not be totally avoided. Numerous geotechnical design criteria, including shoring of temporary cut slopes, temporary ground dewatering, and final cut-and-fill slope gradients have already been prescribed for the proposed development based on preliminary geologic and geotechnical evaluations. These criteria may be refined and or new ones added during the final stages of project design and construction. All design criteria shall be in accordance with applicable county building code standards. The proposed project, as designed, mitigated, and conditioned, is consistent with this policy. Mitigation Measures GSS-B1-1, GSS-B1-2, GSS-B1-3, GSS-C1-1, and GSS-C1-2 relate to this policy. 4. Onsite desilting measures satisfactory to the Director of Public Works (e.g., debris basins, desilting basins, and silt traps) shall be installed in conjunction with initial construction grading operations. They shall be maintained in good operating condition through the construction period to reduce sediment load in runoff waters. Consistency Determination: This policy applies to all project components which require grading. Implementation of erosion control mitigation measures included within Mitigation Measures HWQ-C6 and GSS-C1-1 require the applicant to obtain authorization through the Regional Water Quality Control Board for an NPDES ( National Pollutant Discharge Elimination System ) permit for general construction activity and to comply with the County s erosion control ordinance. With implementation of these mitigation measures the proposed project is consistent with this policy. D-6

7 5. [1] Construction erosion control measures satisfactory to the Director of Public Works (e.g., native vegetation cover, temporary vegetation, seeding, mulching, or other suitable stabilization methods) shall be used to protect soils that have been disturbed during grading or development. [2] Manufactured slopes shall be stabilized as soon as possible with planting of native annual grasses and shrubs, appropriate native compatible plants (consistent with OSAC Plan provisions), and with approved landscaping. Consistency Determination: This policy relates to all development sites. [1] Appropriate construction erosion control measures are required, as outlined under Policy 3 and 4, plus Mitigation Measures HWQ-C6 and GSS-C1-1 [2] The erosion control plan and SWPPP (Mitigation Measure HWQ-C6) require appropriate landscaping to stabilize slopes created during the construction process. Mitigation Measures HWQ-B1-1 and HWQ-B1-2 require implementation of ongoing measures to minimize the long-term water quality effects of stormwater drainage. These measures are discussed more fully under Policy 6. A condition of project approval will require that all landscaping, including landscaping done for erosion, emphasize native plants consistent with OSAC Plan provisions. The proposed project, as designed, mitigated, and conditioned, is consistent with this policy. Mitigation Measures HWQ-B1-1, HWQ-B1-2, HWQ-C6, and GSS-C1-1 relate to this policy. 6. Provisions shall be made to conduct surface water to storm drains or suitable watercourses to prevent erosion. Permanent onsite drainage devices shall be designed to accommodate increased runoff resulting from site modification. Where necessitated by good drainage design considerations, onsite retention of storm water may be considered to reduce the size requirements for drainage structures. Consistency Determination: This policy applies to all project sites. Mitigation Measures HWQ-B1-1 and HWQ-B1-2 require that the potential water quality impacts of stormwater drainage will be avoided and minimized through development and implementation of coordinated drainage features with permanent postconstruction BMP s designed by the applicant and its engineering consultants, in coordination with the Planning & Building Inspection Department. The BMP s will be designed to accommodate the additional drainage discharges and avoid adverse effects such as offsite erosion, sedimentation, or water quality impairments. Appropriate BMP s may include preservation of existing vegetation, ditches and berms, mulching, seeding and planting, slope roughening or terracing, biofiltration buffer strips and grassy swales, catch basins and oil/water separators, infiltration basins, and detention devices. D-7

8 The proposed project, as designed, mitigated, and conditioned, is consistent with this policy. Mitigation Measures HWQ-B1-1 and HWQ-B1-2 relate to this policy. 7. Throughout the Plan area, dumping of spoil (dirt, garbage, refuse, etc.) into riparian habitat and drainage courses shall be prohibited. Consistency Determination: As all project areas involve some grading this policy relates to all portions of the project. The erosion control plan and SWPPP will include provisions which outline the appropriate storage locations of any cut soil taken from a project site. Riparian habitats and drainage courses are not considered as appropriate locations and will be protected with special fencing to keep soil and debris out of these areas. Maintenance of the fencing and these areas will be monitored as part of the inspection process. The proposed project, as designed, mitigated, and conditioned, is consistent with this policy. Mitigation Measures HWQ-C6 and GSS-C1 relate to this policy. Environmentally Sensitive Habitat Areas 8. Environmentally sensitive habitat areas that are not designated as rehabilitation areas shall be protected against any significant disruption of habitat values. Within environmentally sensitive habitat areas, new land uses shall be limited to those that are dependent on the resources therein. Land uses immediately adjacent to environmentally sensitive habitat areas shall be compatible with long-term maintenance of the resource; development shall be sited and designed to prevent impacts which would significantly degrade the protected habitat. In designated open space areas, conformance to the applicable OSAC Plan maintenance standards shall be considered the test of consistency with this policy Consistency Determination: Environmentally sensitive habitat areas (ESHA s) were identified in accordance with Appendix A of the LUP. Development is proposed within ESHA within three areas: the Signal Hill Remnant Dune at the golf course site, the Huckleberry Hill Natural Area., and the residential subdivision in Area F-3. Activities within 100 feet of ESHA are proposed within three project areas: the proposed golf course, the new Equestrian Center, and the Spanish Bay Driving Range. 2 Development in these areas would require the approval of Coastal Development Permits. 2 The following ESHA s are contained within project areas in which development will not occur within 100 feet of the ESHA. : proposed golf course (wetland:/natural freshwater marsh within Wetland L2); D-8

9 Proposed Golf Course: This site contains two ESHA s which will be impacted by development: a natural seasonal pond which is a part of Wetland I, and remnant dunes with native vegetation containing ESHA plants. A portion of the dune area had previously been utilized for sand mining, and is therefore designated a rehabilitation area. While Wetland I, a drainage channel, does not constitute riparian habitat it does contain a natural seasonal pond which is defined as ESHA. As currently designed, the golf maintenance trail crosses this drainage and there is no specific proposal to avoid this area. Also, the grading line for Hole 13, as proposed, comes within about 30 feet of this drainage, and the line of play from the back tees crosses the drainage. Mitigation Measure BIO-A3 requires the redesign of Hole 13 to maintain a 40-foot native vegetation buffer around Drainage I and to provide a bridged crossing for the golf maintenance trail in order to preserve the habitat value of this resource. The applicant proposes to construct a new golf trail from the 14th Hole green to the 15th Hole tee. This trail crosses the Signal Hill Remnant Dune ESHA area for approximately 300 feet in the vicinity of at least four identified special-status plants. Mitigation Measure BIO-A1-1 requires that this golf trail be elevated, avoid the location of special status species, and exclude motorized vehicles. This measure also requires: a) permanent physical barriers along the edge of the new golf course to prevent pedestrians from creating or using informal trails in the dune area, and b) that the line of play areas at the 16 th Hole within dune ESHA be declared out of play. New Equestrian Center: No ESHA wetlands are located within the upper Sawmill site where most permanent improvements are proposed. Permanent improvements will not encroach within 100 feet of the ESHA wetland in the lower Sawmill area. However, the temporary event site plan shows temporary parking and other uses within 100 feet of Wetland S-A, an ESHA wetland, in the lower Sawmill site. A mitigation measure (BIO- C1-1) requires maintenance of a 100-foot buffer around this wetland. Huckleberry Hill Natural Area: The Equestrian Center is located adjacent to the Huckleberry Hill Natural Area and S. F. B. Morse Reserve (HHNA), all of which has been identified within the LUP as ESHA. It is likely that the location of this facility will increase equestrian use of the trails in the HHNA. The project also includes the conversion of the Spanish Bay Employee Housing (riparian habitat); Area G/Preservation Area (Monterey clover habitat); Area I-1/Preservation Area (riparian habitat); Area J/existing lots of record (riparian habitat, wetland/natural freshwater marsh); Area K/existing lot of record (riparian habitat, wetland/natural freshwater marsh); Area L/Preservation Area (remnant dune habitat on natural vegetation, riparian habitat, wetland/natural freshwater marsh); Area PQR/Preservation Area (riparian habitat, sandmat manzanita/significant occurrence); and Development has been determined to cause no negative impact to the resource in these areas. A complete listing of ESHA is contained on Table 3.3-9a of the draft EIR. D-9

10 existing Haul Road, which cuts through the HHNA, into a portion of the Del Monte Forest trail system. Several of the structures within the Equestrian Center are also proposed within 100 feet of the HHNA. These structures include the manager s residence and garage, the camp dormitory, and the staff residence. While the impact of structures is not identified in the environmental document as causing a significant impact, measures are proposed to mitigate the impact of increased equestrian traffic on the sensitive resources of the HHNA. Requirements within Mitigation Measure BIO-A5 include: restricting equestrian use of two specific single-track trail segments that parallel drainages in the HHNA - the Rudd Crawford Trail (b/w Congress and Fire Rd. #6) and the Green Trail/Red Trail between Congress Rd. and Fire Rd #6; requiring the posting of signage directing equestrians and pedestrians to designated trails; requiring the permanent closing and revegetation of all informal social trails within the HHNA; monitoring of trails and trail crossings of drainages during the wet season, temporary closure of single-track trails and other HHNA trails to equestrian trails when a substantial erosion potential exists; removal of invasive species, as called for within the resource management plan; implementation of an annual program of erosion control and trail maintenance along trails in the HHNA requiring the use of weed-free feed for all horses at the equestrian center; and incorporating environmental education about the sensitive resources of the HHNA to all trail users and attendees at special events at the Equestrian Center. The applicant proposes the construction of potable water lines through the HHNA; additionally a sewer line and a potential reclaimed water line are proposed which would cross tributaries of Sawmill Gulch. These lines would serve the relocated Equestrian Center. Mitigation Measure BIO-A2 requires that the utility lines crossing riparian drainages shall avoid all in-water work, the removal of riparian and hydrophytic vegetation, and temporary or permanent disturbance of natural drainages. Mitigation Measure BIO-B1-3 further requires that the reclaimed water line to the relocated Equestrian Center be routed so as to require no forest removal. Spanish Bay Driving Range: A sewer line is planned within approximately 60 feet of the edge of a freshwater marsh (ESHA) in the southwest corner of the site. This work was analyzed in the draft EIR and was judged to be consistent with the long-term maintenance of the wetland and not to constitute degradation of the habitat. Area F-3: As proposed a portion of one of the residential lots within this subdivision would contain Bishop pine / Gowen cypress forest. Mitigation Measure BIO-A4 requires that the tentative map be amended to exclude this association from the residential component of the subdivision. Consistency with OSAC standards for all areas involving ESHA will be required as a condition of project approval. Ongoing maintenance of these areas is mandated through Mitigation Measures BIO-A1-2, BIO-B1-1, and BIO-C1-3. D-10

11 The proposed project, as designed mitigated and conditioned, is consistent with this policy. Environmentally Sensitive Habitat will be avoided, or provided with adequate setbacks and mitigations. Mitigation measures insuring that this policy is met include: BIO-A1-1, BIO- A1-2, BIO-A2, BIO-A3, BIO-A4, BIO-A5, BIO-B1-1, BIO-B10-B1-3, BIO-C1-1, and BIO-C Improvements to facilitate recreational or visitor uses, including vegetation removal, excavation, grading, or filling in designated environmentally sensitive habitat areas shall be sited, designed and managed to avoid any significant disruption of the protected resources. Areas which are especially sensitive to recreational use include riparian habitats, wetlands, and sites of known rare and endangered species of plants and animals. Bird rookeries, major roosting and haul-out sites, and other wildlife breeding or nursery areas identified in Figure 2 of this LUP are generally appropriate only for off-site observation. Any uses of these areas shall be mitigated consistent with OSAC maintenance standards for the affected area and shall be required to demonstrate enhancement of the affected habitat as part of the use proposal Consistency Determination: ESHA is present in the following project sites that include improvements to facilitate recreational or visitor uses: the new golf course, relocated Equestrian Center (including improvements in the adjacent Huckleberry Hill Natural Area), and the Spanish Bay driving range. In addition, there are approximately 29 miles of existing trails that will be realigned and 3.6 miles of new trails proposed, some of which are proposed within, or near, designated ESHA. A full discussion on project impacts to ESHA is outlined within the consistency analysis for Policy 8. The proposed project, as designed mitigated and conditioned, is consistent with this policy relating to ESHA. Mitigation measures relating to this policy include: BIO-A1-1, BIO-A1-2, BIO-A2, BIO-A3, BIO-A4, BIO-A5, BIO-B1-1, BIO-C1-1, and BIO-C [1] New subdivisions which create commitment to development immediately adjacent to environmentally sensitive habitat areas shall be allowed only at densities compatible with protection and maintenance of these resources. [2] New subdivisions may be approved only where potential adverse impacts to environmentally sensitive habitats can be prevented. [3] Conformance to the applicable OSAC maintenance standards shall be required wherever open space lands would be affected. [4] No residential subdivision shall be allowed unless it is first demonstrated that, for each new residential lot, normal residential development, including driveway and utility connections, is feasible without damage to any environmentally sensitive habitat. D-11

12 Consistency Determination: Within the Pebble Beach Company proposal, only two subdivisions are proposed which both create the potential for future development and contain ESHA. These are the residential subdivisions proposed for Area F-3 (4 single-family lots) and PQR (7 single-family lots). Development is proposed within three other subdivisions that contain ESHA within their boundaries. These are the subdivisions involving Area MNOUV (Golf Course), Huckleberry Hill (the Equestrian Center, Corporation Yard, and Huckleberry Hill Natural Area), and Areas B and C (Spanish Bay Driving Range and Employee Housing). The development potential of these sites is fully analyzed in the draft EIR as a part of this project. These developments are analyzed for policy consistency relative to development in ESHA under separate LUP policies, notably Policy 8. [1 and 2] Area F-3: Under the proposed design, four residential lots will be created on the southwestern side of this project area and the northern and eastern area will be dedicated in conservation easement which includes approximately 3.5 acres of Gowen cypress/ Bishop pine ESHA. This conservation area will be managed for its long term health in accord with site-specific resource management plans. Parcel 1 in this subdivision is the only parcel adjacent to the ESHA area, and portion of the mapped ESHA extend approximately 20 feet into Lot 1. A mitigation measure (BIO-A4) requires the redesign of this lot to put all of the designated ESHA within the conservation area which is to be covered by a conservation easement. Area PQR: Seven residential lots are proposed in two clusters along the northern edge of this project area. No residential parcel will be closer than 1,000 feet from the only identified ESHA within Area PQR: a significant occurrence of Sandmat Manzanita. At this distance the residential development is not anticipated to cause an impact. No other ESHA is located adjacent to this development and none is included within the proposed residential lots. [3] Appendix A of the OSAC Open Space Management Plan includes forest maintenance standards for nine parcels. As the proposed project does not include any activity within these nine parcels, this policy is not applicable to the project. [4] As outlined above it has been determined that no residential subdivision will constitute an impact to ESHA. With the implementation of Mitigation Measure BIO-A4 no residential parcel would contain ESHA. The only parcel which is immediately adjacent to ESHA is Lot 1 in Area F-3. The normal residential development of this lot, including driveway and utility connections, is feasible without damage to any environmentally sensitive habitat. D-12

13 The proposed project, as designed mitigated and conditioned, is consistent with this policy. Mitigation measure BIO-A4 relates to this policy. 11. [1] Contiguous areas of undisturbed land in open space uses shall be maintained wherever possible to protect environmentally sensitive habitat areas and associated wildlife values. [2] To this end, development of parcels immediately adjacent to designated environmentally sensitive habitat areas shall be planned to keep development intensity immediately adjacent to the sensitive habitats as low as possible, consistent with other planning criteria (e.g., drainage design, roadway design, and public safety). [3] Conformance to applicable OSAC maintenance standards shall be the test of consistency with this policy Consistency Determination: [1] The proposed project proposes dedication of 492 acres in areas B, C, D, F-3, G, H, I-1, J, K, L, MNOUV, PQR, and the Corporation Yard. Many of these sites include areas designated as ESHA. Approximately 350 acres (proposed preservation/conservation areas in Areas F-3, G, H, PQR, and at the Corporation Yard) are located contiguous with the existing 550 open space forest acres within the Huckleberry Hill Open Space, SFB Morse Botanical Reserve, and Pescadero Canyon watershed. This proposal will maintain contiguous areas of undisturbed land in open space uses which will protect wildlife values, including those of ESHA contained within their boundaries. [2] The project, as proposed, will affect several designated ESHA s which are located within open space areas. Mitigation measures are proposed to relocate project elements away from the designated ESHA areas to allow for adequate buffers. One particular concern is the impact of increased pedestrian and equestrian traffic through the Huckleberry Hill Natural Area and Morse Reserve. This impact is addressed by Mitigation Measure BIO-A5 which will require measures aimed at preserving the habitat of this Reserve. Mitigation Measure BIO-A1 requires measures to limit the impact of a proposed golf trail through the Signal Hill Remnant Dune. A full discussion of measures to limit the development intensity and its impact on ESHA is included under Policy 8. [3] None of the areas proposed for development or preservation within the entire project are directly covered by the forest maintenance standards listed in OSAC Plan. The proposed development and preservation areas are, however, consistent with the management policies for open space categories listed in the OSAC Plan. The OSAC Plan outlines management policies for open space eleven different categories, ranging from intensively used areas through open forest, and rare or endangered species. The policies in this section will be the basis of many of the specific measures which will be developed as part of the Resource Management Plan (Mitigation Measure BIO-B1-1). This consistency is insured by the mitigation measures listed under the biological section of the draft EIR. D-13

14 The proposed project, as designed mitigated and conditioned, is consistent with this policy. Mitigation measures relating to this policy include measures listed in the biological resources section of the draft EIR which relate to ESHA, the two measures relates to ESHA Wetlands (BIO-C1-1 and BIO-C1-2), and those relating to the dedication of conservation areas (BIO-B1-6 and BIO-B1-2[c]). 12. Where development of any type, including subdivision of land for development purposes, is proposed in or near documented or expected locations of environmentally sensitive habitats, field surveys by qualified individuals shall be required in order to determine precise locations and to recommend mitigating measures to ensure protection of any sensitive species or habitat(s) present. Where OSAC maintenance standards have been prepared, these shall be observed in the preparation of such recommendations. Consistency Determination: All project areas were surveyed for sensitive biological resources by qualified biologists. These surveys were reviewed by the County s environmental consultant in conjunction with preparation of the draft EIR. Recommendations of these surveys have been incorporated into the mitigation measures listed in the draft EIR. While none of the project sites are listed under the forest maintenance standards section of the OSAC Plan, the proposed mitigations are consistent with the management policies of the plan. The project is consistent with this policy with implementation of biological resource mitigation measures included in the draft EIR, which will be included as Conditions of Approval. 13. [1] The protection of environmentally sensitive habitats shall be provided through deed restrictions or permanent conservation or scenic easements granted to the Del Monte Forest Foundation. Where developments are proposed within or near areas containing environmentally sensitive habitat, such restrictions or easements shall be established through the development review process. [2] Where development has already occurred in areas supporting environmentally sensitive habitat, property owners should be encouraged to voluntarily grant conservation or scenic easements to the Del Monte Forest Foundation. [3] Except in the case of voluntary easements, each instrument for effecting such restriction or easement shall be subject to approval by the County as to form and content; shall provide for enforcement, if need be, by the County or other appropriate enforcement agency; and shall name the County as beneficiary in event the Foundation ceases or is unable to adequately manage these easements for the intended purpose of natural habitat preservation D-14

15 Consistency Determination: [1] Areas where conservation and scenic easements are proposed include: Areas B, C, D, F-3, G, H, I-1, J, K, L and PQR, the Corporation Yard, and portions of the proposed new golf course location (Area MNOUV). Dedication of easements in favor of the Del Monte Forest Foundation, or another appropriate nonprofit or governmental body as approved by the Director of Planning & Building Inspection, will be required by Mitigation Measures BIO-B1-6 and BIO-B1-2[c]. Additionally the wetland areas identified as ESHA in the County s wetland assessment will be required by Mitigation Measure BIO-C1-2 to be placed in conservation easements. These are Wetland Area L2 and Drainage I on the new proposed golf course, Drainage S-A in the proposed Equestrian Center, and Wetlands C-A and C-B within the conservation area at the Spanish Bay Driving Range.. [2] The Lodge at Pebble Beach, the Spanish Bay Resort, and the portion of the golf course site which now contains the Equestrian Center, are the only sites which contain existing development. It has been determined that they do not contain environmentally sensitive habitat. Therefore no voluntarily grant conservation or scenic easements are required for these locations. [3] The easement wording required by this policy will be included in all of the deed restrictions and easements. The proposed project, as designed mitigated and conditioned, is consistent with this policy. The mitigation measures relating to this policy are BIO-B1-6, BIO-B1-2(C), and BIO-C Near environmentally sensitive habitat areas, the removal of indigenous vegetation and land disturbance (grading, excavation, paving, etc.) shall be restricted to the minimum amount necessary to accommodate development. This policy shall not restrict the activities of the Del Monte Forest Foundation in implementing OSAC Plan maintenance standards Consistency Determination: The protection of the habitat value of ESHA is an important value reviewed in the draft EIR. Mitigation measures require that all development and land disturbance be adequately setback from ESHA. This setback is standardly a minimum of 100 feet, unless a lesser setback can be shown to not affect habitat values. Mitigation measures which minimize disturbance in the vicinity of ESHA include BIO-A1-1, BIO-A2, BIO-A3, BIO-A4, and BIO-A5. Site-specific resource management plans will be required to minimize disturbance and maximize the ongoing maintenance of resources. These measures will incorporate all applicable OSAC Plan maintenance standards. These plans are required by Mitigation Measures BIO-A1-2, BIO-B1-1, and BIO-C1-3. D-15

16 The consistency analysis for Policies 8, 9, and 10 review the impacts of the project to ESHA and methods to minimize these impacts. The proposed project, as designed and mitigated, is consistent with this policy. The mitigation measures relating to this policy include BIO-A1-1, BIO-A1-2, BIO-A2, BIO-A3, BIO-A4, BIO-A5, BIO-B1-1, and BIO- C The use of non-invasive plant species and appropriate native species shall be required in landscape materials used in projects, especially in developments adjoining environmentally sensitive habitat. Consistency Determination: Landscaping will be involved at all project sites. Where restoration or plantings occur, mitigations and conditions will require an emphasis on native species. This is shown in a number of mitigation measures, including BIO-B1-5, BIO-D1-4, BIO-D2, BIO-D5-1, BIO-D5-3, BIO-D5-4, and BIO-D6. As a condition of project approval the applicant will be required to submit a landscape plan for approval for all sites except for the residential subdivisions. This landscape plan will be required to follow the recommendations of the site-specific resource management plans which will emphasize the planting and long-term active maintenance of natives and the elimination of invasive non-native plant species. The 33 residential lots in the subdivisions which are a part of this application will be required to submit landscape plans when development approvals are requested for them. The proposed project, as conditioned and mitigated, is consistent with this policy. Policies Specific to Terrestrial Plants and Habitats 16. [1] The remnant native sand dune habitat along the shore in the Spanish Bay planning area, on Signal Hill, and adjacent to 17-Mile Drive in the Spyglass Cypress planning area, shall be preserved through scenic easement or conservation easement, and shall be conveyed to the Del Monte Forest Foundation, as provided by Policy 13 above, at the time development occurs in adjacent areas. [2] Lots of record in these dune areas may be developed provided that new adverse impacts are prevented and enhancement measures are instituted as part of the development proposal D-16

17 Consistency Determination: The proposed golf course location (Area MNOUV) contains acres of the remnant native sand dune habitat, but the only proposed developed within the remnant dune habitat is a new golf trail (discussed below). The western 0.38 acre tip of Preservation Area L also contains dune habitat coastal strand. Both of these sites are on Signal Dune within the Spyglass Cypress Planning Area. [1] The project proposes revegetation, enhancement, and management actions for these areas. All of Area L and the northwestern portion of the golf course which contains the dune habitat will be protected with conservation and scenic easements which will be granted to the Del Monte Forest Foundation, or another appropriate nonprofit or governmental body as approved by the Director of Planning & Building Inspection consistent with the requirements of Policy 13. [2] Except for Preservation Area L this project does not involve existing lots of record in these dune areas. This component of the policy is therefore not strictly applicable. Implementation of the proposed dune restoration, enhancement, and creation, and the additional mitigation measures in Section 3.3 of the draft EIR, will insure that the proposed project is consistent with this policy. The only development proposed within remnant dune habitat is a new golf trail from the 14th Hole green to the 15th Hole tee. This trail crosses the Signal Hill Remnant Dune ESHA area for approximately 300 feet in the vicinity of at least four identified special-status plants. Mitigation Measure BIO-A1-1 requires that this golf trail be elevated, avoid the location of special status species, and exclude motorized vehicles. This measure also requires: a) permanent physical barriers along the edge of the new golf course to prevent pedestrians from creating or using informal trails in the dune area, and b) that the line of play areas at the 16 th Hole within dune ESHA be declared out of play. The proposed project, as designed and mitigated, is consistent with this policy. The mitigation measures requiring dedication is Mitigation Measure BIO-B2-6. Additionally Mitigation Measure BIO-A1-2 requires that dunes species habitat management and performance criteria be included within the master Resource Management Plan and sitespecific RMP s. 17. Prior to approval of development on existing legal lots of record, protection of rare, endangered, and sensitive native plant and animal habitats which potentially occur in the area shall be ensured by the following means: - A site survey shall be conducted by a qualified botanist (or biologist in the case of animal habitat) for the purpose of determining the presence of rare, endangered, or unique plants and developing appropriate mitigation. This survey should be conducted in April or May, as it must be designed to detect the presence of any of the habitats listed in Appendix A of this Plan. - Performance standards covering building locations, lot setbacks, roadway and driveway width, grading, and landscaping shall be established as a means of carrying out the D-17

18 recommendations of the site survey. The purpose of this is to isolate building sites from identified locations of rare or endangered plants or other environmentally sensitive habitat. - Scenic or conservation easements covering the environmentally sensitive habitat shall be dedicated to the Del Monte Forest Foundation as provided by policy 13 above. (Interpretation: This policy applies only to ESHA areas within existing lots of record and not to development on lands which are proposed for subdivision.) Consistency Determination: Development is proposed in two areas with existing legal lots of record: the Lodge at Pebble Beach 3 and the Inn at Spanish Bay. Biological and botanical surveys were conducted to determine the presence of rare, endangered, or unique plants within the proposed project area, including the areas impacted at the Lodge at Pebble Beach and the Inn at Spanish Bay. No native special status species were identified at either the Lodge at Pebble Beach or the Inn at Spanish Bay. Three of the preservation areas (Areas H, I-1, and L), are within existing lots of record. These areas will be managed in accord with the requirements of site-specific resource management plans as required by Mitigation Measure BIO-B1-1. The project application also describes two areas (Areas F-1 and J) which contain existing lots of record which, while not a part of this project, are the potential site for three single family lots. If, and when, development is proposed for these three existing lots of record the provisions of this policy will be applied. The proposed project, as designed, is consistent with this policy. 18. Uses of the remnant native sand dune habitat shall be limited to low-intensity scientific, educational, or recreational activities dependent on the resource, except in Spanish Bay rehabilitation area, where policy 93 shall apply. Particular attention shall be given to protection of rare and endangered plants from trampling. Conformance to the appropriate OSAC maintenance standards shall be the criteria for consistency with this policy. Such uses must be consistent with restoration and enhancement of the habitat Consistency Determination: This policy applies to Preservation Area L and the proposed golf course. The dune habitat within Preservation Area L will be preserved as open space 3 A lot line adjustment is proposed at the Lodge at Pebble Beach. D-18

19 and thus protected. The dune area of the new golf course site will also be preserved through conservation and scenic easements although the edges of this area are contained within a rehabilitation area due to prior mining activities. The applicant proposes to construct a new golf trail from the 14th Hole green to the 15th Hole tee. This trail crosses the Signal Hill Remnant Dune ESHA area for approximately 300 feet in the vicinity of at least four identified special-status plants. Mitigation Measure BIO-A1-1 requires that this golf trail be elevated, avoid the location of special status species, and exclude motorized vehicles. This measure also requires: a) permanent physical barriers along the edge of the new golf course to prevent pedestrians from creating or using informal trails in the dune area, and b) that the line of play areas at the 16 th Hole within dune ESHA be declared out of play. The Dunes Report, which was prepared by Zander Associates and is a part of the project description, proposed dune restoration, enhancement, and creation for both the golf course and Area L sites. The objectives in this report are proposed for use in developing a set of specific management prescriptions and performance standards to be implemented by the applicant. The inclusion of the recommendations of this report in the resource management plans is required by Mitigation Measure BIO-A1-2. While the OSAC maintenance standards, listed in Appendix A of the OSAC Management Plan, do not strictly apply to the sites within this project the project, as mitigated, is consistent with the OSAC management policies. The requirements of Mitigation Measures BIO-A1-1 and BIO-A1-2 will insure that the proposed project is consistent with this policy. 19. To prevent further degradation and to allow for restoration of degraded dune and bluff habitats, parking along 17-Mile Drive shall be restricted to designated turnouts through the use of barriers (structural and vegetational) and enforcement signs in accordance with the site specific access recommendations Consistency Determination: None of the area developments in the vicinity of 17-Mile Drive (Spanish Bay Inn, Spanish Bay employee housing, Spanish Bay Driving Range, and The Lodge at Pebble Beach) propose parking along 17-Mile Drive. The project as designed is consistent with this policy and DMFLUP site-specific access recommendations along 17- Mile Drive have already been implemented. 20. Development in the Spanish Bay planning area, including the golf course in the reclamation area, shall be designed to avoid conflict with or enhance both remaining native sand dune habitat and shoreline recreational uses. All but the first 2,000 feet of Spanish Bay Road D-19