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RPVCCA_SR_2010_01_05_04_Ord_502_2nd_ReadingCITY OF MEMORANDUM RANCHO PALOS VERDES TO: FROM: DATE: SUBJECT: HONORABLE MAYOR &CITY~COUNCIL MEMBERS JOEL ROJAS,AICP,DIRE .OF PLANNING, BUILDING AND CODE ENFOR MENT JANUARY 5,2010 REVISION TO PLANNING CASE NO.ZON2009-00007 .(CODE AMENDMENT AND ENVIRONMENTAL ASSESS- MENTl;,FURTHER REVISIONS TO THE LANDSLIDE MORATORIUM ORDINANCE (CHAPTER 15.20 OF THE RANCHO PALOS VERDES MUNICIPAL CODE)TO ESTABLISH AN EXCEPTION CATEGORY TO ALLOW FOR THE FUTURE DEVELOPMENT OF THE SIXTEEN (16)MONKS PLAINTIFFS'LOTS IN ZONE 2 TO INCREASE THE MAXIMUM PERMITTED QUANTITY OF GRADING PER LOT FROM LESS THAN 50 CUBIC YARDS TO LESS THAN 1,000 CUBIC YARDS REVIEWED:CAROLYN LEHR,CITY MANAGER & Project Manager:Kit Fox,Associate Planner~ RECOMMENDATION Adopt Ordinance No.502,further revising the City's Landslide Moratorium Ordinance to establish an exception category to allow for the future development of the sixteen (16) Monks plaintiffs'lots in Zone 2 to increase the maximum permitted quantity of grading per lot from less than 50 cubic yards to less than 1,000 cubic yards. DISCUSSION On December 15,2009,the City Council received public testimony and introduced Ordinance No.502 to further revise the City's Landslide Moratorium Ordinance to establish an exception category to allow for the future development of the sixteen (16)Monks plaintiffs' lots in Zone 2.An urgency ordinance for these same revisions (Ordinance No.501 U)was 4-1 MEMORANDUM:Moratorium Ordinance Revisions (Case No.ZON2009-00007) January 5,2010 Page 2 also adopted at the December 15,2009,City Council meeting.Staff now presents the non-urgency Ordinance No.502 for its second reading and adoption. CONCLUSION In conclusion,Staff recommends that the City Council adopt Ordinance No.502,thereby further revising the City's Landslide Moratorium Ordinance to establish an exception category to allow for the future development of the sixteen (16)Monks plaintiffs'lots in Zone 2 to increase the maximum permitted quantity of grading per lot from less than 50 cubic yards to less than 1,000 cubic yards. Attachments: •Draft Ordinance No.502 •Additional public correspondence (received at or since December 15,2009) M:\Projects\ZON2009-00007 (Zone 2 Moratorium Revisions)\20100105_StaffRpt_CC.doc 4-2 ORDINANCE NO.502 AN ORDINANCE OF THE CITY OF RANCHO PALOS VERDES ADOPTING FURTHER REVISIONS TO THE LANDSLIDE MORATORIUM ORDINANCE (CHAPTER 15.20 OF THE RANCHO PALOS VERDES MUNICIPAL CODE)TO ESTABLISH AN EXCEPTION CATEGORY TO ALLOW FOR THE FUTURE DEVELOPMENT OF THE SIXTEEN (16)MONKS PLAINTIFFS'LOTS IN ZONE 2 TO INCREASE THE MAXIMUM PERMITTED QUANTITY OF GRADING PER LOT FROM LESS THAN 50 CUBIC YARDS TO LESS THAN 1,000 CUBIC YARDS WHEREAS,on December 17,2008,the California Supreme Court denied the City's petition for review in the case of Monks v.City of Rancho Palos Verdes,so the City Council must consider the actions that are necessary to comply with the Court of Appeal's decision;and, WHEREAS,on January 21,2009,the City Council adopted Resolution No.2009-06 repealing Resolution No.2002-43,which had required property owners in Zone 2 to establish a 1.5:1 factor of safety before they could develop their lots and was the purported catalyst for the filing of the Monks lawsuit;and, WHEREAS,next action necessary to comply with the Court of Appeal's decision was to enact revisions to the current Moratorium Ordinance to allow the development of the Monks plaintiffs'sixteen (16)undeveloped lots in Zone 2;and, WHEREAS,pursuant to the provisions of the California Environmental Quality Act,Public Resources Code Sections 21000 et seq.("CEQA"),the State's CEQA Guidelines,California Code of Regulations,Title 14,Section 15000 et seq.,the City's Local CEQA Guidelines,and Government Code Section 65962.5(f)(Hazardous Waste and Substances Statement),the City of Rancho Palos Verdes prepared an Initial Study and determined that,by incorporating mitigation measures into the Negative Declaration,there is no substantial evidence that the approval of Planning Case No. ZON2009-00007 would result in a significant adverse effect on the environment. Accordingly,a Draft Mitigated Negative Declaration was prepared and circulated for public review for thirty (30)days between August 10,2009 and September 9,2009,and notice of that fact was given in the manner required by law;and, WHEREAS,after notice issued pursuant to the provisions of the Rancho Palos Verdes Municipal Code,the City Council conducted a public hearing on September 1, 2009,and September 15,2009,at which time all interested parties were given an opportunity to be heard and present evidence regarding the proposed revisions to Chapter 15.20 as set forth in the City Council Staff reports of those dates;and, WHEREAS,at its September 15,2009,meeting,after hearing public testimony, the City Council adopted Resolution No.2009-72 making certain findings related to the 4-3 requirements of the California Environmental Quality Act (CEQA)and adopting a Mitigation Monitoring Program and Mitigated Negative Declaration for the proposed project;and, WHEREAS,at its September 15,2009,meeting,after hearing public testimony, the City Council adopted Ordinance No.498 to establish an exception category to allow for the future development of the sixteen (16)Monks plaintiffs'lots in Zone 2;and, WHEREAS,Ordinance No.498 became effective on October 15,2009;and, WHEREAS,since the effective date of Ordinance No.498,three (3)Monks plaintiffs have filed Landslide Moratorium Exception (LME)applications to develop new homes on their undeveloped lots,but none of these proposals are consistent with the grading limitation of less than fifty cubic yards «50 CY)of grading that was imposed by Ordinance No.498;and, WHEREAS,as a result of discussions between City Staff,the City Attorney,the Monks plaintiffs'attorneys and their geotechnical consultant,it was agreed that the most expeditious solution to this conflict was to increase the maximum permitted quantity of grading associated with each of the Monks plaintiffs'LME applications. NOW,THEREFORE,THE CITY COUNCIL OF THE CITY OF RANCHO PALOS VERDES DOES ORDAIN AS FOLLOWS: Section 1:The City Council has reviewed and considered the further amendments to Chapter 15.20 of Title 15 of the Municipal Code. Section 2:The City Council finds that the further amendments to Chapter 15.20 of Title 15 of the Municipal Code are consistent with the Rancho Palos Verdes General Plan in that they uphold,and do not hinder,the goals and policies of those plans,in particular to balance the rights of owners of undeveloped properties within the Landslide Moratorium Area to make reasonable use of their properties while limiting the potential impacts resulting from such use upon landslide movement,soil stability and public safety within and adjacent to the Landslide Moratorium Area. Section 3:The City Council further finds that the further amendments to Chapter 15.20 of Title 15 of the Municipal Code are consistent Court of Appeal's decision in Monks v.City of Rancho Palos Verdes in that they will allow the potential future development of the sixteen (16)Monks plaintiffs'undeveloped lots within Zone 2 of the Landslide Moratorium Area with new,single-family residences,thereby achieving parity with the rights enjoyed by the owners of the developed lots in Zone 2 of the Landslide Moratorium Area. Section 4:The City Council further finds,based upon its own independent review,that there is no substantial evidence that the further amendments to Title 15 would result in new significant environmental effects,or a substantial increase in the Ordinance No.502 Page 2 of 7 4-4 severity of the effects,as previously identified the Mitigated Negative Declaration, adopted through Resolution No.2009-72 in conjunction with Ordinance No.498 for amendments to Title 15 of the Municipal Code,since the new amendments still provide regulations that would minimize impacts to properties within the City and the environment by protecting surrounding properties from the impacts of the potential future development of the Monks plaintiffs'sixteen (16)undeveloped lots.An Addendum (No.1)to the prior Mitigated Negative Declaration has been prepared and is attached hereto as Exhibit "A'.The City Council hereby finds,based on its own independent judgment,that the facts stated in the Addendum are true because the revisions to Title 15 of the Municipal Code will provide for the development on the Monks plaintiffs'lots in a manner that will have no significant adverse environmental impacts. Section 5:The City Council further finds that the amendments to Chapter 15.20 of Title 15 of the Municipal Code are necessary to protect the public health, safety,and general welfare in the area. Section 6:Based upon the foregoing,Paragraph P of Section 15.20.040 of Chapter 15.20 of Title 15 of the Rancho Palos Verdes Municipal Code is amended to read as follows: P.The construction of residential buildings,accessory structures,and grading totaling less than one thousand cubic yards of combined cut and fill and including no more than fifty cubic yards of imported fill material on the sixteen (16)undeveloped lots in Zone 2 of the "Landslide Moratorium Area"as outlined in green on the landslide moratorium map on file in the Director's office,identified as belonging to the plaintiffs in the case "Monks v.City of Rancho Palos Verdes, 167 Cal.App.4th 263,84 Cal.Rptr.3d 75 (Cal.App.2 Dist.,2008)";provided, that a landslide moratorium exception permit is approved by the Director,and provided that the project complies with the criteria set forth in Section 15.20.050 of this Chapter.Such projects shall qualify for a landslide moratorium exception permit only if all applicable requirements of this Code are satisfied,and the parcel is served by a sanitary sewer system.Prior to the issuance of a landslide moratorium exception permit,the applicant shall submit to the Director any geological or geotechnical studies reasonably required by the City to demonstrate to the satisfaction of the City geotechnical staff that the proposed project will not aggravate the existing situation. Section 7:After the effective date of this Ordinance,it shall apply to all Landslide Moratorium Exception permits and any subsequent development applications submitted on or after the effective date of this Ordinance. Section 8:The City Clerk shall certify to the adoption of this Ordinance and shall cause the same to be posted in the manner prescribed by law. Ordinance No.502 Page 3 of7 4-5 PASSED,APPROVED AND ADOPTED THIS 5TH DAY OF JANUARY 2010. MAYOR ATTEST: CITY CLERK STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES )ss CITY OF RANCHO PALOS VERDES ) I,CARLA MORREALE,City Clerk of the City of Rancho Palos Verdes,do hereby certify that the whole number of members of the City Council of said City is five;that the foregoing Ordinance No.502 passed first reading on December 15,2009,was duly and regularly adopted by the City Council of said City at a regular meeting thereof held on January 5,2010,and that the same was passed and adopted by the following roll call vote: AYES: NOES: ABSENT: ABSTAIN: CITY CLERK Ordinance No.502 Page 4 of 7 4-6 ORDINANCE NO.502 -EXHIBIT lA' ADDENDUM NO.1 TO MITIGATED NEGATIVE DECLARATION JANUARY 5,2010 Project Background:On September 15,2009,the City Council adopted Resolution No.2009-72,thereby adopting a Mitigated Negative Declaration for amendment to Title 15 of the City's Municipal Code (Ordinance No.498).Prior to its adoption,the Mitigated Negative Declaration was circulated for public comment from August 10,2009,through September 9,2009.In adopting the Mitigated Negative Declaration,the City Council found that:1)the Mitigated Negative Declaration was prepared in the manner required by law and that there was no substantial evidence that,with appropriate mitigation measures,the approval of the proposed Zone 2 Landslide Moratorium Ordinance Revisions (Planning Case No.ZON2009-00007)would result in a significant adverse effect upon the environment;2)that the Zone 2 Landslide Moratorium Ordinance Revisions were consistent with the Rancho Palos Verdes General Plan and with the underlying Residential,~1 DU/acre and Residential,1-2 DU/acre land use designations within Zone 2;and 3)that with the appropriate mitigation measures,which require Neighborhood Compatibility Analysis for new residences;limitations on exterior illumination;imposition of City and regional restrictions upon fugitive dust control and construction vehicle emissions;preparation of biological surveys for properties identified as containing sensitive vegetation communities;protection of cultural resources during grading operations;completion of geotechnical analysis of any proposed grading and construction prior to building permit issuance;imposition of fire protection requirements upon the construction of all new structures in accordance with the City's most recently- adopted Building Code;control and treatment of site runoff both during and after construction;limitations on construction hours and haul routes;and connection of all new structures to the Abalone Cove Sewer System,the Zone 2 Landslide Moratorium Ordinance Revisions would not have a significant impact on the environment. Proposed Amendments:The City Council is currently reviewing further amendments to Title 15 that would increase the permissible quantity of grading associated with the future development of each of the Monks plaintiffs lots in Zone 2 from less than fifty cubic yards (Le.,"minor grading")to less than one thousand cubic yards.The proposed amendments are intended to facilitate the timely review and approval of the development of new homes on the Monks plaintiffs'lots,while continuing to balance the impacts of said development upon the surrounding community with the potentially significant adverse financial impacts to the City as a whole if this development is not permitted to occur,as required by the Court of Appeal. Purpose:This Addendum to the previously adopted Mitigated Negative Declaration is being prepared pursuant to Section 15164 of the California Environmental Quality Act (CEQA)Guidelines which allows for the lead agency to prepare an addendum to an adopted negative declaration if only minor technical changes or additions are necessary or none of the conditions described in Section 15162 calling for the preparation of a Ordinance No.502 Page 50f7 4-7 subsequent EIR or negative declaration have occurred.Pursuant to CEQA Section 15162,no subsequent negative declaration shall be prepared for the project unless the lead agency determines,on the basis of substantial evidence in the light of the whole record,one or more of the following: (1)Substantial changes are proposed in the project that will require major revisions of the previous negative declaration due to the involvement of new,significant environmental effects or a substantial increase in the severity of previously identified significant effects; (2)Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;or, (3)New information of substantial importance identifies one or more significant effects not discussed in the previous negative declaration,significant effects previously examined will be substantially more severe than shown in the previous negative declaration,mitigation measures or alternatives previously found not to be feasible or not analyzed in the negative declaration would be feasible and would substantially reduce one or more significant effects but the project proponents decline to adopt of the measure or alternative. FINDINGS ON REGARDING THE PROPOSED PROJECT REVISIONS: 1.Staff analyzed the proposed revisions to determine if any impacts would result from the proposed changes allowing an increase in the maximum permitted quantity of grading per lot from less than 50 cubic yards to less than 1,000 cubic yards.This analysis included review of the proposed revisions by the City Geologist.The City Council has independently reviewed this item and has determined that,pursuant to CEQA Guidelines Section 15162,a new Mitigated Negative Declaration is not required for this revision because the proposed amendments will not result in any new significant environmental effects: (a)The proposed revisions do not result in any new significant environmental effects and,like Ordinance No.498,no unmitigatable significant impacts have been identified.The increase in allowable grading does not present new significant environmental impacts because it still only allows for the future development of each of the Monks plaintiffs'lots with a single- family residence,in a manner that is consistent with the development standards established by the Portuguese Bend Community Association. Furthermore,the City Geologist determined that the proposed revisions do not present any new significant unmitigatable impacts.Therefore,the proposed revisions do not represent a substantial change in the project, and will not result in new significant environmental impacts or a substantial increase in the severity of any impacts. (b)The proposed revisions will not result in any significant environmental impacts,and the circumstances under which the project is being Ordinance No.502 Page 6 of? 4-8 undertaken have not substantially changed since the CEQA determination was made for Ordinance No.498.The scope of allowable development (a single-family residence on each of the sixteen (16)lots)remains the same,and there are no changes with respect to the circumstances under which the revisions are undertaken that will require major revisions of the previous Mitigated Negative Declaration. (c)No new information of substantial importance,which was not known and could not have been known with the exercise of reasonable diligence at the time the prior Mitigated Negative Declaration was adopted,identifies a significant environmental effect.Because the proposed revisions would not result in any new or more severe environmental impacts that those associated with Ordinance No.498,there is no need for new or substantially modified mitigation measures. Therefore,pursuant to CEQA,the City Council finds that no further environmental review is necessary other than the City Council's adoption of this Addendum No.1 M:\Projecls\ZON2009-00007 (Zone 2 Moratorium Revisions)\20100105_DraftOrdinance_CC.doc Ordinance No.502 Page?of?4-9 Page 1 of 1 Kit Fox From:Carolynn Petru [carolynn@rpv.com] Sent:Friday,December 11,2009 11 :14 AM To:'Carla Morreale' Cc:'Teri Takaoka';'Kit Fox' Subject:FW:12.Revision to Planning Case No.ZON2009-00007 (Code Amendment and Environmental Assessment) From:Gordon Leon [mailto:gordon.leon@gmail.com] sent:Friday,December 11,2009 11:09 AM To:cc@rpv.com;Cassie Jones Subject:12.Revision to Planning Case No.ZON2009-00007 (Code Amendment and Environmental Assessment) Honorable Mayor and City Council, I am very concerned about the proposal for a blanket increase in the allowable grading within the fragile Portuguese Bend Landslide area (zone 2)without sufficient study or environmental impact assessment. 1000 Cubic Yards of grading implies digging over 6 feet deep under the maximum allowable house in Portuguese Bend.Excessive grading will have the most significant impact on the overall stability of the landslide area.Further,the decision regarding the 16 Monk lots will likely set president for the remaining lots in Zone 2.I understand that the court has mandated building permits in the Portuguese Bend Community,but you also have an obligation to protect the other residents in the Community. Relaxing safeguards with know impacts to the area's stability is contrary to that duty.Please do not allow a blanket increase to the grading requirements for the 16 Monk lots. Thank you. Gordon Leon 310-463-9244 12/14/2009 4-10 From:Carolynn Petru [carolynn@rpv.com] ¢l'qnt:Monday,December 14,20093:38 PM 'Carla Morreale' Cc:'Teri Takaoka' SUbJect:FW:"Urgency Ordinance"in PB From:Marianne Hunter [mailto:2hunter@cox.net] sent:Monday,December 14,2009 3:30 PM To:City Council Cc:cassie Jones;Tim Kelly Subject:"Urgency Ordinance"in PB William &Marianne Hunter http://www.hunter:~dios.cQ.m Dear City Council; It has come to our attention that there is an "Urgency Ordinance"to be considered that would increase the amount of permitted grading on the 16 Portuguese Bend lots to geometrically expand from 50 yards to 1000 yards.We urge you to reject this request at this time. We.many members of our community and members of surrounding communities are understandably very concerned about the f "5,both long and shorttenn,ofthe building process and end results of such.That is why we have urgently requested the City to p...__....rm an EIR rather than an MND,because only an EIR can determine what it means to allow grading in this fragile community., The City is under considerable pressure,we understand that.However,we believe the City is risking both untold financial loss to itself (and thus all RPV residents)as well as the homes and safety of those whose homes are vulnerable to the landslide areas. Should PV Dr.South fail,or homes in PB slide,the financial repercussions to the City,and quality oflife considerations for residents is incalculable.The ensuing lawsuits (no pun intended)could be massive.(Could Terranea sue the City for not taking proper safeguards in a known hazard area to protect access to it's business?) This "Urgency Ordinance"is just the fll'St of many,to be sure,asking for special treatment and pushing for more than allowed. What the City must decide is if they are going to stand for what is right,which is public safety first,or to expediency and threat.100 families have lived carefully on this landslide for decades.Shall all our restraint and limitations go for nothing as our new neighbors throw caution to the wind and gamble with our homes as they gambled with their moratorium-bought lots before? If you are not going to tum down this request for extra grading,then,at the minimum,it should be determined by geo-engineers without bias.Crenshaw failed due to earth movement and water;the 18th hole at Trump's failed due to man made mistakes,and both situations were engineered.It is unconscionable to proceed without first employing every method of measuring the potential effects when tampering with a known landslide. Please say ''No''to this urgency ordinance.The 100 families who make up this community should have rights to safety and the enjoyment of our investments equal to those 16 who have purchased lots in ignorance or in spite ofthe fragility ofthis place. Respectfully, v ····lam and Marianne Hunter 12/14/2009 /d-4-11 Kit Fox From: Sent: To: Subject: Teri Takaoka [terit@rpv.com] Wednesday,December 16,2009 11:16 AM 'Kit Fox' FW:Revision to Planning Case ZON2009-00007-Further Revisions to the Landslide Moratorium Ordinance -----Original Message----- From:Carolynn Petru [mailto:carolynn@rpv.com] Sent:Tuesday,December 15,2009 7:57 AM To:'Carla Morreale' Cc:'Teri Takaoka' Subject:FW:Revision to Planning Case ZON2009-00007-Further Revisions to the Landslide Moratorium Ordinance -----Original Message----- From:Jeremy Davies [mailto:jdavies@kuboaa.com] Sent:Monday,December 14,2009 9:19 PM To:CC@rpv.com Subject:Revision to Planning Case ZON2009-00007-Further Revisions to the Landslide Moratorium Ordinance Dear Mayor Wolowicz,Mayor Pro Tern Long,Council Members Campbell, Misetich and Stern, Item 12 of your agenda for the your December 15,2009 meeting proposes approving an "Exception Category"for the MND which was approved and adopted on September 15,2009.This MND to the Landslide Moratorium Ordinance was approved only after due public discussion and input, including input and agreement of the Monks plaintiffs.You now propose to increase grading per lot from 50 cubic yards to up to 1,000 cubic yards,a twenty fold increase without any discussion or consideration of the environmental impacts of such a measure in this unstable area. I and many of the homeowners in Portuguese Bend,as well as certain lot owners,have requested that before the issuance of any permits for new residences be issued there should be a full EIR carried out taking into account all the special circumstances of this area and in accordance with the requirements of CEQA.Your latest proposed change to grading allowances ignores any additional environmental impacts of such changes and continues to be contrary to CEQA.I believe that it would be prudent and advisable for the City to not make any additional arbitrary modifications to a City approved MND until a full EIR has been carried out and not to treat this modification as a matter of "Urgency". Respectfully yours, Jeremy Davies 1 4-12 From: Sent: To: Subject: Page 1 of 1 Kit Fox Carol W.Lynch [CLynch@rwglaw.com] Tuesday,December 15,200910:12 AM kitf@rpv.com FW:Correspondence re Item 12 on 12/15/09 City Council Agenda (Revision to Planning Case No.ZON2009-00007) Attachments:Burton Letter.pdf -----Original Message----- From:Yen Hope [mailto:yhope@gilchristrutter.com] sent:Monday,December 14,20096:22 PM To:stevew@rpv.com;tom.long@rpv.com;Brian.Campbell@rpv.com;Anthony.Misetich@rpv.com; Douglas.Stern@rpv.com Cc:citymanager@rpv.com;cityclerk@rpv.com;Carol W.Lynch;Ginetta Giovinco;Rochelle Browne Subject:Correspondence re Item 12 on 12/15/09 City Council Agenda (Revision to Planning case No.ZON2009- 00007) Attached please find a letter from Mr.Martin Burton regarding Item 12 on the December 15,2009 City Council Agenda (Revision to Planning Case No.ZON2009-00007).A hard copy of the letter will follow by mail. Sincerely, Yen N.Hope,Esq. Gilchrist &Rutter Professional Corp. 1299 Ocean Avenue,Suite 900 Santa Monica,CA 90401 Tel:(310)393-4000 Fax:(310)394-4700 Unless otherwise expressly stated,nothing stated herein is intended or wrilten to provide any tax advice on any malter,and nothing stated herein can be used for the purpose of avoiding tax penalties that may be imposed on a taxpayer. a,g 3=C 3=C Privileged/Confidential information may be contained in this message. If you are not the addressee indicated in this message (or responsible for delivery of the message to such person),you may not copy or deliver this message to anyone.In such case you should destroy this message,and notify us immediately.If you or your employer do not consent to Internet e-mail messages of this kind,please advise us immediately.Opinions,conclusions and other information expressed in this message are not given or endorsed by my firm or employer unless otherwise indicated by an authorized representative independent of this message. NOTICE:This communication may contain privileged or other confidential information.If you are not the intended recipient of this communication,or an employee or agent responsible for delivering this communication to the intended recipient,please advise the sender by reply email and immediately delete the message and any attachments without copying or disclosing the contents.Thank you. 12/15/2009 4-13 LAW OFFICES· GILCHRIST &RUTTER PROFESSIONAL OORPORATION WILSHIRE PALISADES 8UllDING 1299 OCEAN AVENUE.SUITE 900 SANTA MONICA,CALIFORNIA 90401-1000 December 14,2009 VIA EMAIL AND U.s.MAIL Mayor Steve Wolowicz Mayor Pro Tern Thomas D.Long Councilmember Brian Campbell Council member Anthony M.Misetich Councilrnember'Douglas W.Stern Rancho Palos Verdes City Council TELEPHONE (310)393-4000 FACSIMILE (310)394-4700 EO-MAil:mburlonOgllchr1sl...tter.com Re:Proposed Ordinance Adopting Further Revisions To Landslide Moratorium Ordinance To Establish An Exception Category To Allow For The Future Development Of The Sixteen(16)Monks Plaintiffs'Lots In Zone 2 To Increase The Maximum Permitted Quantity Of Grading Per Lot From Less Than 1,000 Cubic Yards ("Proposed Amendment").City Council Hearing:Tuesday, December 15,2009 Dear Mayor Wolowicz,Mayor Pro Tern Long,and Councilmembers Campbell,Misetich,and Stem: This office represents Dr.Lewis A.Enstedt,a resident of the City of Rancho Palos Verdes,and the Portuguese Bend Alliance For Safety (the "Alliance"),an unincorporated association.We are writing to object to the Proposed Amendment referenced above,which would further revise the Landslide Moratorium Ordinance. As you are aware,on September 15,2009,the Rancho Palos Verdes City Council ("City Council")adopted Ordinance No.498 (the "Landslide Revisions"or "Project"),which revised the Landslide Moratorium Ordinance to create an exemption category within the City of Rancho Palos Verdes ("RPV,"collectively with City Council,"City")Municipal Code to allow for the future development ofthe sixteen (16)Monks plaintiffs'lots in Zone 2,and Resolution No. 2009~72,which certified a mitigated negative declaration related thereto ("August MND"or "August Mitigated Negative Declaration").Dr.Enstedt and the Alliance objected to the August MND as failing to comply with the requirements of the California Environmental Quality Act,Cal.Pub.Res.Code §§21000,et seq.("CEQA"),and its guidelines,14 Cal.Code Regs.§§15000,et seq.(the "CEQA Guidelines")in that it failed to fully identify,analyze and mitigate the significant environmental impacts arising from the Landslide Revisions. 4-14 LAW oFFicEs GILOHRIST &RU'1."J:'ER PHOFESSJONAI,OORPORA'l.'lON Mayor and City Council Members City of Rancho Palos Verdes December 14,2009 Page 2 Now,only three months after the City adopted the Landslide Revisions and certified the August MND,the City is seeking to amend the Landslide Revisions by increasing the maximum permitted quantity of grading per lot from 50 cubic yards to 1,000 cubic yards,a staggering increase of2000%!However,the City again fails to comply with the CEQA requirements. Rather than fully analyzing the impact of the Proposed Amendment,which drastically changes one of the main assumptions underlying the Geology/Soils mitigation measures in the August MND -that the proposed project would result in no more than 800 cubic yards of grading (August MND at p.11)-the City attempts to simply adopt an addendum to the August MND ("Addendum"). The Proposed Amendment and Addendum represent yet another effort by the City to circumvent CEQA requirements in order to improperly placate the Monks plaintiffs,The December 15,2009 staffreport ("Staff Reporf')essentially admits this fact when it states that its recommendation that the City adopt the Proposed Amendment is based on the "City's possible exposure to financial damages as a result of denying [the Landslide Moratorium Exception Permits]..."(Staff Report at p.12-3.)However,this rationale is insufficient and flawed for the reasons set forth below. First,the City has a rational basis for choosing to limit development to minor grading which is not addressed in the Proposed Amendment or Addendum.Among other things,Zone 2 is an acknowledged geographically unstable area.For example,the August MND admits "[t]he soils of the Palos Verdes Peninsula are 0 generally known to be expansive and occasionally unstable."(August MND at p.11.)Indeed,the conclusion that the Landslide Revisions would result in no more than "800 cubic yards of grading related to the construction ofup to sixteen (16)new single-family residences"served as a key piece of evidence to justify the August MND's finding of no significant impact in its Geography/Soils analysis (which finding was itself flawed even with minor grading).(August MND at p.11.)Yet,despite the fact that the Proposed Amendment would dramatically increase the total quantity of grading from 800 cubic yards to 16,000 cubic yards,the City wholly fails to evaluate and analyze the impact of this drastic increase.The change wrought by the Proposed Amendment,especially given its scope, merits additional environmental review. Second,the Addendum provides no analysis or evidentiary support for its conclusion that the Proposed Amendment will "not result in any new significant environmental effects."(Staff Report at p.12-23.)In fact,although the Addendum alleges "the City Geologist determined that the proposed revisions do not present any significant unmitigatable impacts,"(Staff Report at 12- 23),this conclusion is not only not supported by the evidence,but nowhere does this conclusion even appear in the letter from the City Geologist attached to the Staff Report.The City Geologist's letter fails to state that the Proposed Amendment does not "present any significant 4-15 LAW OFFices GILOHRIST &RUTTER PROFESSIONAL CORPORATION Mayor and City Council Members City of Rancho Palos Verdes December 14,2009 Page 3 unmitigatable impacts."Instead,the letter recommends ''that the amount of grading be evaluated on a case by case basis"and notes that "[a]finding that the proposed grading will not aggravate the existing conditions will need to be made by the geotechnical consultant of record."(Staff Report at p.12-8.) Third,the Staff Report notes that the City faces "possible exposure to financial damages" because the Landslide Moratorium Exception Permit ("LMEs")applications submitted thus far "each propose quantities of grading that exceed the definition of 'minor grading'...[and]cannot be approved by Staff under the current [Municipal Code]."(Staff Report at p.12-3.)However, the grading restriction in the Landslide Revisions does not constitute a taking.The restriction does not deprive the Monks plaintiffs of all economically viable use of the property.(Kavanau v. Santa Monica Rent Control Bd.,16 Cal.4th 761,774 (1997).)Nor does it satisfy any ofthe other factors articulated in Penn Central Transp.Co.v.New York City,438 U.S.104,124 (1978)and subsequent cases which would indicate a taking.(Id.)Rather,the Monks plaintiffs are clearly· able to economically use their property even with the 50 cubic yard restriction. Just because the plaintiffs desire larger houses does not mean they are entitled to them. This puts the cart before the horse.Rather than the City amending its ordinance,the Monks plaintiffs simply need to amend their LME applications.As the City itself notes,"the residences might be re-designed ...so as to 'work with'the slope of the lots and require less site grading." (Staff Report at p.12-4.)That one possible redesign might be incompatible with private architectural guidelines is not a reason for the City to amend the Landslide Revisions,when the Landslide Revisions themselves do not constitute a taking.The City should not amend the Landslide Revisions simply because the plaintiffs'applications cannot be approved in their present form. Finally,and most importantly,the Monks plaintiffs have waived their right to object to the Landslide Revisions altogether.The restriction on grading to 50 cubic yards was clearly spelled out in the MND.There was no attempt on the part of the City to hide the restriction. Counsel for the Monks plaintiffs was present at all the City Council hearings at which the Landslide Revisions,which permitted only minor grading,were discussed and ultimately adopted.Counsel for the Monks plaintiffs,as well as the Monks plaintiffs themselves,had numerous opportunities to object to the limitations on the quantity of grading before the Landslide Revisions were adopted.Yet,neither he nor any of the Monks plaintiffs objected to the Landslide Revisions.To the contrary,counsel for the Monks plaintiffs indicated he had carefully reviewed the Landslide Revisions,and advocated for and enthusiastically championed their adoption.The Monks plaintiffs cannot now threaten the City with a takings claim for taking an action they themselves supported. 4-16 LAWOFFJCES GU..CHRIST&RUTTER PROFESSIONAL CORPORATION Mayor and City Council Members City of Rancho Palos Verdes December 14,2009 Page 4 In sum,we urge the City Council not to adopt the Proposed Amendment and Addendum. By adopting the Proposed Amendment and Addendum,the City is endangering the environment of the Portuguese Bend area and putting the health and safety of its citizens at risk.Ifthe City is truly concerned about a taking being found,at a minimum,the City should await a decision from the trial judge in the Monks case.It cannot,and should not,evade the CEQA requirements and simply adopt the Proposed Amendment to appease the Monks plaintiffs,especially where the plaintiffs themselves have waived their right to object to the grading limitation imposed by the Landslide Revisions. Please include this letter in the record of proceedings on this matter. Very truly yours, GILCHRIST &RUTTER u:;;~~ ___._.....Marti:rrM:-rr-uttOn OftheFinn 199906 1 4811.001 cc:Carolyn Lehr,City Manager Carol Lynch,Esq.,City Attorney Carla Morreale,City Clerk Ginetta Giovinco,Esq. Rochelle Brown,Esq. Yen N.Hope,Esq. 4-17 .-._---_._---------::----------_.---------.-.__._--------._------------------_.._------------._-_._--.._-----_.-.- Scott W.Wellman Scott R.Warrell Derek Banduccl David Van Sambeek Matt Krepper of counsel ..StU&1per*.CIl;QV P am ZottiArsoadmittedin NY WELLMAN ,&WARREN LLP ATTORNEYS AI'LAW 24411 Ridge Route,Suite 200 Laguna Hills,.California 92653 December 15,2009 Tel.949/580-3737 :f,ax ,249/58.0-3738 stuartmiller@learthlink.net Mayor Stefan Wolowicz Mayor Pro Tem Thomas Long . Counci1memper Brian Campbell 'Councilmember Anthony Misetich ·Councilmember Douglas Stem Re:Proposed amendment to Landslide Moratorium Ordinance DeE!!'Mayor Wolowicz,Mayor .Pro Tem Long,and Councilmembers Campbell,Misetich,and Stem: We represent the plaintiffs in Monks v.City ofRancho Palos Verdes.We are writing in response to the letter from Martin Burton,Esq.,in which he expresses opposition to the proposed amendment to Chapter 15.20 ofthe Municipal Code.This matter is on the City Council's agenda tonight.Please make this letter part of the administrative record.- Mr.Burton is incorre~t in a number of critical respects. First,as we all know from the decision ofthe Court of Appeal,Zone 2 is not "an acknowledged geographically unstable area."There has never been any evidence to support Mr. Burton's characterization of Zone 2. .Second,Mr.Burton does not understand the status ofthe Monks litigation.His argument that "the M(Jnks plaintiffs are clearly able to economically use their property even with the 50 cubic yard restriction,"whether true or not,is ofno relevance.The City has already taken the . plaintiffs'properties.It no longer has the option ofavoiding a taking by allowin~a minimal·use. 'Third,Mr.Burton writes,"If the City is truly concerned about a taking being found,at.8. minimum,the·City should await a q.ecision froni the trial judge in the Monks case."A taking has already been found in the Monks case,and the trial judge has no authority to rule otherwise. Fourth,"the Monks plaintiffs have not "waived their right to objectto the Landslide Revisions altogetl).er."Whether and how the City avoids the obligation to purchase the plaintiffs' properties is not our direct concern.We prefer a purchase at fair market value,and llave never acknowledged that the current state of the ordinance suffices to excuse the City from purchasing . the properties.On the contrary,it is our position that the limitation of 50 cubic yards of grading. .does not excuse the City from the obligation to buy the land.Other landowners in the City are . allowed up to 1,000 cubic yards of grading,and there is no reason the Monks plaintiffssh01l1d not have the same right.. Fifth,we have neither "advocated for [nor]enthusiastically championed"the amendment authorizing 50 cubic yards of grading. 4-18 ....._..-.-_.---------._--_._.,._--------_._----_.._._-_._-----_.__.._..---._._._-------_._._.------'" City Council Re:Proposed amendment to Landslide Moratorium Ordinance December 15,2009 page 2 .Sixth,the amendment will not "increase the total quantity of grading ...to'16,000 cubic yards."Although a maximum of 1,000 cubic yards will be allowed on each lot,there is no reason to believe any lot owner will grade that much..The three permit applications already filed,which are described in the staff report,propose an average of only 450 cubic yards per lot.. Seventh,Mr.Burton asserts that there are "significant environmental impacts arising from"the proposed amendment,but he identifies none ofthem.In fact,his assertion of undefined environmental harm is belied elsewh~re in his letter,when he acknowledges that "a finding that the proposed grading will not aggravate the existing conditions will '.'.be made by the geotechnical consultant of record.".. In short,we think i~is in the City's best interest to enact the proposed amendment without .delay. .,..very iiiilY·YOurs, "------~---­ Scott Wellman .~~ Stuart Miller 4-19 Page 1 of3 Kit Fox From:Carol W.Lynch [CLynch@rwglaw.com] Sent:Tuesday,December 15,2009 2:41 PM To:kitf@rpv.com Subject:FW:Agenda item 12 I wonder if Jim Lancaster can come to the meeting tonight. -----Original Message----- From:jim_knight [mailto:jim_knight@juno.com] sent:Tuesday,December 15,2009 2:37 PM To:cc@rpv.com Subject:Agenda item 12 TO:The Mayor and Council members FROM:Jim Knight DA TE:12-12-09 RE:Revision to LME,Agenda item12 Dear Mayor and Council members Below I have listed some concerns regarding agenda item 12 or the Urgency Ordinance. 1)The ordinance does not completely comply with the City Geologist's report. A)Jim Lancaster specifically stated that the modification of grading should not apply to import of material.From his Dec.8,2009 report:"Generally,the grading will be confined to the redistribution of earthmaterials within a single lot or exporting of materials from the site. Import of raw earthmaterials for the use of fill should not exceed the 50 cubic yard threshold (this does not include construction materials such as wall backfill granular materials or underslab granular materials)."The ordinance does not make this distinction as to types of grading. B)Jim Lancaster also recommends in that report It•••that the amount of grading be evaluated on a case by case basis in combination with the subject lot's geotechnical reports, proposed grading plan and potential impact to adjacent properties.'The ordinance does not condition approval on a case by case basis nor require analysis of potential impacts to adjacent properties. C)In the May 15,2007 Report dealing with the Portuguese Bend Landslide from Zieser Kling,the City geologist states "From a risk assessment standpoint,it is our professional opinion that any grading above the 20 cubic yard threshold could raise the risk above an acceptable level".What has changed in the geotechnical opinion that the City Geologist now allows a 50 fold increase in grading? 2)Geological standards of approval for the proposed urgency ordinance uses language that is vague.What is the definition of "aggravate"and "the existing situation"mean?Do these terms have any quantifiable definition?Is "aggravation"and the "existing situation"only referring to the applicant's lot?Or does it include "aggravation"beyond the lot boundaries?Is 12/15/2009 4-20 I '- Page 2 of3 the existing situation only the lot in question or the known landslide complex in which the lot is being developed?Is the ordinance consistent with minimum standards of practice as exercised within the geotechnical community?Is there any concern about geology beyond the boundaries of the applicant's lot? City geologists have rendered an opinion that development within areas of landslide hazards is unwise unless the landslide instability can be mitigated to a level consistent with at least the minimum standards of practice as exercised within the professional geologic and geotechnical community.(Zieser Kling report May 15,2007).Does the ordinance comply with this standard? 3)There is existing litigation challenging the MND's compliance with CEQA guidelines.This MND is being used as being compliant with CEQA to proceed with application approvals. How can the city proceed with a pending litigation that challenges the city's use of this MND? Technically the MND may have standing until a court orders differently,but as a practical matter what will be the consequences to an approved application if a new EIR changes the playing rules and requires further mitigations?I.e.,there are serious storm drain issues in the community that could need mitigation from any further hardscaping of accumulative development.Will taxpayers have to compensate the new residents if new requirements cause additional expense as a result of using this MND instead of a court ordered EIR? Taking the current course of action assumes the court will reject the request for a full EIR. 4)What is the basis for stating the increasing allowable earth movement by 20 fold in a known landslide area "does not present substantial new information of significant impacts caused by the project"? 5)The Urgency Ordinance does not address the full project as described in the MND.The City has acknowledged that it cannot treat these 16 litigants any differently than anyone else in Zone 2.So in reality the ordinance should apply to all lot owners in Zone 2 which is accumulatively a significant impact that the urgency ordinance for the 16 litigant's lots does not address.It also looks a lot like spot zoning.And the addendum to the MND does not match the urgency ordinance in scope.The urgency ordinance only address the 16 litigants lots yet the MND project description is all of the lots in Zone 2.Even the scope of the project within the MND intermingles the 16 litigants with the entire project of Zone 2.This is a direct result of segmenting the project under the MND as between the 16 litigants and all lot owners of Zone 2. I respectfully request that all of these questions and issues be fully addressed in your deliberations of this agenda item. Thank you, Jim Knight 12/15/2009 4-21 Page 3 of3 BarLCI~itLoan ~~~g!<l:1~h·LARP1J'~nQwJQ1:fl~!<r~gitlQillLwj!hfl:1~tl:1p.PIQYl:!l, NOTICE:This communication may contain privileged or other confidential information.If you are not the intended recipient of this communication,or an employee or agent responsible for delivering this communication to the intended recipient,please advise the sender by reply email and immediately delete the message and any attachments without copying or disclosing the contents.Thank you. 12/15/2009 4-22 RECEI'VED MAY 242007 _~ZEISER _KLING:~.._C-ukants,In~. May t5,200? Mr.Joel R.ojas CITY OF :RANCHO PALO$VEJ.U)ES )094&Hawthorne Boulevard Rancho Palos 'fel'df:'S,CA 90275 ..5391 PLANNING,BUILDING &: OODE ENPORCEMENt Subject:~l()gi¢and Geotechnical ~UU()~lte~i1\~Development Within the Landslide MoratPrlum }\rea,Rancho Palos Verdes,California .- Dear Mr.Rojas: At your request and authorization,our finn has been tasked '\\jth providing this geologic at}d geoteclmical opinion paper regarding development within the city's.current landslide moratorium area.This paper intends to address the folloWing general questions: 1)From a geologic and geotechnical engineering perspective,should the City continu~to "prohibit new construction on vacant lots Within the landslide moratorium area? 2)From a geologic and geotechnical enginee~g perspective,is it detrimental to the landslide moratorium area to continue to all<>wexistingresidents to add minor square footage ant improvements to their existing homes,such asthe 600 square :feet maximum allowance that currently exists? 3)Should such rules be the same in the blue -~.asthey are for the red area? We have beellas~edto approach the above qu~ti()l$fi'Qm ageologic and geotechnical engineering perspective based on our knowledge of thegeolQgy ofthe $ora,tonurn.areas;all-assessmelit of the cttn'ent ancipotential movement witltinthe area,and past and present citypoiicies within the landslide moratorium areas. First ofall,we would like to make our basic position regarding developmentQr building within any area of landslide hazard very clear.From a purely geologic perspective,it is our opinion that development within areas oflandslide hazards is unWise at any'time unless the landslide instability can be nUtigated to a level consistent with at least the minimum code and stanciards of practice as exercised within the professional geologic and geotechnical community.It should be understood that by developing in an area of landslides or potential landsliding there are inherent risks to life safety 1221 E.Dyer Road,Suite 105.Santa Ana,Califorl"lia 92705 (714)755-1355 Fax (114)155·1366 The Trusted Name in Geotechnical Consulting For Over Twenty Years 4-23 PN 97082-1364 - CITY OF RANCHO PALOS VERDES May 15,2007 and property that vary depending on the type and scale ofbuilding and/or development,and'location and geologic enviromnent involved.When disoussing the topjc of'risk herein we are referring te the potential of increasing geolegic instability and the petential for creating or increasing unsafe conditions With respect to property and/or the health and ·safety ofthe populace.People who choose to live,within known landslide areas are exposing themselves to a higher degree ofrisk than those whe live elsewhere. The inherent nsl<s involved with development in a lanelslide area inc1'eMC'with the scale of the proposed imprevement.In general,a minor addition with tittle or no grading or landfurm mOOitication poses a lower risk compared to a large development with.1l'H.Yor grading and associated landform modifiCl,ltion.A minor addition that introd~1'10 additio~irrigation or water.USQ poses less risk than.a subdivision comprised ofnumerous new hemesthatwould 6kely introduce additional water into the groundwater system. The above discussion is simplistic and does not cover a landslide area,however it has been utilized as a basis Raneho'Palos Verd¢s Landslide moratorium area. tential hazatds ortisks to development in •our continued discussion directed to the Question #1:From a geologic and geotechnical engineeuingpers.pective,shQuld we continue to pronibitnewconstruction on vacant lots within the landslide moratorium area? The obvious answer to this question is that people ~holj:ve within.an active or petentially active landslide area ate subjeot to a higher degree ofrisk than people who five outside ofsuch areas.By ·allowingnew development to ()ccut within an area withlmo'WIi bigher riskto life safety and pmperty~ more people w()uldbe potentiall~exposed to that risk.' Beyond this simple evaluation is to consider the varying rlsk:s associateEl with different development actions.In order to explore this further,it should be Wlderstood that aU areas within the latJ;dsIide ffiGratorlum atea are SUbject to some degree ofrisk.Some ateas are 'associated with active landslide movement and are subject to an eve»higher degree ofrisk.Stillotherareashaveexperienced little or no perceived movement.However~even with little to no pereeivedmoveme»t,these areas are still considered to be below the accepted geotechnical industry standatdofpra,ctieeand the building code level ofstability. First.of all we.would like to address the issues of~ding to I'ilreate building pads.Asset forth by Municipal Code section 17.76.040,a minor gradingpennitis to be issuedforgradinginexcess of20 cubie yards but less than 50 cubic yardS in any twe yearperiod~on a slope ofless than 35 pt}rcent or which results in an excavation or fill of more then three feet but less than 5 feet.From a risk assessment standpoint,it is our professional opinion that any grading above the"20 cubic yard threshold could raise the dskabove an unacceptable level.On the other hand~limited grading comEl be considered acceptable ifit does not create drainage issues such asblGcking orreElirecting drainage E:\projeclS\t991\97082-1364 position paper moratorium area 5-07.doc 4-24 PN 97082-1364-CITY OF RANCHO PALOS VERDES May 15,2007 to areas oipotential increased subsur.face percolation and is limited to tills up to 3 feet in heightand less than 20 cu.bic yards of earth movement. The addition ofsl.lbsUi'face water within the landslide moratorium area cou1d have a detrimental aft'ect on its stability.The risk therefore increases substantially If the project is served by on~site sewage dispo$al ot has 00 access to stonn drain runoff collection. Anynewprojec~development otsingle.family home that requires only limited gradlng (as defined above)andcou1dcollect and dispose of storm water or sewer emuents from theptoject site to outside the latldsUdearea would theoretically.have no iInpaet on th¢stability oithe landslide; however,the baseline risk associated with any new projecj'would be the samea.s other properties withinthelandsUde.As stated above,these new developments would serve to expose more people to at l~the baseline level of risk associated with living in a landslide .area. Based on the above,it is our professional opinion that new developmentnotbe allowed within any ofthe moratorium area. Question t2:From a geologic and geotechnical enjineering perspectt'vt.is it detrimental to the landslide to continue to allow existing residents to add minorsfJuart{oo(age and improvements to their existing htJmes,such as the 600 square feet maximum allowancethaf currently exists? From a geologic and geotechnical perspective,the issues ofgrading~sew~edispo$aland$torm water 11l11offeollection discussed above are stUl the main factotsunder consideration in addressing thisql.l<::Sti0n.:rheaetmd weight ofastructllre is generally v~~l to the weight of the entirelandsli'4e~s.In addition,itcou1d beatgued that somemin.o~>j..can,actually enhance the ctraina.ge ofthe site.Therefore,from one perspective,amin.imaladditiPn to an existing residence (te.6008qmtte feet or less)or limited grading (20 Cubic yards dtless)wQu1dnot add to the instability oithe landslide moratoriwn areas,and may have the beneficial effect of itnproving drainage and redllcing permeable area for runoff to enter into the landslide.It is also our professional opinion that minor additions that involve only limitedgradiilg(less than 20 cubic yards) and .do not increase the potential for infiltration of water into the subsPrface are acceptable from a geologic and geotechnical perspective.The potential infiltration of wat$:may be prevented with storm water disposal and sanitary sewer or demonstration that the project will not increase the potential ror infiltration otwater into the subsurface. Swimming pools,spas,and other water features could create the potential for adding water into the subsurface,potentially decreasing the stability ofthe landslide area.Therefore,pr~jects that would potentially destabilize the moratorium areas such as swimming pools,spas,and other water features should not be allowed. E:\projecIS\1997\97082·1364 position papermollltorium an:a 5-07.doc @ 4-25 - CITY OF R..A:NCHO PALOS VERDES May 15.:Z007 - PN 97082-1364 The issue ofthe size Of an addition is generally a policy issue.Whether the allowed addition is 200 square {eetor 1,000 square feet will not make a substantial difference from a geologic perspective.It should be understood that the larger the addition the more the issues ofgrading and runoff come into play.In addition,at a certain point,additional square footage would serve to expose more people to landslide risk.. Partially to cobforn1.to current code standards,we would recommend that the levels for additions currently allowed by the moratorium ordinance be eStitblished at acumtkuve.m~umof 1,200 square feet for all additions including habitable and non-habitable space.The cumulative totals may include firSt $'tory,seeottd sto!'Y and garage additions.The square footageofalladditions.including the garageadditionJ,lJUly t>einterchanged provided the cUl1lulative total doesnofexceeda cumulative total of 1,200 square feet.It is fUrther recommended that the geology and soils engineering report requirem~ts set forth in thecutrentcode also continue. Question ff:3:81w'tllrl such rules be the same in the blue area as they are tor the red area?· C~tly the code d~rentiates a portion ofthe Klondike Canyon landSlide:as the "blue"area and has treated itdiff'etentlyftomother areas ofthe moratorium.From a pJ;lrely g~logic perspective, landslides in a state ofmovement are by definition at or below a factor ofsafety of1.0.This is below the commonty accepted standardofa 15 factor of safety.Construcuonot development within a landslide area has'varying rislsdepending on the area chosen and thelo~topographic conditiOnS. Generally,landslides Ctul have areas that are more coherent with less ft$$l;11'esand cracks and other areas whereoracksand fissures are more abundant.These more cohetentaJieas have less risk associated with them than the more broken up areas.In addition,areas ofJ,andslidesthathave more local topo.phioreliefare also generally at higher risk.Generally the entire:~ofthe PoltUguese Bend landslid~has a muehhigher risk:associated with it than does the <J,evelQpOO areas of the Abalone Coveortoondike Canyon landslide areas.This does not i.rn,plYthat there is no risk associated with living on or developing within the Abalone Cove or Klondike Canyon landslides. Both havesn,<)"wn movement and therefore,would be considered below the minimum standard of praetice or code req'tlirelllents fot development. Based on our review of prlorstudies.and displacement data over time,a case may be.made to propose a direct relationship between movement of the Portuguese Bend 'Landslide and Klondike Canyon Landslide area.It is our professional opinion that if the PottugueseBend Landslide experiences a significant level ofmovement.either over time or in a catasttophicepisode,support for the western flank ofthe Klondike Canyon landslide could be lost and the Klondike Canyon landslide could be subject to potentially catastrophic movement. For the above reasons,it is our professional opinion that both the "red"and "blue"areas should be treated the same from a code standpoint. E:\projects\1997\97()82·1364 positioll paper llIoratorium area S·07.doc - 4-26 CITY OF RANCHO PALOS VERDES May 15,2007 PN 97082-1364 We appreciate this opportunity to be ofcontinued service to the City ofRancho Palos Verdes.Please call if you have any questions regarding the content ofthis letter. Sincerely, ZEISER KLING CONSULTANTS,INC. JML:MGR:dg E:\projects\1997\97082-1364 position paper moratorium area 5-07.doc 4-27