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CC SR 20250805 03 - GHAD CITY COUNCIL MEETING DATE: 08/05/2025 AGENDA REPORT AGENDA HEADING: Regular Business AGENDA TITLE: Consideration to initiate the process to establish a new third Geologic Hazard Abatement District. RECOMMENDED COUNCIL ACTION: (1) Review the advantages and procedures to forming a new third Geologic Hazard Abatement District (GHAD) not currently part of an existing GHAD; and, (2) If deemed acceptable, direct staff to initiate the formal process to form a third GHAD to be called the “Portuguese Bend Landslide Abatement District” (the “PBLAD”). FISCAL IMPACT: Determining whether to form a new third GHAD will not have an initial fiscal impact on the City. However, if the City Council decides to initiate the process, there will be costs to be considered by the City Council at the time a professional services agreement is presented for a consultant to prepare a required engineer’s report and plan of control. Amount Budgeted: N/A Additional Appropriation: N/A Account Number(s): N/A ORIGINATED BY: William Wynder, City Attorney WW REVIEWED BY: Catherine Jun, Deputy City Manager CJ APPROVED BY: Ara Mihranian, AICP, City Manage ATTACHED SUPPORTING DOCUMENTS: A. Senate Bill No. 1195, California State Statute, Public Resources Code, Sections 26500-26654 (Linked) B. Proposition 218 Notice and Protest Procedures (Linked) C. Resolution No. 81-4 (Page C-1) D. Resolution No. 82-17 (Page D-1) E. Proposed Map of the Portuguese Bend Landslide Abatement District (Page E-1) 1 BACKGROUND: General Information GHADs are governmental districts formed for the prevention, mitigation, abatement or control of a “geologic hazard,” which is defined as an actual or threatened landslide, land subsidence, soil erosion, earthquake, fault movement or any other natural or unn atural movement of land or earth. (Public Resources Code §§ 26525, 26507.) The GHAD Law (Sections 26500 et seq.), authored by the City’s then-State Senator, Robert Beverly (and assisted by former Councilmember Ken Dyda) was enacted by the State Legislature in 1979 in response to the Portuguese Bend landslides and gives local agencies the authority to form GHADs (Attachment A). A GHAD is a political subdivision of the State. It is not an agency or instrumentality of a local agency. A GHAD is governed either by a board consisting of five property owners within the district or the legislative body forming the district. GHADs are authorized to acquire, construct, operate, manage and maintain improvements on public or private lands and accept such improvements undertaken by anyone. “Improvement” means any activity that is necessary or incidental to the prevention, mitigation, abatement, or control of a geologic hazard, including, without limitation, construction, maintenance, repair or operation of any improvement. GHADs are authorized to levy and collect property owner assessments to pay for the costs and expenses of the maintenance and operation of any improvements acquired or constructed pursuant to the GHAD Law. These assessments attach as liens on property located within the GHAD and may be collected at the same time and in the same manner as general taxes on real property. All assessment proceedings must comply with Proposition 218’s notice and protest procedures for new or increased property related fees (Attachment B). The first two GHADs formed in California were the Abalone Cove Landslide Abatement District (“ACLAD”) and Klondike Canyon Landslide Abatement District (“KCLAD”). There are now some 55 GHADs organized and functioning in California. Formation of ACLAD and KCLAD In September 1978, the City Council was presented with information regarding cracks and movement along Palos Verdes Drive South and Narcissa Drive that indicated a landslide was in progress. This landslide was the Abalone Cove Landslide, a sub-slide that is separate from the Portuguese Bend Landslide sub-slide that activated in 1956. The Council immediately established a building moratorium in the area and authorized the first in a series of geological investigations to define the problem and identify potential solutions. During March 1979, the Council hired Robert Stone and Associates to perform a comprehensive hydrogeologic investigation to determine the feasibility of dewatering the 2 landslide to slow it down. Later that year, the preliminary borehole tests favored installing a series of dewatering wells. The Public Resources Code allows two different types of governing bodies for a GHAD. A city council must either (a) appoint five owners of real property within the district to the initial board of directors or (b) appoint itself to act as the board of directors. In the case of a board of directors composed of property owners, after the appointment of the initial directors, the board must be composed of five directors elected from within the GHAD, each of whom serves a term of four years. The City Council formed ACLAD in 1981 pursuant to Resolution No. 81-4, and KCLAD was formed in 1982 pursuant to Resolution No. 82-17 (Attachments C and D). At the July 1, 2025 meeting, Councilmember Perestam requested, and the Council concurred, that staff bring forward a future report for the City Council’s consideration to form a third GHAD encompassing the properties, including possible private and public property, that are not part of an existing GHAD within the Greater Portuguese Bend Landslide Complex (Landslide Complex). Tonight, the City Council is being asked to review the procedures to form this third GHAD, and if deemed acceptable, direct staff and the City Attorney’s Office to initiate the process. DISCUSSION: Advantages of Forming a GHAD Through a Plan of Control prepared as part of a required engineer’s report, a GHAD can act to prevent damage resulting from landslide hazards by monitoring the earth movement and undertaking improvements for the prevention, mitigation, abatement, or control thereof. Moreover, there are certain advantages to forming a GHAD, as summarized below. GHADs Have Borrowing Authority A GHAD is authorized to levy and collect assessments on each property within its district to pay for the cost of maintenance and operation of any improvements. A GHAD is also authorized to use the Improvement Act of 1911, Municipal Improvement Act of 1913, or the Improvement Bond Act of 1915 to pay for the costs of improvements made pursuant to the GHAD Law. Neither ACLAD nor KCLAD have opted to utilize this financing mechanism which, if utilized, could require substantial annual debt service. Immunity from Liability for Damages A GHAD is provided a degree of immunity from liability for damages caused by injury to persons or property as a result of gradual earth movement or actions taken to abate such hazard provided that the board has (1) found the existence of such hazard on the basis of adequate evidence; (2) determined appropriate remedial action to abate such hazard; and (3) undertaken to implement such remedial action. This degree of limited liability 3 encourages the formation of GHADs and undertaking of remedial action to abate the hazard. GHADs Are Exempt from the California Environmental Quality Act (“CEQA”) Improvements or other remediation efforts caused to be undertaken under the GHAD Law and all activities in connection therewith are exempt from CEQA. This statutory exemption is broad as these improvements and activities are deemed to be specific action s necessary to prevent or mitigate an emergency as defined by Section 21080(b), a section of CEQA that expressly exempts certain activities from CEQA. GHADs Are Exempt from the Requirements of the Public Contract Code Public Resources Code § 26600 provides that “the board of directors may negotiate improvement contracts or may award such contracts by competitive bidding pursuant to procedures adopted by the board of directors.” Part 3 of Division 2 of the Public Contract Code establishes competitive bidding requirements for local agencies but does not include requirements for GHADs. California Courts have recognized that “absent a statutory directive, a public entity is not bound to engage in competitive bidding.” (Construction Industry Force Account Council, Inc. v. Ross Valley Sanitary District, 244 Ca.App.4th 1303, 1316 (Cal. App. 1st Dist. 2016); Construction Industry Force Account Council v. Amador Water Agency , 71 Cal.App.4th 810, 815 (Cal. App. 1st Dist.. 1999) (recognizing that the Legislature has taken “an ad hoc approach” in establishing contracting requirements for local agencies); Associated Builders and Contractors v. Contra Costa Water District, 37 Cal.App.4th 466 (Cal. App. 1st Dist. 1995) (finding that appellants had cited no section of the Public Contract Code requiring a county water district to comply with open bidding and award a contract to the lowest bidder). The general provisions of the Public Contract Code would most likely not apply to GHADs because the law dealing with GHADs contains more specific contracting procedures in Section 26600. (Las Tunas Beach GHAD v. City of Malibu, 38 Cal. App 4th 1002, 1010 (1995) [determining that more specific provisions of the GHAD Law control over more general provisions in other statutory schemes].) Even if the Public Contract Code provisions were to apply, much of the work to be performed under contract for a GHAD could be excluded from the public bidding requirements due to the emergency nature of GHAD functions. GHADs are Likely Subject to the State’s Prevailing Wage Laws A GHAD is not explicitly exempted from the State's prevailing wage requirements under the Labor Code. Whether GHADs must comply with prevailing wage laws depends on the nature of the work performed and whether it qualifies as "public works" under California Labor Code §§ 1720 et seq. The California Supreme Court's decision in Kaanaana v. Barrett Business Services, Inc., 11 Cal.5th 158 (2021) has significant implications for GHADs regarding prevailing wage 4 requirements under Labor Code 1720. Previously, the prevailing wage law was generally understood to apply primarily to construction-related work for public agencies. However, the Kaanaana decision broadened the definition of "public work" under Labor Code 1720(a)(2) to include any work done for special districts, such as sanitation districts, irrigation districts, or improvement districts. Two unresolved questions were left by the Kaanaana decision. First, while it is the court that greatly expanded the scope of work that can be covered by the Prevailing Wage Law, it neglected to define precisely which “special districts” are affected by its ruling. The section of the statute being interpreted by the court, Labor Code §1720(a)(2), states that “public works means” “[w]ork done for irrigation, utility, reclamation, and improvement districts, and other districts of this type.” (Emphasis added.) Which are “districts of this type” for purposes of the statute and the court’s interpretation? Nowhere in its decision does the court directly address this question, or suggest where, if anywhere, the line can be drawn between “other districts of this type” and districts outside the reach of Labor Code § 1720(a)(2). The second major practical question left unanswered is precisely what “work” performed for special districts by their contractors will henceforth be deemed “covered” by the state Prevailing Wage Law. Given these uncertainties, the Kaanaana ruling likely means that if a GHAD contracts for any work costing over $1,000, not just construction -related work, the contractors and subcontractors performing that work must pay their employees the prevailing wage as determined by the California Department of Industrial Relations (DIR). This includes tasks such as maintenance, inspections, and monitoring related to geologic hazards that may not have previously been considered traditional "public works". Broadly speaking, prevailing wage requirements can increase overall project costs by approximately 25% or more. In addition, the administrative and compliance obligations associated with prevailing wage may limit participation from some contractors or firms. Disadvantages of Forming a GHAD Though a GHAD is a subdivision of the state and technically would not be part of the City, if the City Council serves as the board of directors of a GHAD and the potential for this GHAD to enter into agreements with the City to utilize certain personnel and equipment, there is the risk of blurring the boundaries of actions taken by the GHAD and actions taken by an agent or representative of the City that could potentially expose City assets to liability claims. As such, it is imperative that strict lines o f separation be maintained between the City and the GHAD. GHAD Formation Procedure The proceedings for the formation of a GHAD are set forth in the GHAD Law and are exclusive, notwithstanding any other provision of law. Under State law, GHAD formation is exempt from the Local Agency Formation Commission (“LAFCO”) review process and from review under CEQA, as previously noted. It is important to reiterate that 5 improvements or other remediation efforts caused to be undertaken under the GHAD Law and all activities in connection therewith are also exempt from state contracting law requirement, thereby streamlining the remediation and response process to land movement. The following are the recommended procedural steps: 1. Direct staff to prepare and issue a Request for Proposal (RFP) to retain a certified engineering geologist to prepare an engineer’s report which would lead to the development of a “Plan of Control” describing the landslide hazards and a plan for the abatement or mitigation thereof. The City Council will be requested to consider approving the Professional Services Agreement (if the cost exceeds the City Manager’s signing authority of $25,000), in order to commence the preparation of the engineer’s report. 2. Conduct a town hall to receive community input on forming a new third GHAD and to present the draft engineer’s report including the draft plan of control. 3. Conduct a public meeting for the City Council to receive information on the plan of control and to determine that public health, safety, and welfare require formation of a district. After receiving the report, the Council would be asked to first adopt a resolution declaring that it is subject to the GHAD Law and forward a copy of this resolution to the State Controller. The City Council may then adopt a resolution to initiate proceedings for the formation of a district. The resolution must c ontain the following: a) A statement that the resolution is made pursuant to the GHAD Law. b) A statement that the City Council has been presented with and has reviewed a plan of control and has determined that the health, safety, and welfare require formation of a district. c) The setting of a public hearing on such determination and directing that notice be mailed to all owners of real property included within the proposed district. 4. Notice & Public Hearing The City Council would then be asked to conduct a public hearing. Notice of the public hearing must be mailed at least 20 days before the date of the public hearing to each property owner within the proposed district. A copy of the resolution initiating formation proceedings must be attached to the notice. The notice sha ll set forth the time, date, and place of the hearing, briefly describe the purpose of the hearing, and indicate where the plan of control may be reviewed or duplicated. The notice shall also set forth the address where objections to the proposed formation may be delivered up to and including the time of the hearing. Property owners may make a written objection to the formation in accordance with Proposition 218. The City Council will be presented with all objections at the public 6 hearing. The City Council may adjourn such hearing from time to time, but not to exceed 60 days from the date specified in the original notice. At the close of the hearing or within 60 days thereafter, the City Council may proceed by resolution to order the formation of the proposed district and appoint five (5) property owners within the district to the initial board of directors for terms not to exceed four (4) years. Alternatively, the City Council may appoint itself to act as the board of directors. If property owners are appointed to the initial board of directors, then following the initial term, the board of directors shall consist of five (5) elected directors as provided by Section 26583. However, if it appears at the hearing that property owners of more than 50% of the assessed valuation of the proposed district object to the formation, the City Council must close the hearing and direct that formation proceedings be abandoned. Proposed Lands Included in a New Third GHAD A GHAD may include lands in more than one local agency, and the lands may be publicly or privately owned. The lands included within a district may be noncontiguous provided that all lands are specially benefitted by the construction proposed to be undertaken by the district in a plan of control approved by the legislative body. However, no parcel of real property shall be divided by the boundaries of the proposed district. The lands to be included in the newly formed GHAD, which is proposed to be called the Portuguese Bend Landslide Abatement District (“PBLAD”) would be limited to lands outside of any remaining GHAD’s jurisdiction. This would leave ACLAD and/or KCLAD intact. These lands consist primarily of the Portuguese Landslide in the middle of the Abalone Cove and Klondike landslides (Attachment E). Out of the 113 properties within the proposed GHAD, 90 are privately owned. Furthermore, 23 properties are owned by the City and exceeds 50% of the assessed valuation of land within the proposed GHAD. These properties currently do not engage in any landslide abatement efforts, and forming a new GHAD would contribute towards the overall efforts in the Landslide Complex to prevent damage, mitigate, abate, and control the landslide. Considering properties outside the City’s jurisdictional boundaries may cause delays in the process and at this time is not recommended. Levy & Collection of Assessments In order to levy and collect assessments to pay for costs and expenses of maintenance and operation of any improvements, an officer of the GHAD must first prepare a report that sets forth the yearly estimated budget, the proposed estimated assessments to b e levied each year against each parcel of property, and a description of the method used in formulating the estimated assessments. Next, the GHAD board shall adopt a resolution declaring its intention to order that the costs and expenses of maintaining and operating improvements be assessed against property within the district and consider all protests at a duly noticed public hearing . At 7 the conclusion of the hearing, the board may adopt, reduce, or modify any assessment and shall make its determination upon each assessment described in the report. Thereafter, the board may confirm the assessments and order the levy and collection thereof by resolution. If assessments are proposed to increase from the maximum amount levied in any previous year, the board is required to comply with Proposition 218 notice, protest, and hearing procedures with respect to that increase (Attachment B). It would require a 50% protest vote to block such proposed increase. ADDITIONAL INFORMATION Dissolving a GHAD At the July 1 City Council meeting under Public Comments on Non-Agenda Items, Sha Tahmasebi, a resident of Seaview, requested the City Council consider, among other things, dissolving KCLAD. The City Council can dissolve a GHAD pursuant to the Public Resources Code if it obtains the unanimous consent of the board, or by a vote of the owners of more than 50% of the assessed valuation of the real property in the GHAD, but the Council would then be responsible for the GHAD’s liabilities; the Council could then reform the GHAD with the Council as the board of directors, but if more than 50% of the assessed valuation of the real property in the proposed GHAD object, the formation must be abandoned. The City Council may, by resolution, order the dissolution of GHAD. The resolution is only valid if the City Council, based on substantial evidence, makes one or more of the following findings: (a) The corporate powers have not been used, there is a reasonable probability that those powers will not be used in the future, and the district holds no significant liquid assets. (b) The board of directors, by resolution passed by unanimous vote of the directors, or by a vote of the owners of more than 50% of the assessed valuation of the real property in the district, approved the dissolution of the district. (c) The district has not levied or collected any assessments and holds no significant liquid assets. (d) The district has not substantially complied with a material condition of the resolution of formation adopted by the legislative body. If the City obtained a dissolution, then the City Council or GHAD’s board would need to adopt a resolution setting a noticed public hearing on the proposed dissolution. Note however, that if the GHAD were dissolved, the City Council would be required to assume all remaining responsibilities and obligations of the District, and to fulfill certain 8 statutory requirements regarding the GHAD’s assets. Since the City is a property owner, the City can offer an alternative plan than what is provided for in the statutes for the distribution of ownership of a GHAD’s assets. The City could propose to transfer the assets to the re-formed GHAD. Initiate Re-formation of a GHAD The re-formation of a GHAD may be initiated by resolution of the City Council. Note that if it appears at the public hearing that owners of more than 50% of the assessed valuation of the proposed GHAD object to the formation, the City Council must close the hearing and direct that proceedings for the formation of a district be abandoned. If not more than 50% of the property owners object to the formation of the GHAD, at the close of the hearing or within 60 days thereafter, the Council may proceed by resolution to order the formation of the proposed GHAD with the Council as the board of directors. (Pub. Res. Code § 26567) A potential drawback to this approach is that ACLAD could successfully be dissolved, but the City might not be able to successfully re-form the District. This would leave the City with all of the liabilities and obligations of a GHAD. Apply to LAFCO for a Reorganization of a GHAD. Alternatively, the Council could apply for a reorganization by Los Angeles County Local Agency Formation Commission (“LAFCO”). LAFCO has the power to review and approve with or without amendment, wholly, partially, or conditionally, or disapprove proposals for changes of organization or reorganization, consistent with LAFCO’s written policies, procedures, and guidelines. LAFCO may initiate proposal by resolution of application for the dissolution of a district, a merger, the establishment of a subsidiary district, or the formation of a new district. However, LAFCO may only initiate a proposal if the change in organization or reorganization is consistent with a recommendation or conclusion of a study prepared under LAFCO’s authority. Applications for a reorganization or dissolution done under LAFCO can be found on their website: http://www.lalafco.org/. If the City attempts to change the organization of the Board through LAFCO, then the special reorganization filing fee is $10,000. If the GHAD decides to dissolve through LAFCO instead of reorganizing, then a district dissolution is $5,000 dollars. The City can initiate proceedings as a landowner or affected agency. This approach is more costly than dissolving under the Public Resources code and requires studies supporting the City’s proposal. Additionally, a dissolution under LAFCO runs the same risk of transferring all the liabilities and obligations to the City if a new GHAD is not formed. However, instead of applying for a dissolution, the City can apply for a reorganization under LAFCO which is not accompanied by that risk. Another benefit of reorganization under LAFCO is the City would not have to ensure all the liabilities and obligations were successfully transferred to the new GHAD since the district would not be dissolved. LAFCO does not always accept the proposal exactly as submitted and may choose to make alterations, but LAFCO cannot continue a project without the applicant 9 so if the City does not like the direction LAFCO’s proposal is headed, they can withdraw the application. CONCLUSION: The City Council is being asked to consider whether to proceed with the formation of a new third GHAD to be called the Portuguese Bend Landslide Abatement District (“PBLAD”). If desired, direct staff to initiate the formation proceedings. As part of that process, the City Council will consider retaining a certified engineering geologist to prepare an engineer’s report and plan of control to inform the City Council on the formation of the lands to be included therein and costs for remediation measures. ALTERNATIVES: In addition to Staff’s Recommendations, the following alternative actions are available for the City Council’s consideration: 1. Direct staff to return with a report on dissolving ACLAD and/or KCLAD and initiate the proceedings to form a successor GHAD that encompasses the entire Landslide Complex. 2. Direct Staff to form a third GHAD but only include either public and/or private property. 3. Direct Staff not to proceed with forming a new third GHAD. 4. Take other action as deemed appropriate. 10 RESOLUTION NO. 81-4 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF RANCHO PALOS VERDES ORDERING THE FORMATION OF THE ABALONE COVE LANDSLIDE ABATEMENT DISTRICT The City Council of the City of Rancho Palos Verdes hereby resolves as follows: Section 1: The City Council of the City of Rancho Palos Verdes passed Resolution No. 80-76 on December 2, 1980, initiating proceedings for the forma- tion of a landslide abatement district. Said resolution established January 6, III1981 as the date for a public hearing on formation of the landslide abatement district. The City Council finds and determines that notice of said hearing was properly sent out to all property owners in compliance with Section 26561, et seq. , of the Public Resources Code. Section 2: The City Council of the City of Rancho Palos Verdes held a public hearing on the formation of the landslide abatement district on January 6, 1981 and received objections to the proposed formation from all owners of real property within the proposed district wishing to make objections. After reviewing all said objections the City Council hereby finds and determines that objections were re- ceived from owners of less than 50% of the assessed valuation of property within the proposed district. Since such objections were received from owners of less than 50% of the assessed valuation, the City Council may proceed with the formation of a landslide abatement district. Section 3: The City Council hereby orders the formation of the Abalone Cove landslide abatement district pursuant with boundaries as shown on Exhibit "A" attached hereto, to the provisions of Division 17 of the Public Resources Code of the State of California. Section 4: The following five owners of real property within the. proposed district are hereby named to the initial Board of Directors of the Abalone Cove landslide abatement district for the terms indicated: 1. James Stewart 2 years 2. John Tretheway 2 years 3. Harriet Medve 4 years 4. Ken Dyda 4 years 5. Seymour Warner 4 years After the initial term, each term will be for a four (4) year period. PASSED, APPROVED AND ADOPTED this 6th day of January, 1981. c.- c=lzf3srutitaiL)t.d MAYOR aRlk__ ___ III ATTEST: DONALD F. GULUZZY, CITY CLERK & EX OFFICIO CLERK OF THE COUNCIL dIL IF.; . . 7" L. . 1:' . 0( / TY CL I HEREBY CERTIFY that the foregoing is a true and correct copy of Resolution No. 81-4 approved and adopted by the City Council of the City of Rancho Palos Verdes at a meeting thereof held on the 6th day of January, 1981. All,t• / Ty C' RK C-1 cligitillikWa 4 Eir.e.-...V.: N4,,A,.. 4-' s--"`" r—,"7""\-. 4.. 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I.Si t9Q1 C-2 D-1 D-2 Sa n t aCr u z O cea n Te rr ace Dr Sa il V i e w A ve C o u n t r y Mea do w Rd P a c i f i caDr A n a c a p a S a n ta Cruz Sa nt a Cruz Misty A cres R d Sa n t a R os a Cres t Rd Cre st R d Arrowroot L n P a c k e t R d Sea Cov e D r B a r k e nt in e Rd C l i p p e r R d Palos VerdesDr S Barkentine Canyon Preserve S e a C o v e D r C r e n s h a w Bl v d Pa rk P l B u r m a Rd S a n Cl e men t e Dr Sa nt a Ca t al in a Dr Va n d e r l ip Dr C r e s t R d Del Cerro Park Na rci s sa D r Narcis s a D r N arcissa D r C i n n a m o n L n Swe e t b a y Rd Gi n g e r Roo t Ln F igt reeRd Van d e r l i p D r P epp ertr e e Dr N arcissa D r P e p p e r t r e e DrP al o s V e r d e s DrS Abalone Cove Shoreline Park California Coastal National Monument Burma R d B urma R dBu r m a Rd A m b e r S k y D r O c e a naire D r Covevi e w D r B ug gy W hip Dr Crest R d W Burma Rd B u r m aRd T a n g e ri n e R d L i m e t r e e L n Portuguese Bend Nature Preserve A d m i r a b l e D r S e a w a l l R d Bur ma R d P a l o s V e r d e s D r S Abalone Cove Shoreline Archery Range Por tu gu ese Bend R d Geo r g e f f R d Q u a i l R i d g e R d N Po s s u m Ri d ge Rd Crest R d W C r e s t R d E Po r t ugu e s e B end R d Run n i ng B r a nd R d P a c ks a d d l e Rd W P int o R d Crest Rd E F o r r e sta l D r E x u l t ant Dr D a u n tl e s s Dr A d mi r a ble Dr S e a R a v e n D r P irate D r Stal w art D r Co n qu e r o r Dr M ain S a i l D r Palos V erdes Dr S Forrestal Nature Preserve Ladera Linda Park and Community Center PalosVerde s D r S Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community, Maxar Legend Abalone Cove Landslide Abatement District Klondike Canyon Landslide Abatement District Privately Owned Parcels Landslide Moratorium Geologic Hazard Abatement District E-1