CC RES 2026-051 RESOLUTION NO. 2026-51
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF RANCHO PALOS VERDES, CALIFORNIA,
APPROVING, WITH CONDITIONS, A COASTAL
PERMIT AND AN ASSOCIATED HABITAT
CONSERVATION PLAN FOR THE LOS ANGELES
COUNTY SANITATION DISTRICT SEWER LINE AND
MANHOLES REPAIR PROJECT ON TRUMP
NATIONAL GOLF CLUB AND CITY-OWNED OCEAN
TRAILS RESERVE PROPERTIES (CASE NO.
PLCP2026-0003)
WHEREAS, on June 1, 1992, the City Council of the City of Rancho Palos Verdes
(the "City") adopted Resolution No. 92-53, certifying Environmental Impact Report (EIR)
No. 36 and adopted Resolution Nos. 92-54, 92-55, 92-56, 92-57, approving Vesting
Tentative Tract Map Nos. 50666 and 50667, Tentative Parcel Map Nos. 20970 and
23004, Conditional Use Permit Nos. 162 and 163, Coastal Development Permit No. 103
(the "CDP"), and Grading Permit No. 1541 for a Residential Planned Development, an
18-hole public golf course, and public open space on an approximately 261.4 acre
property located in the City (the "Property") for what is now known as the Trump National
Golf Club Project (TNGC), owned by VH Property Corp. (the "Developer") and VHPS,
LLC (the "Owner"); and
WHEREAS, the TNGC project includes an 18-hole golf course, clubhouse, driving
range, public open space, habitat conservation areas, and residential lots adjacent to
environmentally sensitive coastal lands containing habitat for protected species, including
the federally threatened coastal California gnatcatcher; and
WHEREAS, the Los Angeles County Sanitation Districts ("LACSD") owns and
operates existing regional sewer infrastructure beneath portions of the TNGC property
and adjacent City-owned Ocean Trails Reserve property pursuant to existing easement
rights and a Sewer Build Over Agreement was entered into with the original developer of
the TNGC Project; and
WHEREAS, in late 2025, LACSD ("Applicant") informed the City that several
segments of the existing sewer line are in a highly deteriorated condition, sewer leaks
and failure are imminent, and that this is a high priority project to prevent sewage failure
resulting in possible bluff failure, contamination, and temporary discontinuation of public
sewer services; and
WHEREAS, in late 2025, LACSD proposed a sewer rehabilitation project
("Project") involving reinforcement and lining of approximately 9,362 linear feet of existing
underground sewer trunk line within the City of Rancho Palos Verdes, rehabilitation of
associated manholes, temporary bypass pumping operations, temporary access roads
and staging areas, and associated construction and restoration activities within the TNGC
property and City-owned Ocean Trails Reserve; and
WHEREAS, the proposed Project includes temporary impacts to environmentally
sensitive habitat areas, including coastal sage scrub habitat occupied by the federally
threatened coastal California gnatcatcher, requiring preparation of a Habitat Conservation
Plan ("HCP") and issuance of a Section 10(a)(1)(B) Incidental Take Permit by the United
States Fish and Wildlife Service ("USFWS"); and
WHEREAS, the proposed HCP establishes habitat avoidance and minimization
measures, habitat restoration and monitoring, and long-term adaptive management
measures intended to reduce and mitigate temporary habitat impacts associated with the
Project; and
WHEREAS, as the proposed HCP will propose activity and provisions for the
management of City-owned parcels, it must be reviewed and approved by the City
Council; and
WHEREAS, the proposed Project is located within the appealable area of the City's
Coastal Zone and partially within the Coastal Setback Zone and therefore requires
approval of a Coastal Permit pursuant to Chapter 17.72 of the Rancho Palos Verdes
Municipal Code ("RPVMC"); and
WHEREAS, pursuant to RPVMC §17.72.080(C), the City Council may consider a
Coastal Permit directly when the purpose of the permit is to maintain access or essential
public services; and
WHEREAS, the Project, along with the ancillary HCP, has been reviewed pursuant
to the California Environmental Quality Act ("CEQA") and has been determined to be
categorically exempt pursuant to CEQA Guidelines Section 15301 (Existing Facilities),
because the Project involves repair and rehabilitation of existing public sewer facilities;
and
WHEREAS, on June 2, 2026, notice of the public hearing was mailed to all property
owners and residents in neighborhoods directly adjacent to the project site (greater than
the 100-foot required radius) and published in the Palos Verdes Peninsula News on June
4, 2026, in accordance with applicable noticing requirements; and
WHEREAS, on June 16, 2026, the City Council conducted a duly noticed public
hearing, at which time all interested persons were given the opportunity to be heard and
present evidence.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF RANCHO PALOS
VERDES DOES HEREBY FIND, DETERMINE, AND RESOLVE AS FOLLOWS:
Section 1: The above recitals are true and correct and are hereby incorporated
into this Resolution as set forth herein.
Resolution No 2026-51
Page 2 of 5
Section 2: The City Council finds that approval of the Coastal Permit with
associated conditions, attached hereto as Exhibit A, is warranted based on the following
findings:
A. The proposed sewer rehabilitation project is consistent with the Rancho Palos
Verdes Coastal Specific Plan because it maintains essential public sewer
infrastructure while minimizing impacts to environmentally sensitive habitat
areas, coastal open space, and scenic coastal resources within Subregions 7
and 8. The project utilizes primarily trenchless rehabilitation methods to reduce
grading and surface disturbance, and the associated' HCP includes biological
monitoring, habitat restoration, compensatory mitigation, and long-term
management measures intended to protect coastal sage scrub habitat and the
federally threatened coastal California gnatcatcher. Additionally, the project
preserves the long-term recreational, scenic, and ecological function of the
Ocean Trails Reserve and surrounding coastal open space areas.
B. The proposed project is consistent with the applicable public access and
recreation policies of the Coastal Act, because it maintains the long-term
usability, safety, and environmental quality of coastal recreational and access
areas while preventing potential sewer failure that could adversely affect
coastal waters, shoreline habitat, and public recreational resources. Although
temporary trail closures and construction-related access restrictions may occur
during construction, the project does not permanently eliminate or privatize
existing public trails, bluff-top viewpoints, shoreline accessways, or recreational
opportunities. The project also includes restoration of temporarily impacted
areas and preserves the long-term public use and enjoyment of the Ocean
Trails Reserve and surrounding coastal open space areas.
Section 3: The City Council hereby approves the HCP, attached hereto as Exhibit
B, associated with the LACSD Project based on the provisions outlined below. It is
important to note that the work associated with the LACDS Sewer Maintenance Project
and associated HCP falls more under the categories of maintenance and restoration
rather than development as defined in RPVMC Section 17.96.560.
A. The proposed HCP is consistent with the Rancho Palos Verdes General Plan.
Specifically, the HCP is consistent with Conservation and Open Space Element
Goal No. 1 and Policy No. 2 (8), which supports protection of environmentally
sensitive habitat areas and requires mitigation for impacts to wildlife habitat.
The proposed HCP includes habitat restoration, biological monitoring, and
compensatory mitigation measures for impacts to coastal sage scrub habitat
and the federally threatened coastal California gnatcatcher.
B. The HCP is also consistent with Circulation Element Goal No. 4 and Policy No.
43, which support maintaining adequate sewer infrastructure systems, because
the project repairs critical regional sewer infrastructure necessary to maintain
Resolution No. 2026-51
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essential public sewer service.
C. The HCP is further consistent with Land Use Element Goal Nos.1 and 10, which
promote protection of the natural environment and preservation of open space
character, because the project minimizes long-term disturbance and restores
temporarily impacted open space and habitat areas.
D. Additionally, the HCP is consistent with Safety Element Goal No. 3 and Policy
No. 13, which support protection of public health and sanitation systems,
because the project reduces the potential for sewer failure, coastal
contamination, and associated public health risks.
E. Finally, the HCP is consistent with Visual Resources Element Goal No. 1, which
seeks preservation of scenic coastal character and public enjoyment of open
space resources, because the project includes restoration measures intended
to preserve the long-term scenic and ecological character of the Ocean Trails
Reserve and surrounding coastal open space areas.
Section 4: Except as expressly modified herein, all conditions of approval
contained in the most recent Conditional Use Permit Revision "LLL" (Resolution No. 2026-
09), as well as all terms, covenants, conditions, obligations, and restrictions contained in
the Amended and Restated Declaration of Restrictions approved by the City Council on
June 2, 2026, and the Amended and Restated Development Agreement, recorded on
November 27, 2018, shall remain unchanged and in full force and effect, except as may
be amended in the future.
Section 5: The Mayor, City Manager, and City Clerk or their designees, are
authorized and directed to take such actions and execute such documents as may be
necessary to implement and affect execution, recordation and enforcement of this
Resolution.
111
Resolution No 2026-51
Page 4 of 5
PASSED, APPROVED, and ADOPTED this 16th day of June 2026.
aul , yor
ATTEST:
CTeresaTaTyrk—
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss
CITY OF RANCHO PALOS VERDES )
I, Teresa Takaoka, City Clerk of the City of Rancho Palos Verdes, hereby certify that the
above Resolution No. 2026-51, was duly and regularly passed and adopted by the said
City Council at a regular meeting thereof held on June 16, 2026.
'e,t, . ... .Pkotri-------_,„
T a Takaoka, City Clerk
111
Resolution No 2026-51
Page 5 of 5
Resolution No. 2026-51
Exhibit A
Page 1 of 5
EXHIBIT ‘A’
CONDITIONS OF APPROVAL FOR
COASTAL PERMIT & HCP
LACSD PROJECT AT TRUMP NATIONAL GOLF CLUB
AND OCEAN TRAILS RESERVE
(PLCP2026-0003)
General Conditions:
1. Prior to the submittal of plans into Building and Safety plan check, the Applicant
and/or property owner shall submit to the City a statement, in writing, that they
have read, understand, and agree to all conditions of approval contained in this
Exhibit “A”. Failure to provide said written statement within ninety (90) days
following the date of this approval shall render this approval null and void.
2. The Applicant shall indemnify, protect, defend, and hold harmless, the City, and/or
any of its officials, officers, employees, agents, departments, agencies, and
instrumentalities thereof, from any and all claims, demands, lawsuits, writs of
mandamus, and other actions and proceedings (whether legal, equitable,
declaratory, administrative or adjudicatory in nature), and alternative dispute
resolutions procedures (including, but not limited to arbitrations, mediations, and
other such procedures) (collectively “Actions”), brought against the City, and/or
any of its officials, officers, employees, agents, departments, agencies, and
instrumentalities thereof, that challenge, attack, or seek to modify, set aside, void,
or annul, the action of, or any permit or ap proval issued by, the City and/or any of
its officials, officers, employees, agents, departments, agencies, and
instrumentalities thereof (including actions approved by the voters of the City), for
or concerning the project.
3. Prior to conducting any work in the public right -of-way, such as for curb cuts,
temporary bypass pumps, trenching for temporary bypass sewer pipes, etc., the
Applicant shall obtain an encroachment permit and a traffic control plan from the
Director of Public Works.
4. Approval of this permit shall not be construed as a waiver of applicable and
appropriate zoning regulations, or any Federal, State, County and/or City laws and
regulations. Unless otherwise expressly specified, all other requirements of the
City of Rancho Palos Verdes Municipal Code (RPVMC) shall apply.
5. Pursuant to RPVMC §17.78.040, the Director of Community Development is
authorized to make minor modifications to the approved plans and any of the
conditions of approval if such modifications will achieve substantially the same
results as would strict compliance with the approved plans and conditions.
Substantial changes to the project shall be considered a revision and require
approval by the final body that approved the original project, which may require
Resolution No. 2026-51
Exhibit A
Page 2 of 5
new and separate environmental review and public notification.
6. The project development on the site shall conform to the specific standards
contained in these conditions of approval or, if not addressed herein, shall conform
to the residential development standards of the RPVMC, including but not limited
to height, setback and lot coverage standards.
7. Failure to comply with and adhere to all of these conditions of approval may be
cause to revoke the approval of the project pursuant to the revocation procedures
contained in RPVMC §17.86.060 or administrative citations as described in
RPVMC Chapter 1.16.
8. If the Applicant has not submitted an application for a building permit for the
approved project or not commenced the approved project as described in RPVMC
§17.86.070 within one year of the final effective date of this Notice of Decision,
approval of the project shall expire and be of no further effect unless, prior to
expiration, a written request for extension is filed with the Community Development
Department and approved by the Director.
9. In the event that any of these conditions conflict with the recommendations and/or
requirements of another permitting agency or City department, the stricter standard
shall apply.
10. Unless otherwise designated in these conditions, all construction shall be
completed in substantial conformance with the plans stamped approved by the
City with the effective date of this approval.
11. This approval is only for the items described within these conditions and identified
on the stamped approved plans and is not an approval of any existing illegal or
legal non-conforming structures on the property, unless the approval of such illegal
or legal non-conforming structure is specifically identified within these conditions
or on the stamped approved plans.
12. The construction site and adjacent public and private properties and streets shall
be kept free of all loose materials resembling trash and debris in excess of that
material used for immediate construction purposes. Such excess material may
include, but not be limited to: the accumulation of debris, garbage, lumber, scrap
metal, concrete asphalt, piles of earth, salvage materials, abandoned or discarded
furniture, appliances or other household fixtures.
13. All construction sites shall be maintained in a secure, safe, neat and orderly
manner, to the satisfaction of the City’s Building Official. All construction waste and
debris resulting from a construction, alteration or repair project shall be removed
on a weekly basis by the contractor or property owner. Existing or temporary
portable bathrooms shall be provided during construction. Portable bathrooms
Resolution No. 2026-51
Exhibit A
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shall be placed in a location that will minimize disturbance to the surrounding
property owners, to the satisfaction of the City’s Building Official.
14. Construction projects that are accessible from a street right-of-way or an abutting
property and which remain in operation or expect to remain in operation for over
30 calendar days shall provide temporary construction fencing, as defined in
RPVMC §17.56.050(C). Unless required to protect against a safety hazard,
temporary construction fencing shall not be erected sooner than 15 days prior to
commencement of construction.
15. Permitted hours and days for construction activity are 7:00 AM to 6:00 PM, Monday
through Friday, 9:00 AM to 5:00 PM on Saturday, with no construction activity
permitted on Sundays or on the legal holidays specified in RPVMC §17.96.920.
During demolition, construction and/or grading operations, trucks shall not park,
queue and/or idle at the project site or in the adjoining street rights -of-way before
7:00 AM Monday through Friday and before 9:00 AM on Saturday, in accordance
with the permitted hours of construction stated in this condition. When feasible to
do so, the construction contractor shall provide staging areas on -site to minimize
off-site transportation of heavy construction equipment. These areas shall be
located to maximize the distance between staging activities and neighboring
properties, subject to approval by the Building Official.
16. A Special Construction Permit shall be applied for and obtained at least 72 hours
before any work is proposed to occur outside of the permitted construction hours
detailed in Condition No. 15 above.
17. For all grading, landscaping and construction activities, the Applicant shall employ
effective dust control techniques, either through screening and/or watering.
18. PRIOR TO STARTING CONSTRUCTION OF ANY TEMPORARY ROAD AND
STAGING AREA GRADING, the Applicant shall obtain approval from the City
Geologist and the project shall comply with all required conditions imposed by the
City Geologist.
19. PRIOR TO STARTING CONSTRUCTION, the Applicant shall obtain grading
permits from the Building & Safety Division, which shall include erosion control
measures and best management practices.
20. PRIOR TO ISSUANCE OF ANY GRADING AND/OR BUILDING PERMIT,
whichever occurs first, an earth hauling permit shall be approved by the Public
Works Department.
PROJECT SPECIFIC CONDITIONS:
21. This approval shall allow the following improvements to the project site:
Resolution No. 2026-51
Exhibit A
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• Reinforcing approximately 9,362 linear feet (11,334 linear feet total including the
portion of the Project within the City of Los Angeles) of existing major underground
sewer trunk line by injecting a coating to line existing infrastructure to strengthen
and rehabilitate it.
• Rehabilitating 13 manholes (25 total including the portion of the Project within the
City of Los Angeles).
• Clearing, grubbing, and/or grading temporary access roads and establishing
staging areas.
• Installing a temporary flow bypass placed on Palos Verdes Drive South along the
entire length of the golf course, along La Rotonda Drive, as well as within City-
owned parcels including Lot D to the west of the driving range at TNGC and on
Shoreline Park, during the project duration to redirect sewage flow approximately
between July 2026 and March 2027.
• Installing bypass equipment including pumps.
• Impacting 0.8 acres of native habitat (coastal sage scrub)
• Ongoing monitoring and maintenance of LACSD sewer infrastructure
• Grading approximately 2,000 yd3 of temporary imported material (dirt, sand,
gravel, etc.) to create access roads and staging areas that will be exported at the
completion of the Project.
22. All conditions of approval contained in the most recent Conditional Use Permit
Revision “LLL” (Resolution No. 2026-09), as well as all terms, covenants,
conditions, obligations, and restrictions contained in the Amended and Restated
Declaration of Restrictions approved by the City Council on June 2, 2026, and the
Amended and Restated Development Agreement, recorded on November 27,
2018, shall remain unchanged and in full force and effect, except as may be
amended in the future.
23. The Applicant and/or their contractor(s) shall provide written notice to City Staff AT
LEAST ONE WEEK prior to the required full and/or partial closure of any public
trails and/or public open space. Notice shall include the following information:
a. Trail name;
b. Anticipated closure date;
c. Estimated length of closure.
24. The project shall comply with all requirements included in the attached “Habitat
Conservation Plan for the Los Angeles County Sanitation Districts Joint Outfall J
Unit 1E Trunk Sewer Rehabilitation Project” document provided to the Applicant
and the City by the U.S. Fish & Wildlife Service.
25. Construction activities associated with the project shall occur outside the coastal
California gnatcatcher nesting season to avoid impacts/disturbance to the best
Resolution No. 2026-51
Exhibit A
Page 5 of 5
extent possible and in compliance with USFWS HCP.
26. Pre- and post-construction biological surveys shall be completed in compliance
with the HCP to identify any sensitive nesting species as well as map vegetation,
if not already available. Surveys should be used to inform a restoration plan and
include mitigation measures if any sensitive species are identified.
27. A restoration plan shall be prepared based on recommendations from USFWS,
and approved by the City of Rancho Palos Verdes City Manager, including, but not
limited to, adherence to an updated Habitat Conservation Plan to mitigate habitat
impacts, and ensure selected restoration area(s) have not already been selected
for prior restoration/conservation and would not be in a location proposed for
realigned trails.
28. PRIOR TO STARTING CONSTRUCTION, the Applicant shall initiate tribal
consultation with Gabrieleño (Tongva)-affiliated tribes identified on the NAHC list
and incorporate any recommendations into the project provided from tribal
representatives through consultation.
29. Grading should be minimized to the maximum extent feasible. Any temporary fill
required for temporary road construction should consider sediment suitability with
the adjacent habitat. Crushing rather than removal of vegetation should be utilized
when feasible, if avoidance is not possible.
30. In addition to complying with the revegetation requirements of the HCP, the
vegetation in Lot D will need to be replanted within three months of completion of
the work adjacent to Lot D. Any irrigation will need to comply with the originally -
approved irrigation plans, and the Water Control Plan for Tract 50666.
31. PRIOR TO STARTING CONSTRUCTION, the Applicant shall comply with any
required NPDES requirements.
32. PRIOR TO STARTING CONSTRUCTION, the Applicant shall obtain authorization
from the State Coastal Conservancy for work within their conservation easements,
which cover the Ocean Trails Reserve, which includes the area formerly referred
to as Shoreline Park.
33. PRIOR TO CONDUCTING ANY HABITAT RESTORATION WORK on City-
owned property or within the Palos Verdes Nature Preserve, the City Manager or
his designee shall review and approve the Habitat Conservation Plan for the Los
Angeles County District Sewer Line and Manholes Repair project.
Habitat Conservation Plan
for the
Los Angeles County Sanitation Districts
Joint Outfall J Unit 1E Trunk Sewer Rehabilitation Project
(Administered by LACSD’s Sanitation District No. 2)
Prepared for:
U.S. Fish and Wildlife Service
Carlsbad Field Office
2177 Salk Ave, Suite 250
Carlsbad, CA 92008-7385
Resolution No. 2026-51
Exhibit B
Page 1 of 30
Exhibit B
Table of Contents
Executive Summary ...................................................................................................................... 3
Section 1. Introduction and Background ....................................................................................... 4
1.1 Overview and Background ............................................................................................ 4
1.2 Permit Holder and Permit Duration ............................................................................... 4
1.3 Permit Boundary / Covered Lands ................................................................................ 4
1.4 Species to be Covered by Permit .................................................................................. 4
1.5 Regulatory Requirements .............................................................................................. 5
Section 2. Project Description ....................................................................................................... 6
Section 3. Biological Resources ................................................................................................... 7
3.1 Environmental Setting ......................................................................................................... 7
3.2 Coastal California Gnatcatcher (Polioptila californica californica) ....................................... 7
Section 4. Potential Biological Impacts / Take Assessment .......................................................... 8
4.1 Project Impacts and Anticipated Take ................................................................................. 8
Impacts Resulting from Construction .................................... Error! Bookmark not defined.
Impacts Resulting from Maintenance Activities ..................................................................... 9
4.2 Effects on Critical Habitat .................................................................................................. 10
Section 5. Measures to Minimize and Mitigate for Impacts ......................................................... 11
5.1 Biological Goal and Objective ........................................................................................... 11
5.3 Avoidance, Minimization, and Mitigation Measures .......................................................... 11
5.3.1 Measures to Avoid and Minimize Impacts .................................................................. 11
5.3.3 Measures to Mitigate Unavoidable Impacts ............................................................... 11
5.4 Monitoring and Success Criteria ....................................................................................... 12
5.5 Reporting .......................................................................................................................... 12
Section 6. Plan Implementation .................................................................................................. 13
6.1 Changed Circumstances ................................................................................................... 13
6.1.2 Summary of Circumstances ....................................................................................... 13
6.1.3 Newly Listed Species ................................................................................................. 13
6.2 Unforeseen Circumstances ............................................................................................... 14
6.3 Amendments ..................................................................................................................... 14
6.3.1 Minor Amendments .................................................................................................... 14
6.3.2 Major Amendments .................................................................................................... 14
6.4 Suspension / Revocation .................................................................................................. 15
6.5 Permit Renewal ................................................................................................................. 15
Resolution No. 2026-51
Exhibit B
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6.6 Other Measures as Required by the Director .................................................................... 15
Section 7. Funding ...................................................................................................................... 16
7.1 Cost of HCP Implementation ............................................................................................. 16
7.2 Funding Source ................................................................................................................. 16
Section 8. Alternatives ................................................................................................................ 17
8.1 Summary ........................................................................................................................... 17
8.2 No Action Alternative ......................................................................................................... 17
Section 9. Literature Cited .......................................................................................................... 18
Figures ........................................................................................................................................ 19
Figures
Figure 1. Project Overview .......................................................................................................... 20
Figure 2. Anticipated impacts at MHs J 0217- 0220. .................................................................. 21
Figure 3. Anticipated impacts at MH J 0222. .............................................................................. 22
Figure 4. Anticipated impacts at MH J 0234. .............................................................................. 23
Figure 5. Anticipated Impacts at MH J 0235. .............................................................................. 24
Figure 6. Anticipated impacts at MH J 0481. .............................................................................. 25
Figure 7. Gnatcatcher territories within the western portion of the Trump National Preserve. .... 26
Figure 8. Gnatcatcher territories within the eastern portion of the Trump National Preserve and
Shoreline Park ............................................................................................................................ 28
Resolution No. 2026-51
Exhibit B
Page 3 of 30
Executive Summary
The Los Angeles County Sanitation Districts (LACSD) is proposing the Joint Outfall J Unit 1E
Trunk Sewer Rehabilitation project (Project) that will reinforce approximately 11,334 feet of
existing underground sewer line within the City of Rancho Palos Verdes and the community of
San Pedro in the City of Los Angeles. It will also rehabilitate up to 25 manholes with a protective
coating system and abandon 2 manholes in place. Workers will access existing underground
pipelines from manholes, and impacts will occur from heavy equipment access to manholes and
staging areas. For the purposes of this plan, references to “the Project” will encompass
approximately 9,362 feet of existing underground sewer line within the City of Rancho Palos
Verdes that are within or near habitat associated with the Ocean Trails Habitat Conservation
Plan. Approximately 0.80 acre of impacts to occupied habitat for the federally threatened coastal
California gnatcatcher (Polioptila californica californica) are anticipated within the Trump
National Preserve areas established as mitigation in association with the Ocean Trails Habitat
Conservation Plan that was permitted by the U.S. Fish and Wildlife Service (Service) in 1996.
Impacts to coastal sage scrub habitat occupied by the coastal California gnatcatcher associated
with the Project will be restored on site where the impacts occur, and an additional 6-acre area
(Offsite Restoration Area) of disturbed habitat will be restored within Shoreline Park and
potentially the San Ramon Reserve, also known as Switchbacks, to mitigate for temporal
impacts. The Offsite Restoration Area in these areas will be identified and approved by the
Service prior to initiation of any vegetation removal associated with the Project. To the extent
practical, project construction will occur outside the breeding season for the coastal California
gnatcatcher.
Resolution No. 2026-51
Exhibit B
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Section 1. Introduction and Background
1.1 Overview and Background
The Los Angeles County Sanitation Districts (LACSD) has identified vulnerabilities in the Joint
Outfall J Unit 1E Trunk Sewer Line (Project) within the project area (Figure 1). To prevent
potential sewer leakage, LACSD proposes to rehabilitate the existing sewer line with cured-in-
place pipe liner. The Project will require a temporary flow bypass during construction at manhole
(MH) J 0217 and near MH J 0235. The Project will not require direct access to pipelines but
rather the liner will be inserted at existing manholes. Rehabilitation of the sewer line will require
vehicular access, pedestrian access, and staging areas to facilitate movement of equipment that
will impact approximately 0.80 acres of occupied habitat for the federally threatened coastal
California gnatcatcher (Polioptila californica californica; gnatcatcher) that was conserved in
perpetuity associated with Ocean Trails Habitat Conservation Plan to mitigate for impacts
associated with that project. Future maintenance activities will require access to certain
infrastructure through gnatcatcher habitat; however, LACSD will take measures as described in
the HCP to ensure that there will be no incidental take of gnatcatchers beyond the permit term.
Perpetual easements were recorded in 1957, granting LACSD the right to construct, maintain,
reconstruct, use, operate, and access the Joint Outfall J Unit 1E Trunk Sewer on the land where
the Ocean Trails Golf Course and Shoreline Park were developed decades later. Additionally, in
1997, prior to the construction of the golf course, because the development would be built on
top of the existing sewer, LACSD entered into a Sewer Buildover Agreement with The Ocean
Trails Course at Palos Verdes. This agreement allowed for the construction of the golf course
over the sewer, subject to certain conditions, including the perpetual right to access the sewer
for operation, maintenance, repair, and reconstruction.
The purpose of this Habitat Conservation Plan (HCP) is to support an application to the U.S.
Fish and Wildlife Service (Service) for an incidental take permit under section 10(a)(1)(B) of the
Endangered Species Act (Act), as amended 1973. The proposed permit will address potential
impacts to the gnatcatcher and its habitat during project construction, habitat removal, and
habitat restoration that LACSD has committed to as mitigation for impacts to the gnatcatcher
and its habitat. The HCP describes measures that will ensure that maintenance activities
beyond the permit term will not result in incidental take of gnatcatchers.
1.2 Permit Holder and Permit Duration
The LACSD will be the section (10)(a)(1)(B) permittee. The duration of the incidental take permit
will be 7 years. Project construction and habitat restoration are anticipated to be completed
within 5 years of permit issuance, but 7 years will be allowed to accommodate potential
construction or restoration delays.
1.3 Permit Boundary / Covered Lands
The permit boundary will be defined as the 1.67-acre project impact area shown in Figures 2-6
and the Offsite Restoration Area.
1.4 Species to be Covered by Permit
The applicant is requesting coverage for the federally threatened coastal California gnatcatcher
(Polioptila californica californica).
Resolution No. 2026-51
Exhibit B
Page 5 of 30
1.5 Regulatory Requirements
The Act (16 U.S.C. 1531 et seq.) provides for the protection and conservation of fish, wildlife
and plants that have been federally listed as threatened or endangered. Activities otherwise
prohibited by section 9 of the Act and subject to the civil and criminal enforcement provisions of
section 11 of the Act may be authorized for Federal entities pursuant to the requirements of
section 7 of the Act and for other persons pursuant to section 10 of the Act.
Section 10(a)(2)(A) of the Act states that no permit may be issued authorizing any taking
referred to in section 10(a)(1)(B) unless the applicant submits to the Secretary (the Secretary of
the Interior) an HCP that specifies:
1.The impact which will likely result from such taking;
2.What steps the applicant will take to minimize and mitigate such impacts, and the
funding that will be available to implement such steps;
3.What alternative actions to such taking the applicant considered and the reasons why
such alternatives are not being utilized; and
4.Such other measures that the Secretary may require as being necessary or
appropriate for purposes of the plan.
This HCP has been prepared in consultation with the Service to fulfill the requirements of
section 10(a)(2)(A) of the Act as part of an application for a section 10(a)(1)(B) incidental take
permit.
With guidance and technical assistance from the Service, the LACSD is proposing this
document as a “low effect” HCP. A low-effect HCP is one “involving: (1) minor or negligible
effects on federally listed, proposed or candidate species and their habitats … and (2) minor or
negligible effects on other environmental values or resources. ‘Low effect’ incidental take
permits are those permits that, despite their authorization of some small level of incidental take,
individually or cumulatively have a minor or negligible effect on species covered …” (Service
2016).
Resolution No. 2026-51
Exhibit B
Page 6 of 30
Section 2. Project Description
The Project portion under permit jurisdiction by the Service is located within the City of Rancho
Palos Verdes and will rehabilitate approximately 9,362 feet of existing reinforced concrete pipe
sewer with a cured-in-place pipe liner. It will also rehabilitate approximately 13 manholes with a
protective coating system, and abandon 2 manholes in place. The Project begins at MH J 0235
southwest of the driving range in the Trump National Golf Course (formerly known as Ocean
Trails) and ends in the residential community east of Shoreline Park (Figure 1). Post-
construction, periodic maintenance activities to prevent sewerage spills will include: 1) visual
inspection every two years to assess if cleaning is needed, 2) closed-circuit television (CCTV)
inspection of the sewer line every 15 years, 3) application of protective coating to the MH every
20 years to minimize corrosion, and 4) cleaning of the sewer line as needed.
Construction Project impacts are shown in Figures 2-6. Impacts begin at the western boundary
of the Trump National Golf Course, continue through the golf course and the Ocean Trails
Reserve, and end in Shoreline Park with manholes located in coastal sage scrub, golf greens,
existing trails, and cart pathways. To access the manholes, the applicant will clear, grub, and/or
grade temporary access roads, and establish staging areas at MHs J 0220, J 0222, and J 0235.
The Project will impact a total of 1.67 acres, including 0.80 acre of coastal sage scrub.
Maintenance activities within the California Gnatcatcher territories will occur at MHs J 0217- J
0222 and J 0226. Impacts to coastal sage scrub will be restored onsite where the impacts
occurred, and the Offsite Restoration Area within Shoreline Park and/or the San Ramon
Reserve, also known as Switchbacks, in the City of Rancho Palos Verdes.
Resolution No. 2026-51
Exhibit B
Page 7 of 30
Section 3. Biological Resources
3.1 Environmental Setting
The Project area runs along the coast generally following a bluff overlooking the Pacific Ocean.
The sewer system runs under residential areas, developed golf course, and conserved native
habitat. The native habitat is primarily coastal sage scrub with some non-native grassland. The
coastal sage scrub within the Project area was conserved as mitigation for impacts associated
with the Ocean Trails HCP, now known as the Trump National golf course. The Project area has
a Mediterranean climate with warm arid summers and mild wet winters. Typical year-round
average temperatures range from 51 to 74 degrees Fahrenheit. Rainfall typically averages 10-
13 inches per year, mostly occurring during the winter months.
3.2 Coastal California Gnatcatcher (Polioptila californica
californica)
The gnatcatcher is a small, non-migratory songbird that occurs along the Pacific coastal regions
of southern California and northern Baja California, Mexico. Gnatcatchers occur in association
with the coastal sage scrub vegetation community. Much of the species’ current range within the
United States is covered by large, regional HCPs permitted under section 10(a)(1)(B) of the Act
and under the State of California’s Natural Community Conservation Planning (NCCP) Act.
These regional plans have made substantive contributions to the species’ conservation. Threats
to the species include agricultural and urban development, wildfire, grazing, predation and
brood parasitism. Within the project area, gnatcatchers have been consistently observed during
annual surveys (Robert A. Hamilton Biological, Inc 2024, 2025), and all coastal sage scrub
within the project area is considered occupied by the species. Nest density varies drastically by
year as shown in Figures 7 and 8.
The Project area is part of an isolated population in the Palos Verdes Peninsula. Population size
in the area fluctuates drastically based on consistent survey information (Endemic
Environmental Services, Inc 2024). A large landslide has affected large areas of the Palos
Verdes Peninsula throughout history. This landslide has recently accelerated causing substantial
impacts to infrastructure and habitat. In addition, construction activities designed to slow the
landslide have resulted in substantial loss of habitat that has not been quantified. As a result, we
anticipate that gnatcatcher pairs have been forced to reduce territory size to fit all territories into
the remaining habitat. The dense territories shown in Figures 7 and 8 for 2024 support the
argument for higher territory density.
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Exhibit B
Page 8 of 30
Section 4. Potential Biological Impacts / Take
Assessment
4.1 Project Impacts and Anticipated Take
Construction of temporary access roads and staging areas will directly remove 0.80 acre of
nesting and foraging habitat for the gnatcatcher. Noise and visual disturbance will also affect
individual gnatcatchers that fly away for safety. The gnatcatcher breeding season is typically
from February 15 through August 31. Construction is expected to avoid the breeding season to
the maximum extent practicable. Additionally, routine maintenance activities, including visual
inspection, CCTV inspection, protective coating application, and periodic cleaning, will require
access to certain MHs beyond the permit term. To assess these impacts, we describe
anticipated effects in sections shown in Figures 2-6.
Impacts Resulting from Construction
Figure 2 (MHs J 0217- J 0220):
LACSD proposes to access MH J 0217 to install a bypass pipe no earlier than July 1, 2026. The
bypass pipe is required to initiate work on the sewer alignment to the east. Accessing MH J
0217 will require clearing and grubbing of 0.14 acre of coastal sage scrub as well as clearing
and grubbing of approximately 0.50-acre of existing trail. Construction activities could affect
between up to three territories. The maximum length and width of each segment are shown in
the associated figures. As shown in Figure 8, nest density around MH J 0217 is variable. Given
the nature of the impact, we anticipate that no more than one territory will be directly affected
such no more than one nesting attempt will fail. We anticipate that with guidance from an onsite
biomonitor, gnatcatcher reproduction will not be affected; however, work within the breeding
season may result in the loss of up to one gnatcatcher brood in and around MH J 0217.
The remaining work in this area will occur on or after September 1, 2026, and will not have
direct effects to gnatcatcher breeding success in 2026; however, these impacts combined with
impacts to MH J 0217 will reduce habitat availability until habitat restoration is complete, which
we anticipate will take up to 5 years. Accessing MHs J 0218-0220 will require clearing and
grubbing of 0.80 acre of existing trail, clearing, grubbing, and grading of 0.12 acre of occupied
coastal sage scrub for staging and access, and clearing and grubbing of 0.09 acre of coastal
sage scrub for stockpiling. July 1st is within the gnatcatcher breeding season, and construction
activity at this time of year has potential to impact breeding success. In total, there will be a
temporary loss of 0.35 acre of coastal sage scrub that may reduce breeding success for up to
one gnatcatcher territory for up to 5 years.
Figure 3 (MH J 0222):
This work will be done outside of the gnatcatcher breeding season. Access to MH J 0222 will
require clearing, grubbing, and grading of 0.18 acre of coastal sage scrub as well as clearing
and grubbing of 0.12 acre of coastal sage scrub. In total, there will be a temporary loss of 0.30
acre of coastal sage scrub that will reduce breeding success for one territory for up to 5 years.
As shown in Figure 7, nest density is variable in and around MH J 0222, but it is likely that one
territory will be affected by the loss of habitat. Given the potential density of nests in the area
(e.g., 2024), 0.30 acre could represent a substantial loss of habitat for a territory and could
cause loss of a brood annually for up to 5 years.
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Figure 4 (MH J 0234):
This work will be done outside of the gnatcatcher breeding season. Access to MH J 0234 will
require clearing and grubbing of 0.04 acre of coastal sage scrub. Figure 7 (territory A) shows
that gnatcatchers consistently establish territories around MH J 0234. We anticipate a slight
reduction in territory size that may affect brood success annually for up to 5 years. Given the
small size of this impact, we expect that brood success in most years will be unaffected.
Figure 5 (MH J 0235):
LACSD proposes to access MH J 0235 to install a bypass pipe on July 1, 2026. Access to MH J
0235 will require clearing and grubbing of 0.16 acres of mixed coastal sage scrub and other
scrub habitat as well as grading and filling of 0.03 acres of the same habitat type. In addition,
0.06-acre of coastal sage scrub will be impacted for vehicle staging. Gnatcatcher surveys have
not been conducted around MH J 0235 because the scrub habitat was installed only recently.
Given the habitat quality, we expect that up to one territory may be established immediately
surrounding MH J 0235. Given the nature of the impact, we anticipate that no more than one
territory will be directly affected such that no more than one nesting attempt will fail in 2026. The
total impact to gnatcatcher breeding from work in and around MH J 0217 will be loss of up to
one brood. After 2026, 0.25 represents a minor loss of habitat for any future territory and could
cause loss of a brood annually for up to 5 years. Given the nature of the existing habitat, we
expect that brood success in most years will be unaffected.
Figure 6 (MH J 0481):
This work will be done outside of the gnatcatcher breeding season. Access to MH J 0481, will
require clearing and grubbing of 0.01 acre of coastal sage scrub. Figure 7 (territory O in 2024)
shows that gnatcatchers are packed densely around MH J 0481. We anticipate a slight
reduction in territory size that may affect brood success annually for up to 5 years. Given the
small size of this impact, we expect that brood success in most years will be unaffected. This
MH will be abandoned in place during construction and LACSD will not need to return to this MH
in the future.
Maintenance Activities Beyond the Permit Term
Four separate maintenance activities will occur in perpetuity, at different frequencies, as long as
the sewer line is in service. A visual inspection of the MHs will be conducted every 2 years to
assess the condition of the sewer line. Foot access to the MHs will be needed. Minimal, if any,
impacts to the habitat are expected from visual inspection. A CCTV inspection of the sewer line
will be conducted every 15 years by a 4- or 5-person crew using equipment mounted on and
brought in by a large van and a truck. CCTV inspection will result in some vegetation being
flattened, but it is expected to recover on its own. A protective coating of the MH will be applied
every 20 years if a visual inspection identifies such a need. This work can be done via foot
access, similar to the visual inspection. Cleaning will be conducted on an as-needed basis and
will require personnel and equipment access to the MHs, similar to that required for a CCTV
inspection. Maintenance activities will be performed outside of the gnatcatcher breeding season,
typically from February 15 through August 31.
MHs J 0218 and J 0220
LACSD proposes accessing MHs J 0218 and J 0220 via an existing 12-foot-wide access road
as depicted in Figure 9 to provide vehicular access for maintenance activities. This will allow
Resolution No. 2026-51
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vehicles to be parked adjacent to the MH, but away from the thick, dry brush that may be a fire
hazard. Minimal amounts of vegetation will need to be flattened to accommodate vehicular
positioning adjacent to the MH. This temporary vegetation impact will occur every 15 years.
The flattened vegetation is expected to recover on its own. This option would also provide
easier access to MH J 0217 by walking through the vegetation between MH J 217 and MHs
J 0218 and J 0220.
MH J 0217
Due to the terrain’s steepness, direct vehicular access to this MH is not possible. LACSD
proposes to set up the equipment at the MHs J 0218 and J 0220. The crew will pull a cable from
the equipment to MH J 0217 by walking through the vegetation (Figure 9), which could damage
the vegetation between the truck and the MH when the cable is in tension. We expect that any
snapped or broken vegetation will recover on its own.
MHs J 0219 and J 0221
Similar to MH J 0217, LACSD proposes to park the truck on the trail approximately 400 feet
away from the MH and pull the cable up to the MHs (Figure 9). Vegetation could be damaged
between the truck and the MHs when tension is applied to the cable, but it is expected to
recover naturally.
MHs J 0222 and J 0226
LACSD proposes parking the vehicles and setting up the equipment on existing golf cart paths.
Although the vehicle and equipment will remain on the golf course, personnel will walk through
the vegetation to reach the MHs. It is likely that some vegetation will be damaged when the
cable snaps into a straight line under tension during cleaning. We expect this vegetation to
recover naturally.
4.2 Effects on Critical Habitat
The entire 0.80-acre area that will be temporarily impacted by the Project as well as the Offsite
Restoration Area are within designated critical habitat for the gnatcatcher. These impacts will be
temporary, likely up to 5 years, and are not large enough to have a substantial impact on the
4,462-acre Critical Habitat Unit 8. When the restoration is complete, the Project will have
expanded the total area of critical habitat with the physical and biological characteristics of
Critical Habitat within Unit 8.
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Section 5. Measures to Minimize and Mitigate for
Impacts
5.1 Biological Goal and Objective
Section 10(a)(2)(A) of the Act requires that an HCP specify the measures that the permittee will
take to minimize and mitigate to the maximum extent practicable the impacts of the taking of
any federally listed animal species resulting from activities addressed by the plan.
As part of the “Five Point” Policy adopted by the Service in 2000, HCPs must establish
biological goals and objectives (Service 2016). The purpose of the biological goals is to ensure
that the operating conservation program in the HCP is consistent with the conservation and
recovery goals established for the species. The goals are also intended to provide the applicant
an understanding of why these actions are necessary. These goals are developed based upon
the species’ biology, threats to the species, the potential effects of the Covered Activities, and
the scope of the HCP.
The biological goal of the HCP is to increase the breeding habitat available to the gnatcatcher to
compensate for the loss of habitat associated with the Project. The objective will be to restore
the established mitigation areas in the Project footprint as well as disturbed habitat within the
Offsite Restoration Area at Shoreline Park or the San Ramon Reserve in the City of Rancho
Palos Verdes.
5.3 Avoidance, Minimization, and Mitigation Measures
5.3.1 Measures to Avoid and Minimize Impacts
LACSD will develop a program to educate all workers and new workers that come on site
throughout the duration of the Project on the importance of impact avoidance to the gnatcatcher
and their habitat. The education program will be given to all workers before any work is
conducted within and adjacent to coastal sage scrub. The education will focus on ensuring
contractors understand that avoidance outside of the Project footprints (see Figures) is essential
to minimize impacts to native habitat where a federally listed species is present. A qualified
biomonitor approved by the Service will be on site for all vegetation clearing to provide access
and during Project activities to prevent unanticipated intrusions into coastal sage scrub. With the
exception of work on MH J 0217 and MH J 0235 (earliest start date July 1), all work in coastal
sage scrub will take place outside of the breeding season defined as February 15 to August 31.
The biomonitor will be responsible for helping the contractors flag the access areas where the
work will be performed and flag any active nests in close proximity to the work being conducted
on MH J 0217 and MH J 0235.
5.3.3 Measures to Mitigate Unavoidable Impacts
LACSD will enter into an agreement with the Palos Verdes Peninsula Land Conservancy
(PVPLC), or an equally qualified entity approved by the Service, to conduct restoration work.
PVPLC has an extensive record of successful coastal sage scrub restoration within the Palos
Verdes Peninsula. The habitat restoration plan will include restoration of temporary impacts from
project construction and offsite habitat restoration at Shoreline Park or the San Ramon Reserve.
The restoration plan will be provided to the Service for review prior to the initiation of work on
the Project, and the restoration plan must be approved within 3 months of initiation of work. The
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specific location of habitat restoration will be encumbered with a legal instrument such as a
restrictive covenant. This legal instrument will attribute the restoration efforts on these acres to
LACWS and acknowledge that the restoration was mitigation associated with this HCP.
5.4 Monitoring and Success Criteria
There are three types of monitoring: (1) compliance monitoring which tracks the permit holder’s
compliance with the requirements specified in the HCP and permit; (2) effects monitoring which
tracks the impacts of the covered activities on the covered species; and (3) effectiveness
monitoring which tracks the progress of the conservation strategy in meeting the HCP’s
biological goals and objectives (includes species surveys, reproductive success, etc.).
Monitoring provides information for making adaptive management decisions.
PVPLC, or the equally qualified entity approved by the Service, will submit a detailed restoration
plan with objective success criteria for review and approval by the Service prior to initiation of
Project construction. Final success criteria will include at least 50 percent cover of native coastal
sage scrub vegetation, no more than 15 percent cover of invasive perennial species, and no
more than 25 percent cover of non-native species total. There will be no invasive species listed
on CalIPC List A with the exception of grass species (Cal-IPC 2026). The Service will sign off on
the restoration work once PVPLC, or the equally qualified entity approved by the Service, has
demonstrated that success criteria have been met.
5.5 Reporting
LACSD will provide a description of all impact to coastal sage scrub from the Project once it is
completed. If the Project is not completed in 2026, LACSD will provide an annual report by the
end of March detailing the work that has been done in the most recent year and cumulatively.
PVPLC, or the equally qualified entity approved by the Service, will provide annual reports of
restoration progress by the end of June annually until the Service signs off on the success
criteria.
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Exhibit B
Page 13 of 30
Section 6. Plan Implementation
6.1 Changed Circumstances
6.1.2 Summary of Circumstances
Section 10 regulations [(69 Federal Register 71723, December 10, 2004 as codified in 50 Code
of Federal Regulations (C.F.R.), Sections 17.22(b)(2) and 17.32(b)(2))] require that an HCP
specify the procedures to be used for dealing with changed and unforeseen circumstances that
may arise during the implementation of the HCP. In addition, the HCP No Surprises Rule [50
CFR 17.22 (b)(5) and 17.32 (b)(5)] describes the obligations of the permittee and the Service.
The purpose of the No Surprises Rule is to provide assurance to the non-Federal landowners
participating in habitat conservation planning under the Act that no additional land restrictions or
financial compensation will be required for species adequately covered by a properly
implemented HCP, in light of unforeseen circumstances, without the consent of the permittee.
Changed circumstances are defined in 50 CFR 17.3 as changes in circumstances affecting a
species or geographic area covered by an HCP that can reasonably be anticipated by plan
developers and the Service and for which contingency plans can be prepared (e.g., the new
listing of species, a fire, or other natural catastrophic event in areas prone to such event). If
additional conservation and mitigation measures are deemed necessary to respond to changed
circumstances and these additional measures were already provided for in the plan’s operating
conservation program (e.g., the conservation management activities or mitigation measures
expressly agreed to in the HCP or IA), then the permittee will implement those measures as
specified in the plan. However, if additional conservation management and mitigation measures
are deemed necessary to respond to changed circumstances and such measures were not
provided for in the plan’s operating conservation program, the Service will not require these
additional measures absent the consent of the permittee, provided that the HCP is being
“properly implemented” (properly implemented means the commitments and the provisions of
the HCP and the IA have been or are fully implemented).
Drought or disease may cause delays in achieving success criteria for habitat restoration. The
restoration plan will include a 10 percent contingency fund to address any additional work that
will be necessary to address these delays.
6.1.3 Newly Listed Species
If a new species that is not covered by the HCP but that may be affected by activities covered
by the HCP is listed under the Act during the term of the section 10(a)(1)(B) permit, the section
10 permit will be reevaluated by the Service and the HCP covered activities may be modified, as
necessary, to insure that the activities covered under the HCP are not likely to jeopardize or
result in the take of the newly listed species or adverse modification of any newly designated
critical habitat. The LACSD shall implement the modifications to the HCP covered activities
identified by the Service as necessary to avoid the likelihood of jeopardy to or take of the newly
listed species or adverse modification of newly designated critical habitat. The LACSD shall
continue to implement such modifications until such time as the LACSD has applied for and the
Service has approved an amendment of the section 10(a)(1)(B) permit, in accordance with
applicable statutory and regulatory requirements, to cover the newly listed species or until the
Service notifies the LACSD in writing that the modifications to the HCP covered activities are no
longer required to avoid the likelihood of jeopardy of the newly listed species or adverse
modification of newly designated critical habitat.
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6.2 Unforeseen Circumstances
Unforeseen circumstances are defined in 50 CFR 17.3 as changes in circumstances that affect
a species or geographic area covered by the HCP that could not reasonably be anticipated by
plan developers and the Service at the time of the HCP’s negotiation and development and that
result in a substantial and adverse change in status of the covered species. The purpose of the
No Surprises Rule is to provide assurances to non-Federal landowners participating in habitat
conservation planning under the Act that no additional land restrictions or financial
compensation will be required for species adequately covered by a properly implemented HCP,
in light of unforeseen circumstances, without the consent of the permittee.
In case of an unforeseen event, the permittee shall immediately notify the Service staff who
have functioned as the principal contacts for the proposed action. In determining whether such
an event constitutes an unforeseen circumstance, the Service shall consider, but not be limited
to, the following factors: size of the current range of the affected species; percentage of range
adversely affected by the HCP; percentage of range conserved by the HCP; ecological
significance of that portion of the range affected by the HCP; level of knowledge about the
affected species and the degree of specificity of the species’ conservation program under the
HCP; and whether failure to adopt additional conservation measures would appreciably reduce
the likelihood of survival and recovery of the affected species in the wild.
If the Service determines that additional conservation and mitigation measures are necessary to
respond to the unforeseen circumstances where the HCP is being properly implemented, the
additional measures required of the permittee must be as close as possible to the terms of the
original HCP and must be limited to modifications within any conserved habitat area or to
adjustments within lands or waters that already set-aside in the HCP’s operating conservation
program. Additional conservation and mitigation measures shall involve the commitment of
additional land or financial compensation or restrictions on the use of land or other natural
resources otherwise available for development or use under original terms of the HCP only with
the consent of the permittee.
6.3 Amendments
6.3.1 Minor Amendments
Minor amendments are changes that do not affect the scope of the HCP’s impact and
conservation strategy, change amount of take, add new species, and change significantly the
boundaries of the HCP. Examples of minor amendments include correction of spelling errors or
minor corrections in boundary descriptions. The minor amendment process is accomplished
through an exchange of letters between the permit holder and the Service’s Carlsbad Fish and
Wildlife Office.
6.3.2 Major Amendments
Major amendments to the HCP and permit are changes that do affect the scope of the HCP and
conservation strategy, increase the amount of take, add new species, and change significantly
the boundaries of the HCP. Major amendments often require amendments to the Service’s
decision documents, including the NEPA document, the biological opinion, and findings and
recommendations document. Major amendments will often require additional public review and
comment.
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6.4 Suspension / Revocation
The Service may suspend or revoke their respective permits if LACSD fails to implement the
HCP in accordance with the terms and conditions of the permits or if suspension or revocation is
otherwise required by law. Suspension or revocation of the Section 10(a)(1)(B) permit, in whole
or in part, by the Service shall be in accordance with 50 CFR 13.27-29, 17.32 (b)(8).
6.5 Permit Renewal
Unanticipated construction or habitat restoration delays may extend the covered activities
beyond 7 years and may require a permit renewal.
Upon expiration, the section 10(a)(1)(B) permit may be renewed without the issuance of a new
permit, provided that the permit is renewable, and that biological circumstances and other
pertinent factors affecting covered species are not significantly different than those described in
the original HCP. To renew the permit, LACSD shall submit to the Service, in writing:
•a request to renew the permit; reference to the original permit number;
•certification that all statements and information provided in the original HCP and permit
application, together with any approved HCP amendments, are still true and correct,
and inclusion of a list of changes;
•a description of any take that has occurred under the existing permit; and
•a description of any portions of the project still to be completed, if applicable, or what
activities under the original permit the renewal is intended to cover.
If the Service concurs with the information provided in the request, it shall renew the permit
consistent with permit renewal procedures required by Federal regulation (50 CFR 13.22). If
LACSD files a renewal request and the request is on file with the issuing Service office at least
30 days prior to the permits expiration, the permit shall remain valid while the renewal is being
processed, provided the existing permit is renewable. However, LACSD may not take listed
species beyond the quantity authorized by the original permit or change the scope of the HCP.
If LACSD fails to file a renewal request within 30 days prior to permit expiration, the permit shall
become invalid upon expiration. LACSD must have complied with all annual reporting
requirements to qualify for a permit renewal.
6.6 Other Measures as Required by the Director
There are no additional measures required for this HCP.
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Section 7. Funding
7.1 Cost of HCP Implementation
Habitat restoration will cost $612,000, including 0.80 acres of on-site restoration and 6 acres of
off-site restoration.
7.2 Funding Source
Funding for avoidance and minimization measures, as well as for conducting and monitoring of
the restoration work, shall be the responsibility of the Permittee. The primary source of funding
shall be from LACSD’s Operating Fund. Outside funding sources, including financial or in-kind
donations or grants, may be used if available, but overall responsibility falls to the Permittee in
the absence of such support. Failure of the Permittee to provide sufficient funding and
document such expenses in the annual report shall be grounds to terminate the Permit at the
discretion of the Service.
LACSD is a California Special District able to raise necessary revenues to fund its operations
through a number of sources, including annual revenues from user fees, ad valorem taxes,
connection fees, revenue bonds, and other sources. Multiple revenue sources, in conjunction
with adequate reserves, impart a substantial degree of financial stability to LACSD. The
customers served by LACSD provide a stable and reliable source of revenue, which enhances
financial stability. Historically, LACSD has been able to develop a timely and balanced budget to
fund both capital projects and expenses for the coming fiscal year (July 1 through June 30).
LACSD will designate or encumber implementation funds for this HCP in its annual budget
through the specific LACSD budgetary process described below.
1. In the fall of each year, each LACSD department provides all revenue and expense
items for the following fiscal year.
2.Based on proposed revenues and expenses, Budget and Finance prepares long-
term models in order to develop preliminary budgets.
3.The preliminary budgets are reviewed and adjustments are made as needed.
4.The final annual budget is adopted by Board Resolution in May to June of each year.
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Section 8. Alternatives
8.1 Summary
Section 10(a)(2)(A)(iii) of the Act, [and 50 CFR 17.22(b)(1)(iii) and 17.32(b)(1)(iii)] requires that
alternatives to the taking of species be considered and reasons why such alternatives are not
implemented be discussed.
8.2 No Action Alternative
The No Action Alternative means that an HCP and incidental take permit would not be issued.
This also means current conditions and activities that will not cause take of federally listed
species could continue. Project construction would not proceed, and engineering projections
show that the sewer lines will burst and cause leakage within the next 5 years. There would
likely be significant impacts to human health and wildlife habitat, including occupied gnatcatcher
habitat.
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Section 9. Literature Cited
[Cal-IPC] California Invasive Plant Council. 2026. https://www.cal-
ipc.org/resources/library/publications/ipcw/categories/. Accessed February 26, 2026.
Endemic Environmental Services, Inc. 2024. Palos Verdes Nature Preserve Survey for the
California Gnatcatcher and the Cactus Wren. Palos Verdes Peninsula Land
Conservancy, Los Angeles County 2024. Final Report.
Robert A. Robert A. Hamilton Biological, Inc. 2024. 2024 Focused Surveys for California
Gnatcatchers and Cactus Wrens, Ocean Trails Reserve. July 12, 2024
Robert A. Robert A. Hamilton Biological, Inc. 2025. 2025 Focused Surveys for California
Gnatcatchers and Cactus Wrens, Ocean Trails Reserve. July 21, 2025
[Service] U.S. Fish and Wildlife Service. 2016. Habitat Conservation Planning and Incidental
Take Permit Processing Handbook. U.S. Fish and Wildlife Service and National Oceanic
and Atmospheric Administration. December 21, 2016.
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Figures
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Figure 1. Project Overview
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Figure 2. Anticipated impacts at MHs J 0217- J 0220.
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Figure 3. Anticipated impacts at MH J 0222.
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Figure 4. Anticipated impacts at MH J 0234.
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Figure 5. Anticipated Impacts at MH J 0235.
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Figure 6. Anticipated impacts at MH J 0481.
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Exhibit B
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Figure 7. Gnatcatcher territories within the western portion of the Trump National Golf Course
Preserve in 2024 (top) and 2025 (bottom). From Hamilton 2024 and 2025.
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Exhibit B
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Figure 8. Gnatcatcher territories within the eastern portion of the Trump National Golf Course
Preserve and Shoreline Park in 2024 (top) and 2025 (bottom). Data from Hamilton 2024 and 2025.
Resolution No. 2026-51
Exhibit B
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Figure 9. Anticipated impacts from maintenance activities to access MHs J 0217 to J 02221.
Resolution No. 2026-51
Exhibit B
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Figure 10. Anticipated impacts from maintenance activities to access MHs J 0222.
Resolution No. 2026-51
Exhibit B
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