Exhibit 10 Public Comments. Local Coastal Program Update - Phase 2A Ventura County Planning Division

Transcription

1 Exhibit 10 Public Comments Local Coastal Program Update - Phase 2A Ventura County Planning Division

2 EXHIBIT 10 Public Comments This Exhibit contains responses to comments submitted for the Draft Local Coastal program (LCP) text amendments. Letters were submitted by the California State Department of Parks and Recreation, Naval Base Ventura County, the California Film Commission, County residents, and consultants specializing in the field of archaeology and paleontology. The County appreciates the substantive input that was received by the commenters. Many comments resulted in modifications to the LCP amendments. Staff responses are included and shown in italic font. Comments within this Attachment are organized by agency, and in the case of archaeological and paleontological resources, listed by consultant. State of California Department of Parks and Recreation..2 Naval Base Ventura County. 16 California Film Commission.. 17 Bryan Harre, Silverstrand Beach Property Owner 23 Archaeological and Paleontological Resources Pat Maxon, M.A. RPA, BonTerra, Psomas 26 Robin Turner, ArchaeoPaleo Resource Management, Inc.. 28 Bruce Lander, Ph.D The comments summarized in this Exhibit were made during or after public meetings, via , during phone conversations, or (in the case of Bryan Harre) formal comments were submitted at the Planning Division counter. Lengthy comments were edited for brevity, and comments were not listed unless they were directly related to the proposed amendments to the LCP. Page 1 of 30

3 Mr. Craig Sap and Mr.Richard Rozzelle State of California Natural Resources Agency Department of Parks & Recreation Letter dated May 13, 2014 General Comments Comment #1: California State Parks plays an important role in fulfilling the Coastal Act and should be treated as a public agency whose projects are subject to the broader perspective provided by California Coastal Commission staff, thus should be exempted from inappropriate additions of local agency codes and ordinances which generally apply to commercial and/or private development, without the broader public good that is delivered by California State Parks. Response: The County s authority to issue permits in the coastal zone is vested in the 1983 certification by the Coastal Commission of the County s Local Coastal Program (LCP), which includes the Coastal Area Plan (CAP) and the Coastal Zoning Ordinance (CZO). After the County s LCP was certified, coastal development permit authority was delegated to Ventura County, but the Commission continues to retain permit jurisdiction over certain specified lands (such as tidelands and public trust lands). However, should State Parks wish to process its own permits, the Department of Parks and Recreation could submit a Long Range Development Plan (LRDP) to the Coastal Commission for review and approval in the same manner prescribed for LCPs (pursuant to Coastal Act Section 30605). Absent such a plan, Ventura County s LCP is the governing document. Proposed amendments to the County s LCP comply with Coastal Act Section 30251, which states that permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the character of surrounding areas, and, where feasible to restore and enhance visual quality in visually degraded areas. The three State Parks located within Ventura County s coastal zone are visible from highly trafficked public vantage points, and our assumption is that Coastal Act provisions do apply. However, as noted above, the Department of Parks and Recreation could submit a customized plan, tailored to its needs, for review and approval by the Coastal Commission. Should that plan be certified by the Coastal Commission, Ventura County s LCP would no longer apply. Comment #2: The costly fees that the Ventura County Planning Division requires for review and permitting costs are not proportional to the scope of many proposed recreational facility and resource management projects; consequently, these unfunded costs either reduce or eliminate California State Parks ability to implement important public use facilities that directly benefit the public use of the California coast in the spirit of the California Coastal Act. Response: Permit processing fees that appear to be disproportionate to the final outcome can be the result of incomplete submittals, difficult issues that require more in- Page 2 of 30

4 depth analysis and investigation, or necessary coordination with other County Departments. Early consultation with the Planning Division would help minimize the costs and time needed to process permits. Comment #3: The Ventura County Planning Division s strict definition of Environmentally Sensitive Habitat Areas (ESHAs), which encompass most of our coastal parklands, does not allow for an NOE filing for projects requiring a Coastal/Planned Development Permit located within ESHA. Response: The County s definition of ESHA is taken from Coastal Act Section , and State law (Coastal Act Section 30240(a)) restricts development within ESHA to those uses dependent on the resource. The Commission found that such activities as hiking and educational trails, low impact camping, educational signage and kiosks, research, and restoration qualify as resource dependent development. The purpose of CEQA is to inform decision-makers of the potential adverse environmental consequences of proposed development. Notice of Exemptions (NOEs) are filed by the Lead Agency only when the project is exempt from CEQA, and exemptions are defined by State law and fall into four categories: statutory exemptions, categorical exemptions, general rule and disapproved project. CZO Section lists the statutory exemptions and categorical exclusions, which are exempt from a coastal development permit. In all instances, however, the removal of major vegetation or development in ESHA is not exempt and would be subject to a discretionary Planned Development Permit, the county s equivalent to a coastal development permit. Comment #4: Section 1, Coastal Area Plan, Archaeological Resources Context information includes standard references that are quite old and outdated. Current sources should also be used for this LCP Update, as years of subsequent research has refined our knowledge of Chumash lifeways and subsequent European colonization (for example see Gamble 2008, Jones and Klar 2007). Response: In response to this comment, the abstract for this topic was updated to provide a more descriptive overview of regional prehistory in order to provide a context for understanding the importance of archaeological resources. Periodicals, reports, and data including The Chumash World at European Contact Gamble 2008 and California Prehistory Jones and Klar 2007 were reviewed when modernizing the abstract. Comment #5: Section 1, Coastal Area Plan, Archaeological Resources Policies, #3 Replace ethnobotanical with ethnographic. The former term only refers to the cultural use of plant resources, whereas the latter is more broad-based and includes a variety of traditional cultural practices. Response: In response to this comment, CAP policy 3 and the term ethnobotanical was modified to use the term ethnographic as recommended. Comment #6: The difference between Policies on pages 2 and 3, and CAP Policies beginning on Page 5 are unclear, as there seems to be a couple of repetitions. Page 3 of 30

5 Response: The CAP is organized by geographic areas, specifically the north, central and south coasts. The abstracts, objectives and policies developed for archaeological resources are currently repeated in each geographic area, which results in redundancy within the plan. The proposed revisions would consolidate the abstracts, objectives and policies for Archaeological Resources under one general heading that would be applied to all three geographic coastal areas. Policies 1 and 2 are new and policies 3 and 4 are certified CAP polices that would be retained with minor revisions. The CAP policy strikeouts and revisions under each sub-area are provided to show the changes, and the final draft will only include one reference to the CAP policies that address archaeological (and paleontological) resources. Archaeology and Paleontology Comment #7: Section 2, Coastal Area Plan, Paleontology Context information only includes references from personal communications. Current written sources should be used for this LCP update, perhaps the Los Angeles County Museum of Natural History could recommend a couple of key current references. Response: In response to this comment, the abstract under B. Paleontology, was revised to include information obtained from a telephone conversation and correspondence with Dr. Bruce Lander, co-author of Paleontological Resource Assessment Overview, Southern Ventura County (July 1988). Comment #8: Further the Quaternary Period is dated from 2.58 million years ago to the present, and includes substantial paleontological deposits in southern California, including the La Brea Tar Pits. Instead, Quaternary should be replaced with Holocene. Response: The geologic time scale places the Holocene and Pleistocene as epochs to the Quaternary Period. In consultation with Brian Baca, Certified Engineering Geologist (CEG) 4571, Section Methodology, Table 1 was revised and the level of importance for the following geologic formations elevated from low to none to moderate: Paralic deposits for the Holocene and Pleistocene epochs; and the Saugus, Sisquoc, and Casitas Formations. By elevating the importance of these geologic formations, further investigation of the paleontological resources will be required. Comment #9: Section 2, Coastal Area Plan, Paleontology, Objective Prehistoric is generally used to identify archaeological resources, not paleontology, so we recommend that the word is removed from this section. Response: Prehistory (meaning "before history ) is the span of time preceding human existence and the invention of writing. More broadly, it can refer to the evolutionary history of life on earth tracing the processes by which living and fossil organisms have evolved since life on the planet first originated until the present day. Research into the Page 4 of 30

6 term prehistoric has uncovered many references that link paleontology to the term prehistoric. The term prehistoric is being retained. Comment #10: Section 2, Coastal Area Plan, Paleontology, Policies Recommend replacing paleontology with Paleontological significance to be more in-line with national guidelines provided by the Bureau of Land Management. Response: In response to this comment, CAP policy 1 was revised to state the following: Discretionary development shall be evaluated for potential impacts to paleontological resources. The revised policy establishes the requirement to determine presence or absence of the resource followed by level of significance. Comment #11: Section 1, Article 2, Definitions Although the staff explanation notes that the proposed definition provides a higher standard of protection than is provided under CEQA, by limiting the definition of archaeological resources to pre-date the 19 th century, Ventura County is essentially eliminating protections for resources less than two centuries in age. Under CEQA, any cultural resource greater than 50 years of age could potentially be significant, and such resources do not need to be limited to Native American materials. To avoid confusion with the cultural resources field, and be consistent with the California Environmental Quality Act and guidance provided by the Office of Historic Preservation (OHP), we recommend that the definition for archaeological resources be revised. Further, there appears to be no policies in the LCP update covering historic-period built environment resources. Response: In response to this comment, and to establish a more informative timeline of California history, the definition of Archaeological Resource was amended to include maritime history and historical events up to and including United States statehood. CZO Section Archaeological Resources Determined to be Historic Resources, was also added to ensure historical resources are considered when evaluating the significance or archaeological resources. Comment #12: Section 6, Article 8, Section , Methodology The Register of Professional Archaeologists (RPA) is one way to identify a qualified archaeologist, but not all qualified archaeologists necessarily have RPA status, nor are they required to register under current state and federal law. Instead, the LCP should define a qualified archaeologist as someone who meets the Secretary of Interior standards of qualifications that the California Historical Resources Information System (CHRIS) use. Response: In response to this comment, the definition of Archaeologist, Qualified Consultant was revised to be consistent with the Ventura County Initial Study Assessment Guidelines and reference to a Registered Professional Archaeologist was omitted. Comment #13: Section 6, Article 8, Section , Methodology, c. through d. OHP has developed guidelines for the preparation of Archaeological Resource Management Reports, including Phase I studies. Please refer to these standards for components required in such reports. A Phase I study only documents an inventory of Page 5 of 30

7 resources through background research and surface survey; it does not assess the significance of subsurface cultural deposits, nor does it provide recommendations for mitigation. The Phase I study may however, provide recommendations for further work, such as a Phase II study, which may be required to assess project effects on archaeological resources when they cannot otherwise be avoided. Response: In response to this comment, Section (b)(5) Phase I Inventory was revised to note that the Phase I Inventory Report shall provide resource management recommendations and not mitigation as previously stated. Additionally, the report titles were revised to be consistent with current practice, specifically, Phase I Inventory, Phase II Evaluation, and Phase III Mitigation, consistent with the California Office of Historic Preservation. Comment #14: Section 6, Article 8, Section , Methodology, f. Why would a Registered Professional Archaeologist need to consult a qualified archaeological resources monitor to prepare a Phase II Evaluation research design? Similarly, why would a Phase III data recovery excavation require an archaeological resources monitor if a qualified archaeologist is directing the work (see subsection h). Response: In response to this comment, CZO Section Methodology was revised. Reference to archaeological monitors assisting the qualified archaeological consultant in the preparation of a Phase II Evaluation or Phase III Mitigation was removed. Comment #15: Section 6, Article 8, Section , Methodology, g.4. Replace cultural with resource. Response: In response to this comment, the term cultural was replaced with resource. The suggested revision required sections to be renumbered. Section (g)(4) is now Section (d)(4). Comment #16: Section 6, Article 8, Section , Methodology, h and i. In what circumstance would an archaeological data recovery excavation performed as mitigation for a proposed development require a separate grading permit? As written the LCP update requires a coastal development permit to support mitigation for a project applying for a coastal development permit. Additionally the text appears to be conflating the Data Recovery Plan, which is a research design proposal for carrying out an archaeological excavation, with a Data Recovery Report, which would summarize the results of the completed excavation. The latter report may require extensive analyses, depending on the size of the project, and could take one of several years to complete, creating substantial project delay should the report be required to be completed before issuance of the project coastal development permit. Response: In response to this comment, the requirements set forth for the Data Recovery Plan and Data Recovery Report were clarified and the timing for submitting the Data Recovery Report was changed to occur after archaeological excavations are completed. The data recovery excavation performed as mitigation for the project would Page 6 of 30

8 be included in the coastal development permit for the project. Reference to a grading permit being required for the purpose of a Phase III excavation was omitted. The suggested revisions required sections to be renumbered. Section (h) and (i) is now Section Phase III Mitigation. Comment #17: Section 6, Article 8, Section , Monitoring It should be made clear the determining factors for construction that have the potential to uncover or otherwise disturb archaeological resources. Suggest including something like, as determined by the Phase I and/or Phase II archaeological studies. The Native American Heritage Commission (NAHC) does not provide lists of qualified monitors; instead, the NAHC provides a contact list of groups of individuals who may have knowledge of resources in the project area and who should be contacted for project consultation. Some of these contacts, but not all, may provide Native American monitoring services, or may provide recommendations for appropriate monitors. As currently written, this section only takes into account Native American archaeological resources and require a Native American monitor be present for all projects with the potential for encountering archaeological materials. But monitoring may also be required for historical archaeological resources, which would not necessarily require the services of a Native American monitor (see comments regarding historic-period resources, above). Response: In response to this comment, CZO Section was revised to require archaeological monitoring during earth moving activities as determined by the Phase I Inventory and/or Phase II Evaluation. If the resource is significant to Chumash or Native American prehistory or history, the monitor shall be a Native American monitor chosen in consultation with the Native American Heritage Commission. The Planning Division cannot endorse a particular Native American representative, and the reference to the Native American Heritage Commission is a starting point to find local representatives. Comment #18: Section 6, Article 8, Section , Monitoring, d. Please note here that the NAHC will designate a Most Likely Descendent (MLD). Response: CZO Section Monitoring, (f) is text taken from Public Resources Code (PRC) It may be that Native American Heritage Commission (NAHC) has designated a MLD; however, the PRC suggests that there may be instances when MLD cannot be identified. Comment #19: Section 6, Article 8, Section , Mitigation, 2. Remove the reference to the Phase III report here recovery of resources is the Phase III archaeological work, so that report would not recommend recovery as it would already have been completed. Response: In response to this comment, CZO Section (a)(2), Mitigation, reference to the Phase III report was omitted. Comment: Section 6, Article 8, Section Archaeological Resources The edits state that this section will be deleted and Appendix 2, although outdated, will be Page 7 of 30

9 maintained without edits due to budget constraints. However, due to the potential confusion, we recommend noting as such on the title sheet of Appendix 2 during the current LCP. Response: Information in Appendix 2 supplements the LCP by providing planners and the public and introduction to the procedure that is required of an archaeological investigation. Due to time and budgetary constraints, the replacement of Appendix 2 was not included in the scope of work for this project. Also, adding a preamble to Appendix 2 that the information is outdated would introduce ambiguity to the certified LCP, and Appendix 2 does not include information that would conflict with the proposed amendments to archaeology. Filming Comment #21: Article 4, Section , Permitted Uses By Zone It is unclear if the Ventura County film permitting procedures apply to state-owned lands, but it is our understanding that productions completely within state land are not required to obtain a film permit from Ventura County. Can this be confirmed? California State Parks has our own film permitting system in coordination with the California Film Commission, and it would be an additional cost and time burden to add a third layer of permitting. Response: As noted in the response under comment [1], should State Parks wish to process its own permits, the Department of Parks and Recreation could submit a Long Range Development Plan (LRDP) to the Coastal Commission for review and approval in the same manner prescribed for LCPs (pursuant to Coastal Act Section 30605). Absent such a plan, Ventura County s LCP is the governing document. Comment #22: Article 4, Section (a), Permitted Uses By Zone We feel that student productions should not be exempt, and they should be held to the same standard as any other film activity. In fact, our experience has shown that student productions can have more logistical issues and potential impacts to resource protection, public access and public safety as they are still learning the process, and as such, we require the presence of state monitors on student productions. Response: When temporary film production activities require a Planned Development Permit (PDP) or neighborhood consent, then student filming would not be exempt from a permit. PDP and neighborhood consent is required in circumstances where potentially significant impacts to coastal resources could occur. However, in all other circumstances, student filming would be exempt from permits, as students do not have the financial means to pay for application fees, daily business license fee, or the $1 million insurance policy. To require students to be held to the same standard as commercial production companies would effectively preclude them from engaging in their field of study. Comment #23: Article 5, Section , Film Permits Required What is the fee schedule for film permits, and what is the minimum processing time for film permits issued via a Zoning Clearance or a Planned Development Permit? California State Parks would Page 8 of 30

10 also like to clarify whether the California Coastal Commission Permit Jurisdiction for lands where the public trust may exist includes state-owned lands, particularly our beach access. Response: Film permit application fees are listed in the Planning Division Fee Schedule located here: Minimum time to process a film permit is established by the proposed regulations. For example, CZO Section 5.6.2(b), Film Permit Application Procedures, states that a minimum of three (3) working days is required to process a Zoning Clearance for a film permit. If neighborhood consent is a prerequisite to permit approval, pursuant to Section (b), then a minimum of five (5) working days is required to process a film permit. A PDP can take up to three months to process, including County and Coastal Commission appeal periods (which combined take approximately one month). This does not include the required follow-up zoning clearance. To shorten the review and approval processing time, pursuant to Section , the public hearing for a Planned Development Permit may be waived. Additionally, if the application submittal is determined to be complete or requires minimal revisions to deem it complete, the processing time can be shortened. According to CZO Section 5.6.2(c), film production activities that require a PDP were judiciously selected pursuant to the Coastal Commission s Regulations of Temporary Events in the Coastal Zone (January 23, 1998), and Coastal Act Policy Environmentally Sensitive Habitats and adjacent developments. The Coastal Commission retains permit jurisdiction over any portion of a project that is in state waters, on land up to the mean high tide line, or lands subject to the public trust. If filming is proposed within these areas, a Commission permit is required. Determining if an area is within the Coastal Commission s or Ventura County s permit jurisdiction will depend on where the mean high tide line is located. Because the mean high tide line has moved landward over time, Ventura County s certified permit jurisdiction maps may not be accurate. Where there is ambiguity, the Coastal Commission can assist in determining permit jurisdiction. It is our understanding that State Parks lands are not subject to the public trust, but you may wish to consult with the Coastal Commission. Comment #24: Article 5, Section , Planned Development Film Permit What is considered adjacent to ESHA and how is the buffer area defined? California State Parks is concerned about the timeframe for processing Planned Development permits for filming on parklands, should that be a requirement under the proposed procedures, as much of our state-owned lands are designated as ESHA according to Ventura County mapping. For parking, California State Parks ensures that sufficient public parking, determined by seasonal visitor use, is available at all times while filming is proceeding; however, the language in the LCP suggests that the determination on the level of impact would lie with the Planning Division staff person who is not familiar with park operations, in determining if a full Planned Development permit is required. Response: In CZO Article II Definitions, buffer area is defined as the area within 100 feet of the boundary of any environmentally sensitive habitat area (ESHA). CZO Section Page 9 of 30

11 also states that, within a buffer area, no new principally permitted structures will be permitted unless the prohibition would preclude the utilization of the larger parcel for its designated use. When it is necessary to allow structures within the buffer area, they must be located as far from habitat resources as possible and mitigation measures are required to eliminate or reduce impacts to an insignificant level. Uses permitted within the buffer include but are not limited to nature study, habitat enhancement, and passive recreational uses CZO Section. Pursuant to CZO Section (a)(2), a Planned Development Permit is required if temporary film production activities directly or indirectly impact ESHA. Examples provided include the removal of major vegetation in order to construct a temporary film set or the introduction of loud and persistent noise or intense light that would harm animals with a low tolerance for these types of effects. In the Santa Monica Mountains, legally permitted developed areas, including improved roads, are adjacent to and within the ESHA buffer. Where there is no potential to impact ESHA, and filming is confined to developed areas, film permits could be issued with a ministerial permit (Zoning Clearance, see CZO Section ). In 1993, the Coastal Commission adopted the Regulation of Temporary Events in the Coastal Zone in order to address concerns related to the nature and frequency of temporary events, their impacts on coastal resources, nearby residential neighborhoods, and the public s ability to get to and utilize coastal recreational lands during such events. Of particular concern is temporary events scheduled during the peak summer months (Memorial Day through Labor Day). The proposed filming regulations would allow filming at the beach during weekdays in the peak summer months (see CZO Section ), provided that the permittee can verify that film production activities will not preclude public access or impact coastal access. Under such circumstances, film production permits could be processed with a Zoning Clearance. In Ventura County, there are underutilized parking areas that can provide offsite base camps. Depending on the size of the production, beach locations could be selected that would avoid conflicts with public parking and beach access during the peak summer months. Comment #25: Article 5, Section , Standards for Film Production Activities California State Park Guidelines allow for 24-hour filming in park locations that do not have impacts on nearby campgrounds or sensitive resources. If the Ventura County LCP regulations apply to state-owned lands, the specific hours provided for filming, and temporary night lighting (since most all California State Parks lands are considered to be ESHA by the County) are not consistent with our current guidelines and would need to be rectified. Response: Please see the response to Comment #1. Proposed standards for temporary film production activities includes the following: CZO Section (a): All film production activities shall occur between the hours of 7:00 a.m. and 10:00 p.m. on weekdays and between the hours of 8:00 a.m. and 8:00 p.m. on weekends. Film production activities that occur outside the hours require neighborhood consent pursuant to Section Page 10 of 30

12 CZO Section (c) Standards for Film Production Activities in all Zones, Noise and Lighting: Temporary exterior night lighting is prohibited in ESHA. Within areas adjacent to ESHA, temporary exterior night lighting may be allowed if the light source is hooded or shielded so that no direct beams from the film production activities fall upon ESHA. The County s proposed regulations are consistent with research on the effects of night lighting and the Coastal Commission LCP Update Guide, which states that artificial night lighting disrupts the normal breeding, foraging and migratory activities of seabirds and songbirds. Both were observed to fall prey to light entrapment, whereby they remain trapped within the zone of illumination and are unable or unwilling to return to the darkness until overcome with exhaustion or the lights are hidden by the dawn. Birds also become disoriented in the presence of bright lighting at night, suffering injury or death after colliding with lights or nearby structures. Parking Comment #26: Article 6, Section , Maintenance Ventura County should not have jurisdiction over the maintenance of California State Parks parking lots. Funding for parking lot surfacing, striping, and general repair is dictated by available state funds, and although we make our best efforts to keep facilities maintained for the visiting public, we cannot always comply with set timeframe notices to remedy a condition given constraints on budgets and purchasing authority. Response: The Planning Division is aware of the Department s budget constraints, and would work with the Department of Parks and Recreation should a conflict arise regarding compliance with the Coastal Act and CZO Section , Maintenance. Comment #27: Article 6, Section , Number of Parking Spaces Required California State Parks abides by statewide standards for parking spaces, including requirements for accessible parking. We believe our current facilities are consistent with the County standards listed for recreation uses. However, the 10% requirement for shortterm bicycle parking in parks and picnic grounds, given the design standards for developed bicycle parking requiring a certain number of racks, delineation and lighting (Section ), could be difficult to achieve in existing facilities under current budget constraints. Response: Bicycle standards have evolved and many require very little space to install and be accessible to bicyclists. CZO Section Bicycle Parking sets forth the required number of bicycle parking spaces, and CZO Section (g) gives the Planning Director the authority to approve other short-term bicycle parking designs. As a result, the proposed regulations provide flexibility and options that may be suitable for the Department of Parks and Recreation. If project location or proposed use precludes the installation of bicycle parking, then CZO Section gives the Planning Director the authority to waive the bicycle parking requirements. Page 11 of 30

13 The purpose of the County s proposed regulations is to improve multi-modal transportation options, consistent with Assembly Bill 32 (California Global Warming Solutions Act of 2006) and Senate Bill 375. The proposed regulations are also consistent with the County s existing General Plan (Policy , Public Facilities and Services, Transportation/Circulation) which requires that bicycle racks and lockers be provided for proposed discretionary development. Bicycle parking is also consistent with the purpose of most public parks. For example, the McGrath General Plan, Land Use Facilities Element, Planning Issues addresses the need for a permanent bicycle campground, and the Point Magu State Park General Plan notes the park was planned to support recreational opportunities including bicycling. Comment #28: Article 6, Section , Parking Space Marking In order to provide a natural feel to California State Parks recreation areas, concrete wheel stops are not always necessary or feasible, as sometimes natural rock is used to define parking areas, and some parking lots are comprised entirely of pervious surfaces. The requirement for installation of concrete wheel stops for each parking space should not be applicable to all recreational land use parking facilities. Response: Proposed CZO Section Exception gives the Planning Director the authority to waive space marking requirements on unimproved surfaces if the applicant can demonstrate they are not appropriate to the land use or location. Comment #25: Article 6, Section , Lighting Does the lighting requirement also apply to campgrounds? If so, this could dramatically change the natural character of existing California State Park camping areas. Response: During a permitting process, the Planning Division would work with the Department of State Parks to ensure that required lighting is appropriate to the setting and the needs of park visitors. The proposed regulations in CZO Section (e) requires that new light fixtures installed to serve above-ground, uncovered parking areas be full cut-off fixtures, recessed or flush-mounted and equipped with flat lenses. Signs Comment #30: Article 5, Section , Permit Requirements The draft language requires that California State Parks obtain permits for new sign installations, and changes and modifications to non-traffic signage, even if signs comply with Department of Parks and Recreation (DPR) signage guidelines and have already been approved as part of existing park General Plan or project that has undergone review under CEQA. California State Parks uses a variety of signs in the categories of recreation, hazard, land and park management, interpretive, regulatory, warning and construction. Those signs comply with the California State Parks Sign Handbook should be included as an exemption in Section as they promote safety and enjoyment of public coastal recreation and protect coastal resources. Page 12 of 30

14 Response: To promote greater efficiency when permitting signs, and as an alternative to project-by-project review (see Section (d)), the Department of Parks and Recreation could submit a Planned Development Permit (PDP) for review and approval of the Brand Standards Handbook as it relates to signs (i.e. a sign plan). Future changes to the handbook could be processed with a permit adjustment, depending on the degree of change. Absent an issued PDP for the Department s sign plan, a permit would be required that complies with the proposed sign regulations. Those regulations were reviewed by Coastal Commission staff to identify signs that qualify for an exemption. CZO Section Signs Exempt from a Permit limits exempt signs to a small sign affixed to a structure, consistent with California Code of Regulations (CCR and 13253). CZO Section also exempts repair and maintenance of a legally permitted sign from permit requirements. Except for prohibited signs, all other signs require either a ministerial (see Section , Zoning Clearance) or discretionary permit (see Section Planned Development). For the Department s Brand Standards Handbook to be exempt from permit requirements, all of the Department s signs would need to qualify as an exempt permit. Comment #31: Article 5, Section , Prohibited Signs, c The vast majority of parklands are considered ESHA by the Ventura County Planning Division. By limiting signage exceptions within ESHA to interpretive signs only, California State Parks is concerned that extensive permitting will be required for the placement of standard regulatory and park management signage which is intended to protect and preserve sensitive resource areas. All California State Parks signage installations undergo CEQA review to ensure avoidance of environmental impacts and compliance with internal guidelines. Accordingly all categories of signs on California State Parks lands that comply with DPR signage guidelines, including those proposed for areas designated by Ventura County as ESHA should be allowed. Response: Although the Department of Parks and Recreation may have complied with CEQA on a programmatic level, there is no mention of obtaining permits for signs installed in ESHA and no explanation of the degree of disturbance that occurred in areas designated ESHA. As previously note (see response to Comment #1), the Department of Parks and Recreation could submit a Long Range Development Plan (LRDP) to the Coastal Commission for review and approval in the same manner prescribed for LCPs (pursuant to Coastal Act Section 30605). Absent such a plan, Ventura County s LCP is the governing document. County-issued discretionary permits require evaluation pursuant to CEQA, and CEQA Section does grant an exemption from environmental review if minor alteration of land or vegetation results in the improvement of habitat. While the California Coastal Act requires that only development dependent on the resource be allowed in ESHA, the Commission did find that educational signage and kiosks qualify as resource dependent development. Comment #32: Article 5, Section , Sign Exempt from A Permit Include California State Park signage on state-owned parklands that complies with the California State Handbook guidelines and has undergone CEQA review, even when the signs are located within designated ESHA. Page 13 of 30

15 Response: Please see the response to Comment #1 and Comment #30. Comment #33: Article 5, Section , Zoning Clearance Sign Permit It appears that the LCP update would require California State Parks to obtain an over-the-counter Zoning Clearance Permit even for replacement in-kind of standard existing signs, which we periodically have to do as signs become faded or vandalized. California State Parks is concerned that this requirement would have negative time and cost impacts on the operations of our public-serving facilities. Response: CZO Section (d) would exempt the repair and maintenance of an existing, permitted sign from further permit requirements, provided that the proposed repair and maintenance activities do not result in an addition to or enlargement of the existing sign. Such repair and maintenance activities also must not result in any disturbance to ESHA or ESHA buffer. Additionally, Section would allow a noncommercial message of any type to be substituted, in whole or in part, for any commercial message or any other noncommercial message, provided that the sign, including the sign structure and mounting device, is consistent with the standards of this Article and its permitting requirements. Such substitution of message can occur without additional permits. Comment #34: Article 5, Section , Planned Development Sign Permit Many of the signs described that require a full Planned Development permit are the type and location that California State Parks regularly manages, including signage within 300 feet of the mean high tide line, within 100 feet of streams and scenic resources, interpretive signs, and new free-standing signs. Again, California State Parks is concerned that this requirement would have negative time and cost impacts on the operations of our public-serving facilities and assert that all categories of signs on California State Parks lands that comply with DPR signage guidelines, including those proposed for areas designated by Ventura County as ESHA, should be exempted from the permit requirements under Section Response: Please see the response to Comment #1 and Comment #30. Comment #35: Article 5, Section , Numbering and Dimension of Signs California State Park has existing statewide guidelines that we must follow, which may not necessarily match sign size and location requirements described in the LCP Update; therefore all categories of signs on California State Parks lands that comply with DPR signage guidelines shall be allowed. Response: Please see the response to Comment #1 and Comment #30. Comment #36: Article 5, Section , Maintenance Ventura County should not have jurisdiction over the maintenance of California State Park signs. Funding for sign replacement and repair is dictated by available state funds, and although we make our best efforts to keep signage maintained for the visiting public, we cannot always Page 14 of 30

16 comply with a 30-day notice to remedy a condition given constraints on budgets and purchasing authority. Response: Please see prior responses to comments regarding sign maintenance and repair. Also, please see proposed Section Maintenance, which states that the Planning Director may require any improperly maintained sign, temporary or permanent, to be repaired or removed. The Planning Department would work with the Department of Parks and Recreation should a conflict arise regarding compliance with the Coastal Act and CZO Section , Maintenance. Comment #37: Article 5, Section , Interpretive Signs California State Parks embarks on extensive internal review of interpretive signs and do not believe that we should be required to have additional reviews by the County Cultural Heritage Board for signage at historic sites, the State Preservation Officer (which is a unit of DPR) for cultural sites, and the U.S. Fish and Wildlife Service for ESHA. Additionally, there may be some instances where California State Parks interpretive signage may require temporary illumination, such as at a campfire center, but as written, the LCP update prohibits this without exception. Response: Within CZO Section Types of Interpretive Signs, the word shall was replaced by should when referring to formal reviews by an independent agency. This change in language provides greater flexibility when applying standards to interpretive signs. Also, as previously noted, interpretive signs may be placed within ESHA. However, the County s proposed standards for signs in ESHA are consistent with Coastal Act Section 30240, which states that such areas shall be protected against any significant disruption of habitat values. Consistent with that requirement, CZO Section Illuminated Signs, prohibits illuminated, free standing interpretive signs. A free standing sign would require undergrounding of electricity and introduction of an artificial light source in an area that is considered vulnerable to degradation by human activity and disturbance. However, illumination of interpretive kiosks affixed to a building would be allowed. Your letter mentions temporary illumination, which we assumed meant portable lights or light emanating from a camp fire. Comment #38: Article 5, Section , Nonconforming Signs Many California State Parks signs have been in place for many years or were installed as small projects not previously subject to coastal development permits, and would be considered nonconforming. The amended LCP would require California State Parks to obtain a Zoning Clearance Permit for repair of non-conforming signs (see also Section above), which would have negative time and cost impacts on the operations of our public-serving facilities. We are also concerned about the amortization period given for bringing signs into conformity, especially in light of our previous comments regarding conflicts between internal statewide sign guidelines and County requirements, and budget concerns. Response: CZO Section (b)(1) Legal Nonconforming Signs allows for routine maintenance of non-conforming signs provided the proposed repair and Page 15 of 30

17 maintenance activities do not result in an addition to or enlargement of the existing sign. CZO Section clarifies legal non-conforming signs and allowing legal nonconforming signs to remain until its value has been recovered. COMMENT LETTER Anna Shepherd, AICP Community Plans and Liaison Officer Naval Base Ventura County dated July 10, 2014 Archaeological and Paleontological Resources Comment #1: Remove the Register of Professional Archaeologists requirement and use the professional qualifications, modeled after the Secretary of the Interior's Standards and Guidelines. There are many qualified archaeologists who are not members of the RPA, and many members of the RPA who are not qualified archaeologists. Response: In response to this comment, the definition of Archaeologist, Qualified Consultant has been revised to be consistent with the Ventura County Initial Study Assessment Guidelines and reference to a Registered Professional Archaeologist omitted. Comment #2: Change the definition of archaeological resource. There are historic-era archaeological sites in the coastal zone that have little or nothing to do with Native Americans. Model definition after 43 CFR 7. Consistency is important. Response: In response to this comment, and in order to establish a more informative timeline of California history, the definition of Archaeological Resource was amended to include maritime history and historical events up to and including United States statehood. CZO Section Archaeological Resources Determined to be Historic Resources was also added to ensure historical resources are considered when evaluating the significance or archaeological resources. Parking and Loading Comment #3: Under purpose, please add a goal for parking to be compatible with surrounding and adjacent land uses. As you know, we have a significant amount of parking next to our fence line that is incompatible with our security posture. We hope that future parking adjacent to Naval Base Ventura County will be planned and regulated to be as compatible with our property and land use. Response: In response to this comment, Section Purpose, Compatibility with Adjacent Uses, was updated to include the following statement: Ensure that new or modified parking areas within residential areas are compatible with adjacent military base requirements and uses. This comment reflects previous information from Naval Base Ventura County (NBVC), including recommendations in the recently completed Joint Land Use Study (JLUS), that Panama Drive and Island View Avenue are adjacent to the NBVC security fence. The Planning Division was advised that this parking poses a potential security threat should people use the high portions of their vehicles to scale the fence and trespass onto NBVC. Currently, the fence line for the military installation along Panama Drive is not located along the property line. Instead the fence is set back by approximately five feet, and private vehicles use this area to park their vehicles. Unless Page 16 of 30

18 the Naval Base opts to build a second security fence inside its current perimeter fence, resolving this problem would require a comprehensive review of parking and traffic options on Panama Drive, a task that is outside the scope-of-work for this project. The primary Coastal Act issues associated with parking along Panama Drive and Island View Avenue is the availability of coastal access parking. When coastal development permit applications include the loss of public parking spaces, the Commission requires replacement parking to offset the loss. Comment #4: Under off-site parking for non-residential uses, please include a condition that would also apply to the waiver that off-site parking would not negatively impact neighboring land uses. Response: In response to this comment, Section Purpose, Compatibility with Adjacent Uses, was added to promote compatibility between parking facilities and adjacent land uses. COMMENT LETTER Amy Lemisch, Director Eve Honthaner, Deputy Director California Film Commission dated April 30, 2014 Film Production, Temporary Comment #1: We would like to confirm that if a film activity is to be staged entirely on state property that a county permit is not required, nor is permission from the Coastal Commission. And if that is the case, we would like to request verification of such in writing. Response: Currently, film permits within our coastal zone are either issued by the California Coastal Commission or by a Ventura County agency with a Commissioncertified local coastal program. The California Coastal Commission retains original permit jurisdiction over certain specified lands (such as tidelands and public trust lands). Our understanding is that Ventura County, not the Coastal Commission, is responsible for film permits in State parks that are located within the County s coastal zone. However, pursuant to Public Resource Code 30605, the Department of Parks and Recreation could issue film permits if they obtain a Long Range Development Plan (LRDP) certified by the Coastal Commission. However, the Department of Parks and Recreation has not provided evidence of such a plan, and in its absence Ventura County s LCP is the governing document. Comment #2: We find that this document is complicated and difficult to understand. We suggest that it be rewritten in a way that would make it easier for the general public to comprehend. Response: In response to this comment, the Film Ordinance was revised to be more reader friendly and easier to understand. Page 17 of 30

19 Comment #3: Could you please explain (again) when a Planned Development Permit would be required I see no indication as to how much time is required for the approval of a Planned Development Permit. Response: The Permitted Use matrix in Article 4 provides an easy-to-use system for determining when a Planned Development Permit (PDP) is required. In addition, CZO Section includes a list of circumstances when a PDP is required. Most film permits in the County are ministerial permit (Zoning Clearance). However, a PDP would be required for the following types of temporary film productions: (a) the production will last longer than 14 days, (b) there may be direct or indirect impacts to ESHA, (c) grading or landform alteration is proposed, (d) the production would restrict public use of coastal roadways or public access to designated recreation areas, and (e) the production would result in inadequate coastal access parking (this is an issue for beach filming during summer peak periods). Comment #4: Another concern would be that as per Sec Film Permit Application Procedures (c) a film permit that requires a Planned Development may be appealed. As most film, TV and commercial productions work on tight schedules (and budgets) and do not have an unlimited amount of pre-production time; it would be difficult to schedule a shoot without a fair amount of certainty that a desired location would be available. It would therefore be important to know how long it would take for a Planned Development Permit to be processed, assuming all requirements are promptly submitted and allowing for any possible appeal. An overly lengthy process would likely discourage most productions from applying. Response: In order to support the film industry within Venture County, the Planning Division attempted to provide a well-defined path for film permits that can be issued with a Zoning Clearance, which is a shorter and less expensive process than a Planned Development Permit (PDP). A PDP is a discretionary permit that, by definition, requires the exercise of judgment or deliberation by a public agency. It is a lengthy process, one that production companies would need to plan for well in advance if their temporary film production activities meet the criteria set forth in CZO Section Planned Development Film Permit. Within the proposed Film Ordinance, the PDP requirement is linked to circumstances when the film production could result in potentially significant impacts to coastal resources or coastal access. Film production companies can avoid the need for a PDP by avoiding specific locations or time periods that trigger a PDP requirement. Comment #5: (Reference cited): Sec Film Permits Required, Film Permit, (a) A film permit is required for all film production activities, unless exempt from film permit requirements pursuant to Sec Exempt generally refers to non-commercial work, student films, personal/family films or breaking news. Can you tell us what the cost is for these permits and what the turnaround time would be? Response. There is no permit requirement or fees for film production activities that are listed as exempt from permits. Page 18 of 30

20 Comment #6: (Reference cited): Sec Film Permits Required, Film Permit, (b) A Planned Development Permit shall be required for film production activities that are otherwise exempt from a film permit or authorized with a Zoning Clearance pursuant to Section if the Planning Division determines that the film production activities or access to the site will either directly or indirectly impact coastal resources or will be located within or adjacent to an environmentally sensitive habitat area (ESHA) or buffer area. Does this mean that all or most film permits would require a Planned Development Permit? And what about the state beaches that are in ESHA zones are they exempt as long as the production is contained to state property? Response: The requirement cited above does not mean that all or most film permits would require a Planned Development Permit (PDP), as many types of film productions and film locations would only require a Zoning Clearance. Please see responses above under Comments 1, 3 and 5 for additional information on the PDP requirement, filming on State Parks land, and filming in ESHA. As explained previously, filming within ESHA could result in potentially significant impacts to coastal resources, and the PDP requirement is necessary to ensure that impacts to ESHA are either avoided or mitigated. The proposed regulations cite specific areas where a film production crew would need to avoid ESHA. For example, CZO Section Temporary Filming on the Sandy Beach, states that film production activities must be located at least 100 feet from tide pools and sand dunes. There are numerous beach locations in Ventura County where film productions could occur that meet these requirements. Comment #7: (Reference cited): (b) Following the approval of a Planned Development Permit, the applicant shall obtain a Zoning Clearance pursuant to Section [Staff Explanation: PRC 30610(i)(1) states that any proposed development which the executive director finds to be a temporary event which does not have a significant adverse impact upon coastal resources is exempt from a coastal development permit. Filming is considered a Temporary Event pursuant to the California Coastal Commission s Regulation of Temporary Events in the Coastal Zone (dated January 23, 1998). Rather than exempt filming activities, zoning clearance will be required to insure some level of review is provided. Will every permit issued in the Ventura Coastal zone have to be reviewed for zoning clearance? Response: Please see the response to Comment #5. As shown in Article 4 Permitted Uses, permit requirements include a range of three options: (a) activities exempt from permits, (b) activities that require a Zoning Clearance, and (c) activities that require a Planned Development Permit (PDP). Permit requirements are further defined by CZO Section Film production activities that are not exempt, and would not result in potentially substantial adverse impacts to coastal access or coastal resources, may be processed with a Zoning Clearance in accordance with Section However, if a PDP is required, then a Zoning Clearance is issued (see CZO Section ) prior to the initiation of the film production authorized by PDP. This is a standard step for all discretionary permits issued by the Planning Division (coastal, non-coastal). The purpose Page 19 of 30

21 is this type of Zoning Clearance, which is issued over-the-counter, is to confirm that the conditions of approval included in the discretionary permit were satisfied. Comment #8: (CZO section cited): Sec Film Permit For Sandy Beach Areas. The following types of permits shall be required for film production activities that occupy all or a portion of a sandy beach area as follows: a. Zoning Clearance Film production activities that meet all of the following criteria and are otherwise authorized with a Zoning Clearance pursuant to Section above: 1. Occur outside the period between Memorial Day weekend through Labor Day weekend; or 2. Occur between Memorial Day weekend and Labor Day weekend but meet all of the following criteria: (a) are located in a remote location with minimal demand for public use, (b) will not result in adverse effects on tributaries that discharge to the ocean, tide pools and sand dunes, (c) will not be located within or adjacent to an environmentally sensitive habitat area (ESHA) or buffer area, (d) maintain public access to and along the coast, and (e) last for less than one day in duration. To limit productions to no more than a one-day shoot would greatly discourage production in these areas. Response: In response to this comment, Section Zoning Clearance (Film Permit) was revised to allow filming on the sandy beach for up to 14 days, provided that the applicant can demonstrate that no impacts would occur to coastal access or coastal resources (criteria are established that address these issues so that a Zoning Clearance process can be used). Comment #9: (CZO section cited): b. Planned Development Permit Film production activities that meet all of the following criteria: 1. Are held between Memorial Day weekend and Labor Day, unless the activities meet the criteria stated in subpart (a)(2) above in which case a Zoning Clearance shall apply; and 2. Would restrict public use of roadways or parking areas or otherwise significantly impact public use or access to coastal waters; and Our state Parks Angeles District has always allowed productions parking lot use (3/4 in off-season and ½ in peak season). Response: Please see the response to Comment #1, which addresses permits issues within areas managed by the State s Department of Parks and Recreation. As was previously noted, the proposed regulations are designed to allow film productions with a Zoning Clearance, provided that such activities would not result in potentially significant impacts to coastal resources or coastal access. With respect to film productions on parking lots with a State Park, the applicant would need to demonstrate activities are limited to the parking lot (i.e. would not impact ESHA). Also, the applicant would need to Page 20 of 30

22 demonstrate that film production would not affect coastal access, which will depend on the size of the parking lot and parking demand. For example, if a particular state park has a large lot that is not in demand at that time of year, then it is likely that a film permit could be issued. However, if the state park is a popular destination, parking is limited, and it s the summer peak period, then it s likely that a permit cannot be issued. Comment #10: (CZO Section cited): Sec Film Permit Application Procedures. a. The film permit application shall be filed with Ventura County Planning Division in accordance with Section and signed by the applicant or authorized agent thereof. b. Zoning Clearance - A minimum of three (3) working days is required to process a Zoning Clearance for a film permit. If neighborhood consent is a prerequisite to permit approval, pursuant to Section , a minimum of five (5) working days is required to process a film permit. c. Planned Development Permit - Planned Development Permits shall be processed pursuant to Section , Section and Section The public hearing for a Planned Development Permit may be waived pursuant to Section A film permit that requires a Planned Development may be appealed pursuant to Section Can you tell us what the cost is? And how would this work in conjunction with the regular processing of permits? [10] Response: The film permit fee schedule is available on the County s website: ( and is adjusted over time to reflect fee increases that are adopted by the Board of Supervisors. Currently, the costs are as follows: Zoning Clearance: $ Planned Development Permit (PDP): The deposit is $2,000.00, but total costs for a PDP may exceed this amount. A PDP is more expensive because it can take up to three months to process. To shorten the review and approval processing time, the public hearing may be waived. Additionally, if the application submittal is determined to be complete or requires minimal revisions to deem it complete, the processing time can be shortened. Comment #11: CZO section cited: Sec Standards for Film Production Activities - Hours: 1. All film production activities shall occur between the hours of 7:00 a.m. and 9:00 p.m. on weekdays and between the hours of 8:00 a.m. and 8:00 p.m. on weekends. 1 A Zoning Clearance Film Permit Fee is broken down as follows: Application Fee: $300.00, First Location: $225, Business License: $151.00, Fire Department Review Fee: $ (w/ neighborhood consent add $355.00) Page 21 of 30

23 Please note that many cities allow filming activities between the hours of 7:00 a.m. and 10 p.m. during the week and longer hours on weekends with the approval of neighboring residents. Response: In response to this comment, the time restrictions for weekdays were revised to be consistent with the film permit time restrictions in the non-coastal areas, which is 7:00 am to 10:00 pm. However, weekend restrictions were retained at 8:00 am to 8:00 p.m., which provides greater relief for neighboring residents and businesses. Please note that the Board of Supervisors has the discretion to change the time frames as proposed. Also note that, because the County is primarily rural, noise levels are typically less than within urban areas and, as a result, film production activities that occur early in the morning or late evening may be more disruptive. Also, there is limited artificial light in rural areas, which makes film production more difficult during late evening periods. Comment#12: Film production activities that occur outside the hours identified in (1) above require neighborhood consent. What is the radius from the production activity that would require consents from residents, and what is the percentage of consents required? Response: The neighborhood consent radius varies depending on where the film permit areas are located. In urbanized areas (Coastal Commercial (CC), Coastal Rural Exclusive (CRE), Residential Beach (RB), Residential Beach Harbor (RBH), and Coastal Residential Planned Development (CRPD)), property owners and residents within a 300 foot radius must be contacted. In rural areas (Coastal Agricultural (CA), Coastal Open Space (COS), Coastal Rural (CR), and the Santa Monica Mountains (M) Overlay), property owners and residents within a 1,000 foot radius must be contacted. The difference in radius is designed to ensure that an adequate sample of affected property owners and residents are notified of the proposed temporary film production activities. Comment #13: (Cited regulation): Noise and Lighting. Noise and lighting shall not create a nuisance upon nor otherwise negatively impact neighboring uses including but not limited to environmentally sensitive habitat areas. While the CFC clearly understands the desire for filming to have as little impact on the surrounding area as possible, the nature of a film/tv/commercial shoot is that it can sometimes be intrusive, even though the impact may be minimal and all good faith efforts are made to mitigate the effects of the filming activities. And as it would be nearly impossible to guarantee that noise and lighting shall not create a nuisance, the CFC always recommends a mitigation of disruption within the affected area. Response: With film productions, the primary noise concern is generators and their location. Although that issue could be addressed by requesting an acoustical analysis for generators, such requests would add another application requirement and cost to the film permit, which in turn would discourage film production companies from filming in Ventura County. As such, the proposed film ordinance addresses noise through CZO Section (d)(1), which requires the applicant to graphically depict the location(s) of the generator(s) on a site plan. This allows the County Film Permit Coordinator to determine if noise attenuating devices need to be incorporated because of the generator s proximity Page 22 of 30

24 to noise sensitive land uses which include dwellings, schools, hospitals, nursing homes, churches and libraries. CZO Section (c) was also added to prohibit film pyrotechnics and special effects that emit sound associated with gunfire or similar device when filming is adjacent to ESHA because such noises can have significant impacts on animal animals and birds. COMMENT LETTER Bryan Harre Silverstrand Beach property owner Verbal comment #1A was made at the public outreach meeting held on March 26, / Written comments #1 through #6 were submitted to the Planning Division on April 1, 2014 Comment #1A (Verbal). Film permits do not distinguish between Hollywood type productions and the Porn Film Industry. I have seen what the porn industry brings to town, and it is undesirable to say the least. My neighbor had to explain to her 3 year old daughter who was being woken up by the filming each time at night that the lady she heard screaming was ok. We had all the film party attendees knocking on our door asking where the party was. Response: Converting a home into a porn film studio (or party business) would constitute a violation of the proposed zoning regulations and subject the film production company to the enforcement and penalty provisions defined by CZO Article 13 Enforcement and Penalties. The proposed regulations fall under the title Film Production, Temporary, and only cover film production activities, as defined by CZO Article 2, Definitions, Film Productions Activities. However, that definition specifically excludes permanent film studios in the coastal zone, and the type of activity addressed by this comment would constitute a permanent film studio. Also, on May 7, 2013, the Ventura County Board of Supervisors adopted Ordinance 4452, which requires the use of condoms in adult film shoots. Makers of adult films must obtain a permit from the Public Health Department and post a copy of the permit and the ordinance at the production site. And finally, temporary film production can only occur in the Residential Beach (RB) or Residential Beach Harbor (RBH) zones when the production company obtains Neighborhood Consent (see CZO Section ), which requires that at least 50% of residents in the surrounding area sign the consent form. The neighborhood consent informs the residents of potential impacts that could occur, such as loud sound effects, night lighting, etc. The County cannot regulate temporary film production activities based solely on the subject matter of the filming. Comment #1 (Written). Some important things to remember about our experience and concern: 1) Porn film industry cuts corners to make a profit, resulting in a fire hazard: a. Non-permitted and substandard wiring b. Cutting holes to exterior for non-permitted AC units, etc. c. Homes are very close together, any fire can spread quickly to other homes, and this represents an unacceptable hazard. Page 23 of 30

25 Response: Please see response to Verbal Comment #1A above. With respect to comments about fire hazards, please note that such problems occur outside the film industry, and the County does provide a process whereby residents can address such issues. For example, if it appears that illegal construction is taking place, an individual can file a formal complaint that would be investigated. Permitting requirements for construction activities within the coastal zone are governed by the Ventura County Building Code, and various development standards (setbacks, building heights, etc.) for Silverstrand are defined by the Coastal Zoning Ordinance (CZO, see Residential Beach Harbor (RBH) zone). Comment #2: Streets are narrow and film permits would result in increased traffic on narrow streets, which is a hazard to our communities kids a. Film trucks would be parking on streets b. Porn film party attendees park all over the place. c. Silverstrand already has limited parking, the film crews would take up parking spaces. d. Who is liable when fire trucks and ambulances cannot get down a street in a timely manner, the homeowner, the film company, or the county? Response: As previously noted, temporary film production could only occur in Silverstrand when the production company obtains Neighborhood Consent (see CZO Section ), which requires that at least 50% of residents in the surrounding area sign the consent form. As part of that process, local residents would be informed about proposed film activities such as loud sound effects, night lighting, etc. Banning film production entirely, however, was not deemed necessary or desirable because it would also ban very small-scale film productions and still photography that may be compatible with the neighborhood. During the summer peak periods, filming within beach communities would either be prohibited (weekends, holiday) or restricted (weekdays). Typically, public safety issues are addressed during the permitting process, and any film production that includes a road closure that exceeds 3 minutes would have to obtain an encroachment permit from the County s Public Works Agency (PWA) Transportation Department. Typically, such permits are not issued for road closures scheduled during morning and evening peak hours or other times when the closure would cause excessive disruption. Also, road closure permits are difficult to obtain for the following reasons: At least 67% of the affected property owners and occupants eligible to vote must agree to the proposed closure within a four-block radius of the closure; If the road closure could affect emergency service, the applicant would need to hire an Ambulance and/or Fire Engine to be stationed beyond the closure and be available for emergency response; The applicant may need to arrange and pay for traffic control by the California Highway Patrol at locations identified by PWA Transportation Department staff. If the Encroachment Permit includes temporary parking for film trucks, the permittee must post temporary No Parking signs a minimum of 24 hours in advance to inform area residents. Page 24 of 30

26 Written approval of a road closure must be obtained from the Fire Prevention Bureau of the County Fire Department and the Sheriff s Patrol Area representative. These requirements are designed to protect the safety of local residents. Comment #3: Porn film industry brings in crime: a. High rate of drug and alcohol abuse issues; b. Prostitution Response: Please see the response to Verbal Comment #1A above. Note, prostitution is handled by the County Sheriff s Department pursuant to Ventura County Municipal Code, Division 6, Article 3, Sections 6134 and Comment #4: Porn filming parties: a. Attendees paid a door fee to watch or participate in the film, b. Parties occurred every two weeks with over 50 attendees each time [4] Response: Please see the response to Verbal Comment #1A. Note such activities described above are handled by the County Sheriff Department. Ventura County Municipal Code Section which addresses loud or raucous noise. Comment #5: (2) Area is residential, let s keep it residential and not a business. (a) I can t turn my house into a gas station, why should someone be allowed to turn their homes into a porn film party business making money off of porn actors and their attendees. Response: Please see the response to Verbal Comment #1A. Note, converting a home into a porn film studio (or party business) would constitute a violation of the proposed zoning regulations and subject the film production company to the enforcement and penalty provisions defined by CZO Article 13 Enforcement and Penalties. Comment #6: 3% of the County doesn t allow filming already for safety and community concerns, let s keep it that way. Our streets are too narrow and the hazards to a high in a congested area. If you want to film go to the other 97% of the County that is more conducive to filming. Response: In response to this comment (and to other comments raised by property owners and residents in the Hollywood and Silverstrand beach communities), the draft film regulations were modified to address safety and neighborhood compatibility concerns within the County s more densely populated neighborhoods, which are zoned Residential Beach (RB) and Residential Beach Harbor (RBH). CZO Section , Neighborhood Consent, was added to require that film productions in areas zoned RB or RBH obtain Neighborhood Consent, which means that at least 50% of the households in the surrounding community must sign the consent form prior to the issuance of a permit. This provision is intended to ensure the safety of the community and to minimize the temporary inconvenience that is inherent with temporary film production activities. Page 25 of 30

27 COMMENT LETTER Patrick O. Maxon M.A., RPA BonTerra Psomas dated March 18, 2014 CAP Final Draft - Archeological and Paleontological Resources Comment #1: CAP. With respect to A. Archaeological Resources Policy 3 (page 3) and CAP Policy 6 (page 6), it should be made more clear as to what is intended, and should include communication/consultation with the Native American Heritage Commission (NAHC) to request a Sacred Lands File search and provide a list of local Native Americans who might have additional knowledge of resources and history not recorded in the CHRIS. Names on the list should be contact for information. Response: The proposed regulations include policies in the CAP and related implementation measures in the CZO. Please see CAP Policy 5, which does require that Native American tribal groups, approved by the Native American Heritage Commission, be consulted when proposed development has the potential to adversely impact archeological resources. In response to this comment, CZO Section (a)(2) Phase I Inventory was amended to add a requirement to conduct a Sacred Lands File Search. However, the ordinance does not cite or endorse specific Native American representatives, as that type of listing would not be located within an ordinance. However, the reference to the Native American Heritage Commission is located in the ordinance, and that reference provides a starting point to find local representatives. Comment #2: Regarding CAP Policy 2, an RPA is typically not required for an archaeologist to conduct records searches in CHRIS or to prepare reports. Secretary of the Interior Standards usually suffice. Not sure you want to make RPA a requirement since some very qualified archaeologists do not join RPA on principal. Response: In response to this comment, the definition of Archaeologist, Qualified Consultant was revised to be consistent with the Ventura County Initial Study Assessment Guidelines and the reference to a Registered Professional Archaeologist was deleted. Comment #3: B. Paleontology. Although rock formations do not change, perhaps a more recent citation than the personal communication in 1980 would be appropriate here. Is Bruce Welton even still at the NHMLAC? He may be at the New Mexico Museum of Natural History. Response: In response to this comment, the introductory text (called an abstract) under B. Paleontology, was revised to include information obtained from a telephone conversation and correspondence with Dr. Bruce Lander, co-author of Paleontological Resource Assessment Overview, Southern Ventura County (July 1988). In 2014, Dr. Welton was working at the New Mexico Museum of Natural History. Page 26 of 30

28 Comment #4: For Policy 1 (page 11), the intent should be made more clear and should include a paleontological records search at the appropriate museum (NHMLAC or other) to determine rock formations present and any recorded fossil localities. Response: The issue cited above is already addressed with the proposed LCP amendments. Policy 1 requires that discretionary development be evaluated for potential impacts to paleontological resources. That policy will be implemented through CZO Section (b)(2), Methodology, which states the requirement for a records search at the appropriate museum. CZO Final Draft - Archeological and Paleontological Resources Comment #5: Article 2: Definitions. Archaeological resources are not only those resources that predate the 19th century. That is an arbitrary cut-off. Independent Native American groups survived well into the 19th century. Archaeological resources can also be present but retain no significance. In addition, archaeological resources can be as recent as 50 years old and include house foundations, trash pits, privies, etc. Response: In response to this comment, and to establish a more informative timeline of California history, the definition of Archaeological Resource was amended to include maritime history and historical events up to and including United States statehood. In addition, CZO Section Archaeological Resources Determined to be Historic Resources was added to ensure historical resources are considered when evaluating the significance of archaeological resources. Comment #6: Section Methodology. c. Phase I studies are typically only the identification phase, where the presence of resources is confirmed or refuted. The Phase I study may identify archaeological sites that require Phase II testing (prior to mitigation). Response: In response to this comment, CZO Section Phase I Archaeological Survey was retitled to Phase I Inventory, which is the phase in which the presence or absence (but not necessarily the significance) of the resource is determined. CZO Section , requires a Phase II Evaluation when required by the results of the Phase I Inventory report. Comment #7: f. and g.: Any substantial subsurface work in the Coastal Zone (including most test excavations) requires the development of an Archaeological Research Plan (ARP) as part of the Coastal Development Permit. The ARP must be approved prior to subsurface disturbance and includes peer review by three qualified archaeologists. Response: An ARP is a specific request from the Coastal Commission for areas within their permit jurisdiction. The requested reference to ARP was not incorporated into the draft regulations, as this is a specific term used by the Coastal Commission. Page 27 of 30

29 Comment #8: Section Monitoring. NAHC does not keep a list of qualified archaeological monitors as far as I am aware. They may keep lists of qualified Native American monitors, but I'm doubtful of that. Response: In response to this comment, CZO Section Monitoring was corrected to include a qualified archaeologist or Native American Monitor if the resource is of Native American/Chumash descent. COMMENT LETTER Robin Turner ArcheoPaleo Resource Management, Inc. dated March 21, 2014 Comment #1: 1) All artifacts and fossils are significant since they are non-renewable resources and are no longer made and/or tell us about the local past. Not only are they of scientific significance, but in the Native American view, they tell stories about the ancestors. That makes them significant. As for fossils, they all are significant. On every job site, we find new species of fossils when monitoring is mandated by the lead agency. Response: In response to this comment, the definition of Archaeological Resource was revised and the reference to important archaeological resources was deleted. This change is also consistent with Coastal Commission policy, which considers all archaeological resources to be important/significant. In response to this comment, and in consultation with Brian Baca, Certified Engineering Geologist (CEG) 4571, Section Methodology, Table 1, was revised and the level of importance was elevated for the following geologic formations: Paralic deposits, and the Saugus, Sisquoc, and Casitas Formations. By elevating the importance of these geologic formations, further investigation of the paleontological resources will be required. Unconsolidated materials such as active wash had a low or no paleontological importance given that the material has eroded. Comment #2: Regarding paleontology, all agencies need to understand the difference between bedrock and alluvium and the fact that geologists consider alluvium as overburden or fill. There is a definitive difference between construction or engineered fill and alluvium (geologic fill). Make sure the planners understand this fact. Response: In response to this comment, Article 2, Definitions was amended to add alluvium and artificial fill. Comment #3: Many planners make the mistake in writing in an EIR or other document that if the contractor sees artifacts or fossils they are to stop work and call/hire an archaeologist or paleontologist to assess the situation for significance. Contractors or developers should not ever make this decision. They are not trained in nor care about saving nonrenewable resources. 90% of all of the fossils or artifacts, sites, features that Page 28 of 30

30 we find in the field is because we were already monitoring the project. All Ventura County projects should require construction monitoring. Response: The proposed regulations do require construction monitoring by a qualified professional when construction could result in potential impacts to paleontological resources. For example, CZO Section describes a detailed methodology for evaluating the potential for paleontological resources. However, if the result of this preliminary assessment is that paleontological resources may be buried at a depth beneath alluvium or artificial fill that will not be disturbed by earth-moving activities, and the qualified paleontologist or registered Engineering Geologist recommends that monitoring is not necessary, then there is no reason (or legal nexus) to require construction monitoring. The standard condition, which requires that the contractor contact the Planning Department if resources are encountered during earth disturbing activities, will be retained only as an additional precaution for protecting archaeological and paleontological resources. COMMENT LETTER Bruce Lander, Ph.D. and M.A. Paleontology B.S. Geology dated March 28, 2014 Comment #1: My only concern is that many units with well-documented fossil records are considered to be of low or no paleontologic importance. However, many quaternary units, even those regarded as Holocene in age, have been demonstrated to be highly productive elsewhere, especially at comparatively shallow depths, where many such units are of Pleistocene age. Comment #2: Until better known, the potential fossil productivity of most Quaternary units should be evaluated for each project, based on grain size (coarse-grained units usually less productive, but I ve found a mammoth tooth in a stream cobble gravel deposit), fossil record from the surrounding region, and proposed depth of earthwork. Comment #3: Perhaps the paleontologic importance of those units determined to be of no or only low or even moderate importance should be reevaluated by a paleontologist with local experience, much as I did for the southern half of the County in Combined Response: In response to these comments, the formations table (which shows paleontological importance) was modified to elevate Paralic deposits for the Holocene and Pleistocene epochs; and the Saugus, Sisquoc, and Casitas Formations; to a level of moderate importance. This modification will ensure that additional evaluation is conducted for these formations. Background information: The geologic formations map of the coastal zone was prepared in consultation with the County Geologist, Jim O Tousa, a Certified Engineering Geologist (CEG) 1393, and Brian Baca CEG Formation names were identified using Dibblee Page 29 of 30

31 Geologic Foundation Quadrangle Maps. CZO Section Methodology Table 1, provides a list of geologic formations and the ranking of paleontological importance, and the map and table will be used together to determine if a proposed project has the potential to uncover important paleontological resources. CZO Section Methodology also requires the preliminary assessment to be conducted by a qualified paleontological consultant or registered geologist. The assessment must include a literature and archival reviews at the appropriate museum (Natural History Museum of Los Angeles County or other curating facility), consultations with geologists and paleontologists knowledgeable about the paleontological potential of rock units present in the vicinity of the proposed project, and a field survey of the areas where earth-moving activities such as grading, trenching, drilling, tunneling, and boring are proposed. Page 30 of 30

32 State of California Natural Resources Agency DEPARTMENT OF PARKS AND RECREATION Angeles District 1925 Las Virgenes Road Calabasas, CA Edmund G. Brown Jr., Governor Major General Anthony L. Jackson, USMC (Rot), Director May 13, 2014 Jennifer M. Welch County of Ventura Resource Management Agency Planning Division 800 South Victoria Avenue Ventura, CA RE: Ventura County Local Coastal Program Update Dear Ms. Welch: California Departnt of arks and Recreation (California State Parks) has reviewed the draft sections of"ventura County Local Coastal Program (LCP) update which were posted in March These sections cover archaeological and paleontological resources, filming, parking, and signs. We thank you for the opportunity to review these portions of the LCP Update and provide the following comments. California State Parks operates several parks within coastal areas subject to the Ventura County LOP, including the County Line portion of Leo Carrillo State Park, Point Mugu State Park, portions of Emma Wood State Beach, and the Rincon subunit of Carpinteria State Beach. All together, these parks encompass nearly nine miles of coastline and over 7,000 acres of open space within the coastal zone, providing quality recreation for the public, including 214 family campsites and six group camps, and the protection and interpretation of the parks' natural and cultural resources. California State Parks plays an important role in fulfilling the Coastal Act and should be treated as a public trust agency whose projects are subject to the broader perspective provided by California Coastal Commission staff, thus should be exempted from inappropriate additions of local agency codes and ordinances which generally apply to commercial and/or private development, without the broader public good that is delivered by California State Parks. The costly fees that the Ventura County Planning Division requires for review and permitting costs are not proportional to the scope of many proposed recreational facility

33 L,5 CC1 Jennifer M. Welch May 13, 2014 Page 2 and resource management projects; consequently, these unfunded costs either reduce or eliminate California State Parks ability to implement important public use facilities that directly benefit the public use of the California coast in the spirit of the California Coastal Act. California State Parks guidelines for compliance with the California Environmental Quality Act (CEQA) allow for Notices of Exemption (NOEs) to be filed for a broad range of projects in support of our dua mission to provide for quality recreation and preserve natural and cultural resources The Ventura County Planning Division's strict definition of Environmentally Sensitive a itat Areas (ESHAs), which encompass most of our coastal parklands, does not allow for an NOE filing for pro'ects... requiring a Coastal/Planned Development Permit located within ESHA automatically elevating virtually all California State Parks projects to costly and tim -consuming Initial Study/Negative Declaration reviews, Several of the changes proposed In the current LCP update, which appear to be applicable to state-owned parklands, will create new regulatory burdens on the standard operations of California State Parks. Archaeological and Paleontological Resources Section 1, Coastal Area Plan, Archeological Resources Context information includes standard references which are quite old and outdated. Current sources should also be used for this LCP update, as years of subsequent research has refined our knowledge of Chumash ilfeways and subsequent European colonization (for example, see Gamble 2008; Jones and Klar 2007). aection 1, Coastal Area Plan, Archeological Resources, Policies, #3 Replace ethnobotanicai" with "ethnographic." The former term only refers to the cultural use of plant resources, whereas the latter term is more broad-based and includes a variety of traditional cultural practiceme difference between "Policies" on pages 2 and 3, and "CAP Policies" beginning on page 5 are unclear, as there seem to be a couple of repetitions] ection 2, Coastal Area Plan, Paleontology Context Information only includes qj references from personal communications. Current written sources should be used for i this LCP update; perhaps the Los Angeles Count Museum of Natural History could recommend a couple of key current references. urther, the Quaternary Period is dated from 2.58 million years ago to the present, and inc udes the Pleistocene epoch, which has proven to include substantial paleontological deposits in southern California, including the La Brea Tar Pits. Instead, "Quaternary" should be replaced with "Holocene Section 2, Coastal Area Plan, Paleontology, Objective "Prehistoric" is generally used to identify archaeological resources, not paleontology, so we recommend that the word is removed from this section.

34 Jennifer M. Welch May 13, 2014 Page 3 Section 2, Coastal Area Plan, Paleontology, Policies Recommend replacing "paleontology" with "paleontological significance" to be more in-line with national guidelines provided by the Bureau of Land Management. Section 1, Article 2, Definitions Although the staff explanation notes that the proposed definition "provides a higher standard of protection than is provided under CEQA," by limiting the definition of archaeological resources to pre-date the 19th century, Ventura County is essentially eliminating protections for resources less than two centuries in age. Under CEQA, any cultural resource greater than 50 years of age could potentially be significant, and such resources do not need to be limited to Native American materials. To avoid confusion within the cultural resources field, and be consistent with the California Environmental Quality Act and guidance provided by the Office of Historic Preservation (OHP), we recommend that the definition for archaeological resource be revised, Further, there appears to be no policies in the LCP update covering historicperiod built environment resources. Section 6, Article 8, Section , Methodology The Register of Professional Archaeologists (RPA) is one way to identify a qualified archaeologist, but not ail qualified archaeologists necessarily have RPA status, nor are they required to register under current state and federal law. Instead, the LCP should define a qualified archaeologist as someone who meets the Secretary of Interior Standards, or the California State Personnel Board Specifications, which are the standards of qualification that the California Historical Resources Information System (CHRIS) use. Section 6, Article 8, Section ,2., Methodology, c. through d. OHP has developed guidelines for the preparation of Archaeological Resource Management Reports, including Phase I studies. Please refer to these standards for components required in such reports. A Phase I study only documents an inventory of resources through background research and surface survey; it does not assess the significance of subsurface cultural deposits, nor does it provide recommendations for mitigation. The Phase I study may however, provide recommendations for further work, such as a Phase II study, which may be required to assess project effects on archaeological resources when they cannot otherwise be avoided. Section 6, Article 8, Section , Methodology, f. Why would a Registered Professional Archaeologist need to consult a "qualified archaeological resources monitor" to prepare a Phase II Evaluation research design? Similarly, why would a Phase III data recovery excavation require an archaeological resources monitor if a qualified archaeologist is directing the work (see subsection h)? Section 6, Article 8, Section , Methodology, g.4. Replace "cultural" with "resource." Section 6, Article 8, Section , Methodology, h and i. In what circumstance would an archaeological data recovery excavation performed as mitigation for a

35 Jennifer M. Welch May 13, 2014 Page 4 proposed development require a separate grading permit? As written, the LCP update requires a coastal development permit to support mitigation for a project applying for a coastal development permit. Additionally, the text appears to be conflating the Data Recovery Plan, which is a research design proposal for carrying out an archaeological excavation, with a Data Recovery Report, which would summarize the results of the completed excavation. The latter report may require extensive analyses, depending on the size of the project, and could take one to several years to complete, creating substantial project delay should the report be required to be completed before issuance of the project coastal development permit. Section 6, Article 8, Section , Monitoring It should be made clear the determining factors for "construction that have the potential to uncover or otherwise disturb archaeological resources." Suggest including something like, "as determined by the Phase I and/or Phase II archaeological studies." The Native American Heritage Commission (NAHC) does not provide lists of qualified monitors; instead, the NAHC provides a contact list of groups and individuals who may have knowledge of resources In the project area and who should be contacted for project consultation. Some of these contacts, but not all, may provide Native American monitoring services, or may provide recommendations for appropriate monitors. As currently written, this section only takes into account Native American archaeological resources and requires a Native American monitor be present for all projects with the potential for encountering archaeological materials. But monitoring may also be required for historical archaeological resources, which would not necessarily require the services of a Native American monitor (see comments regarding historic-period resources, above) Section 6, Article 8, Section , Monitoring, d. Please note here that the NAHC will designate a Most Likely Descendant (MLD). Section 6, Article 8, Section , Mitigation, 2. Remove the reference to the Phase ill report here recovery of resources is the Phase III archaeological work, so that report would not recommend recovery as it would already have been completed. Section 6, Article 8, Section , Archaeological Resources The edits state that this section will be deleted and Appendix 2, although outdated, will be maintained without edits due to budget constraints. However, due to the potential for confusion, we recommend noting as such on the title sheet for Appendix 2 during the current LCP update. Filming Article 4, Section , Permitted Uses By Zone It is unclear if the Ventura County film permitting procedures apply to state-owned lands, but it Is our understanding that productions completely within state land are not required to obtain a film permit from Ventura County. Can this be confirmed? California State Parks has our own film permitting system in coordination with the California Film Commission, and it would be

36 Jennifer M. Welch May 13, 2014 Page 5 an additional cost and time burden to add a third layer of permitting. Article 4, Section (a), Permitted Uses By Zone We feel that student productions should not be exempt, and they should be held to the same standard as any other film activity. In fact, our experience has shown that student productions can have more logistical issues and potential impacts to resource protection, public access and public safety as they are still learning the process, and as such, we require the presence of state monitors on student productions. Article 5, Section , Film Permits Required What is the fee schedule for film permits, and what is the minimum processing time for film permits issued via a Zoning Clearance or a Planned Development Permit? California State Parks would also like to clarify whether the California Coastal Commission Permit Jurisdiction for "lands where the public trust may exist" includes state-owned lands, particularly our beach access. Article 5, Section , Planned Development Permit Film Permit What is considered "adjacent" to ESHA and how is the buffer area defined? California State Parks is concerned about the timeframe for processing Planned Development Permits for filming on parklands, should that be a requirement under the proposed procedures, as much of our state-owned lands are designated as ESHA according to Ventura County mapping. For parking, California State Parks ensures that sufficient public parking, determined by seasonal visitor use, is available at all times while filming is proceeding; however, the language in the LCP update suggests that the determination on the level of impact would lie with a Planning Division staff person who is not familiar with park operations, in determining if a full Planned Development Permit is required. Article 5, Section , Standards for Film Production Activities California State Parks guidelines allow for 24-hour filming in park locations that do not have impacts on nearby campgrounds or sensitive resources. If the Ventura County LCP regulations apply to state-owned lands, the specific hours provided for filming, and temporary exterior night lighting (since most all California State Parks lands are considered to be ESHA by the County) are not consistent with our current guidelines and would need to be rectified. Parking In general, California State Parks is supportive of new and/or clarified measures to encourage sufficient parking for coastal access and recreation, and for resource conservation. Article 6, Section , Maintenance Ventura County should not have jurisdiction over the maintenance of California State Parks parking lots. Funding for parking lot surfacing, striping and general repair is dictated by available state funds, and although we make our best efforts to keep facilities maintained for the visiting public, we cannot

37 Jennifer M. Welch May 13, 2014 Page 6 always comply with set timeframe notices to remedy a condition given constraints on budgets and purchasing authority. Article 6, Section , Number of Parking Spaces Required California State Parks abides by statewide standards for parking spaces, including requirements for accessible parking. We believe our current facilities are consistent with the County standards listed for recreation uses. However, the 10% requirement for short-term bicycle parking in parks and picnic grounds, given the design standards for developed bicycle parking requiring a certain number of racks, delineation and lighting (Section ), could be difficult to achieve in existing facilities under current budget constraints. Article 6, Section , Parking Space Marking In order to provide a natural feel to California State Parks recreation areas, concrete wheel stops are not always necessary or feasible, as sometimes natural rock is used to define parking areas, and some parking lots are comprised entirely of pervious surfaces. The requirement for installation of concrete wheel stops for each parking space should not be applicable to all recreational land use parking facilities. Article 6, Section , Lighting Does the lighting requirement also apply to campgrounds? If so, this could dramatically change the natural character of existing California State Parks camping areas. Signs Article 5, Section , Permit Requirements The draft language requires that California State Parks obtain permits for new sign installations, and changes and modifications to non-traffic signage, even if signs comply with Department of Parks and Recreation (DPR) signage guidelines and have already been approved as part of an existing park General Plan or project that has undergone review under CEQA. California State Parks uses a variety of signs in the categories of recreation, hazard, land and park management, interpretive, regulatory, warning and construction. Those signs that comply with the California State Parks Sign Handbook should be included as an exemption in Section as they promote the safety and enjoyment of public coastal recreation and protect coastal resources, Article 5, Section , Prohibited Signs, c. The vast majority of parklands are considered ESHA by the Ventura County Planning Division, By limiting signage exceptions within ESHA to interpretive signs only, California State Parks is concerned that extensive permitting will he required for the placement of standard regulatory and park management signage which is intended to protect and preserve sensitive resource areas. All California State Parks signage installations undergo CEQA review to ensure avoidance of environmental impacts and compliance with internal guidelines. Accordingly, all categories of signs on California State Parks lands that comply with DPR signage guidelines, including those proposed for areas designated by Ventura County as ESHA, should be allowed.

38 Jennifer M. Welch May 13, 2014 Page 7 Article 5, Section , Signs Exempt from a Permit Include California State Parks signage on state-owned parklands that complies with the California State Parks Sign Handbook guidelines and has undergone CEQA review, even when the signs are located within designated ESHA. Article 5, Section , Zoning Clearance Sign Permit It appears that the LCP update would require California State Parks to obtain an "over-the-counter" Zoning Clearance Permit even for replacement in-kind of standard existing signs, which we periodically have to do as signs become faded or vandalized. California State Parks is concerned that this requirement would have negative time and cost Impacts on the operations of our public-serving facilities. Article 5, Section , Planned Development Sign Permit Many of the signs described that require a full Planned Development permit are of the type and location that California State Parks regularly manages, including signage within 300 feet of the mean high tide line, within 100 feet of streams and scenic resources, interpretive signs, Lbicl and new free-standing signs. Again, California State Parks is concerned that this requirement would have negative time and cost impacts on the operations of our publicserving facilities and assert that all categories of signs on California State Parks lands that comply with DPR signage guidelines, including those proposed for areas designated by Ventura County as ESHA, should be exempted from permit requirements under Section r.- L Article 5, Section ,9.1., Number and Dimensions of Signs California State Parks has existing statewide guidelines that we must follow, which may not necessarily match sign size and location requirements described in the LCP update; therefore, all categories of signs on California State Parks lands that comply with DPR signage guidelines should be allowed. Article 5, Section ,, Maintenance Ventura County should not have jurisdiction over the maintenance of California State Parks signs. Funding for sign [ -941 replacement and repair is dictated by available state funds, and although we make our best efforts to keep signage maintained for the visiting public, we cannot always comply with a 30-day notice to remedy a condition given constraints on budgets and purchasing authority. [51 Article 5, Section , Interpretive Signs California State Parks embarks on extensive internal review of interpretive signs and do not believe that we should be required to have additional reviews by the County Cultural Heritage Board for signage at historic sites, the State Historic Preservation Officer (which is a unit of DPR) for cultural sites, and the U.S. Fish and Wildlife Service for ESHA. Additionally, there may be some instances where California State Parks interpretive signage may require temporary illumination, such as at a campfire center, but as written, the LCP update prohibits this without exception.

39 Jennifer M. Welch May 13, 2014 Page 8 Article 5, Section , Nonconforming Signs Many California State Parks signs have been in place for many years or were Installed as small projects not previously subject to coastal development permits, and would be considered to be "noncomforning." The amended LCP would require California State Parks to obtain a Zoning Clearance Permit for repair of non-conforming signs (see also Section above), which would have negative time and cost impacts on the operations of our public-serving facilities. We are also concerned about the amortization period given for bringing signs into conformity, especially In light of our previous comments regarding conflicts between internal statewide sign guidelines and County requirements, and budget concerns. We thank you for the opportunity to comment on this project. Please contact Barbara Tejada, Associate State Archeologist at barbara.teiada@parks,ca.gov or , if clarifications are required. Sincere Craig Angeles'bistrict Superintendent Richard Rozzelle Channel Coast District Superintendent

40 Welch, Jennifer From: Sent: To: Cc: Subject: Signed By: Shepherd, Anna CIV NAVFAC SW, MUGU Thursday, July 10, :50 AM Welch, Jennifer Rowan, Rosemary; Choi, Jennifer Local Coastal Plan - Parking and Loading, Archaeological and Paleontological Resources, Film Permiting, and Signs ANNA.SHEPHERD@NAVY.MIL Jennifer, Thank you for meeting with me last week to discuss the Local Coastal Plan and for the opportunity to provide early input on this portion of the update. We look forward to reviewing the proposed language for Tree Protection, Landscaping, Definitions, and Environmentally Sensitive Habitat Areas in the fall. At this point, I want to provide our informal input and expect that we will provide formal, official comment closer to your public hearing dates. Here are our comments: LO -2.] Regarding Archaeological and Paleontological Resources: 1) Remove the Register of Professional Archaeologists requirement and use the professional qualifications, modeled after the Secretary of the Interior's Standards and Guidelines. There are many qualified archaeologists who are not members of the RPA, and many members of the RPA who are not qualified archaeologists. 2) Change the definition of archaeological resource. There are historic-era archaeological sites in the coastal zone that have little or nothing to do with Native Americans. Model definition after 43 CFR 7. Consistency is important. D Regarding Parking and Loading: 1) Under purpose, please add a goal for parking to be compatible with surrounding and adjacent land uses. As you know, we have a significant amount of parking next to our fenceline that is incompatible with our security posture. We hope that future parking adjacent to Naval Base Ventura County will be planned and regulated to be as compatible with our property and land use. 41 waiver, t2h)autnedfferiot off-site none-residential usets, pl.eahsbe include a condition, s that would also apply to the parking land 1... Thanks for the opportunity to provide input. Please call me if you have questions or need additional information. VR Anna Shepherd, AICP Community Plans and Liaison Officer Naval Base Ventura County or DSN

41 Welch, Jennifer From: Sent: To: Cc: Subject: Honthaner, Wednesday, April 30, :21 PM Welch, Jennifer Lemisch, CFC Comments Re: Amendments To Local Coastal Program - Ventura County Dear Jennifer, On behalf of the California Film Commission (CFC) I want to thank you for inviting the CFC to review the proposed amendments to the local Coastal Program as they relate to the Film Production Ordinance. As a state department under the Governor's Office of Business and Economic Development, we are tasked with retaining and increasing motion picture production and to see that it continues to create jobs and boost business throughout the state. In addition to issuing film permits for all state properties and offering a variety of services to the production community, the CFC also works cooperatively and collaboratively with all city, county, state, and federal jurisdictions to encourage filming and grow our state's economy. Before I get into our notes and questions, and as per your message to Amy Lemisch, Director of the California Film Commission, we would like to confirm that if a film activity is to be staged entirely on state property that a county permit is not required, nor is permission from the Coastal Commission. And if that is the case, we would like to request verification of such in writing. Now to our comments and questions: Although you have been great about answering any questions we have had (and thank you for that), in general, we find that this document is complicated and difficult to understand. We suggest that it be rewritten in a way that would make it easier for the general public to comprehend. I know you spoke to Amy about this, but could you please explain (again) when a Planned Development Permit would be required? I apologize if I've missed it, but I see no indication as to how much time is required for the approval of a Planned Development Permit, although it is noted that modification requests shall be received within 30 days of the film permit issuance date.lanother concern would be that as per Sec Film Permit Application Procedures (c) a film permit that requires a Planned Development may be appealed. As most film, TV and commercial productions work on tight schedules (and budgets) and do not have an unlimited amount of pre-production time; it would be difficult to schedule a shoot without a fair amount of certainty that a desired location would be available. It would therefore be important to know how long it would take for a Planned Development Permit to be processed, assuming all requirements are promptly submitted and allowing for any possible appeal. An overly lengthy process would likely discourage most productions from applying3 Sec Film Permits Required a. Film Permit A film permit is required for all film production activities, unless exempt from film permit requirements pursuant to Sec Exempt generally refers to non-commercial work, student films, personal/family films or breaking news. Can you tell us what the cost is for these permits and what the turnaround time would be? Sec Planned Development Permit Film Permit

42 1 a. A Planned Development Permit shall be required for film production activities that are otherwise exempt from a film permit or authorized with a Zoning Clearance pursuant to Section if the Planning Division determines that the film production activities or access to the site will either directly or indirectly impact coastal resources or will be located within or adjacent to an environmentally sensitive habitat area (ESHA) or buffer area. Does this mean that all or most film permits would require a Planned Development Permit? And what about the state beaches that are in ESHA zones are they exempt as long as the production is contained to state property? b. Following the approval of a Planned Development Permit, the applicant shall obtain a Zoning Clearance pursuant to Section [Staff Explanation: PRC 30610(i)(1) states that any proposed development which the executive director finds to be a temporary event which does not have a significant adverse impact upon coastal resources is exempt from a coastal development permit. Filming is considered a "Temporary Event" pursuant to the California Coastal Commission's Regulation of Temporary Events in the Coastal Zone (dated January 23, 1998). Rather then exempt filming activities, zoning clearance will be required to insure some level of review is provided.] Will every permit issued in the Ventura Coastal zone have to be reviewed for zoning clearance? Sec Film Permit For Sandy Beach Areas The following types of permits shall be required for film production activities that occupy all or a portion of a sandy beach area as follows: a. Zoning Clearance Film production activities that meet all of the following criteria and are otherwise authorized with a Zoning Clearance pursuant to Section above: 1. Occur outside the period between Memorial Day weekend through Labor Day weekend; or 2. Occur between Memorial Day weekend and Labor Day weekend but meet all of the following criteria: (a) are located in a remote location with minimal demand for public use, (b) will not result in adverse effects on tributaries that discharge to the ocean, tide pools and sand dunes, (c) will not be located within or adjacent to an environmentally sensitive habitat area (ESHA) or buffer area, (d) maintain public access to and along the coast, and (e) last for less than one day in duration. To limit productions to no more than a one-day shoot would greatly discourage production in these areas. b. Planned Development Permit Film production activities that meet all of the following criteria: 1. Are held between Memorial Day weekend and Labor Day, unless the activities meet the criteria stated in subpart (a)(2) above in which case a Zoning Clearance shall apply; and 2. Would restrict public use of roadways or parking areas or otherwise significantly impact public use or access to coastal waters; and Our state Parks Angeles District has always allowed productions parking lot use (3/4 in off-season and'/ in peak season). Sec Film Permit Application Procedures a. The film permit application shall be filed with Ventura County Planning Division in accordance with Section and signed by the applicant or authorized agent thereof. b. Zoning Clearance - A minimum of three (3) working days is required to process a Zoning Clearance for a film permit. If neighborhood consent is a 6 prerequisite to permit approval, pursuant to Section , a minimum of five (5) working days is required to process a film permit. c. Planned Development Permit - Planned Development Permits shall be processed pursuant to Section , ---, Section and Section The public hearing for a Planned Development Permit may be waived pursuant.,. I D to Section A film permit that requires a Planned Development may be appealed pursuant to Section t - Can you tell us what the cost is? And how would this work in conjunction with the regular processing of permits? Sec Standards for Film Production Activities Hours 1. All film production activities shall occur between the hours of 7:00 a.m. and 9:00 p.m. on weekdays and between the hours of 8:00 a.m. and 8:00 p.m. on weekends. 2

43 t \\--\ Please note that many cities allow filming activities between the hours of 7:00 a.m. and 10 p.m. during the week and longer hours on weekends with the approval of neighboring residents, 2. Film production activities that occur outside the hours identified in (1) above require neighborhood consent. the radius from the production activity that would require consents from residents, and what is the percentage D)--I-3 What of consents is required? b. Noise and Lighting Noise and lighting shall not create a nuisance upon nor otherwise negatively impact neighboring uses including but not limited to environmentally sensitive habitat areas. While the CFC clearly understands the desire for filming to have as little impact on the surrounding area as possible, the D5 nature of a film/tv/commercial shoot is that it can sometimes be intrusive, even though the impact may be minimal and all good faith efforts are made to mitigate the effects of the filming activities. And as it would be nearly impossible to guarantee that noise and lighting shall not create a nuisance, the CFC always recommends a mitigation of disruption within the affected area. Thank you again for letting us comment and ask questions. Best regards, Eve Honthaner Deputy Director CALIFORNIA FILM COMMISSION 7080 Hollywood Blvd, Suite 900 Hollywood, CA office#: , ext. 136 direct office#: cell#: ehonthanerpfilm.ca.gov f ;COMMISSION 3

44 Bryan Harre Silverstrand Beach property owner Dropped off Key Points About Filming on April 1, 2014 Key points about filming in our neighborhood. EL 1) Porn film industry cuts corners to make a profit, resulting in a fire hazard a. Non permitted an d substandard wiring b. Cutting of holes to exterior for non permitted AC units, etc c. Homes are very close together, any fire can spread quickly to other homes d. The county only reviews permits, they do not inspect the film companies actual installed work 2) Streets are narrow and film permits would result in increased traffic on narrow streets, which is a hazard to our communities kids a. Film trucks would be parking in streets b. Porn Film party attendees park all over the place c. Silverstrand already has only limited parking, the film crews would take up parking spaces d. Who is liable when the fire trucks and ambulances cannot get down a street in a timely manner, the homeowner, the film company, or the county? 3) Porn film industry brings in crime a. High rate of drug and alcohol issues b. Prostitution 4) Porn filming parties a. Attendees paid a door fee to watch or participate in the film b. Parties occurred every two weeks with over 50 "attendees" each time 5) Area is residential, let's keep it residential and not a business. a. I can't turn my house into a gas station, why should someone be allowed to turn their house into a porn film party business making money off of porn actors and their attendees 6) 3% of the county doesn't allow filming already for the safety and community concerns, let's keep it that way. Our streets are too narrow and the hazards to high in a congested area. If you want to film go to the other 97% of the county that is more conducive to filming.

45 This petition is to show that you do not want to change Ventura County's current restrictions on filming in the unincorporated area of Silverstrand Beach and Hollywood By the Sea. 1 House # Name (print) Signature ---r----, 't5 1,-iPtl'"Atarl. Diclna -klus1lr\ i"he."6,\c \le.c Approve keeping current filming restrictions in place 2 lc lig,fixed f //ti-ire- e _ : -- e -.-- i-' 3 9C //t/:.1?th:,:ft WAs. k,f i ki..6"1 - J1 (,76A-7` J00-)...:.,b- 3iC 6 V-1, 7.).77 goily, 4 I 8 3iiiiikly 'el Ahiqhmii, L, Ri V C I /,4.751" i rt_s. 6,cec.,, s.55 n",,..,y, --) -L,,, --,,,- `-('c 5., Y'c5 10 3z1 '; 1, r i,hilln0 peii -2_,t.ti; v \l,,\ Aic..1, QA\ ) 0 Aso\ `11-e s 12 :36) (t. 4,ct,tr--;c1 el 4 i A D.,;(- :- -.., Q...- 1/4 - '...1 rr k 14 ' i,, t \..\\v,,,a \ ii 15 $5-6a 06-0/4 A 4tile` It.84 0 P - t C / iiipci ii 6e7f,(341.,A_ c /F D g 19 i<. 9-at7 0(xtt::: O /- /I 20,., LC, t Li- e.../ 7-1, zn, i.2,,. j -, I.:It ircte. Jai i(-7. LC) 41,4 i.:1, 1-- k 2 L)- --s. -,'''L-: y_..,

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48 This petition is to show that you do not want to change Ventura County's current restrictions on filming in the unincorporated area of Silverstrand Beach and Hollywood By the Sea. House # Name (print), Si nature Approve keeping current filming restrictions in place 1 (licapiac. 1; 3 La N.),7, 1 a/a \llasleta).ecoa,, Ve_s 2 13_1 mo) cmil 3-- \t c (1 /4) at. ).. -.L._, 4._ii_ct-. ( 9, 3 / t Ft F. l RCA -4--ep ka,,l , Clow Ave Lou; 0% TC4vIcif,- ;,-;-i././1/1,1,0171 u, ----N 414, Scu\ta-Rgso, "Dc Oz-k) NI est -,:kickno-- 1\10,c_ io 6 vu N L k s.i ,,Wr-t. ye i /,

49 Welch, Jennifer From: Sent: To: Subject: Pat Maxon Tuesday, March 18, :38 PM Welch, Jennifer Re: Ventura County LCP Update Jennifer - Unfortunately I will be unable to attend in person, but have some comments to the draft: CAP Final Draft With respect to A. Archaeological Resources Policy 3 (page 3) and CAP Policy 6 (page 6), it should be made more clear as to what is intended, and should include communication/consultation with the Native American Heritage Commission (NAHC) to request a Sacred Lands File search and provide a list of local Native Americans who might have additional knowledge of resources and history not recorded in the CHRIS. Names on the list should be contact for information. Regarding CAP Policy 2, an RPA is typically not required for an archaeologist to conduct records searches in CHRIS or to prepare reports. Secretary of the Interior Standards usually suffice. Not sure you want to make RPA a requirement since some very qualified archaeologists do not join RPA on principal. B. Paleontology. Although rock formations do not change, perhaps a more recent citation than the personal communication in 1980 would be appropriate here. Is Bruce Welton even still at the NHMLAC? He may be at the New Mexico Museum of Natural History. For Policy 1 (page 11), the intent should be made more clear and should include a paleontological records search at the appropriate museum (NHMLAC or other) to determine rock formations present and any recorded fossil localities. CZO Final Draft Article 2: Definitions. Archaeological resources are not only those resources that predate the 19th century. That is an arbitrary cut-off. Independent Native American groups survived well into the 19th century. Archaeological resources can also be present but retain no significance. In addition, archaeological resources can be as recent as 50 years old and include house foundations, trash pits, privies, etc. Section Methodology: c: Phase I studies are typically only the identification phase, where the presence of resources is confirmed or refuted. The Phase I study may identify archaeological sites that require Phase II testing (prior to mitigation). f. and g.: Any substantial subsurface work in the Coastal Zone (including most test excavations) requires the development of an Archaeological Research Plan (ARP) as part of the Coastal Development Permit. The ARP must be approved prior to subsurface disturbance and includes peer review by three qualified archaeologists. Section Monitoring: NAHC does not keep a list of qualified archaeological monitors as far as I am aware. They may keep lists of qualified Native American monitors, but I'm doubtful of that. Thanks for the opportunity to comment. Please let me know if you have any questions about my comments, Pat Patrick 0. Maxon, M.A., RPA BonTerra Psomas I Balancing the Natural and Built Environment Director, Cultural Resources Environmental Planning & Resource Management 2 Executive Circle, Suite 175 Irvine. CA ,

50 Welch, Jennifer From: Sent: To: Subject: Robin Turner Friday, March 21, :03 PM Welch, Jennifer RE: Ventura County LCP Update Hi Jennifer, My comments are pretty broad. I will not be able to make the meeting but appreciate the opportunity to give you my opinions. 1) All artifacts and fossils are significant since they are non-renewable resources and are no longer made and/or tell us about the local past. Not only are they of scientific significance, but in the Native American view, they tell stories about the ancestors. That makes them significant. As for fossils, they all are significant. On every job site, we find new species of fossils when monitoring is mandated by the lead agency. 2) Regarding paleontology, all agencies need to understand the difference between bedrock and alluvium and the fact that geologists consider alluvium as overburden or fill. There is a definitive difference between construction or engineered fill and alluvium (geologic fill). Make sure the planners understand this fact. 3) Many planners make the mistake in writing in an EIR or other document that "if the contractor sees artifacts or fossils they are to stop work and call/hire an archaeologist or paleontologist to assess the situation for significance. Contractors or developers should not ever make this decision. They are not trained in nor care about saving nonrenewable resources. 90% of all of the fossils or artifacts, sites, features that we find in the field is because we were already monitoring the project. All Ventura County projects should require construction monitoring. Thanks for listening to my issues. Sincerely, Robin Turner ArchaeoPaleo Resource Management, Inc. From: Jennifer Welch [mailto:jennifer.welch@ventura.org] Sent: Tuesday, March 18, :58 AM To: ARCHAEO/PALEO: (VCAS), Ventura; Archer, Gavin; Associates, Greenwood; Austerman, Gini; Cisneros, Charles; Consultants, Conejo; Consultants, Rincon; Delu, Antonina; James, Stacy; "Lander, Bruce <paleo"@earthlink.net; Lopez, Robert; Macfarlane, Heather; Mason, Roger; Maxon, Patrick; Moratto, Michael; Romani, Gwendolyn; Simon, Joe; Tabor, John; Tumamait, Julie; Turner, Robin; Woodland, Craig Subject: Ventura County LCP Update Dear Sir/Madam: The County of Ventura is currently drafting amendments to the Local Coastal Program, which includes the Coastal Area Plan and Coastal Zoning Ordinance. Proposed changes will include

51 Welch, Jennifer From: Sent: To: Subject: Attachments: Bruce Lander <paleo earthlink.net> Friday, March 28, :31 AM Welch, Jennifer RE: Ventura County LCP Update SVP mitigation 2010.pdf Hi, Jennifer. Many thanks for including me in your mailing so that I might comment on the County's updated Coastal Plan. r I have little to provide in the way of a comment.ey only concern is that many units with well-documented fossil records are considered to be of low or no paleontologic importance. However, many quaternary units, even those regarded as Holocene in age, have been demonstrated to be highly productive elsewhere, especially at comparatively shallow depths, where many such units are of Pleistocene aunor that reason, those units are considered to have a potential for containing fossil remains. As a general rule, a depth of 5 feet is the point at which the potential is considered to be at least undetermined, unless fossil occurrences have been documented as occurring at even shallower depths. The coastal terrace deposits in Santa Barbara County if not also Ventura County have produced Pleistocene land mammals, some only recorded in geotechnical reports. Alluvial deposits underlying the city of Ventura have produced similar remains and those of marine mammals. We've even recovered late Pleistocene mollusks from beach deposits in Long Beachthltil better known, the potential fossil productivity of most Quaternary units should be evaluated for each project, based on grain size (coarse-grained units usually less productive, but I've found a mammoth tooth in a stream cobble gravel deposit), fossil record from the surrounding region, and proposed depth of earthwork Even limestone units in the Conejo Volcanics of Los Angeles County have produced marine mollusks, whey as a tuff breccia in the same unit has produced fossilized wood in the Santa Monica Mountains of Ventura County Perhaps the paleontologic importance of those units determined to be of no or only low or even moderate importance should be reevaluated by a paleontologist with local experience, much as I did for the southern half of the County in I've attached the latest SVP guidelines for your reference. Best regards. Bruce Lander From: Jennifer Welch [mailto:jennifer.welch@ventura.org] Sent: Tuesday, March 18, :58 AM To: ARCHAEO/PALEO: (VCAS), Ventura; Archer, Gavin; Associates, Greenwood; Austerman, Gini; Cisneros, Charles; Consultants, Conejo; Consultants, Rincon; Delu, Antonina; James, Stacy; Lander, Bruce; Lopez, Robert; Macfarlane, Heather; Mason, Roger; Maxon, Patrick; Moratto, Michael; Romani, Gwendolyn; Simon, Joe; Tabor, John; Tumamait, Julie; Turner, Robin; Woodland, Craig Subject: Ventura County LCP Update Dear Sir/Madam: The County of Ventura is currently drafting amendments to the Local Coastal Program, which includes the Coastal Area Plan and Coastal Zoning Ordinance. Proposed changes will include updated regulations to conform to current County and Coastal Commission standards and state and federal laws. 1