Agenda packet — Carmel-by-the-Sea City Council, November 4, 2025 (part 4 of 6)

Appendix C – Sites Inventory C-35
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 of yielding residential units (Program 2.1.A: Incentives for Mixed Use Development and Program

2.3.A: Preserve and Increase Upper Floor Residential Use).

While the City does not anticipate the displacement of low- or very low-income households, the City is prepared to comply with the requirements of Government Code section 65915, subdivision (c)(3).

Program 2.1.C in Chapter 2 will be in effect to require replacement housing units subject to the requirements of the Government Code. Additionally, CMC 17.14.050.A prohibits the conversion or demolition of an existing residential unit unless replacement housing is provided subject to the findings in 17.64.070.

Development Trends
Historically, residential development in Carmel-by-the-Sea has been most feasible using densities ranging between 22-33 dwelling units per acre. Development trends in the City reveal successful residential development in the commercial district primarily through office conversion and secondstory additions for residential units. In the last 10 years, the City has not had any one-story developments in the commercial districts. All new construction in the commercial districts has consisted of two-story buildings with second-floor residential use (as required in CMC Section

17.14.050.F).

This has been a successful strategy utilized by the City to enable the development of residential units within the constraints of limited developable land. The following projects are examples of 5th cycle residential development in Carmel-by-the-Sea, which have been considered in determining the realistic capacity of sites identified in the Site Inventory.

Some of the most recent mixed-use development projects include:

Great Valley Holdings/Clark Apartments: In 2020, the Planning Commission approved the construction of a new two-story mixed-use building. The 3,600-square-foot site contained a 2,200- square-foot two-story commercial building with surface parking. The project consisted of demolishing the existing building and constructing a new 3,500-square-foot two-story mixed-use building for a ground-floor restaurant and two second-floor rental apartment units. The building was previously occupied on both floors by a restaurant and had been vacant for a few years. The project density is 25 dwelling units per acre.

This project is an example of redeveloping an underutilized site with a new two-story mixed-use building in the Service Commercial (SC) District. No appeals of the project were filed. The project has been constructed and received final occupancy.

Schultz: In 2020 the Community Planning & Building Director approved an interior and exterior remodel of a commercial space in a 4,500-square-foot multi-tenant two-story mixed-use building in the Service Commercial (SC) District for the conversion of second-floor commercial space to a 1,160- square-foot apartment. The property is 4,000 square feet (0.09 acres). The residential density on this mixed-use parcel is 22 du/acre.

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Appendix C – Sites Inventory C-36
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Parashis: In 2020 the Community Planning & Building Director approved minor exterior alterations to a 6,700-square-foot two-story commercial building in the Central Commercial (CC) District to facilitate the conversion of second-floor office space to a 2,118-square-foot apartment. The property is 6,400 square feet (0.15 acres). The residential density on this mixed-use parcel is 7 du/acre. Other past mixeduse development projects are shown in Table C-17.

Table C-17 - Past Mixed-Use Development Projects
Project Name Year Approved Zoning District
Lot Size
(square feet)
Residential
Spaces Units Per Acre
Del Dono 2016 Service Commercial (SC) 8,000 8 44
Fink Condominium 2017 Central Commercial (CC) 4,000 1 11 Lincoln Lane 2018 Service Commercial (SC) 8,000 2 11
Marliz Estate 2018 Central Commercial (CC) 2,750 1 17
Brigantino 2018 Residential & Limited
Commercial (RC)
3,500 2 25
MDC Real Estate 2018 Central Commercial (CC) 4,000 1 11 Brosche Building 2019 Central Commercial (CC) 3,470 2 28 Flint-Herman
Residence
2019 Residential & Limited
Commercial (RC)
3,500 1 25
Der Ling Building 2019 Central Commercial (CC) 3,000 1 16 While many of the projects listed above were approved for densities between 22-33 dwelling units per acre, some were approved at 44 dwelling units per acre (Del Dono I and Del Dono II) and a few were approved below 20 dwelling units per acre (Fink Condominium; Lincoln Lane; MDC Real Estate; Marliz Estate; Der Ling Building; and Parashis). Additionally, all but one of the projects listed above are less than 0.5 acres. These factors were taken into consideration when determining appropriate densities to apply to the Sites Inventory, and supports the City’s decision to amend the base zoning for the commercial zoning districts (SC, RC, and CC) and the multi-family residential district (R-4) to establish a minimum density of 33 dwelling units per acre. The intention of this zoning code amendment is to facilitate the development of residential units at a higher yield, rather than enabling the development of larger units at a lower yield.

Considerations for Capacity Analysis
Dry Utilities and Water Capacity
Current or planned availability and accessibility of sufficient water, sewer, and dry utilities has also been considered for each site. All sites have sufficient dry utilities. Program 1.2.A has been included to grant priority water and sewer services to proposed developments that include units affordable to lowerincome households.

On January 27, 2025, the Monterey Peninsula Water Management District (MPWMD) adopted Ordinance 197 allocating 14 acre feet of water to the City of Carmel-by-the-Sea from the Pure Water Monterey/Groundwater Replenishment Project, an advanced water recycling project jointly developed ATTACHMENT 6

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Appendix C – Sites Inventory C-37
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 by MPWMD and Monterey One Water. MPWMD anticipates that this water will be available for use by the fourth quarter 2025.

In accordance with the City’s water management program (Carmel Municipal Code Chapter 17.50), the City Council must establish a list of defined land use or project categories for which water will be made available and the quantity of water to be allotted for each category. At least 10 percent of available water resources must be reserved for projects that will create new affordable housing units for very low, low, or moderate income units. 10 percent of 14 acre feet is 1.4 acre feet of water which could serve approximately twenty (20) 1-2 bedroom/1 bath apartments. The Carmel City Council will consider establishing land use categories and the quantity of water to be allotted for each category in the Fall of 2025 (see Chapter 2).

Site Typology
Government Code Section 65583.2 (c)
This housing plan and Site Inventory provides capacity for a variety of housing types; including multifamily rental housing, factory-built housing, mobile homes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. The Zoning Ordinance and General Plan for the sites allow the housing types listed above. Figure C-2 illustrates the anticipated housing development types included in this site inventory.

To enable the development of a variety of housing types, the City has expanded possible options for property owners to construct, rehabilitate, convert, or add to an existing single-story structure including:
 Zoning changes included with Program 1.1.F in Chapter 2 that incentivize existing overnight visitor accommodation sites to be converted into multi-family housing units; and  Zoning changes with Program 1.1.G in Chapter 2 that incentivize the construction of employee housing units at overnight visitor accommodation sites; and  Zoning changes with Program 1.1.C in Chapter 2 that incentivize the development of “Live/Work” units in vacant and underutilized commercial spaces.

Adequate Infrastructure Capacity
Government Code Section 65583.2 (b)(5)
Sewer
The Carmel Area Wastewater District (CAWD) serves the wastewater treatment needs for Carmel-bythe-Sea. The District completed a rehabilitation project at the wastewater treatment plant to renew existing infrastructure that was originally installed in the 1970s and 1980s. The wastewater treatment plant has a permitted capacity of 3.0 million gallons per day (MGD).

The CAWD uses a wastewater generation rate of 100 gallons per day (GPD) per residential unit. Based on this rate, the City’s RHNA of 349 residential units is projected to generate 40,000 GPD of ATTACHMENT 6

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Appendix C – Sites Inventory C-38
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 wastewater. The wastewater treatment plant currently has the capacity and ability to take on the City’s RHNA (Barbara Buikema, General Manager, September 13, 2023).

Water
Carmel-by-the Sea receives its water from the California-American Water Company (Cal-Am) Central Division who pumps its water from several local water sources: groundwater from the Carmel River Aquifer, Seaside Groundwater Basin, Aquifer Storage and Recovery, indirect portable reuse from Pure Water Monterey, and desalinated water from Sand City. The majority of water received in the City is from the Carmel River and the Seaside Groundwater Basin (City of Carmel-by-the-Sea 2023b).

Cal-Am’s Final Urban Water Management Plan (UWMP) (June 2021) provides several tables illustrating normal, single- and five consecutive-dry year water supply and demands to determine the total available supply. The supply from the Carmel River Aquifer, Seaside Groundwater Basin, Sand City Desalination Plant, and Monterey Peninsula Water Supply Project (MPWSP) Desalination Plant (anticipated to be operational by 2030) are all anticipated to be reliable and provide their contractual or design supply in all year types.

Until the MPWSP Desalination Plant is online, it is expected that demands will need to be constrained through the enactment of the Water Shortage Contingency Plan (California-American Water Company 2021, p. E-4). As described in the UWMP, the Water Shortage Contingency Plan is used to provide guidance to the Monterey County District’s governing body, staff, and the public by identifying response actions to allow for efficient management of any water shortage with predictability and accountability. It provides the tools to maintain reliable supplies and reduce the impacts of supply interruptions due to extended drought or catastrophic supply interruptions.

The water demand for the UWMP was calculated based on regional population growth projections available prior to the release of AMBAG’s current RHNA. The RHNA would result in more residential units within Cal-Am’s service area than what was considered in the UWMP. According to the Monterey Peninsula Water Management District’s (MPWMD) Technical Memorandum dated June 1, 2023, the City requires 40 acre feet of water to accommodate its RHNA of 349 units. When including the 17 percent buffer in the Housing Element Update approximately 46 acre-feet of water would be needed to meet the needs of the City’s RHNA (i.e., total of 410 housing units).

On January 27, 2025, MPWMD adopted Ordinance 197 allocating 14 acre feet of water from the Pure Water Monterey Expansion project to the City of Carmel-by-the-Sea. The District anticipates that the additional water supply will be on-line by the fourth quarter of 2025.

Many of the housing sites are developed with existing businesses or residences that currently use water.

It would be speculative at this time to document the existing water use at each site and whether adaptive reuse or redevelopment of those sites would result in the need for more or less water supply.

Therefore, as development applications are received for the housing sites, City staff will evaluate the applications to determine if additional water supply is required, and if it is available to the project.

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Appendix C – Sites Inventory C-39
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 The City of Carmel Regional Housing Needs Allocation (RHNA) is for 231 units of moderate, low-, or very low-income housing (out of a total 349 units). Section 17.50.040.A of the City Municipal Code states that projects involving no net increase in water use or that will create new housing affordable to moderate, low-or very low-income households may be accepted and processed without regard to water allocations.

Adjustment Factors for Realistic Capacity
Government Code Section 65583.2(c)(2)
Land use controls and site improvement requirements have been analyzed for constraints within Appendix B – Housing Constraints, and necessary changes to the review process are included as programs within Chapter 2 – Goals, Policies and Programs. Additionally, the City will amend the Municipal Code base zoning for the commercial zoning districts (SC, RC, and CC) and the multifamily residential (R-4) zoning district to establish a minimum density of 22 dwelling units per acre and a maximum allowable density of 40 units per acre, with a total capacity of 88 units per acre inclusive of local and State density bonuses, to increase the potential yield of residential units. The realistic development capacity for the sites begins with assuming those process changes to be in place by or prior to July 2025. Generally, the following adjustment factors have been considered for determining realistic capacity of the sites.
 Site geometry and on-site improvements
 Age of structures and building conditions
 Vacancy and under-utilization
 Improvement-to-land value ratio
 FAR
The table below identifies additional opportunities for residential development. While the City has previously demonstrated that small sites are typically developed at the maximum allowable density and can be feasible to facilitate affordable housing development, the City does not rely on these small sites below to meet its lower income RHNA. Development capacity on these sites is conservatively estimated at 33 units per acre, not at the proposed change to 40 units per acre.

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Appendix C – Sites Inventory C-40
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Table C-18 - Additional Scattered Sites
Site #
Location
(Reference to ECO NW Study) APN Zoning
General Plan
Land Use Acreage
Applied
Density
(DU/AC)
Minimum
Capacity Very Low Low Moderate
Above
Moderate
Primary Underutilized Sites
S-1 Forest Cottages Specific Plan,
NE Corner of Ocean & Mountain View
010085004000 Single Family
Residential (R-1)
Single Family
Residential

0.30 20 6 -- 2 -- 4
010085005000
010085003000
Subtotal Primary Underutilized Sites 0.30 6 0 2 0 4
Sites Recycled from 5th Cycle
S-2 Court of the Fountains,
NW Corner Mission & 7th
010141003000 Central
Commercial (CC)
Core
Commercial

0.37 33 12 -- -- -- 12
S-3 First American Title,
7th 2 SW of Mission
010142013000 Service
Commercial (SC)
Core
Commercial

0.07 33 2 -- -- -- 2
S-4 Office building,
NE Corner Monte Verde & 7th
010191004000 Residential &
Limited
Commercial (RC)
Residential/
Commercial

0.07 33 2 -- -- -- 2
S-5 Yafa,
NW Corner Junipero & 5th
010097007000 Service
Commercial (SC)
Core
Commercial

0.18 33 5 -- -- -- 5
S-6 Three Garages Site (#7) 010098004000 Service
Commercial (SC)
Core
Commercial

0.11 33 3 -- -- -- 3
S-7 Carmel Realty Office Site (#4),
NE Corner 8th & Delores
010145008000 Residential &
Limited
Commercial (RC)
Residential/
Commercial

0.19 33 6 -- -- -- 6
S-8 (Parashis) Millard Building,
NW Corner Dolores & 6th
010138006000 Central
Commercial (CC)
Core
Commercial

0.13 33 4 -- -- -- 4
S-9 The Agency,
NW Corner Ocean & Dolores
010139001000 Central
Commercial (CC)
Core
Commercial

0.09 33 2 -- -- -- 2
S-10 Enzo's,
San Carlos 2 SW of Ocean
010146001000 Central
Commercial (CC)
Core
Commercial

0.15 33 4 -- -- -- 4
S-11 Paseo San Carlos Square #1,
San Carlos 2 NW of 7th Ave
010146003000 Central
Commercial (CC)
Core
Commercial

0.18 33 5 -- -- -- 5
S-12 Carmel Office Supply & Business Center,
Lincoln SE of Ocean
010147010000 Central
Commercial (CC)
Core
Commercial

0.09 33 2 -- -- -- 2
Subtotal Recycled Sites 1.54 47 0 0 0 47
Total 1.84 53 0 2 0 51
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Appendix C – Sites Inventory C-41
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Site #S-1 - Forest Cottages Specific Plan
The Forest Cottages site is approximately 0.30 acres and is located within a Specific Plan area. The Forest Cottages Specific Plan was adopted by the City Council in 2006 and amended in 2008. Existing uses on the site include a hotel/motel.

The Specific Plan allows a total of 6 units, of which 4 are single-family residential units. It contains an affordable housing requirement of two multi-family residential units permanently dedicated and used to provide housing for low-income or very low-income households as defined by State statutes. The Specific Plan requires that a deed restriction be recorded establishing this requirement prior to issuance of the first building permit within the Specific Plan.

Developed at 20 dwelling units per acre, the site would allow a total of six units to accommodate two low-income units and four above-moderate income units (Table C-19). This density calculation does not account for adjustments, as the site is part of a Specific Plan that has approved densities, anticipated unit counts by income category, and existing site improvements. The Specific Plan affordable housing requirement discussed above satisfies the “interest” in developing affordable housing on the site.

Table C-19 - Site #S-1, Forest Cottages Specific Plan: Site Description Site Description Site Image & Capacity Calculation
Address Northeast corner of Ocean and
Mountain View
APN 010-085-004-000
010-085-005-000
010-085-003-000
By-Right with 20%
Affordable
No, not used in the previous cycle
Size of Site 0.30 acre
Zoning R-1
Allowable Density 20 du/ac
RHNA Affordability Low-Income: 2 unit
Above Moderate-Income: 4 units
Existing Use Non-vacant; hotel/motel
Infrastructure Availability Yes, no constraints. Realistic Capacity = (0.30 X 20) = Environmental Constraints None known 6 units Specific Plan Approved Density Other Constraints Shape: None
Access: None
Title Conditions: None
Historic Preservation: None
Easement: None
Source: City of Carmel-by-the-Sea
Site #S-2 - Court of the Fountains
The Court of the Fountains is approximately 0.37 acres. Existing uses include multi-tenant retail shops and a restaurant across multiple single-story commercial buildings. The site was included in the 5 th Cycle inventory.

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Appendix C – Sites Inventory C-42
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 The site is zoned Central Commercial (CC), which currently allows residential densities up to 22 du/acre by-right, 33 du/acre with approval of a conditional use permit, 44 du/acre under the Density Bonus law, and up to 88 du/acre if the project is 100 percent affordable. Program 3.1.G has been included in this housing element to establish a by-right density of 22-40 du/acre for residential development in the commercial districts (see Chapter 2).

Developed at 33 du/acre, the gross acreage of the site would produce 12 above moderate-income units.

When factoring in potential land-use controls and site improvements, the site's realistic capacity, and typical densities, the site's net acreage would yield 9 above moderate-income units (Tables C-20 and C21). Based on recent developments, such as Ulrika Plaza and Scandia Lopez/Hakim, both located in the commercial district, the City has determined that 33 du/acre, including adjustments, is the most feasible density for development on this site. A density of 33 du/acre would be achieved through a zoning code amendment allowing a by-right density of 22-40 du/acre.

Table C-20 - Site #S-2 Court of the Fountains: Site Description Site Description Site Image and Capacity Calculation
Address Northwest corner of Mission Street
and 7th Avenue
Realistic Capacity utilizing factors =
(0.37 X 38) (.90) (.95) (.95) = 9 units
75% of minimum density
APN 010-141-003-000
By-Right with 20% Affordable No, used in 4th and 5th cycles, but nonvacant and market rate.

Size of Site 0.37 acre
Zoning CC
Allowable Density 0-22 du/ac*
Applied RHNA Affordability Above Moderate-Income: 12 units Existing Use Non-vacant
Infrastructure Availability Yes, no constraints.

Environmental Constraints None known
Other Constraints Shape: None
Access: None
Title Conditions: None
Historic Preservation: None
Easement: None
Source: City of Carmel-by-the-Sea
Notes: *The existing Carmel Municipal Code establishes a by-right density of 0-22 du/acre in the commercial zones (CC, SC, and RC). Program

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

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Appendix C – Sites Inventory C-43
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Table C-21 - Site #S-2 Court of the Fountains: Capacity Assumptions Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the site 95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and single-family and current cost of construction.

Typical densities 95% Future medium-density projects in Carmel-by-the-Sea are more likely to be built out close to maximum density due to lot sizes, limited developable sites, and very high demand for new units.

Infrastructure availability No adjustment Not applicable, no constraints Environmental Constraints No adjustment No known site constraint Source: City of Carmel-by-the-Sea
Site # S-3 First American Title
The First American Title site is approximately 0.07 acres and is currently underdeveloped, with a small commercial building occupied by an insurance office.

The site is zoned Service Commercial (SC), which currently allows residential densities up to 22 du/acre by-right, 33 du/acre with approval of a conditional use permit, 44 du/acre under the Density Bonus law, and up to 88 du/acre if the project is 100 percent affordable. Program 3.1.G has been included in this housing element to establish a by-right density of 22-40 du/acre for residential development in the commercial districts (see Chapter 2).

Developed at 33 du/acre, the gross acreage of the site would produce 2 above moderate-income units.

When factoring in potential land-use controls and site improvements, the site's realistic capacity, and typical densities, the site's net acreage would yield a total of 1 above moderate-income unit (Tables C-22 and C-23). Based on recent developments, such as Ulrika Plaza and Scandia Lopez/Hakim, both located in the commercial district, the City has determined that 33 du/acre, including adjustments, is the most feasible density for development on this site. The City intends to achieve a density of 33 du/acre through a zoning code amendment allowing a by-right density of 22-40 du/acre.

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Appendix C – Sites Inventory C-44
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Table C-22 - Site # S-3 First American Title: Site Description Site Description Site Image & Capacity Calculation
Address 7
th Ave 2 Southwest of Mission Street
Realistic Capacity utilizing factors =
(0.07 X 33) (.90) (.95) (.95) = 1 unit
50% of minimum density
APN 010-142-013-000
By-Right with 20%
Affordable
No, used in 4th and 5th cycles, but
nonvacant.

Size of Site 0.07 acre
Zoning SC
Allowable Density 0-22 du/ac*
Applied RHNA Affordability Above Moderate-Income: 2 units Existing Use Non-vacant
Infrastructure Availability Yes, no constraints.

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

Table C-23 - Site # S-3 First American Title: Capacity Assumptions Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the site 95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and single-family and current cost of construction.

Infrastructure availability No adjustment Not applicable, no constraints Environmental Constraints No adjustment No known site constraint Source: City of Carmel-by-the-Sea
Site #S-4 Office Building
The Office Building site is approximately 0.07 acres. The property is currently significantly underdeveloped. The one-store commercial building is occupied by a private foundation and used as professional office space. The site is in a transition zone from the Residential & Limited Commercial (RC) District to Single-Family Residential (R-1) District with a hotel to the north (that was originally constructed as apartments), an apartment complex to the south, and a duplex to the west.

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Appendix C – Sites Inventory C-45
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 The site is zoned Residential & Limited Commercial (RC), which allows residential densities up to 22 du/acre by-right, 33 du/acre with approval of a conditional use permit, 44 du/acre under the Density Bonus law, and up to 88 du/acre if the project is 100 percent affordable. Program 3.1.G has been included in this housing element to establish a by-right density of 22-40 du/acre for residential development in the commercial districts (see Chapter 2).

Developed at 33 du/acre, the gross acreage of the site would produce 2 above moderate-income units.

When factoring in potential land use controls and site improvements, the site’s realistic capacity, and typical densities, the site’s net acreage would yield a total of 1 above moderate-income unit (Tables C-24 and C-25). Based on recent developments, such as Ulrika Plaza and Scandia Lopez/Hakim, both located in the commercial district, the City has determined that 33 du/acre, including adjustments, is the most feasible density for development on this site. A density of 33 du/acre would be achieved through a zoning code amendment allowing a by-right density of 22-40 du/acre.

Table C-24 - Site #S-4 Office Building: Site Description Site Description Site Image & Capacity Calculation
Address Northeast corner of Monte Verde
Street and 7
th Avenue
Realistic Capacity utilizing factors =
(0.07 X 33) (.90) (.95) (.95) = 1 unit
50% of minimum density
APN 010-191-004-000
By-Right with 20%
Affordable
No, used in 4th and 5th cycles, but
nonvacant.

Size of Site 0.07 acre
Zoning RC
Allowable Density 0-22 du/ac*
Applied RHNA Affordability Above Moderate-Income: 2 units Existing Use Non-vacant; office space
Infrastructure Availability Yes, no constraints.

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

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Appendix C – Sites Inventory C-46
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Table C-25 - Site #S-4 Office Building: Capacity Assumptions Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the site 95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and single-family and current cost of construction.

Infrastructure availability No adjustment Not applicable, no constraints Environmental Constraints No adjustment No known site constraint Source: City of Carmel-by-the-Sea
Site # S-5 Yafa
The Yafa Building is located on a corner lot totaling 0.18 acres. A restaurant currently occupies the existing single-story commercial building.

Developed at 33 du/acre, the gross acreage of the site would produce 5 above moderate-income units.

When factoring in potential land-use controls and site improvements, the site's realistic capacity, and typical densities, the site's net acreage would yield 4 above moderate-income units (Tables C-26 and C27). Based on recent developments, such as Ulrika Plaza and Scandia Lopez/Hakim, both located in the commercial district, the City has determined that 33 du/acre, including adjustments, is the most feasible density for development on this site. A density of 33 du/acre would be achieved through a zoning code amendment allowing a by-right density of 22-40 du/acre.

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Appendix C – Sites Inventory C-47
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Table C-26 - Site #S-5 Yafa: Site Description
Site Description Site Image & Capacity Calculation
Address Northwest corner of Junipero and 5th
Avenue
Realistic Capacity utilizing factors =
(0.18 X 33) (.90) (.95) (.95) = 4 units
80% of minimum density
APN 010-097-007-000
By-Right with 20% Affordable No, used in 4th and 5th cycles, but nonvacant.

Size of Site 0.18 acre
Zoning SC
Allowable Density 0-22 du/ac*
Applied RHNA Affordability Above Moderate-Income: 5 units Existing Use Non-vacant; commercial space and
parking lot
Infrastructure Availability Yes, no constraints.

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

Table C-27 - Site #S-5 Yafa: Capacity Assumptions
Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the site 95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and single-family and current cost of construction.

Neighboring structures are multi-story.

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Appendix C – Sites Inventory C-48
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Developed at 33 du/acre, the gross acreage of the site would produce 3 above moderate units. When factoring in potential land-use controls and site improvements, the site's realistic capacity, and typical densities, the site's net acreage would yield 2 above moderate-income units (Table C-28 and Table C29). Based on recent developments, such as Ulrika Plaza and Scandia Lopez/Hakim, both located in the commercial district, the City has determined that 33 du/acre, including adjustments, is the most feasible density for development on this site. A density of 33 du/acre would be achieved through a zoning code amendment allowing a by-right density of 22-40 du/acre.

Table C-28 - Site #S-6 Three Garages: Site Description
Site Description Site Image & Capacity Calculation
Address Southwest of Junipero between 5th
and 6th Ave
Realistic Capacity utilizing factors =
(0.11 X 33) (.90) (.95) (.95) = 2 units
66% of minimum density
APN 010-098-004-000
By-Right with 20% Affordable No, used in 4th and 5th cycles, but nonvacant.

Size of Site 0.11 acre
Zoning SC
Allowable Density 0-22 du/ac*
Applied RHNA Affordability Above Moderate-Income: 3 units Existing Use Non-vacant; attached garages
Infrastructure Availability Yes, no constraints.

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

Table C-29 - Site #S-6 Three Garages: Capacity Assumptions Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the site 95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and single-family and current cost of construction.

Infrastructure availability No adjustment Not applicable, no constraints Environmental Constraints No adjustment No known site constraint Source: City of Carmel-by-the-Sea
ATTACHMENT 6

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Appendix C – Sites Inventory C-49
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Site #S-7 Carmel Realty Office
Carmel Realty Office is a 0.19-acre corner lot currently owned and used by Carmel Realty, a real estate agency, for office space. It is a single-story structure with low lot coverage, surrounded by two-story structures to the north and east.

The site is zoned Residential and Limited Commercial (RC), which currently allows residential densities up to 22 du/acre by-right, 33 du/acre with approval of a conditional use permit, 44 du/acre under the Density Bonus law, and up to 88 du/acre if the project is 100 percent affordable. Program 3.1.G has been included in this housing element to establish a by-right density of 22-40 du/acre for residential development in the commercial districts (see Chapter 2).

Developed at 33 du/acre, the gross acreage of the site would produce 6 above moderate-income units.

When factoring in potential land-use controls and site improvements, the site's realistic capacity, and typical densities, the site's net acreage would yield 5 above moderate-income units (Tables C-30 and C31). Based on recent developments, such as Ulrika Plaza and Scandia Lopez/Hakim, both located in the commercial district, the City has determined that 33 dwelling units per acre, including adjustments, is the most feasible density for development on this site. A density of 33 du/acre would be achieved through a zoning code amendment allowing a by-right density of 22-40 du/acre.

Table C-30 - Site #S-7 Carmel Realty Office: Site Description Site Description Site Image & Capacity Calculation
Address Northeast corner of Dolores Street and
8th Ave
Realistic Capacity utilizing factors =
(0.19 X 33) (.90) (.95) (.95) = 5 units
83% of minimum density
APN 010-145-008-000
By-Right with 20%
Affordable
No, used in 4th and 5th cycles, but
nonvacant.

Size of Site 0.19 acre
Zoning RC
Allowable Density 0-22 du/ac*
Applied RHNA Affordability Above Moderate-Income: 6 units Existing Use Non-vacant; office space
Infrastructure Availability Yes, no constraints.

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

ATTACHMENT 6

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Appendix C – Sites Inventory C-50
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Table C-31 - Site #S-7 Carmel Realty Office: Capacity Assumptions Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the site 95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and single-family and current cost of construction.

Infrastructure availability No adjustment Not applicable, no constraints Environmental Constraints No adjustment No known site constraint Source: City of Carmel-by-the-Sea
Site # S-8 Parashis/Millard Building
The Parashis/Millard Building is a 0.13-acre mixed-use parcel that includes one- and two-story buildings. Commercial uses primarily occupy the first floor, while professional offices historically occupied the second floor. The second floor has been undergoing a remodel for a few years. The property is now under new ownership and plans for the property include additional residential development.

The site is zoned Central Commercial (CC), which currently allows residential densities up to 22 du/acre by-right, 33 du/acre with approval of a conditional use permit, 44 du/acre under the Density Bonus law, and up to 88 du/acre if the project is 100 percent affordable. Program 3.1.G has been included in this housing element to establish a by-right density of 22-40 du/acre for residential development in the commercial districts (see Chapter 2).

Developed at a minimum of 33 du/acre, the gross acreage of the site would produce 4 above moderateincome units. When factoring in potential land-use controls and site improvements, the site's realistic capacity, and typical densities, the site's net acreage would yield 3 above moderate-income units (Tables C-32 and C-33). Based on recent developments, such as Ulrika Plaza and Scandia Lopez/Hakim, both located in the commercial district, the City has determined that 33 du/acre, including adjustments, is the most feasible density for development on this site. A density of 33 du/acre would be achieved through a zoning code amendment allowing a by-right density of 22-40 du/acre.

City staff met with the new property owner in June 2022. They are interested in redeveloping the site with a new mixed-use building (similar to the MacDonald Gallery building one block west). As of August 2025, plans to add four apartments to the site are in design development.

ATTACHMENT 6

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Appendix C – Sites Inventory C-51
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Table C-32 - Site #S-8 Parashis/Millard Building: Site Description Site Description Site Image & Capacity Calculation
Address Northwest corner of Dolores Street
and 6th Ave
Realistic Capacity utilizing factors =
(0.13 X 33) (.90) (.95) (.95) = 3 units
75% of minimum density
APN 010-138-006-000
By-Right with 20% Affordable No, used in 4th and 5th cycles, but nonvacant.

Size of Site 0.13 acre
Zoning CC
Allowable Density 0-22 du/ac**
Applied RHNA Affordability Above Moderate-Income: 4 units Existing Use Non-vacant; commercial space
Infrastructure Availability Yes, no constraints.

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

Table C-33 - Site #S-8 Parashis/Millard Building: Capacity Assumptions Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the
site
95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and singlefamily and current cost of construction.

Infrastructure availability No adjustment Not applicable, no constraints Environmental Constraints No adjustment No known site constraint Source: City of Carmel-by-the-Sea
Site #S-9 The Agency
The Agency is a single-story real estate office located on a 0.09-acre corner lot. It has low lot coverage and is surrounded by two-story structures to the west and by two-story structures across the street to the east.

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Appendix C – Sites Inventory C-52
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 included in this housing element to establish a by-right density of 22-40 du/acre for residential development in the commercial districts (see Chapter 2).

Developed at 33 du/acre, the gross acreage of the site would produce 2 above moderate-income units.

When factoring in potential land-use controls and site improvements, the site's realistic capacity, and typical densities, the site's net acreage would yield 2 above moderate-income units (Tables C-34 and C35). Based on recent developments, such as Ulrika Plaza and Scandia Lopez/Hakim, both located in the commercial district, the City has determined that 33 du/acre, including adjustments, is the most feasible density for development on this site. A density of 33 du/acre would be achieved through a zoning code amendment allowing a by-right density of 22-40 du/acre.

Table C-34 - Site #S-9 The Agency: Site Description
Site Description Site Image & Capacity Calculation
Address Northwest corner of Ocean and
Dolores
Realistic Capacity utilizing factors =
(0.09 X 33) (.90) (.95) (.95) = 2 units
100% of minimum density
APN 010-139-001-000
By-Right with 20%
Affordable
No, used in 4th and 5th cycles, but
nonvacant.

Size of Site 0.09 acre
Zoning CC
Allowable Density 0-22 du/ac*
Applied RHNA Affordability Above Moderate-Income: 2 units Existing Use Non-vacant; retail space
Infrastructure Availability Yes, no constraints.

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

Table C-35 - Site #S-9 The Agency: Capacity Assumptions Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the
site
95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and single-family and current cost of construction.

Infrastructure availability No adjustment Not applicable, no constraints Environmental Constraints No adjustment No known site constraint Source: City of Carmel-by-the-Sea
ATTACHMENT 6

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Appendix C – Sites Inventory C-53
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Site # S-10 Enzos
Enzo’s is a 0.15-acre corner lot adjacent to the Doud Arcade. It is a single-story structure occupied by a restaurant that could either be fully redeveloped or receive a second-floor addition.

Developed at 33 du/acre, the gross acreage of the site would produce 4 above moderate-income units.

When factoring in potential land-use controls and site improvements, the site's realistic capacity, and typical densities, the site's net acreage would yield 4 above moderate-income units (Tables C-36 and C37). Based on recent developments, such as Ulrika Plaza and Scandia Lopez/Hakim, both located in the commercial district, the City has determined that 33 dwelling units per acre, including adjustments, is the most feasible density for development on this site. A density of 33 du/acre would be achieved through a zoning code amendment allowing a by-right density of 22-40 du/acre.

Table C-36 - Site #S-10 Enzos: Site Description
Site Description Site Image & Capacity Calculation
Address San Carlos 2 Southwest of Ocean
Realistic Capacity utilizing factors =
(0.15 X 33) (.90) (.95) (.95) = 4 units
100% of minimum density
APN 010-146-001-000
By-Right with 20%
Affordable
No, used in 4th and 5th cycles, but
nonvacant.

Size of Site 0.15 acre
Zoning CC
Allowable Density 0-22 du/ac*
Applied RHNA Affordability Above Moderate-Income: 4 units Existing Use Non-vacant; commercial
Infrastructure Availability Yes, no constraints.

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

ATTACHMENT 6

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Appendix C – Sites Inventory C-54
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Table C-37 - Site #S-10 Enzos: Capacity Assumptions
Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the site 95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and single-family and current cost of construction.

Infrastructure availability No adjustment Not applicable, no constraints Environmental Constraints No adjustment No known site constraint Source: City of Carmel-by-the-Sea
Site # S-11: Paseo San Carlos Square (Parcel 1)
Paseo San Carlos Square (Parcel 1) is a multi-tenant commercial building located on a 0.18-acre parcel.

It has low lot coverage and is a single-story structure that is surrounded by two-story structures to the west and across the street to the east.

Developed at 33 du/acre, the gross acreage of the site would produce 5 above moderate units. When factoring in potential land-use controls and site improvements, the site's realistic capacity, and typical densities, the site's net acreage would yield 4 above moderate-income units (Tables C-38 and C-39).

Based on recent developments, such as Ulrika Plaza and Scandia Lopez/Hakim, both located in the commercial district, the City has determined that 33 dwelling units per acre, including adjustments, is the most feasible density for development on this site. A density of 33 du/acre would be achieved through a zoning code amendment allowing a by-right density of 22-40 du/acre.

ATTACHMENT 6

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Appendix C – Sites Inventory C-55
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Table C-38 - Site #S-11 Paseo San Carlos Square: Site Description Site Description Site Image & Capacity Calculation
Address San Carlos 2 Northwest of 7th Ave
Realistic Capacity utilizing factors =
(0.18 X 33) (.90) (.95) (.95) = 4 units
80% of minimum density
APN 010-146-003-000
By-Right with 20%
Affordable
No, used in 4th and 5th cycles, but
nonvacant.

Size of Site 0.18 acre
Zoning CC
Allowable Density 0-22 du/ac*
Applied RHNA Affordability Above Moderate-Income: 5 units Existing Use Non-vacant; commercial space
Infrastructure Availability Yes, no constraints.

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

Table C-39 - Site #S-11 Paseo San Carlos Square: Capacity Assumptions Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the
site
95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and single-family and current cost of construction.

Infrastructure availability No adjustment Not applicable, no constraints Environmental Constraints No adjustment No known site constraint Source: City of Carmel-by-the-Sea
Site # S-12: Carmel Office Supply & Business Center
Carmel Office Supply & Business Center is a 0.09-acre parcel that includes a single-story structure that neighbors a two-story structure to the south. The building contains two commercial tenant spaces, one of which is currently vacant.

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Appendix C – Sites Inventory C-56
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 included in this housing element to establish a by-right density of 22-40 du/acre for residential development in the commercial districts (see Chapter 2).

Developed at 33 du/acre, the gross acreage of the site would produce 2 above moderate units. When factoring in potential land-use controls and site improvements, the site's realistic capacity, and typical densities, the site's net acreage would yield 2 above moderate-income units (Tables C-40 and C-41).

Table C-40 - Site #S-12 Carmel Office Supply & Business Center: Site Description Site Description Site Image & Capacity Calculation
Address Lincoln Southeast of Ocean
Realistic Capacity utilizing factors =
(0.09 X 33) (.90) (.95) (.95) = 2 units
100% of minimum density
APN 010-147-010-000
By-Right with 20%
Affordable
No, used in 4th and 5th cycles, but
nonvacant.

Size of Site 0.09 acre
Zoning CC
Allowable Density 0-22 du/ac*
Applied RHNA Affordability Above Moderate-Income: 2 units Existing Use Non-vacant; commercial space
Infrastructure Availability Yes, no constraints.

3.1.G establishes a by-right density of 22-40 du/acre in the commercial zones. Assumptions for site development use 33 du/acre.

Table C-41 - Site #S-12 Carmel Office Supply and Business Center: Capacity Assumptions Site Description Adjustment Reasoning
Land use controls and site
improvements
90% For net acreage due to challenging site geometry, on-site improvements, and utility easement needs.

Realistic capacity of the site 95% Based on market demand for medium-density housing types such as condominiums, apartments, townhomes, and single-family and current cost of construction.

Infrastructure availability No adjustment Not applicable, no constraints Environmental Constraints No adjustment No known site constraint Source: City of Carmel-by-the-Sea
ATTACHMENT 6

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Appendix C – Sites Inventory C-57
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 C.5 Summary of RHNA Strategies
The revised Housing Element provides a comprehensive strategy to meet the City’s RHNA through diverse housing options and locations.

Table C-42 -Summary of Sites Inventory
Very LowIncome UnitsLowIncome UnitsModerateIncome Units Above
ModerateIncome Units Total Units
RHNA Figures
Total RHNA 113 74 44 118 349
Credits (ADUs and Pipeline Projects) 13 13 13 29 68
Remaining RHNA 100 61 31 89 281
ADUs 21 21 21 7 70
Hotel Conversion 40 40 40 41 161
Church Properties 33 32 0 0 65
All Saints’ Episcopal 10 10 0 0 20
First Church of Christian Science 7 6 0 0 13
Church of the Wayfarer 16 16 0 0 32
Live/Work Units 39 39 0 0 78
Mixed-Income Incentive Program 2 2 2 6 12
Other Housing Opportunities 0 2 0 51 53
Forest Cottages Specific Plan 0 2 0 4 6
Other Market Rate Scattered Sites 0 0 0 47 47
Total Capacity 135 136 63 105 439
Over Remaining RHNA 35 75 32 16 158
% Over Remaining RHNA 35% 123% 103% 18% 56%
Source: City of Carmel-by-the-Sea, Community Planning & Building Department C.6 Technical Background Documents
Exhibit A - Hotel Conversion Full Proforma
Table C-43 - Basic Pro Forma of Hotel Program 1.1.F
Sample Hotel Operating at one standard deviation below average RevPAR in Carmel Market Rooms 19
Average Daily Rate (ADR) $ 211
Occupancy 68%
Revenue Per Available Room (RevPAR) $143
Annual Revenue $ 995,034 $ 52,370 per key
Net Operating Income (NOI) 35% $ 348,262 $ 18,330
Valuation Method
Gross Rent Multiplier (GRM) 7.7% $ 7,612,009
Cap Rate Value 4.50% $ 7,739,152
Average Valuation $ 7,675,580 $ 403,978
Sample Hotel Conversion to Affordable Housing
Hotel to Housing Conversion Ratio 85%
Affordable Housing Units Created 16
ATTACHMENT 6

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Appendix C – Sites Inventory C-58
Carmel-by-the-Sea 6th Cycle Housing Element Amendment Update Adopted November 2025 Affordable Housing Type Approx. Share Units Created
Efficiency/Studio (1) 50% 8
1 Bedroom (1.5) 50% 8
Efficiency/Studio (1) Qty Mo. Rent Mo. Revenue
Very Low 2 $ 1,159 $ 2,318
Low 2 $ 1,854 $ 3,708
Moderate 2 $ 2,168 $ 4,336
Market Rate 2 $ 2,600 $ 5,200
1 Bedroom (1.5) Qty Monthly. Rent Monthly Revenue
Very Low 2 $1,325 $ 2,650
Low 2 $ 2,120 $ 4,240
Moderate 2 $ 2,478 $ 4,956
Market Rate 2 $ 3,000 $ 6,000
Annual Housing Revenue $ 400,896 $ 25,056 per Unit
Maintenance 20% $ (80,179)
Utilities (excludes Market Rate Units) $ (18,000)
Net Operating Income (NOI) $ 302,717 $ 18,920
Cap Rate Value* 6.00% $ 5,045,280 $ 315,330
Summary
Purchase of Hotel $ 7,675,580
Conversion Costs Per $ 100,000 $ 1,600,000
Total Developer Investment $ 9,275,580
Sale of Hotel Keys Per $ 438,656 $ 8,334,464
Sale of Affordable Housing $ 5,045,280
Total Developer Return $ 13,379,744
Return on Investment (ROI) 44.25%
* Deed-Restricted Affordable Housing, compared to market rate multifamily properties which fall in the 4% range.

ATTACHMENT 6

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HE6Adopted
Program
No. Program Name Timeframe

1.1.A Adequate Sites 06/2031

1.1.B City-Owned Sites 12/2025

1.1.C Development on Small Sites 12/2024

1.1.D Allow Religious Institution Affiliated Housing 12/2026 Development

1.1.E City Partnership with the Carmel 12/2027 Foundation to Develop Affordable Housing

1.2.A Water Distribution Prioritization for 06/2025 Affordable Housing

1.2.B Address Infrastructure Constraints 06/2031

1.3.A Condominium Conversions 06/2031

1.3.B Overnight Visitor Accommodation 06/2027 (Conversion) Development Transfer Rights

1.3.C Accessory Dwelling Units 12/2026

1.3.D Overnight Visitor Accommodation -
12/2026 Employee Housing Program

1.3.E Amend the A-2 Zoning District 12/2025

1.3.F Employee Housing 12/2024

1.3.G Manufactured Homes on a Foundation 12/2024 System

1.3.H Senate Bill 35 and Senate Bill 423 12/2024 Processing Procedure Implement State Law SB10 Opportunities to

1.3.I Maximize Feasibility of Development in 12/2024
Strategic Locations

1.3.J Emergency Shelters 12/2024

1.3.K Forest and Beach Commission Required 12/2024 Findings

1.4.A Eliminate Unncessary Use Permits 12/2024

1.4.B Objective Design and Development 12/2025 Standards

2.1.A Incentives for Mixed-Use Development 12/2024

2.1.B Permanent Housing 06/2031

2.1.C Monitor Affordable Housing Stock 06/2025

2.1.D Establish Affordable Housing Trust Fund 06/2031

2.2.A Historic Preservation Educational Programs 06/2031

2.3.A Preserve and Increase Upper Floor 12/2031 Residential Uses

2.4.A Housing Rehabilitation and Maintenance 06/2031 Information

3.1.A Mixed-Use Affordable Housing 12/2027

3.1.B Housing for Extremely Low-Income 06/2031 Households

3.1.C Density Bonus 12/2024

3.1.D Reduce Entitlement and Development Fees 07/2025

3.1.E Reduced Parking Requirements 12/2024

3.1.F Expedited Processing Procedures 12/2024

3.1.G Establish Minimum Densities and Ministerial 12/2024 Approval Process

3.2.A Reasonable Accommodation Procedures 06/2025

3.2.B Housing Mobility 2027

3.2.C Local Universal Design Standards 06/2026

3.2.D Family Friendly Housing Mid-Term

3.3.A Zoning for Transitional and Supportive 12/2024 Housing

3.3.B Low-Barrier Navigation Centers 12/2024

3.3.C Unlicensed Residential Care Facilities 12/2024

3.3.D Single Room Occupancy (SRO) Units 12/2024

4.1.A Water Conservation 06/2031

4.1.B Energy Conservation and Green Building 06/2031

5.1.A Fair Housing Services 06/2031

5.1.B Housing Choice Voucher Program 06/2031

5.1.C Shared Housing Information 06/2031

5.1.D Farmworker Housing Ongoing

5.2.A Support Community Orqanizations 06/2031
HE6 Amendment
Program
No. Program Name

1.1.A Adequate Sites

1.1.B Development on Small Sites

1.1.C Live/Work Housing

1.1.D Mixed-Income Incentive Program

1.1.E Affordable Housing on Religious Facility
Properties

1.1.F Hotel-to-Residential Conversion

1.1.G Hotel Employee Housing Program

1.1.H Accessory Dwelling Units

1.2.A Water Distribution Prioritization for
Affordable Housing

1.2.B Address Infrastructure Constraints

1.3.A Condominium Conversions

1.3.B Employee Housing (Farmworker)

1.3.C Manufactured Homes on a Foundation
System

1.3.D Senate Bill 35 and Senate Bill 423
Processing Procedure

1.3.E Emergency Shelters

1.3.F Forest and Beach Commission Required
Findings

1.4.A Modify or Eliminate Onerous Use
Permits

1.4.B Objective Design and Development
Standards

1.4.C By-Right Approval

2.1.A Incentives for Mixed-Use Development

2.1.B Permanent Housing

2.1.C Monitor Affordable Housing Stock

2.1.D Establish Affordable Housing Trust Fund

2.2.A Historic Preservation Educational
Programs

2.3.A Preserve and Increase Upper Floor
Residential Uses

2.4.A Housing Rehabilitation and Maintenance
Information

3.1.A Mixed-Use Affordable Housing

3.1.B Housing for Extremely Low-Income
Households

3.1.C Density Bonus

3.1.D Reduced Entitlement and Development
Fees

3.1.E Reduced Parking Requirements

3.1.F Expedited Processing Procedures

3.1.G Establish Minimum Densities

3.2.A Reasonable Accommodation Procedures

3.2.B Housing Mobility

3.2.C Family Friendly Housing

3.3.A Zoning for Transitional and Supportive
Housing

3.3.B Low-Barrier Navigation Centers

3.3.C Unlicensed Residential Care Facilities

3.3.D Single Room Occupancy (SRO) Units

4.1.A Water Conservation

4.1.B Energy Conservation and Green Building

5.1.A Fair Housing Services

5.1.B Housing Choice Voucher Program

5.1.C Shared Housing Information

5.1.D Farmworker Housing

5.2.A Support Community Orqanizations
Adopted
Program Timeframe
No.
12/2031

1.1.C 06/2028
I
06/2026
06/2028

1.1.D 06/2028

1.3.B 12/2025

1.3.D 06/2027

1.3.C 12/2026
12/2025
12/2031
12/2031

1.3.F 06/2026

1.3.G 06/2026

1.3.H 12/2026

1.3.J 06/2026

1.3.K 06/2026
06/2028
06/2027
12/2031
06/2028
12/2031
06/2026
12/2026
12/2031
12/2031
12/2031
06/2028
12/2031
12/2031
07/2026
06/2026
06/2027
06/2028
10/2025
12/2027

3.2.D 06/2028
06/2026
06/2026
06/2026
06/2026
12/2031
12/2031
12/2031
12/2031
12/2031
Ongoing
12/2031
Legend
Deleted
Modified
Supercharged
New
ATTACHMENT 7

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City of Carmel-by-the-Sea

COMMUNITY PLANNING AND BUILDING DEPARTMENT

POST OFFICE BOX CC
CARMEL-BY-THE-SEA, CA 93921
(831) 620-2010 OFFICE
California Department of Housing and Community Development (HCD) 2025 Income and Rent Limits for Monterey County
2025 Annual Income Limits for Monterey County
Income Limits Acutely Low Extremely Low Very Low Low Median Moderate 0-15% 16-30% 31-50% 51-80% 81-100% 101-120%
No. of People
1 $ 11,000 $ 30,400 $ 50,600 $ 81,000 $ 73,150 $ 87,800 2 $ 12,550 $ 34,750 $ 57,850 $ 92,600 $ 83,600 $ 100,300 3 $ 14,150 $ 39,100 $ 65,100 $ 104,150 $ 94,050 $ 112,850 4 $ 15,700 $ 43,400 $ 72,300 $ 115,700 $ 104,500 $ 125,400 5 $ 16,950 $ 46,900 $ 78,100 $ 125,000 $ 112,850 $ 135,450 6 $ 18,200 $ 50,350 $ 83,850 $ 134,250 $ 121,200 $ 145,450 2025 Monthly Income Limits for Monterey County
Income Limits Acutely Low Extremely Low Very Low Low Median Moderate 0-15% 16-30% 31-50% 51-80% 81-100% 101-120%
No. of People
1 $ 916.67 $ 2,533.33 $ 4,216.67 $ 6,750.00 $ 6,095.83 $ 7,316.67 2 $ 1,045.83 $ 2,895.83 $ 4,820.83 $ 7,716.67 $ 6,966.67 $ 8,358.33 3 $ 1,179.17 $ 3,258.33 $ 5,425.00 $ 8,679.17 $ 7,837.50 $ 9,404.17 4 $ 1,308.33 $ 3,616.67 $ 6,025.00 $ 9,641.67 $ 8,708.33 $ 10,450.00 5 $ 1,412.50 $ 3,908.33 $ 6,508.33 $ 10,416.67 $ 9,404.17 $ 11,287.50 6 $ 1,516.67 $ 4,195.83 $ 6,987.50 $ 11,187.50 $ 10,100.00 $ 12,120.83 2025 Monthly Rent Limits for Monterey County
Income Limits Acutely Low Extremely Low Very Low Low Median Moderate 0-15% 16-30% 31-50% 51-80% 81-100% 101-120%
No. of People
1 $ 275.00 $ 760.00 $ 1,265.00 $ 2,025.50 $ 1,828.75 $ 2,195.00 2 $ 313.75 $ 868.75 $ 1,446.25 $ 2,315.00 $ 2,090.00 $ 2,507.50 3 $ 353.75 $ 977.50 $ 1,627.50 $ 2,603.75 $ 2,351.25 $ 2,821.25 4 $ 392.50 $ 1,085.00 $ 1,807.50 $ 2,892.50 $ 2,612.50 $ 3,135.00 5 $ 423.75 $ 1,172.50 $ 1,952.50 $ 3,125.00 $ 2,821.25 $ 3,386.25 6 $ 455.00 $ 1,258.75 $ 2,096.25 $ 3,356.25 $ 3,030.00 $ 3,636.25 2025 Market Rate Rents for Zip Code 93921
Efficiency 1-Bedroom 2-Bedroom 3-Bedroom 4-Bedroom
$ 3,320 $ 3,410 $ 4,100 $ 5,530 $ 6,030
Data Sources:

1. State of California Department of Housing and Community Development, Division of Housing Policy Development, letter dated April 23, 2025, 2025 State Income Limits.

2. HUD User FY 2025 Fair Market Rent Documentation System, The FY 2025 Salinas, CA MSA Small Area FMRs for Zip Code 93921.

ATTACHMENT 8

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Oct 20, 2025
City of Carmel-by-the-Sea
P.O. Box CC
Carmel-by-the-Sea, CA 93921
Re: Proposed Amendment to Housing Element
By email: [email protected]
Cc: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
Dear Carmel-by-the-Sea Planning Commission,
The California Housing Defense Fund (“CalHDF”) submits this letter to remind the City of its obligation to abide by all relevant state housing laws when considering an amendment to the City’s Housing Element, as contemplated by agenda item 1 from the October 20, 2025 Planning Commission meeting, which calls for removing the City-owned sites known as Vista Lobos, Sunset Center North, and Sunset Center South.

The City’s proposed amendments to its Housing Element would violate state law, including recently decided appellate case law, in several ways, as detailed below. The City’s contemplated approach brings a significant risk of litigation.

Background
The City’s Housing Element of its General Plan must provide an inventory of sites where housing is likely to be built in the upcoming cycle for each income level in its Regional Housing Needs Allocation (“RHNA”). (Gov. Code § 65583, subd. (a)(3).) The City’s RHNA includes the construction of 113 very low-income units, 74 low-income units, 44 moderate-income units, and 118 above moderate income units. The City’s Housing Element Site Inventory allocates 78 very low-income units to the three City-owned sites, along with 46 low-income units and 25 moderate-income units. Together, these sites account for the vast majority of lower-income units in the City’s Housing Element. 2201 Broadway, PH1, Oakland, CA 94612
www.calhdf.org
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Additionally, these are the three best sites for potential funding as Low-Income Housing Tax Credit (“LIHTC”) projects, given their size, potential unit yield, and land cost. Were these three sites to be removed from the Housing Element, the Site Inventory would have a serious deficit, falling well short of both the Housing Element’s target production of 410 units, including 201 lower-income units, and the RHNA of 349 units, including 187 lower-income units. Because removing these sites would cause a deficit of lower-income units in the City’s Site Inventory, the City’s Housing Element would no longer be in substantial compliance with state law.

The City has proposed to make up for this shortfall by amending its Housing Element to establish multiple new programs, including:
● Program 1.1.C: Live/Work Housing
● Program 1.1.B: Development on Small Sites / Program 1.1.D: Mixed-Income Incentive Program
● Program 1.1.E: Affordable Housing on Religious Facility Properties ● Program 1.1.F: Hotel- to-Residential Conversion (Hotel ‘Key’ Transfer) However, each of these programs are defective with respect to state law, as discussed infra.

Underlying Purpose of the Amendment
Before addressing the substance of the proposed amendment to the City’s Housing Element, it is worth addressing the very purpose of the amendment. The City’s existing, approved Housing Element plans to develop affordable housing via a tried and true technique - the disposal of City-owned land to affordable developers in order to build 100% affordable housing, almost certainly using federal Low-Income Housing Tax Credits (“LIHTC”).

Pages 2-1 and 2-2 of the amended Housing Element contain the City’s justification for this amendment (emphasis added):
“Beginning in Summer 2024, the City of Carmel-by-the-Sea began exploring strategies to further enhance the City’s ability in delivering affordable housing opportunities throughout the community, and developing alternative strategies that present near-term potential for affordable units … The City is proud of the policies and programs that follow below. They represent an honest desire by both the local government and residents of Carmel to create real affordable housing opportunities in what, by all accounts, is an unaffordable place to live. This shared desire is evidenced by how these policies and programs came together … it leveraged the knowledge of both residents and City staff, making it possible to turn Carmel’s unique constraints into opportunities for the creation of new housing.” 2 of 16
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However, these statements are simply not true. This amendment was created because members of the community have sought to block the development of 100% affordable housing on the City-owned sites.

The public record makes it clear that an antipathy towards housing for low-income households underlies this effort to amend the Housing Element.

A news article has documented how the City Council directed City staff to work with a group of local activists to amend the housing element to exclude the City sites, a group that evidently includes former Council Member Victoria Beach, who is quoted as saying, “The idea of clumping people who are lower-income together is a discredited housing strategy.” The development of housing in which 100% of units are affordable to lower-income households is in fact the primary method of developing affordable housing across the nation. Across the country, LIHTC funding has placed into service more than 3.7 million affordable homes, according to the federal government. In California, LIHTC developments are almost always 100% affordable to lower-income households. The LIHTC program, particularly when paired with local or state subsidy, is the primary way that California develops affordable housing.

The City, by choosing to abandon a 100% affordable strategy involving the disposition of City-owned land, is choosing riskier, unproven models that are much less likely to result in the development of housing affordable to lower-income households during the planning period. And the City seems to be doing so in order to appease residents who do not want 100% affordable housing developed in their community.

Lack of Site Inventory
Before addressing the various major legal problems in the proposed amendment, it is worth noting the fact that the amendment fails to include an adequate site inventory. Appendix C largely rehashes and expands upon various Housing Element programs. However, it fails to complete a critical Housing Element task - an inventory of land with specific numbers of units by income level assigned to each parcel.

This duty is imposed upon the City by state law. Government Code section 65583, subdivision (a)(3) requires that the Housing Element include::
(a)(3) An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites, and an analysis of the relationship of the sites 3 of 16
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identified in the land inventory to the jurisdiction’s duty to affirmatively further fair housing.

If this were not clear enough, page 9 of the HCD’s Housing Element Site Inventory Guidebook states:

Identify which RHNA income category that each site in the inventory is anticipated to accommodate. On the site inventory, specify whether the site or a portion of the site is adequate to accommodate lower income housing, moderate-income housing, or abovemoderate-income housing. Sites can accommodate units for more than one income category. However, the inventory should indicate the number of units of each income category, and together the total of units attributed to each income category may not exceed total units attributed to the site, so that no unit is designated for more than one income category.

The proposed amendment fails in this elementary task.

Given that Appendix C, Sites Inventory, does not actually include a site inventory, below is a discussion of tables in Appendix C that do identify potential housing sites:
● Tables C-2 and C-3 identify pipeline projects, which is appropriate. ● Table C-8 identifies 45 different hotels that could conceivably be converted into affordable housing, but it fails to identify how many units by income level are planned for each site. However, Table C-42 assigns 80 lower-income units to the hotel conversion program. It is unclear which of these hotels are actually planned for lower-income units.
● Table C-10 identifies three churches that are planned for conversion to affordable housing, with unit counts and income levels. This is acceptable for this specific program. [The program itself violates state law for other reasons, including minimum site capacity issues, as discussed infra.]
● Table C-15 identifies eight parcels for the Live/Work program along with a number of units achievable on each site, but it fails to identify which income levels the sites will serve.
○ It is worth noting that on page C-29 the Housing Element states that only low-income units will be allowed to be developed in these buildings. However, Table C-15 assigns less than the minimum number of units required for low-income sites, as discussed infra.
○ Disturbingly, Table C-15 is entitled “Properties with Live/Work Potential for Lower-Income Housing.” It is unclear if the City is actually committing to rezoning these parcels, or if it even considers these particular parcels to be on its site inventory.
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● Table C-16 includes two parcels that will be rezoned and it also includes the number of units by income levels. However, Table C-16 assigns less than the minimum number of units required for low-income sites, as discussed infra. ● Table C-18 includes pipeline sites and recycled sites, with units by income level, which is appropriate.

In sum, the proposed amendment fails to include a site inventory that meets the requirements of state law. Even when taking all the tables in Appendix C in aggregate, the amendment simply does not supply enough information to constructively generate a site inventory. Crucially, Table C-8 fails to identify how many units by income level are planned for each hotel site.

However, the site inventory is superseded in importance by the failure of the amendment’s housing programs, which do not satisfy Housing Element Law.

Required Minimum Number of Units Per Lower-Income Site
The five aforementioned programs fail to follow the requirements of state law regarding the minimum number of units per site.

Zoning code amendments, zoning map amendments, or both are required to implement each of the five listed programs. This means that the current zoning does not accommodate the programmed RHNA. For sites where the current zoning does not accommodate the programmed RHNA, Government Code section 65583.2, subdivision (h)(2) requires that the City rezone each site slated for a portion of its low-income RHNA for at least 16 units per site.

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low-income site to accommodate at least 16 units.

However, many of the sites in the City’s proposed amended Housing Element do not allow at least 16 units of residential development.
● Program 1.1.C: Live/Work Housing - AFFH
○ All the sites in Table C-15 have between 7 and 13 units of capacity ● Program 1.1.D: Mixed-Income Incentive Program / Program 1.1.B: Development on Small Sites
○ Each of the two sites listed in Table C-16 have fewer than 16 units of capacity, with 010-138-020 planned for 7 units and 010-142-001 planned for 5 units ● Program 1.1.E: Affordable Housing on Religious Facility Properties - AFFH ○ First Church of Christian Science’s site capacity is only 13 units ○ Rezoning required as the City may not rely on SB 4 in lieu of a rezoning, as discussed infra. This means that the 16-unit minimum applies. 5 of 16
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● Program 1.1.F: Hotel-to-Residential Conversion (Hotel ‘Key’ Transfer) - AFFH ○ The following hotels listed in table C-7 have less than 16 rooms:
■ Briarwood Inn
■ Briarwood Inn II/Holland Court Inn
■ Carmel Cottage Inn LLC
■ Carmel Country Inn LLC
■ Carmel Garden Inn
■ Carriage House Inn
■ Forest Lodge
■ Lamplighter Inn
■ Monte Verde Inn
■ Monte Verde Inn East
■ Ocean View Lodge
■ Sea View Inn
■ Sunset House
■ Tally-Ho Inn
■ The Homestead
■ Vagabond House
○ As discussed supra, Program 1.1.F also fails to satisfy state law because the site inventory does not assign units by income level to the various sites The City’s Housing Element therefore does not comply with state law because it fails to satisfy the requirement that each lower-income site accommodate at least 16 units. (See Gov. Code, § 65583.2, subd. (h)(2).) This is a basic requirement for any housing element.

Required Local Zoning for Religious Properties Program
Program 1.1.E: Affordable Housing on Religious Facility Properties has legal defects beyond the insufficient number of units on one of the sites. Specifically, the City cannot rely on the use of SB 4 (Gov. Code, § 65913.16) to generate housing on those sites. As discussed on page 14 of HCD’s Housing Element Site Inventory Guidebook, the base density of each site must allow the achievement of the number of units planned in the site inventory.

Furthermore, SB 4 imposes a number of constraints on housing development. The City must analyze and account for these constraints in its Housing Element. Specifically, SB 4 requires that projects be both 100% affordable and pay prevailing wage for construction labor. This requirement, in addition to the meager number of units planned for each site, means that potential projects on these sites must receive a full LIHTC award and additional governmental subsidy (“soft money”) in order for a project to pencil out. The City must explain how it anticipates that such projects will be feasible or where the additional soft money will come from to pay the prevailing wage requirement of SB 4. 6 of 16
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The City should remember that it must make required findings based on substantial evidence that the existing uses on these sites are likely to discontinue during the planning period, as required by Government Code section 65583.2, subdivision (g)(2), given that the City is relying on nonvacant sites for at least 50% of its low-income RHNA. The City should bear in mind the prevailing wage requirements of SB 4 when making these findings.

Instead of relying on SB 4, the City must include a plan to rezone these church sites in order to allow residential development on a by-right basis, as is required by Government Code section 65583.2, subdivision (h)(1).

Additional Legal Defects in Mixed-Income Program
Program 1.1.D: Mixed-Income Incentive Program has legal defects beyond the insufficient number of units planned for each site. The City states that it is planning on using incentive zoning to achieve the number of low-income units on each site. However, this approach is forbidden by HCD’s Housing Element Site Inventory Guidebook. From page 14 of the Guidebook:

The analysis of “appropriate zoning” should not include residential buildout projections resulting from the implementation of a jurisdiction’s inclusionary program or potential increase in density due to a density bonus, because these tools are not a substitute for addressing whether the underlining (base) zoning densities are appropriate to accommodate the RHNA for lower income households.

The City must instead rezone each of these potential mixed-income sites to achieve both the minimum density and minimum unit count prescribed by law. (Gov. Code, § 65583.2, subd. (h)(2).) And the City must allow residential development on a by-right basis on each site. (Id. at subd. (h)(1).)
Additional Legal Defects in Hotel Conversion Program
Program 1.1.F: Hotel-to-Residential Conversion (Hotel ‘Key’ Transfer) fails to satisfy the requirements of state law regarding the Housing Element Site Inventory. Government Code section 65583.2, subdivisions (b) and (c) spell out what the Housing Element’s Site Inventory must contain. As discussed supra, the site inventory must list (among other information) each site by APN along with the number of units at each income level that each site will accommodate.

The City’s proposed amended Housing Element fails to accomplish this basic task. The Housing Element lists a large number of hotels that could potentially be converted, but fails to assign specific numbers of units to specific properties at specific income levels. 7 of 16
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And, as discussed supra, the program does not have at least 16 units on each lower-income site, violating state law. (See Gov. Code, § 65583.2, subd. (h)(2).) Requirement for By-Right Development
The program also fails to comply with Government Code section 65583.2, subdivision (h)(1), which mandates that the City allow residential development on a by-right basis for residential projects on low-income sites where at least 20% of the units are affordable. If the City plans on allowing hotels to convert to residential use in order to satisfy its low-income RHNA, then it must allow residential use on those sites on a by-right basis.

Ability to Make Findings Re Discontinuance of Uses
It is also unlikely that the City can make the required findings based on substantial evidence that the existing uses on these sites are likely to discontinue during the planning period, as required by Government Code section 65583.2, subdivision (g)(2), given that the City is relying on nonvacant sites for at least 50% of its low-income RHNA.

The program relies on the sale of “hotel keys” (i.e. a transfer of development rights program, akin to taxi medallions or liquor licenses). In order for this program to function, there must be sufficient zoned capacity of commercial land to accommodate new hotels, so that there will be a market created for the “hotel keys.” However, the program has deeper flaws.

The City is counting on the conversion of failing hotels into affordable housing while at the same time relying on a $438,000 market value of each “hotel key.” This is an internal contradiction of the program - it is unclear why hotels are failing and ripe for conversion to affordable housing if there is such overwhelming demand for hotel rooms that developers are willing to pay $438,000 per door just for the right to develop/operate a hotel room.

Additionally, the anticipated market value of each “hotel key” seems highly inflated. To put it into perspective, in 2018, St. Patrick’s Cathedral in Midtown Manhattan was attempting to sell its development rights at an asking price of $385 per square foot, and JP Morgan Chase purchased development rights for its new Midtown office building at $350 per square foot. If each Carmel hotel room is (conservatively) 400 square feet in size, plus 100 square feet for hallways and other circulation space, this means that the City is assuming that hotel development rights in Carmel are worth approximately $600 per square foot. It is improbable that development rights in Carmel for hotel use are worth so much more than development rights in Midtown Manhattan.

Constraints from Coastal Commission Policies re Low Cost Lodging When implementing the Housing Element, the City will likely need to amend the Land Use and Coastal Access and Recreation (due to the impact on hotels/motels) chapters of its General Plan. The City will certainly need to amend its zoning code. 8 of 16
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The City will be required to submit these various amendments to the Coastal Commission for approval, as they make up parts of the City’s Local Coastal Program.

The Coastal Commission has long prioritized lower-cost lodging in the coastal zone.

Program 1.1.F is predicated on the conversion of lower-cost hotels/motels into lower-income housing. Replacement hotel/motel units are likely to be significantly more expensive. In fact, they must be dramatically more expensive in order to pay off the $438,000 that the City plans to charge for a ‘hotel key.’
The City must analyze the degree to which the Coastal Commission’s policies regarding low-cost lodging represent a constraint on this program.

Additional Defects in Live/Work Program
As discussed supra, Program 1.1.C: Live/Work Housing has an insufficient number of units on each site, in violation of Government Code section 65583.2, subdivision (h)(2).

Beyond this, however, the program assumes that property owners will voluntarily renovate underutilized commercial space into deed-restricted, low-income residential units without government subsidy. The proposed amended Housing Element paints a rosy picture of how deed-restricted affordable housing will generate higher rents than the current commercial rents of these spaces. However, this proposal fails to address the renovation costs needed to convert these spaces into residential units.

Chapter 10 of California’s Existing Building Code (C.C.R. Title 24, Part 10) imposes a host of requirements whenever a change of occupancy is proposed, and such building improvements will be required in addition to the installation of bathrooms, kitchens, interior walls, HVAC, etc. The notion that property owners would opt into such renovations to create affordable housing without government funding is improbable, to say the least.

Successful programs in California rely on bonuses of additional market rate development to encourage the development of deed-restricted, affordable housing. Highly successful programs that use this model include the state’s Density Bonus Law (Gov. Code, § 65915) and San Diego’s bonus ADU program. However, programs tend to be very unsuccessful if they allow additional units only on the condition that they be deed-restricted, affordable units.

It is therefore unlikely that the City can make the required findings based on substantial evidence that the existing uses on these sites are likely to discontinue during the planning period, as required by Government Code section 65583.2, subdivision (g)(2), given that the City is relying on nonvacant sites for at least 50% of its low-income RHNA. 9 of 16
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Limitations on Non-Residential Use for Low-Income Sites Government Code section 65583.2, subdivision (h)(2) places strict requirements on the type of zoning allowed for low-income RHNA sites (emphasis added):

These sites shall be zoned with minimum density and development standards that permit at least 16 units per site at a density of at least 16 units per acre in jurisdictions described in clause (i) of subparagraph (B) of paragraph (3) of subdivision (c), shall be at least 20 units per acre in jurisdictions described in clauses (iii) and (iv) of subparagraph (B) of paragraph (3) of subdivision (c), and shall meet the standards set forth in subparagraph (B) of paragraph (5) of subdivision (b). At least 50 percent of the lower income housing need shall be accommodated on sites designated for residential use and for which nonresidential uses or mixed uses are not permitted, except that a city or county may accommodate all of the lower income housing need on sites designated for mixed use if those sites allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project.

As can be seen from this excerpt, at least half the City’s lower-income RHNA must be planned on sites that only allow residential use. However, the proposed amended Housing Element fails to meet this statutory requirement.

The following four programs all fail to meet this standard:
● Program 1.1.C: Live/Work Housing
○ This program is explicitly mixed-use and therefore fails to comply with the requirements of Government Code section 65583.2, subdivision (h)(2). ○ 78 lower-income units
● Program 1.1.D: Mixed-Income Incentive Program / Program 1.1.B: Development on Small Sites
○ The City must zone these sites so that only residential development is allowed. ○ 4 lower-income units
● Program 1.1.E: Affordable Housing on Religious Facility Properties ○ Because religious facility uses are still permitted on these properties, this program fails to comply with the requirements of Government Code section 65583.2, subdivision (h)(2).
○ 65 lower-income units
● Program 1.1.F: Hotel-to-Residential Conversion (Hotel ‘Key’ Transfer) ○ Because commercial (hotel) uses are still permitted on these properties, this program fails to comply with the requirements of Government Code section 65583.2, subdivision (h)(2).
○ 80 lower-income units
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This means that the City is accommodating 227 lower-income units on sites that allow nonresidential or mixed uses.

The City’s lower-income RHNA is 187 units. The pipeline projects (26 lower-income units), ADUs (42 lower-income units), mixed-income program (6 lower-income units), and Forest Cottages Specific Plan (2 lower-income units) represent 74 units total. This means that well under half of the City’s lower-income RHNA (74/187=40%) is planned for sites where the zoning allows exclusively residential use.

This means that the proposed amended Housing Element violates the requirements of Government Code section 65583.2, subdivision (h)(2).

Government Code section 65583.2, subdivision (h)(2) allows low-income RHNA sites to be mixed-use only if: “... those sites allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project.” However, the various programs either do not allow 100% residential use, do not require 50% of floor area to be residential, or fail both tests.

It also appears that the Mixed-Income Program may also allow for non-residential use (see pages 2-11), as is planned to be implemented in the downtown area and the City states that such projects may include first floor commercial space, as the intent is to model these projects on the recent development “Trevvett Court.” Furthermore, it is unclear if the Forest Cottages Specific Plan only allows residential use, as there is an existing motel on the site. ● Program 1.1.C: Live/Work Housing
○ This program neither allows 100% residential use nor requires 50% of floor area to be residential.
● Program 1.1.D: Mixed-Income Incentive Program / Program 1.1.B Development on Small Sites
○ This program neither allows 100% residential use nor requires 50% of floor area to be residential (see discussion of this program supra) ● Program 1.1.E: Affordable Housing on Religious Facility Properties ○ This program does not require 50% of floor area to be residential. Additionally, this program relies on SB 4 and does not facilitate 100% residential use via the underlying zoning.
● Program 1.1.F: Hotel-to-Residential Conversion (Hotel ‘Key’ Transfer) ○ This program does not require 50% of floor area to be residential for mixed-use projects. Additionally, the City would have to rezone all the hotels on its list of potential sites for 100% residential use. 11 of 16
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Recently published, binding caselaw from the California Court of Appeal has clarified the requirements of Housing Element Law regarding mixed-use zoning on sites planned for power-income units.

In New Commune DTLA LLC v. City of Redondo Beach (Oct. 10, 2025, No. B336042) ___ Cal.App.5th ___ [attached], the Court held that an overlay cannot be used to satisfy the requirements of state law for rezonings for lower-income sites (see Gov. Code, § 65583.2, subd. (h)(2)) if the zoning expressly permits development that does not include housing.

Allowing underlying, non-residential uses would not satisfy the minimum residential density requirement imposed by state housing law.

As applied to Carmel-by-the-Sea’s Housing Element, the Redondo Beach decision prohibits the City from proposing zoning for lower-income sites that allows for any development that does not include a residential component.

This has implications for the following programs:
● Program 1.1.C: Live/Work Housing
○ These low-income RHNA sites must be mapped with zoning that prohibits the establishment or expansion of commercial development, with the exception of mixed-use developments satisfying Government Code section 65583.2, subdivision (h)(2)). This would mean that zoning must prohibit existing commercial buildings from expanding their floor area on site, absent a residential development.
● Program 1.1.D: Mixed-Income Incentive Program / Program 1.1.B Development on Small Sites
○ These low-income RHNA sites must be mapped with zoning that prohibits the establishment or expansion of commercial development, with the exception of mixed-use developments satisfying Government Code section 65583.2, subdivision (h)(2)). This would mean that zoning must prohibit existing commercial buildings from expanding their floor area on site, absent a residential development.
● Program 1.1.E: Affordable Housing on Religious Facility Properties ○ These low-income RHNA sites must be mapped with zoning that prohibits the establishment or expansion of religious uses, with the exception of mixed-use developments satisfying Government Code section 65583.2, subdivision (h)(2)). This would mean that zoning must prohibit existing houses of worship from expanding their floor area on site, absent a residential development. ● Program 1.1.F: Hotel-to-Residential Conversion (Hotel ‘Key’ Transfer) ○ These low-income RHNA sites must be mapped with zoning that prohibits the establishment or expansion of hotels/motels, with the exception of mixed-use developments satisfying Government Code section 65583.2, subdivision 12 of 16
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(h)(2)). This would mean that zoning must prohibit existing hotels/motels from expanding their floor area on site, absent a residential development.

The City Should Follow Through on Its Commitments
Given the timelines necessary for housing development, the fact that we are already two years into the planning period, and the comparative lack of vacant land in the City, it is inappropriate for the City to abandon its most important low-income sites. Government Code Section 65583, subdivision (a)(3) requires that the Housing Element include (emphasis added) “An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites, and an analysis of the relationship of the sites identified in the land inventory to the jurisdiction’s duty to affirmatively further fair housing.” The City-owned sites were scheduled for an RFP by December 2025, and it is highly unlikely that any private organizations, such as churches, would be able to come to an agreement regarding potential development plans on the same schedule as the City had committed to.

Furthermore, any plans by such organizations to develop affordable housing via SB 4 will likely run into equivalent community opposition, given that their scale would likely have to be similar to what has been proposed for the City-owned lots given the realities of affordable housing finance. Unlike a private developer, a church is much more susceptible to public pressure given that it is made up of members of the community.

Fair Housing Implications
The public record makes it clear that an antipathy towards housing for low-income households underlies this sudden decision to amend the Housing Element.

Basic affordable housing finance dictates that the most effective way to develop affordable housing is via projects of sufficient size and composition to qualify for LIHTC funding. This typically means 100% affordable projects of 40-80 units for 9% LIHTC and more than 100 units for 4% LIHTC. Furthermore, this scale ensures efficient delivery of services for residents. This is exactly why state law dictates minimum densities on sites for low-income households (See Gov. Code, § 65583.2, subd. (h).) In contrast, the City’s proposed amended Housing Element envisions a large number of low-income sites with densities below what is required by state law. (Ibid.)
Amending the City’s Housing Element to exclude the City-owned sites is transparently discriminatory towards lower-income households. For purposes of state fair housing law (See Gov. Code, § 8899.50, inter alia.), low-income residents are a protected class. (Gov. Code 13 of 16
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§ 65008, subs. (a)(3), (b)(1)(C), and (b)(2)(B).) The City is obligated by state law (Gov. Code, § 8899.50) not to discriminate against such residents based on protected characteristics.

Additionally, the City has a duty to affirmatively further fair housing (“AFFH”) in preparing its Housing Element. (See Gov. Code § 8899.50 and § 65583 (c)(5).) The Housing Element itself, moreover, must assess fair housing within the City. (Gov. Code § 65583, subd. (c)(10)(A).) Under Government Code section 8899.50, all public agencies must affirmatively further fair housing through their housing and community development programs. Government Code section 8899.50, subdivision (a)(1), defines “affirmatively furthering fair housing” as taking meaningful actions, in addition to combatting discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.

The duty to affirmatively further fair housing extends to all of a public agency’s activities and programs relating to housing and community development. Public agencies are required to take meaningful actions to AFFH and take no action that is materially inconsistent with its obligation to AFFH. (Id. at subd. (b).)
Amending its Housing Element to exclude the City-owned sites would be disparate treatment based on a protected characteristic and it would also fail to affirmatively further fair housing.

Carmel-by-the-Sea is much, much wealthier than the rest of Monterey County and has a vastly higher proportion of White residents. According to the 2020 decennial census, Carmel-by-the-Sea is 87% White and only 6% Latino, whereas Monterey County is 27% White and 60% Latino. Furthermore, the median household income in Carmel-by-the-Sea is $126,406 per year, according to the 2022 5-year American Community Survey, whereas the Monterey County median household income is $91,043, according to the same dataset.

The City has also permitted only 13 lower-income units according to its annual progress reports dating back to 2018. Eliminating the main program in its housing plan to produce low-income homes, while replacing this production with a variety of programs unlikely to produce any new homes, would be a clear violation of fair housing laws.

Housing Element Substantial Compliance and the Builder’s Remedy If the City continues to attempt to amend its Housing Element, rather than issue the RFPs for the City-owned sites, it runs a high likelihood of missing the December 2025 deadline for the RFPs. If the City fails to implement required programs within the timeframes outlined in the housing element, the City is no longer in substantial compliance with Housing Element law.

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The Housing Accountability Act (Gov. Code, § 65589.5; the “HAA”) requires approval of “builder’s remedy” projects that are submitted during periods of local housing element noncompliance. (Gov. Code, § 65589.5, subd. (d)(6).) Under the HAA, a city may not disapprove a builder’s remedy project on the grounds it does not comply with the city’s zoning and general plan if the developer submitted either a statutorily defined "preliminary application" or a "complete development application" while the city's housing element was not in substantial compliance with state law. (See Gov. Code, § 65589.5, subds. (d)(6), (h)(5), (o)(1).) This statutory provision temporarily suspends the power of non-compliant municipalities to enforce their zoning rules against qualifying affordable housing projects.

See California Housing Defense Fund v. City of La Cañada Flintridge, Case Number:
23STCP02614 (attached), for a recent court decision affirming the plain language of the statute in this regard.

If the City’s compliance with Housing Element law lapses, developers will be able to propose any residential project, no matter how tall or large, as long as it qualifies as a builder’s remedy project. The City will be bound to approve all such projects even if the City later comes back into compliance with housing element law. For instance, in Santa Monica, a single developer proposed 4,260 housing units, including several 18-story buildings, when Santa Monica’s housing element fell out of compliance. If the City wrongfully denies such builder’s remedy applications, not only may the applicant seek judicial remedies, but the HAA specifically empowers housing organizations, such as CalHDF to enforce the act via litigation. (Gov. Code, § 65589.5, subd. (k)(1)(A)(i).) And if the City contests such Builder’s Remedy applications, it may be liable for costs. For example, the HAA authorizes courts to award attorney’s fees and costs both to applicants and to housing organizations if they prevail in litigation to enforce the HAA. (Id. at subd. (k).) As an example, the City of Berkeley was fined $2.6 million and forced to pay $1.4 million in attorneys’ fees after incorrectly denying a housing development project in violation of the HAA.
⧫⧫⧫
In sum, if the City amends its housing element to exclude the three City-owned sites, or fails to issue the RFPs for the City-owned sites, it will be exposing itself to potential litigation. If the City loses such litigation, it will be exposed to a variety of remedies, potentially including the Builder’s Remedy, as well as attorneys’ fees and other costs. CalHDF recommends that the City drop its effort to amend the Housing Element and instead proceed with its plans to dispose of the City-owned sites to develop 100% affordable housing, which is badly needed in Carmel-by-the-Sea.
15 of 16
ATTACHMENT 9

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CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased access to housing for Californians at all income levels, including low-income households. You may learn more about CalHDF at www.calhdf.org.

Sincerely,
Dylan Casey
CalHDF Executive Director
James M. Lloyd
CalHDF Director of Planning and Investigations
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ATTACHMENT 9

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October 20, 2025
My Fellow Commissioners:

I would like to thank staff for their tremendous efforts at compiling property information and the near-final Housing Element document. I am unable to attend today’s special meeting, but I offer the following few comments on the draft amendments to the City's adopted 6th-cycle Housing Element:
• Program 1.2.A: Water Distribution Prioritization for Affordable Housing. This section needs to be updated to reflect the allocation of water in March 2025 to the City of Carmel-by-the-Sea and the revised estimate of water needs for future housing.
• Program 1.1.C: Live/Work Housing. Should be an option, not requirement, for deed restricted affordable. I have concerns about the requirement that property owners will only be allowed to convert a space to a live/work use if they deed restrict the residential portion of the live/work unit at an affordable rental level.

Some business owners may want to take advantage of this opportunity, but may be above the affordable income level, or they may be below it with aspirations to exceed the income requirements. What happens when they do? Do they then have to move out?
• Program 1.1.F: Hotel- to-Residential Conversion (Hotel ‘Key’ Transfer). It should be noted that the relocation of “hotel keys” will require water from the City’s “commercial” pot of water. Although the Planning Commission recommended that 2 acre-feet of water be placed in that “account,” the discussion at the last Council meeting ended with no water in the commercial account. Action on the water allocation will return to the Council for further discussion in November, and the need for commercial water to support the key program and other commercial uses should be included in the staff report and recommendation. • Attachment 8, Monterey County’s 2025 Income and Rent Limits is an eye-opener! If this information is shared with the property owner(s) at the time of permitting, it could result in agreement to restrict the unit as affordable. This information shows that one can receive a reasonable rent and provide housing for a lowincome tenant.

In addition to the previous comments related to the housing element, I would like to submit the following general comments related to the push for housing:
• Families. Much of the focus on affordable housing seems directed at small units that are unlikely to support families (e.g. more than one or two occupants). This is unfortunate given the recent article in the Pinecone about the lack of homes occupied by families with children. I would hope that any affordable housing projects undertaken on church sites, hotel sites, and public sites would include a mix of apartment sizes. • Parking. Much of the housing contemplated in the Housing Element does not include parking. This is a serious problem in our village, and we must identify and implement ways to improve it.

Thank you for the opportunity to submit these comments.

Sincerely,
Stephanie Locke
ATTACHMENT 10

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Additional Opportunities
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City Boundary
City of Carmel
Housing Element Update 2023-2031
Sites Inventory 0 500 1,000
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ATTACHMENT 11

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CITY OF CARMEL-BY-THE-SEA
City Council
Staff Report
November 4, 2025

ORDERS OF BUSINESS
TO: Honorable Mayor and City Council Members
SUBMITTED BY: Tom Ford, Administrative Analyst
APPROVED BY: Chip Rerig, City Administrator
SUBJECT: Resolution 2025-099, Approving a Construction Contract with Avila Construction Company in the amount of $143,335.26 for the Fire Station Upgrade Project and Authorizing the City
Administrator to Execute the Contract and Approve Change Orders up to a 15% Contingency (Estimated time - 10 min) RECOMMENDATION:

Adopt Resolution 2025-099 Approving a construction contract with Avila Construction Company in the amount of $143,335.26 for the Fire Station Upgrade Project and Authorizing the City Administrator to Execute the Contract and Approve Change Orders up to a 15% Contingency.

BACKGROUND / SUMMARY:

As part of the FY25–26 Capital Improvement Plan (CIP), the City Council previously approved $175,000 in funding for upgrades to the Carmel Fire Station. The primary purpose of this project remains the modification and expansion of the engine bays to accommodate a newly purchased large fire engine scheduled for delivery in January 2025.

The plans prepared by WRD Architects (Attachment 3) detail necessary modifications, including: downsizing existing office space, removal of partition walls to create a turnout room, framing and siding improvements, mechanical, electrical, and HVAC adjustments, and ceiling, drywall, and interior finishing. The scope of work includes the use of WRD plans, hazard abatement per the M3 report, and prevailing wage labor.

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Failure of Prior Awardee:

On October 7, 2025, the City Council adopted Resolution 2025-089, which approved a construction contract with Moya & Sons Builders, Inc. in the amount of $136,185. This firm was identified as the lowest responsive construction contractor among the three quotes received.

Following the award, Moya & Sons Builders, Inc. was provided notice of award but failed to execute the contract and submit all required documentation, including bonds and insurance requirements, within 15 calendar days. Therefore, the award made under Resolution 2025-089 is void due to the bidder's non-responsiveness and failure to execute the contract documents.

Authority for Award to Next Bidder (Avila Construction Company):

The City’s Purchasing System grants specific authority for this circumstance. Section

3.12.260, Bidders’ Security, states: "The City Council may, on refusal or failure of the successful bidder to execute the contract, award it to the next lowest responsible, responsive bidder."
Staff has reviewed the proposal submitted by Avila Construction Company (Attachment 2), the next lowest responsive contractor, dated August 22, 2025. Their proposal includes a stipulated sum base bid of $143,335.26. The scope of work offered by Avila Construction Company is responsive and includes labor and materials necessary for the Fire Station Upgrade Project. Furthermore, Staff has spoken with Avila Construction Company, who affirmed their ability to deliver the proposed product within an adequate timeframe, provided their knowledge and the City’s knowledge of the scope of the project.

Emergency Justification (Reaffirmation):

The necessity for prompt action remains critical. Completing this project prior to the new fire engine delivery in January 2025 is essential to ensure the City can house the new vehicle safely and maintain uninterrupted, accessible, and responsive public safety services. This project continues to qualify as an emergency under California Public Contract Code § 22050, which allows the Council to forego formal bidding when prompt action is required to address a clear and imminent threat to public safety or essential services.

To ensure the timely completion of the Fire Station Upgrade Project and maintain continuity of emergency services, Staff recommends that the City Council adopt a Resolution (Attachment 1) approving the contract with the next lowest responsive bidder, Avila Construction Company, as authorized by the City’s Purchasing System.

FISCAL IMPACT:

The newly awarded contract to Avila Construction Company is $143,335, with a 15% contingency of $21,500 totaling $164,835. This amount is within the approved CIP budget of $175,000 for this project.

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PRIOR CITY COUNCIL ACTION:

Resolution 2025-089 approved the original contract award on October 7, 2025.

ATTACHMENTS:

1. Resolution 2025-099

2. Avila Construction Fire Station bid 8.22.25

3. Carmel Fire Station Remodel Plans

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ATTACHMENT 1

CITY OF CARMEL-BY-THE-SEA

CITY COUNCIL
RESOLUTION NO. 2025-099

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARMEL-BY-THE-SEA

APPROVING A CONSTRUCTION CONTRACT WITH AVILA CONSTRUCTION COMPANY IN THE AMOUNT OF $143,335.26 FOR THE FIRE STATION UPGRADE PROJECT AND

AUTHORIZING THE CITY ADMINISTRATOR TO EXECUTE THE CONTRACT AND APPROVE CHANGE ORDERS UP TO A 15% CONTINGENCY
WHEREAS, the City Council previously approved funding in the amount of $175,000 in the FY25–26 Capital Improvement Plan for upgrades to the Carmel Fire Station to accommodate the City’s new fire engine; and
WHEREAS, WRD Architects prepared construction plans detailing modifications to the station’s engine bays and related facilities to ensure adequate space and functionality; and WHEREAS, on October 7, 2025, the City Council approved Resolution 2025-089, awarding the construction contract to Moya & Sons Builders, Inc.; and WHEREAS, the previously awarded contractor failed to execute the contract and submit required bonds and insurance documentation within the 15-day calendar limit following the notice of award, thereby voiding the authority granted in Resolution 2025-089; and WHEREAS, this Resolution supersedes Resolution 2025-089; and WHEREAS, the City’s Purchasing System, Section 3.12.260 of the Carmel Municipal Code, permits the City Council to award the contract to the next lowest responsible, responsive bidder upon the failure of the successful bidder to execute the contract; and WHEREAS, the City has identified Avila Construction Company as the next lowest responsible, responsive contractor, submitting a quote of $143,335.26; and WHEREAS, the Fire Station Upgrade Project qualifies as an emergency under California Public Contract Code § 22050 due to the imminent delivery of the City’s new fire engine in December 2025, which requires timely completion of construction to ensure public safety and continuity of emergency services; and
WHEREAS, the City has complied with its purchasing policy by obtaining multiple quotes and ensuring competitive pricing despite foregoing formal bidding due to the emergency nature of the project.

NOW, THEREFORE, BE IT RESOLVED THAT THE CITY COUNCIL OF THE CITY OF CARMEL-BY-THE-SEA DOES HEREBY:

1. Approve a construction contract with Avila Construction Company in the amount of $143,335.26 for the Fire Station Upgrade Project and authorize the City Administrator to

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Resolution 2025-099 ATTACHMENT 1

Page 2 of 2 ends

execute the contract and approve change orders up to a 15% contingency ($21,500) for a total not-to-exceed amount of $164,835.26.

2. Find that the emergency circumstances justify the award of the contract without formal competitive bidding under PCC § 22050.

PASSED AND ADOPTED BY THE CITY COUNCIL OF THE CITY OF CARMEL-BY-THE-SEA this 4th day of November, 2025, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAN:

APPROVED: ATTEST:
_____________________________ __________________________ Dale Byrne, Mayor Nova Romero, MMC, City Clerk

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AVILA CONSTRUCTION COMPANY
12 Thomas Owens Way, Suite 200
Monterey, CA 93940
Ph 831 372-5580 Fax 831 372-5584
License 550380
August 22, 2025
City of Carmel-by-the-Sea
P.O. Box CC, Carmel-by-the-Sea, CA 93921
[email protected]
Attn: Javier Hernandez, City of Carmel by the Sea project manager Ref: Carmel Fire Station Engine Bays
Subj: Construction Bid
Avila Construction is pleased to provide the following bid based on the documents listed below and the following clarifications and exclusions.

Stipulated sum base bid $143,335.26
Includes all material, taxes, labor as prevailing wage, faithful performance labor and material bond by Avila Construction.

Allowance #1- included in base bid
Low voltage relocations, terminations, new work that may consist of data/phone, speaker systems, fire alarm is not indicated on the plans but exist. The extent of work to be determined after demolition with the City of Carmel. An allowance of $2,000.00 for labor and materials by a low voltage contractor has been caried and final cost to be determined.

Scope of Work Clarifications:

General:
• Plans by WRD architects with a plot date of 6.24.25 consisting of A001-A701 • Asbestos and lead inspection report by M3 dated 8.19.25 consisting of 23 pages • Construction schedule is based on up to approximately 6 weeks of continuous critical path construction
• On site supervision is part time
• Normal business hours for construction
• Power and water to be utilized from area of work for construction without cost to contractor
• Station restroom facilities may be used by contactor and subcontractor workers ATTACHMENT 2

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2 Demo and hazard abatement:
• Per M3 report including air board notification and fees

Doors/Frames/Hardware:
• HM welded frame, HM door, Schlage ND series lockset/hinges/ wall stop Storefront
• Dark bronze storefront with 3’ door and spandrel glass at floor level payne Drywall:
• 5/8” drywall at new wall interior side and new ceiling • Level 4 at wall and heavy texture to match existing at ceiling

Acoustical T-bar ceiling:
• New grid to tie into existing where indicated on RCP including where storefront removed in front of office
• New flat lay fissured acoustical ceiling panels per RCP within existing grid and at new grid location
Painting:
• Interior of office and turnout room walls, ceiling, man door. • Exterior side of new walls is T11 wood to be painted. • Office interior wall to have a 4” red strip at approximately 32” high with grey color below and white above to mimic color scheme in FS resident area.

Flooring:
• Existing concrete cleaned
• Rubber base installed at interior of turnout and office, wood base installed on T111 siding exterior side of turnout/office.

Plumbing:
• Remove existing copper air line and run new copper air line, reuse termination

HVAC:
• Rework existing ducts for relocated wall registers location, install salvaged wall registers ceiling registers to remain in new turnout area. • Grill in existing captain office to remain
Electrical:
• Reuse existing light fixtures
• Relocate loft light fixtures
• Install new outlets and lights switches

ATTACHMENT 2

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3 Low Voltage: Allowance
• Relocate existing smoke detector if tied to fire alarm system • Safe off removed low voltage lines
• Remove existing speakers and volume control from system in the 2 existing offices

Exclusions:
• City permits and associated fees
• Builder Risk Insurance and deductible costs- not specified to carry by General Contractor
• Construction contingency- not specified to carry by General Contractor • Lighting controls automation- none indicated
• Fire alarm modifications or additions- none indicated • Fire sprinklers- none exist or indicated
• Floor covering, sealer or (epoxy as noted on floor plan), job walk indicated do not include
• Insulation- none indicated
Thank you for the opportunity. Please reach out for any further clarification or additional information.

Avila Construction
Ted Wasson
[email protected]
831-596-4979
ATTACHMENT 2

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COVER SHEET A00125039-A001 JTI HR SHEET NAME: SET ISSUED: JOB NO.: 2340 GARDEN ROAD, SUITE 100 MONTEREY, CALIFORNIA 93940 PHONE: 831.649.4642 FAX: 831.649.3530 WWW.WRDARCH.COM SHEET NO.: FILE NAME: DRAWN BY: CHECKED BY: THE USE OF THE PLANS AND SPECIFICATIONS IS RESTRICTED TO THE ORIGINAL SITE FOR WHICH THEY WERE PREPARED, AND PUBLICATION THEREOF IS EXPRESSLY LIMITED TO SUCH USE. REUSE, REPRODUCTION OR PUBLICATION BY ANY METHOD IN WHOLE OR IN PART IS PROHIBITED. TITLE TO THE PLANS AND SPECIFICATIONS REMAINS WITH THE ARCHITECT, AND VISUAL CONTACT WITH THEM CONSTITUTES PRIMA FACIE EVIDENCE OF THE ACCEPTANCE OF THESE RESTRICTIONS. PLOT DATE: PRINT DATE: 6.24.2025 25039 CARMEL FIRE DEPARTMENT

ENGINE BAYS

CITY OF CARMEL
6TH AVENUE
CARMEL-BY-THE-SEA, CA 93921 A.P.N.: 010-133-006-000 ARCHITECT OWNER WALD, RUHNKE & DOST ARCHITECTS, LLP 2340 GARDEN ROAD, SUITE 100 MONTEREY, CA 93940 ph: (831) 649-4642 fax: (831) 649-3530 Email: [email protected] Contact: HENRY RUHNKE CITY OF CARMEL CARMEL-BY-THE-SEA, CA 93921 ph: Email: [email protected] and [email protected] Contacts: JAVIER HERNANDEZ (ENGINEERING P.M.) LOCATION MAP VICINITY MAP 156 152Hollister Chualar Soledad to Big Sur G16 Castroville Seaside TRUE NORTH Carmel Pacific Grove 1 Monterey PROJECT LOCATION Marina 101 68 Carmel Valley Salinas Prunedale 183 Fort Ord 156 1 Aptos Santa Cruz 152 Watsonville 101 Gilroy to San Francisco Gonzales A.C. PAVING GYPSUM WALLBOARD PLYWOOD WOOD BLOCKING WOOD FRAMING CONTINUOUS MEMBER METAL WOOD FINISH SOUND INSULATED STUD WALL (E) STUD WALL TO BE REMOVED X PROPERTY LINE REVISION +XXX.X +XXX.X +XXX.X +XXX.X
XAX.XXAX.X DETAIL DETAIL IDENTIFICATION SHEET WHERE DETAIL IS DRAWN FINISH GRADE (SPOT) ELEVATION SURFACE EXISTING GRADE (SPOT) ELEVATION SURFACE SECTION SECTION IDENTIFICATION SHEET WHERE SECTION IS DRAWN (N) STUD WALL (E) STUD WALL CAST-IN-PLACE (C.I.P.) CONCRETE EARTH ROCK CONCRETE BLOCK SAND, MORTAR, PLASTER LEGEND XXXX XXX XXX DEMOLITION TAG VERTICAL OR HORIZONTAL DIAPHRAGM KEY WORK POINT, DATUM POINT OR CONTROL MATCH LINE KEY TAG DOOR SYMBOL WINDOW SYMBOL SYMBOLS 6th AVENUE CARMEL-BY-THE-SEA, CA 93921 CARMEL FIRE STATION ENGINE BAYS PROJECT TEAM GENERAL NOTES CONSTRUCTION: TYPE V.B. (FULLY-SPRINKLERED) OCCUPANCY: 010-133-006-000 6th AVENUE, CARMEL-BY-THE-SEA, CA 93921 PROJECT INFORMATION APN: LOCATION: PROJECT: CARMEL-BY-THE-SEA FIRE STATION ENGINE BAYS SHEET INDEX SHT. # SHEET TITLE TITLE A001 COVER SHEET ARCHITECTURAL A200 EXISTING LOWER FLOOR PLAN D200 DEMOLITION LOWER FLOOR PLAN D221 DEMOLITION REFLECTED CEILING PLAN A201 PROPOSED LOWER FLOOR PLAN A221 PROPOSED REFLECTED CEILING PLAN A701 BUILDING SECTIONS 1. THE GENERAL CONTRACTOR SHALL BE RESPONSIBLE FOR THE VERIFICATION OF ALL DIMENSIONS, GRADES, AND OTHER CONDITIONS, AND SHALL CORRELATE AT THE JOB SITE ALL SUCH ITEMS. GENERAL CONTRACTOR SHALL REPORT ANY DISCREPANCIES TO THE ARCHITECT FOR CLARIFICATION AND CORRECTION PRIOR TO BEGINNING ANY WORK. 2. THE GENERAL CONTRACTOR SHALL BE RESPONSIBLE FOR THE WORK AND THE COORDINATION OF ALL TRADES AND GOVERNING AGENCIES, AND SHALL PROVIDE ALL MATERIALS AND LABOR (SHOWN OR INFERRED) ON THESE PLANS TO RENDER THE WORK COMPLETE. 3. IT SHALL BE THE GENERAL CONTRACTORS RESPONSIBILITY FOR THE SUPERVISION OF THE WORK. 4. THE ARCHITECT ASSUMES NO RESPONSIBILITY FOR THE SUPERVISION OF THE WORK OR THE PROPER EXECUTION OF THE SAME. 5. WRITTEN DIMENSIONS SHALL HAVE PRECEDENCE OVER SCALED DIMENSIONS. ANY AND ALL DISCREPANCIES SHALL BE REPORTED TO THE ARCHITECT IMMEDIATELY, PRIOR TO COMMENCEMENT OF WORK. 6. THESE DRAWINGS SHALL BE CONSIDERED SUBSTANTIALLY COMPLETE. IT IS THE RESPONSIBILITY OF THE GENERAL CONTRACTOR TO PROVIDE ALL LABOR AND MATERIALS NECESSARY TO RENDER THE WORK COMPLETE, AS IS THE INTENT OF THESE DRAWINGS, EITHER SHOWN OR INFERRED HEREIN, THROUGH PROPER AND ESTABLISHED CONSTRUCTION PRACTICES. 7. EXISTING CONSTRUCTION DETAILS SHOWN HEREIN ARE ASSUMED TO BE SUBSTANTIALLY CORRECT AND MAY NOT DEPICT THE ACTUAL CONDITION. THE GENERAL CONTRACTOR SHALL VERIFY (E) CONDITIONS AND NOTIFY THE ARCHITECT ANY DISCREPANCIES PRIOR TO COMMENCEMENT OF WORK. ABREVIATIONS & AND
∠ ANGLE @ AT
℄ CENTERLINE Ø DIAMETER OR ROUND ┴ PERPENDICULAR⅊ PROPERTY LINE # POUND OR NUMBER A.B. ANCHOR BOLT A.B.S. ACRYLONITRILE BUTADIENE ABV. ABOVE A.A. ASPHALTIC CONCRETE A/C AIR CONDITIONING ACOUS. ACOUSTICAL ADJ. ADJUSTABLE A.F.F. ABOVE FINISH FLOOR AGGR. AGGREGATE ALUM. ALUMINUM ANOD. ANODIZED A.P.A AMERICAN PLYWOOD ASSOCIATION APPROX. APPROXIMATE ARCH. ARCHITECTURAL A.S. ADJUSTABLE SHELF BD. BOARD BIT. BITUMINOUS BLDG. BUILDING BLK. BLOCK BLKG. BLOCKING BM. BEAM B.M. BENCH MARK BOT. BOTTOM BRG. BEARING BTWN. BETWEEN B.U.R. BUILD-UP ROOFING B.W. BOTH WAYS CAB. CABINET C.B. CATCH BASIN CBC CALIFORNIA BUILDING CODE CEM. CEMENT CER. CERAMIC CFCI. CONTRACTOR FURNISHED, CONTRACTOR INSTALLED C.F. CUBIC FEET C.I. CAST IRON C.J. CONTROL JOINT CL. CLOSET CLG. CEILING CLKG. CAULKING CLR. CLEAR(ANCE) C.M.U. CONCRETE MASONRY UNIT COL. COLUMN COMP. COMPOSITION CONC. CONCRETE CONN. CONNECTION CONSTR. CONSTRUCTION CONT. CONTINUOUS COR. CORRUGATED C.O.T.G. CLEAN-OUT TO GRADE CSMT. CASEMENT CSWK. CASEWORK C.T. CERAMIC TILE CTR. COUNTER CTSK. COUNTERSINK C.Y. CUBIC YARD DBL. DOUBLE DEPT. DEPARTMENT DET. DETAIL DF. DRINKING FOUNTAIN D.F. DOUGLAS FIR D.G. DECOMPOSED GRANITE D.H. DOUBLE HUNG DIAG. DIAGONAL DIA. DIAMETER DIMEN. DIMENSION DISP. DISPENSER/DISPOSER DN. DOWN DR. DOOR DRWG. DRAWING D.S.B. DBL. STRENGTH B GRADE (GLASS) D.S. DOWNSPOUT DWR. DRAWER D.W. DISH WASHER E. EAST EA. EACH E.J. EXPANSION JOINT ELEV. ELEVATION, ELEVATOR ELEC. ELECTRIC(AL) EMER. EMERGENCY ENCL. ENCLOSURE EQUIP. EQUIPMENT N.I.C. W/ WITH EWC. ELECTRIC WATER COOLER (E) EXISTING EXH. EXHAUST EXP. EXPOSED/EXPANSION EXT. EXTERIOR F.A. FIRE ALARM FAST. FASTEN(ER) F.A. FLAT BAR F.D. FLOOR DRAIN FEC. FIRE EXTINGUISHER CABINET F.F. FINISH FLOOR F.G. FINISH GRADE FND. FOUNDATION F.E. FIRE EXTINGUISHER F. FIBERGLASS FIN. FINISH(ED) F.H.M.S. FLATHEAD MECHANICAL SCREW F.H.W.S. FLATHEAD WOOD SCREW FLASH. FLASHING FLR. FLOOR(ING) FLUOR. FLUORESCENT F.O. FACE OF F.O.B. FACE OF BLOCK F.O.C. FACE OF CONCRETE F.O.F. FACE OF FINISH F.O.M. FACE OF MASONRY F.O.S. FACE OF STUD F.P. FIREPLACE F.R.P. FIBERGLASS REINF. PANEL F.S. FULL SIZE FT. FOOT/FEET FTG. FOOTING FURR. FURRED(ING) FUT. FUTURE GA. GAUGE/GAGE GALV. GALVANIZED G.B. GRAB BAR G.I. GALVANIZED IRON GL. GLASS/GLAZING G.L.B. GLUE-LAM BEAM GR. GRADE(ING) G.W.B. GYPSUM WALLBOARD H.B. HOSE BIB HBD. HARDBOARD H.A. HOLLOW CORE HDR. HEADER HDWR. HARDWARE H.M. HOLLOW METAL HORZ. HORIZONTAL H.S. HEAVY SHEET HT. HEIGHT HTG. HEATING H.W. HOT WATER HWD. HARDWOOD HVAC. HEATING/VENTILATING/AIR CONDITIONING I.C.C. INTERNATIONAL CODE COUNCIL ID. INSIDE DIAMETER INCL. INCLUDE(D) (ING) INSUL. INSULATE(D) (ING) INT. INTERIOR INV. INVERT JAN. JANITOR J.H. JOIST HANGER JT. JOINT KIT. KITCHEN L. LENGTH LAM. LAMINATE LAV. LAVATORY L.B. LAG BOLT LOC. LOCATE(ION) L.V.L. LAMINATED VENEER LUMBER L.W. LIGHTWEIGHT MAS. MASONRY MAT. MATERIAL(S) MAX. MAXIMUM M.B. MACHINE BOLT M.C. MEDICINE CABINET M.H. MAN HOLE MECH. MECHANICAL MEMB. MEMBRANE MEZZ. MEZZANINE MFR. MANUFACTURE(ER) MIN. MINIMUM MIR. MIRROR MISC. MISCELLANEOUS MLDG. MOLDING/MOULDING M.I.W. MALLEABLE IRON WASHER M.O. MASONRY OPENING MTD. MOUNTED MET. METAL MULL. MULLION N. NORTH (N) NEW NAT. NATURAL N.I.C. NOT IN CONTRACT NOM. NOMINAL N.T.S. NOT TO SCALE O/ OVER OBS. OBSCURE O.C. ON CENTER(S) O.D. OUTSIDE DIAMETER OFF. OFFICE OFCI. OWNER FURNISHED, CONTRACTOR INSTALLED OFOI. OWNER FURNISHED, OWNER INSTALLED O.H. OVER HANG O.H.M.S. OVALHEAD MACHINE SCREW O.H.W.S. OVALHEAD WOOD SCREW OPNG. OPENING OPP. OPPOSITE P.A.F. POWDER ACTUATED FASTENER P.B. PANIC BAR PART. TBD. PARTICLE BOARD PCF. POUNDS PER CUBIC FOOT P.D. POWDER DRIVEN P.G. PAINT GRADE PERF. PERFORATE PLF POUNDS PER LINEAR FOOT PLAS. LAM. PLASTIC LAMINATE PLAS. PLASTER PLYWD. PLYWOOD PR. PAIR PSF POUNDS PER SQUARE FOOT PSI POUNDS PER SQUARE INCH P.T. PRESSURE TREATED PART. PARTITION P.T. DISP. PAPER TOWEL DISPENSER P.V.C. POLYVINYL CHLORIDE R. RISER R.A. RETURN AIR RAD. RADIUS R.D. ROOF DRAIN REG. REGISTER REF. REFRIGERATOR REINF. REINFORCED REQ'D. REQUIRED REQMT. REQUIREMENT RESIL. RESILIENT REV. REVERSED R.H.M.S. ROUNDHEAD MACHINE SCREW R.H.W.S. ROUNDHEAD WOOD SCREW RM. ROOM R.O. ROUGH OPENING R.O.W. RIGHT OF WAY R.S. RESAWN RUB. RUBBER RWD. REDWOOD R.W.L. RAIN WATER LEADER S. SOUTH S.B. SOLID BLOCKING S.C. SOLID CORE SCHED. SCHEDULE S.A. STORM DRAIN SECT. SECTION SERV. SERVICE S.F. SQUARE FOOT S.G. STAIN GRADE SH. SHELF/SHELVING SHWR. SHOWER SHT. SHEET SHT'G. SHEATHING SIM. SIMILAR S.S. STAINLESS STEEL SERVICE SINK S.S.D. SEE STRUCTURAL DRAWINGS S.M. SHEET METAL S.M.S. SHEET METAL SCREW SPEC. SPECIFICATION SQ. SQUARE STL. STEEL STD. STANDARD STAG. STAGGERED STOR. STORAGE STRUCT. STRUCTURAL SUSP. SUSPENDED SYM. SYMMETRY(ICAL) SYS. SYSTEM T. TREAD T.B. TOWEL BAR T.B.D. TO BE DETERMINED T.C. TOP OF CURB TEL. TELEPHONE TEMP. TEMPERED T.E.N. TYPICAL EDGE NAILING T & G TONGUE & GROOVE THK. THICK(NESS) THRESH. THRESHOLD T.J.I. TRUSS JOIST INTERNATIONAL T.O. TOP OF T.P.H. TOILET PAPER HOLDER T.Q. TOP OF PAVEMENT TV TELEVISION T.W. TOP OF WALL TYP. TYPICAL U/L UNDERWRITER'S LABORATORY U.N.O. UNLESS NOTED OTHERWISE U.O.N. UNLESS OTHERWISE NOTED UR. URINAL V.I.F. VERIFY IN FIELD W. WEST/WIDTH/WIDE W/ WITH W.C. WATER CLOSET WD. WOOD WDW. WINDOW W.H. WATER HEATER WI. WOODWORK INSTITUTE W/O WITHOUT W.P. WATERPROOF(ING) W.R. WATER RESISTANT W.S. WOOD SCREW WSCT. WAINSCOT WT. WEIGHT W.W.M. WELDED WIRE MESH Ocean Ave. 6th Ave.5th Ave. 4th Ave.3rd Ave. 7th Ave. 8th Ave. 9th Ave. 10th Ave.

Highway 1
Junipero
Torres
Carpenter
San Carlos
Lincoln
Dolores
Mission
Santa Fe
Santa Rita
Guafalupe
Mountain View PROJECT LOCATION GROUP B SCOPE OF WORK EXPAND FIRE ENGINE PARKING DEPTH BY: 1. DOWNSIZE FIRE CAPTAINS OFFICE. 2. REMOVE TWO OFFICES AND RECONFIGURE TO CREATE ONE 'TURNOUT' ROOM. ZONING: CC (FIRE STATION) AREA OF 456 s.f. CONSTRUCTION: NOTE: THIS BUILDING OR SPACE SHALL PROVIDE A READILY DISTINGUISHABLE MEANS OF EGRESS COMPLYING WITH CHAPTER 10 AND CHAPTER 11 (WHERE APPLICABLE FOR ACCESSIBILITY PURPOSE) OF THE 2022 EDITION OF THE CALIFORNIA BUILDING CODE. THE EXIT SYSTEM SHALL MAINTAIN A CONTINUOUS, UNOBSTRUCTED AND UNDIMINISHED PATH OF EXIT TRAVEL FROM ANY OCCUPIED POINT WITHIN THE BUILDING TO A PUBLIC WAY. EXITING: NFPA 13, AUTOMATIC SPRINKLER SYSTEMS, (CA AMENDED) 2022 EDITION NFPA 72, NATIONAL FIRE ALARM CODE, (CA AMENDED) 2022 EDITION PARTIAL LIST OF APPLICABLE STATE STANDARDS 2022 CALIFORNIA ADMINISTRATIVE CODE (CAC), PART 1, TITLE 24, CALIFORNIA CODE OF REGULATIONS (C.C.R.) 2022 CALIFORNIA BUILDING CODE (CBC), PART 2, (VOL. 1 & 2 )TITLE 24 C.C.R. 2022 CALIFORNIA ELECTRICAL CODE (CEC), PART 3, TITLE 24 C.C.R. 2022 CALIFORNIA MECHANICAL CODE (CMC), PART 4, TITLE 24 C.C.R. 2022 CALIFORNIA PLUMBING CODE (CPC), PART 5, TITLE 24 C.C.R. 2022 CALIFORNIA ENERGY CODE (CEC), PART 6, TITLE 24 C.C.R. 2022 CALIFORNIA FIRE CODE (CFC), PART 9, TITLE 24 C.C.R. 2022 CALIFORNIA EXISTING BUILDING CODE (CEBC), PART 10, TITLE 24 C.C.R. 2022 CALIFORNIA GREEN STANDARDS CODE (CALGreen), PART 11, TITLE 24 C.C.R. 2022 CALIFORNIA REFERENCED STANDARDS CODE, PART 12, TITLE 24 C.C.R. TITLE 19 C.C.R., PUBLIC SAFETY, DIVISION 1, STATE FIRE MARSHAL REGULATIONS APPLICABLE BUILDING CODES & STANDARDS APPROVED FOR CONSTRUCTION DATE JAVIER HERNANDEZ 6/25/25 ATTACHMENT 3

Page 416 of 747 ends

PLAN NORTH SCALE: EXISTING LOWER FLOOR PLAN 1/4"=1'-0" UP UP WORK BENCH MAINTENANCE AREA OFFICE OFFICE CAPTAIN'S OFFICE STORAGE / SUPPLIES COPY UTILITY ROOM GYMNASIUM FOYER ENTRY TOILET ROOM SHADEDED AREA NOT IN SCOPE OF WORK 6th AVENUE 44'-9" 14'-10
1 2" 13'-0" 13'-0" BAY 4 10'-4
1 2" CLEAR BAY 3 10'-4
1 2" CLEAR BAY 2 10'-4
1 2" CLEAR BAY 1 10'-6" CLEAR 74'-10" FOAM WATER (E) ENGINE #7111 ?' x 8' FOAM WATER (E) ENGINE #7113 30' x 8' (E) AMBULANCE #7165 ?' x 8' (E) PARAMEDIC #7166 24' x 8' 96 GAL.

BIN
96 GAL.

BIN

TURNOUT RACK TURNOUT RACK

TURNOUT RACK

FLAMMABLES

CABINET

VEHICLE
POLISH
& MISC
31'-8
1 2"
4'-2
1 2" 25'-5"
10'-6
1 2" EXISTING LOWER FLOOR PLAN A20025039-A200 JTI HR SHEET NAME: SET ISSUED: JOB NO.: 2340 GARDEN ROAD, SUITE 100 MONTEREY, CALIFORNIA 93940 PHONE: 831.649.4642 FAX: 831.649.3530 WWW.WRDARCH.COM SHEET NO.: FILE NAME: DRAWN BY: CHECKED BY: THE USE OF THE PLANS AND SPECIFICATIONS IS RESTRICTED TO THE ORIGINAL SITE FOR WHICH THEY WERE PREPARED, AND PUBLICATION THEREOF IS EXPRESSLY LIMITED TO SUCH USE. REUSE, REPRODUCTION OR PUBLICATION BY ANY METHOD IN WHOLE OR IN PART IS PROHIBITED. TITLE TO THE PLANS AND SPECIFICATIONS REMAINS WITH THE ARCHITECT, AND VISUAL CONTACT WITH THEM CONSTITUTES PRIMA FACIE EVIDENCE OF THE ACCEPTANCE OF THESE RESTRICTIONS. PLOT DATE: PRINT DATE: 6.24.2025 25039 CARMEL FIRE DEPARTMENT

ENGINE BAYS

CITY OF CARMEL
6TH AVENUE
CARMEL-BY-THE-SEA, CA 93921 A.P.N.: 010-133-006-000
ATTACHMENT 3

Page 417 of 747 ends

44'-9" 14'-10
1 2" 13'-0" 13'-0" BAY 4 10'-4
1 2" CLEAR BAY 3 10'-4
1 2" CLEAR BAY 2 10'-4
1 2" CLEAR BAY 1 10'-6" CLEAR 74'-10"
96 GAL.

BIN
96 GAL.

BIN PLAN NORTH SCALE: DEMOLITION LOWER FLOOR PLAN 1/4"=1'-0" UP WORK BENCH MAINTENANCE SHOP OFFICE OFFICE CAPTAIN'S OFFICE STORAGE / SUPPLIESUTILITY ROOM GYMNASIUM

COMPRESSOR -
BAUER CFS5.5 FOYER ENTRY TOILET ROOM HOSE TOWER SHADEDED AREA NOT IN SCOPE OF WORK D1 D3 D2 D1 D6 D2 D1 D6 6th AVENUE KOHLER GENERATOR 50 1 3TYP. D4
4D778
2 5 TYP.
3TYP. D7 D11 D7 D7 D7 D5 D8 D9 D10 UP DEMOLITION LOWER FLOOR PLAN D20024039-D200 JTI HR SHEET NAME: SET ISSUED: JOB NO.: 2340 GARDEN ROAD, SUITE 100 MONTEREY, CALIFORNIA 93940 PHONE: 831.649.4642 FAX: 831.649.3530 WWW.WRDARCH.COM SHEET NO.: FILE NAME: DRAWN BY: CHECKED BY: THE USE OF THE PLANS AND SPECIFICATIONS IS RESTRICTED TO THE ORIGINAL SITE FOR WHICH THEY WERE PREPARED, AND PUBLICATION THEREOF IS EXPRESSLY LIMITED TO SUCH USE. REUSE, REPRODUCTION OR PUBLICATION BY ANY METHOD IN WHOLE OR IN PART IS PROHIBITED. TITLE TO THE PLANS AND SPECIFICATIONS REMAINS WITH THE ARCHITECT, AND VISUAL CONTACT WITH THEM CONSTITUTES PRIMA FACIE EVIDENCE OF THE ACCEPTANCE OF THESE RESTRICTIONS. PLOT DATE: PRINT DATE: 6.24.2025 25039 CARMEL FIRE DEPARTMENT

ENGINE BAYS

CITY OF CARMEL
6TH AVENUE
CARMEL-BY-THE-SEA, CA 93921 A.P.N.: 010-133-006-000 THE KEY NOTES THAT FOLLOW APPLY TO THE DRAWING(S) ON THIS SHEET ONLY. REFER TO FOLLOWING SHEETS FOR NOTES THAT ARE APPLICABLE TO THOSE DRAWINGS. 1 EXISTING WALL, OR PORTION OF WALL TO REMAIN. 2 3 KEY NOTES4 THE DEMOLITION NOTES THAT FOLLOW APPLY TO THE DRAWING(S) ON THIS SHEET ONLY. REFER TO FOLLOWING SHEETS FOR NOTES THAT ARE APPLICABLE TO THOSE DRAWINGS. DEMOLITION NOTES 1. CONTRACTOR SHALL FIELD VERIFY ALL EXISTING CONDITIONS PRIOR TO BEGINNING WORK. THE CONTRACTOR SHALL NOTIFY THE ARCHITECT OF ANY DISCREPANCIES BETWEEN THE DOCUMENTS AND FIELD CONDITIONS PRIOR TO PROCEEDING WITH THE WORK. IF ANY QUESTIONS ARISE AS TO THE REMOVAL OF ANY MATERIAL, CLARIFY THE POINT IN QUESTION WITH THE ARCHITECT BEFORE PROCEEDING. 2. CONTRACTOR SHALL PROTECT ALL EXISTING ITEMS THAT ARE NOT SCHEDULED FOR REMOVAL FROM DAMAGE. CONTRACTOR SHALL BE RESPONSIBLE FOR PATCHING AND/OR REPAIRING ANY DAMAGE CAUSED TO ITEMS TO REMAIN. 3. CONTRACTOR SHALL FURNISH ALL LABOR AND MATERIALS/EQUIPMENT AS REQUIRED TO COMPLETE DEMOLITION AND REMOVAL OF ALL ITEMS AS INDICATED. 4. CONTRACTOR TO CLEAN AND PROPERLY DISPOSE OF ALL ABANDONED EQUIPMENT AND TRASH/DEBRIS LEFT FROM PREVIOUS TENANT. CONTRACTOR SHALL VERIFY ALL ITEMS FOR DISPOSAL WITH TENANT AND/OR OWNER PRIOR TO STARTING WORK. 5. CONTRACTOR SHALL IMPLEMENT CONSTRUCTION DUST / DEBRIS CONTROL MEASURES THROUGHOUT THE DURATION OF CONSTRUCTION. 6. AT COMPLETION OF DEMO WORK, THE CONSTRUCTION AREA SHALL BE LEFT IN "BROOM CLEAN" CONDITION. ALL DEBRIS AND MISC. MATERIAL SHALL BE REMOVED. 7. DEMOLITION IS NOT NECESSARILY LIMITED TO WHAT IS SHOWN ON DRAWINGS. THE INTENT IS TO INDICATE THE GENERAL SCOPE OF DEMOLITION REQUIRED TO COMPLETE THE WORK IN ACCORDANCE WITH THE CONTRACT DOCUMENTS. 8. REMOVE TO SOURCE AND CAP ALL PIPES, VENTS, APPLIANCES AND/OR DRAINS NOT BEING RE-USED. 9. GENERAL CONSTRUCTION CONTRACTOR SHALL PROVIDE APPROPRIATE WEATHER PROTECTION OF EXISTING STRUCTURE WHEN DEMOLITION WORK CAUSES EXPOSURE OF EXISTING CONSTRUCTION TO THE ELEMENTS. LEGEND EXISTING DOOR TO REMAIN EXISTING WALL TO REMAIN EXISTING WALL TO BE REMOVED. EXISTING DOOR AND DOOR FRAME TO BE REMOVED. EXISTING WINDOW OR STOREFRONT TO BE REMOVED. D1 D4 D3 REMOVE EXISTING WALL, OR PORTION OF WALL, INCLUDING BUT NOT LIMITED TO GYP. BOARD, STUDS, AND BASE TO ACCOMMODATE NEW WORK. 10. CONTRACTOR TO ENSURE THAT EXISTING UTILITIES (GAS, ELECTRIC OR PHONE, ETC.), ACCESS FOR TENANT & CUSTOMER USE, MECHANICAL VENTILATION, HEATING AND/OR COOLING SYSTEMS, PROVIDED TO ALL TENANTS IN THE EXISTING BUILDINGS WHERE WORK WILL OCCUR (AS WELL AS IN BUILDINGS WHERE WORK WILL NOT OCCUR). 11. CARE SHALL BE TAKEN BY CONTRACTOR TO MINIMIZE DISRUPTION TO THE BUSINESS THROUGHOUT DURATION OF CONSTRUCTION. CONTRACTOR SHALL COORDINATE ALL CONSTRUCTION ACTIVITIES INCLUDING BUT NOT LIMITED TO CONSTRUCTION SCHEDULE AND HOURS OF CONSTRUCTION WITH BUILDING OWNER PRIOR TO WORK. 12. CONTRACTOR SHALL PROTECT ALL EXISTING FLOOR COVERINGS TO REMAIN FROM DAMAGE. 13. CONTRACTOR SHALL LEGALLY DISPOSE OF ANY MATERIALS SCHEDULED FOR DEMOLITION. D2 D5 REMOVE AND AND SET ASIDE EXISTING STOREFRONT FOR POTENTIAL MODIFICATION AND RE-USE. GENERAL NOTES6 EXISTING ELECTRICAL PANEL TO REMAIN. SEE ELECTRICAL DRAWINGS FOR ADDITIONAL REQUIREMENTS. REMOVE AND SET ASIDE EXISTING WORKBENCH FOR POTENTIAL MODIFICATION AND RE-USE. REMOVE EXISTING WINDOW.5 EXISTING CONCRETE COLUMNS AND WALLS TO REMAIN.7 REMOVE EXISTING DOOR. EXISTING UTILITY SINK TO REMAIN.8 EXISTING ROLL-UP DOOR TO REMAIN. D6 REMOVE EXISTING CARPET. D7 TURNOUT RACKS TO BE RELOCATED. SEE FLOOR PLAN. D8 VEHICLE CLEANING / POLISHING/ MAINT. SUPPLIES CABINET TO BE RELOCATED. D9 YELLOW FLAMMABLES CABINET TO BE RELOCATED. D10 TRASH BINS TO BE RELOCATED. D11 WALL MOUNTED WOOD LADDER TO BE REMOVED. EXISTING FIREMAN'S POLE AND LANDING PAD TO REMAIN. EXISTING STAIRWAY TO REMAIN. EXISTING DOOR TO REMAIN.

ATTACHMENT 3

Page 418 of 747 ends

SHADEDED AREA NOT IN SCOPE OF WORK PLAN NORTH SCALE: DEMOLITION REFLECTED CEILING PLAN 1/4"=1'-0" D1 D2 TYP. D2 6th AVENUE 2TYP. 3 D4 D4
3 3 GWB SLOPE UNDER STAIRS C.H.7'-5" GWB C.H.7'-5" GWB C.H.7'-5" GWB C.H.10'-7" C.T. C.H.11'-4" C.T. D3 TYP. 1 TYP. 2 D3 TYP. 1 4TYP. DEMOLITION REFLECTED CEILING PLAN D22125039-D221 JTI HR SHEET NAME: SET ISSUED: JOB NO.: 2340 GARDEN ROAD, SUITE 100 MONTEREY, CALIFORNIA 93940 PHONE: 831.649.4642 FAX: 831.649.3530 WWW.WRDARCH.COM SHEET NO.: FILE NAME: DRAWN BY: CHECKED BY: THE USE OF THE PLANS AND SPECIFICATIONS IS RESTRICTED TO THE ORIGINAL SITE FOR WHICH THEY WERE PREPARED, AND PUBLICATION THEREOF IS EXPRESSLY LIMITED TO SUCH USE. REUSE, REPRODUCTION OR PUBLICATION BY ANY METHOD IN WHOLE OR IN PART IS PROHIBITED. TITLE TO THE PLANS AND SPECIFICATIONS REMAINS WITH THE ARCHITECT, AND VISUAL CONTACT WITH THEM CONSTITUTES PRIMA FACIE EVIDENCE OF THE ACCEPTANCE OF THESE RESTRICTIONS. PLOT DATE: PRINT DATE: 6.24.2025 25039 CARMEL FIRE DEPARTMENT

ENGINE BAYS

CITY OF CARMEL
6TH AVENUE
CARMEL-BY-THE-SEA, CA 93921 A.P.N.: 010-133-006-000 1. CONTRACTOR SHALL FIELD VERIFY ALL EXISTING CONDITIONS PRIOR TO BEGINNING WORK. THE CONTRACTOR SHALL NOTIFY THE ARCHITECT OF ANY DISCREPANCIES BETWEEN THE DOCUMENTS AND FIELD CONDITIONS PRIOR TO PROCEEDING WITH THE WORK. IF ANY QUESTIONS ARISE AS TO THE REMOVAL OF ANY MATERIAL, CLARIFY THE POINT IN QUESTION WITH THE ARCHITECT BEFORE PROCEEDING. ALL ELEMENTS NOT SHOWN TO REMAIN ARE TO BE DEMOLISHED PER ARCHITECT'S APPROVAL. 2. CONTRACTOR SHALL PROTECT ALL EXISTING ITEMS THAT ARE NOT SCHEDULED FOR REMOVAL FROM DAMAGE. CONTRACTOR SHALL BE RESPONSIBLE FOR PATCHING AND/OR REPAIRING ANY DAMAGE CAUSED TO ITEMS TO REMAIN. 3. CONTRACTOR SHALL FURNISH ALL LABOR AND MATERIALS/EQUIPMENT AS REQUIRED TO COMPLETE DEMOLITION AND REMOVAL OF ALL ITEMS AS INDICATED. 4. CONTRACTOR SHALL IMPLEMENT CONSTRUCTION DUST / DEBRIS CONTROL MEASURES THROUGHOUT THE DURATION OF CONSTRUCTION. 5. AT COMPLETION OF DEMOLITION WORK, THE CONSTRUCTION AREA(S) SHALL BE LEFT IN "BROOM CLEAN" CONDITION. ALL DEBRIS AND MISCELLANEOUS MATERIAL SHALL BE REMOVED. 6. DEMOLITION IS NOT NECESSARILY LIMITED TO WHAT IS SHOWN ON DRAWINGS. THE INTENT IS TO INDICATE THE GENERAL SCOPE OF DEMOLITION REQUIRED TO COMPLETE THE WORK IN ACCORDANCE WITH THE CONTRACT DOCUMENTS. 7. GENERAL CONSTRUCTION CONTRACTOR SHALL PROVIDE APPROPRIATE WEATHER PROTECTION OF EXISTING STRUCTURE WHEN DEMOLITION WORK CAUSES EXPOSURE OF EXISTING CONSTRUCTION TO THE ELEMENTS. 12. CONTRACTOR SHALL RELOCATE AND/OR MODIFY EXISTING FIRE SPRINKLER AND FIRE ALARM SYSTEMS AS REQUIRED TO ACCOMMODATE NEW WORK. DRAWINGS AND SUPPORTIVE CALCULATIONS FOR ALL MODIFICATIONS SHALL BE SUBMITTED BY THE CONTRACTOR TO THE GOVERNING AGENCY FOR REVIEW AND APPROVAL. 13. CONTRACTOR SHALL RELOCATE AND/OR MODIFY EXISTING MECHANICAL SYSTEM INCLUDING BUT NOT LIMITED TO MECHANICAL DUCTS AND GRILLES AS REQUIRED TO PROVIDE ADEQUATE DISTRIBUTION OF MECHANICAL SERVICE TO THE SPACE. LEGEND EXISTING LIGHT FIXTURE TO BE REMOVED. EXISTING MECHANICAL GRILLE TO BE REMOVED. DEMOLITION NOTES THE DEMOLITION NOTES THAT FOLLOW APPLY TO THE DRAWING(S) ON THIS SHEET ONLY. REFER TO FOLLOWING SHEETS FOR NOTES THAT ARE APPLICABLE TO THOSE DRAWINGS. D1 REMOVE EXISTING LIGHT FIXTURE. SEE REFLECTED CEILING PLAN AND ELECTRICAL DRAWINGS FOR NEW LIGHTING LOCATIONS AND REQUIREMENTS. REMOVE PORTION OF CEILING. SEE SECTION ON SHEET A701. REMOVE AND RECYCLE 2X4 ACOUSTICAL CEILING TILES THROUGH OUT SPACE. D2 D3 8. CONTRACTOR TO ENSURE THAT EXISTING UTILITIES (GAS, ELECTRIC OR PHONE, ETC.), ACCESS FOR TENANT & CUSTOMER USE, MECHANICAL VENTILATION, HEATING AND/OR COOLING SYSTEMS, PROVIDED TO ALL TENANTS IN THE EXISTING BUILDINGS WHERE WORK WILL OCCUR (AS WELL AS IN BUILDINGS WHERE WORK WILL NOT OCCUR). 9. CARE SHALL BE TAKEN BY CONTRACTOR TO MINIMIZE DISRUPTION TO EXISTING TENANT/ BUSINESS OPERATIONS IN BUILDING THROUGHOUT DURATION OF CONSTRUCTION. CONTRACTOR SHALL COORDINATE ALL CONSTRUCTION ACTIVITIES WITH BUILDING OWNER PRIOR/ BUSINESS PRIOR TO WORK. 10. EXISTING WALLS WERE CONSTRUCTED WITH OTHER PERMITS AND/OR CONTRACT. FIELD VERIFY CONSTRUCTION AND WIDTH PRIOR TO FABRICATION OF DOOR FRAMES OR COMPONENTS WHICH REQUIRE THE WIDTH OF THE WALL TO BE SET. 11. CONTRACTOR TO COORDINATE WITH OWNER ON CONSTRUCTION SCHEDULE AND HOURS OF CONSTRUCTION. 14. EXTRA EXIT SIGNS MAY BE REQUIRED DURING FINAL INSPECTION. 15. EXACT LOCATION OF EXIT SIGNS MAY BE ALTERED DURING FINAL INSPECTION. 16. CONTRACTOR TO RECYCLE ALL ACOUSTICAL CEILING TILES. 17. CONTRACTOR SHALL LEGALLY DISPOSE OF ANY MATERIAL SCHEDULED FOR DEMOLITION. DEMOLITION GENERAL NOTES KEY NOTES THE KEY NOTES THAT FOLLOW APPLY TO THE DRAWING(S) ON THIS SHEET ONLY. REFER TO FOLLOWING SHEETS FOR NOTES THAT ARE APPLICABLE TO THOSE DRAWINGS. 2 3 EXISTING LIGHT FIXTURE TO REMAIN. EXISTING 2' x 4' SUSPENDED CEILING GRID TO REMAIN. EXISTING 2x4 ACOUSTICAL SUSPENSION GRID TILES TO BE REMOVED. SUSPENSION GRID TO REMAIN.1 EXISTING LIGHT FIXTURE TO REMAIN. EXISTING LIGHT FIXTURE TO REMAIN. PORTION OF EXISTING GWB CEILING TO REMAIN. REMOVE EXISTING MECHANICAL GRILLE. SEE MECHANICAL DRAWINGS FOR ANY NEW WORK TO OCCUR. D44 EXISTING ROLL-UP DOOR CHAIN TRACK.

ATTACHMENT 3

Page 419 of 747 ends

UP UP MAINTENANCE SHOP TURNOUT ROOM OFFICE STORAGE / SUPPLIES COPY UTILITY ROOM GYMNASIUM COMPRESSOR FOYER ENTRY TOILET ROOM HOSE TOWER SHADEDED AREA NOT IN SCOPE OF WORK 6th AVENUE ALIGN +/- 26'-8"
6'-7"
35'-8" PLAN NORTH SCALE: PROPOSED LOWER FLOOR PLAN 1/4"=1'-0" 44'-9" 14'-10
1 2" 13'-0" 13'-0" BAY 4 10'-4
1 2" CLEAR BAY 3 10'-4
1 2" CLEAR BAY 2 10'-4
1 2" CLEAR BAY 1 10'-6" CLEAR 74'-10" FOAM WATER (N) ENGINE 31' x 8' (N) AMBULANCE 24' x 8' (E) PARAMEDIC #7166 24' x 8' FOAM WATER (E) ENGINE #7113 30' x 8' 96 GAL.

BIN TOOL BOX
96 GAL.

BIN
1 3TYP.
478
2 5 TYP.
3TYP.
9 10 11 11 12 13 TYP. 1415 16 17 18
+/- 2'-8
1 2"
3 A701
2 A701
1 A701
4'-0"
(3'-0" MIN.)
3'-11
1 2" PROPOSED LOWER FLOOR PLAN A20124039-A201 JTI HR SHEET NAME: SET ISSUED: JOB NO.: 2340 GARDEN ROAD, SUITE 100 MONTEREY, CALIFORNIA 93940 PHONE: 831.649.4642 FAX: 831.649.3530 WWW.WRDARCH.COM SHEET NO.: FILE NAME: DRAWN BY: CHECKED BY: THE USE OF THE PLANS AND SPECIFICATIONS IS RESTRICTED TO THE ORIGINAL SITE FOR WHICH THEY WERE PREPARED, AND PUBLICATION THEREOF IS EXPRESSLY LIMITED TO SUCH USE. REUSE, REPRODUCTION OR PUBLICATION BY ANY METHOD IN WHOLE OR IN PART IS PROHIBITED. TITLE TO THE PLANS AND SPECIFICATIONS REMAINS WITH THE ARCHITECT, AND VISUAL CONTACT WITH THEM CONSTITUTES PRIMA FACIE EVIDENCE OF THE ACCEPTANCE OF THESE RESTRICTIONS. PLOT DATE: PRINT DATE: 6.24.2025 25039 CARMEL FIRE DEPARTMENT

ENGINE BAYS

CITY OF CARMEL
6TH AVENUE
CARMEL-BY-THE-SEA, CA 93921 A.P.N.: 010-133-006-000 THE KEY NOTES THAT FOLLOW APPLY TO THE DRAWING(S) ON THIS SHEET ONLY. REFER TO FOLLOWING SHEETS FOR NOTES THAT ARE APPLICABLE TO THOSE DRAWINGS. KEY NOTES 91011 EXISTING CONCRETE SLAB TO BE PREPPED AND NEW EPOXY FLOOR COATING TO BE APPLIED. 1213 NEW WALL. NEW DOOR. NEW OR RELOCATED TURNOUT RACKS NEW ENGINE. NEW AMBULANCE. 18 LEGEND NEW DOOR - SEE DOOR SCHEDULE EXISTING DOOR TO REMAIN INTACT EXISTING NON-RATED WALL TO REMAIN INTACT EXISTING WINDOW NEW NON-RATED WALL 1. ALL NEW WALLS IN TOILET ROOMS AND OTHER WET WALL LOCATIONS SHALL BE FINISHED WITH WATER RESISTANT BACKING BOARD "GREEN BOARD" COMPLYING WITH A.S.T.M. C630 AND SHALL BE INSTALLED IN ACCORDANCE WITH CBC SECTION 2505 AND SECTIONS 1210.02 AND 1210.03. 2. ALL WALLS SHALL BE FINISHED WITH 5 8" TYPE 'X' GYPSUM WALLBOARD CONFORMING TO A.S.T.M. C36 AND CBC SECTION 2506. ALL GYPSUM WALLBOARD SHALL BE INSTALLED IN ACCORDANCE WITH THE PROVISION OF CBC SECTION 2508. 3. CONTRACTOR SHALL SEAL ALL NEW GYPSUM WALLBOARD WITH PRIMER PRIOR TO APPLYING FINISH PAINT. 4. ALL WALL AND CEILING FINISH MATERIALS SHALL COMPLY WITH CBC SECTION 803 AND HAVE A FLAME SPREAD INDEX NOT GREATER THAN THAT SPECIFIED IN TABLE 803.13 FOR THE GROUP AND LOCATION DESIGNATED. ALL INSULATION TO HAVE FLAME SPREAD RATING OF LESS THAN 25. 5. FIRE BLOCKING SHALL BE PROVIDED AS REQUIRED AND IN ACCORDANCE WITH CBC SECTION 717. 6. CONTRACTOR SHALL FIELD VERIFY AND COORDINATE (E) WALL TYPES/THICKNESS WITH (N) WALL TYPES. (N) WALL TYPES SHALL MATCH (E) WALL TYPES AND HAVE FINISHES THAT ALIGN AT INFILL LOCATIONS OR NOTED ON PLAN. 7. REFER TO THE ROOM FINISH SCHEDULE AND RELATED DETAILS FOR FINISHES REQUIRED AND TO THE MANUFACTURER FOR SURFACE PREP. REQUIREMENTS. 8. PROVIDE 6" METAL STUDS AT ALL PLUMBING WALLS AND / OR WALLS WHERE RECESSED ELECTRICAL PANELS ARE LOCATED. U.N.O. COORDINATE WITH RELATED SUB-CONTRACTORS. WITH ACOUSTIC SEALANT. DO NOT ALLOW OUTLETS ON EITHER SIDE OF PARTITION TO BE IN THE SAME CAVITY. 9. PROVIDE 1/8" MIN. SPACE BETWEEN ELECTRICAL BOXES AND GYP. BOARD. FILL GAP GENERAL NOTES THE KEY NOTES THAT FOLLOW APPLY TO THE DRAWING(S) ON THIS SHEET ONLY. REFER TO FOLLOWING SHEETS FOR NOTES THAT ARE APPLICABLE TO THOSE DRAWINGS. 1 EXISTING WALL, OR PORTION OF WALL TO REMAIN. 2 346 EXISTING ELECTRICAL PANEL TO REMAIN. SEE ELECTRICAL DRAWINGS FOR ADDITIONAL REQUIREMENTS.5 EXISTING CONCRETE COLUMNS AND WALLS TO REMAIN.7 EXISTING UTILITY SINK TO REMAIN.8 EXISTING ROLL-UP DOOR TO REMAIN. EXISTING FIREMAN'S POLE AND LANDING PAD TO REMAIN. EXISTING STAIRWAY TO REMAIN. EXISTING DOOR TO REMAIN. RELOCATED AND / OR MODIFIED WORKBENCH. RELOCATED VEHICLE CLEANING / POLISHING/ MAINTENANCE SUPPLIES CABINET. RELOCATED YELLOW FLAMMABLES CABINET. RELOCATED TRASH BINS. 14151617 ATTACHMENT 3

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SHADEDED AREA NOT IN SCOPE OF WORK
2TYP. 3 C.H.7'-5" GWB C.H.7'-5" GWB C.H.10'-7" C.T. C.H.11'-4" C.T. TYP. 1 TYP. 2 15TYP. TYP. PLAN NORTH SCALE: REFLECTED CEILING PLAN 1/4"=1'-0" 6th AVENUE 6 4 3 GWB SLOPE UNDER STAIRS
7TYP. PROPOSED REFLECTED CEILING PLAN A22125039-A221 JTI HR SHEET NAME: SET ISSUED: JOB NO.: 2340 GARDEN ROAD, SUITE 100 MONTEREY, CALIFORNIA 93940 PHONE: 831.649.4642 FAX: 831.649.3530 WWW.WRDARCH.COM SHEET NO.: FILE NAME: DRAWN BY: CHECKED BY: THE USE OF THE PLANS AND SPECIFICATIONS IS RESTRICTED TO THE ORIGINAL SITE FOR WHICH THEY WERE PREPARED, AND PUBLICATION THEREOF IS EXPRESSLY LIMITED TO SUCH USE. REUSE, REPRODUCTION OR PUBLICATION BY ANY METHOD IN WHOLE OR IN PART IS PROHIBITED. TITLE TO THE PLANS AND SPECIFICATIONS REMAINS WITH THE ARCHITECT, AND VISUAL CONTACT WITH THEM CONSTITUTES PRIMA FACIE EVIDENCE OF THE ACCEPTANCE OF THESE RESTRICTIONS. PLOT DATE: PRINT DATE: 6.24.2025 25039 CARMEL FIRE DEPARTMENT

ENGINE BAYS

CITY OF CARMEL
6TH AVENUE
CARMEL-BY-THE-SEA, CA 93921 A.P.N.: 010-133-006-000 LEGEND KEY NOTES THE KEY NOTES THAT FOLLOW APPLY TO THE DRAWING(S) ON THIS SHEET ONLY. REFER TO FOLLOWING SHEETS FOR NOTES THAT ARE APPLICABLE TO THOSE DRAWINGS. 2 3 EXISTING LIGHT FIXTURE TO REMAIN. EXISTING 2' x 4' SUSPENDED CEILING GRID TO REMAIN. EXISTING 2x4 ACOUSTICAL SUSPENSION GRID TILES TO BE REPLACED. SUSPENSION GRID TO REMAIN.1 EXISTING LIGHT FIXTURE TO REMAIN. EXISTING LIGHT FIXTURE TO REMAIN. PORTION OF EXISTING GWB CEILING TO REMAIN. 4 NEW LIGHT FIXTURE. AREA OF NEW GWB CEILING ALIGNED WITH EXISTING. AREA OF NEW 2' x 4' SUSPENDED CEILING GRID TO BE ALIGNED WITH EXISTING. ADD NEW ACOUSTIC TILES. 7 AREA OF NEW GWB CEILING ALIGNED WITH EXISTING. 6 ATTACHMENT 3

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11'-8"
12'-8"
+/- 7'-5" CONC. SLAB GWB CLG. T.O. PLYWD DECK B.O. CONC. BM. U'SIDE MTL. DECK 8'-0"
10'-8"
10'-612" B.O. CLG. TILE B.O. CONC. BM. CONC. COLUMN SCALE: 2 SECTION AT OFFICES 3/8" = 1'-0" 11'-8"
12'-8"
+/- 7'-5" CONC. SLAB GWB CLG. T.O. PLYWD DECK B.O. CONC. BM. U'SIDE MTL. DECK 8'-0"
10'-8"
10'-612" B.O. CLG. TILE B.O. CONC. BM. CONC. COLUMN BEYOND PERP. CONC. BM. CONC. BEAM PLYWD. DECK o/ 2x6 WD. FRAMING GWB CLG. WOOD SIDING SCALE: 1 SECTION AT CAPTAIN'S OFFICE 3/8" = 1'-0" 7'-4"STOREFRONT WINDOW SYSTEM PERP. CONC. BM. CONC. BEAM PLYWD. DECK o/ 2x6 WD. FRAMING GWB CLG. 2x4 WD. STUD WALL CONC. WALL / COLUMN A EXISTING CONDITION A EXISTING CONDITION 11'-8"
12'-8"
+/- 7'-5" CONC. SLAB GWB CLG. T.O. PLYWD DECK B.O. CONC. BM. U'SIDE MTL. DECK 8'-0"
10'-8"
10'-612" B.O. CONC. BM. B.O. CLG. TILE CONC. COLUMN
11'-8"
12'-8"
+/- 7'-5" CONC. SLAB GWB CLG. T.O. PLYWD DECK B.O. CONC. BM. U'SIDE MTL. DECK 8'-0"
10'-8"
10'-612" B.O. CLG. TILE B.O. CONC. BM. CONC. COLUMN BEYOND PERP. CONC. BM. CONC. BEAM PLYWD. DECK o/ 2x6 WD. FRAMING GWB CLG. WOOD SIDING CONC. WALL / COLUMN 7'-4"REMOVE STOREFRONT WINDOW SYSTEM CONC. WALL / COLUMN B DEMOLITION B DEMOLITION CONC. WALL / COLUMN 11'-8"
12'-8"
+/- 7'-5" CONC. SLAB GWB CLG. T.O. PLYWD DECK B.O. CONC. BM. U'SIDE MTL. DECK 8'-0"
10'-8"
10'-612" B.O. CLG. TILE B.O. CONC. BM. CONC. COLUMN BEYOND PERP. CONC. BM. CONC. BEAM PLYWD. DECK o/ 2x6 WD. FRAMING GWB CLG. WOOD SIDING CONC. WALL / COLUMN 7'-4"NEW OR MODIFIED STOREFRONT WINDOW SYSTEM C PROPOSED 11'-8"
12'-8"
+/- 7'-5" CONC. SLAB GWB CLG. T.O. PLYWD DECK B.O. CONC. BM. U'SIDE MTL. DECK 8'-0"
10'-8"
10'-612" B.O. CONC. BM. B.O. CLG. TILE CONC. COLUMN PERP. CONC. BM. CONC. BEAM PLYWD. DECK o/ 2x6 WD. FRAMING GWB CLG. NEW 2x4 WD. STUD WALL CONC. WALL / COLUMN C PROPOSED PERP. CONC. BM. CONC. BEAM PLYWD. DECK o/ 2x6 WD. FRAMING GWB CLG. NEW 2x4 WD. STUD WALL REMOVE WALL & PORTION OF DECK / CEILING SPLICE IN CEILING TILE AND GRID AT GAP EXISTING CLG. TILE MAINT. OFFICE CONC. COLUMN CONC. WALL WORK BENCH CONC. BM. PERP. CONC. BEAM PLYWD. DECK o/ 2x6 WD. FRAMING GWB CLG. 2x4 WD. STUD WALL 11'-8"
12'-8"
+/- 7'-5" CONC. SLAB GWB CLG. T.O. PLYWD DECK B.O. CONC. BM. U'SIDE MTL. DECK 8'-0"
10'-8" B.O. CONC. BM. SCALE: 3 SECTION AT END OFFICE 3/8" = 1'-0" A EXISTING CONDITION MAINT. OFFICE CONC. COLUMN CONC. WALL REMOVE WORK BENCH CONC. BM. PERP. CONC. BEAM PLYWD. DECK o/ 2x6 WD. FRAMING GWB CLG. REMOVE 2x4 WD. STUD WALL 11'-8"
12'-8"
+/- 7'-5" CONC. SLAB GWB CLG. T.O. PLYWD DECK B.O. CONC. BM. U'SIDE MTL. DECK 8'-0"
10'-8" B.O. CONC. BM. B DEMOLITION MAINT. NEW TURNOUT ROOM CONC. COLUMN CONC. WALL CONC. BM. PERP. CONC. BEAM PLYWD. DECK o/ 2x6 WD. FRAMING GWB CLG. NEW 2x4 WD. STUD WALL - ALIGN WITH FACE OF COLUMN 11'-8"
12'-8"
+/- 7'-5" CONC. SLAB GWB CLG. T.O. PLYWD DECK B.O. CONC. BM. U'SIDE MTL. DECK 8'-0"
10'-8" B.O. CONC. BM. C PROPOSEDEXTEND DECK CEILING TILE CEILING TILE CEILING TILE FACE OF COL. BUILDING SECTIONS A70125039-A501 JTI HR SHEET NAME: SET ISSUED: JOB NO.: 2340 GARDEN ROAD, SUITE 100 MONTEREY, CALIFORNIA 93940 PHONE: 831.649.4642 FAX: 831.649.3530 WWW.WRDARCH.COM SHEET NO.: FILE NAME: DRAWN BY: CHECKED BY: THE USE OF THE PLANS AND SPECIFICATIONS IS RESTRICTED TO THE ORIGINAL SITE FOR WHICH THEY WERE PREPARED, AND PUBLICATION THEREOF IS EXPRESSLY LIMITED TO SUCH USE. REUSE, REPRODUCTION OR PUBLICATION BY ANY METHOD IN WHOLE OR IN PART IS PROHIBITED. TITLE TO THE PLANS AND SPECIFICATIONS REMAINS WITH THE ARCHITECT, AND VISUAL CONTACT WITH THEM CONSTITUTES PRIMA FACIE EVIDENCE OF THE ACCEPTANCE OF THESE RESTRICTIONS. PLOT DATE: PRINT DATE: 6.24.2025 25039 CARMEL FIRE DEPARTMENT

ENGINE BAYS

CITY OF CARMEL
6TH AVENUE
CARMEL-BY-THE-SEA, CA 93921 A.P.N.: 010-133-006-000

ATTACHMENT
3

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CITY OF CARMEL-BY-THE-SEA
City Council
Staff Report
November 4, 2025

ORDERS OF BUSINESS
TO: Honorable Mayor and City Council Members
SUBMITTED BY: Valerie Gaino, Environmental Analyst
APPROVED BY: Chip Rerig, City Administrator
SUBJECT: Discuss and Provide Direction on a Proposed Policy Prohibiting New Installations of Architectural Copper to Protect Water Quality, and Provide Direction on Preparation of an Ordinance Adding Chapter 17.43 (Water Quality Protection) to the Carmel Municipal Code (Estimated time - 20 min)
RECOMMENDATION:

Staff recommends that the City Council discuss and provide direction on a proposed policy prohibiting the new installation of architectural copper to protect water quality, and direct staff to prepare an ordinance adding Chapter 17.43 (Water Quality Protection) to the Carmel Municipal Code for future Council consideration.

BACKGROUND / SUMMARY:

Background and Summary
The City of Carmel-by-the-Sea (Carmel) is part of the Central California Regional ASBS Monitoring Program. The regional program measures water quality in stormwater discharges and ocean receiving waters in conformance with the Special Protections for Areas of Special Biological Significance (ASBS). In the 1970s, thirty-four Areas of Special Biological Significance were designated by the California State Water Resources Control Board (State Board) to protect valuable or sensitive biological communities. Regulations prohibit discharges of waste to these ASBS. In order to qualify for an exemption to the prohibition against discharge of waste carried by stormwater, participants (jurisdictions) are required to monitor and reduce source pollutants. In 2016, the Central Coast Regional ASBS Monitoring Program released a

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Final Report for the years 2013-2016 (Attachment #1). The results of that report identified several exceedances of the water quality criteria for copper and fecal indicator bacteria (FIB) associated with stormwater discharged from Carmel into the Carmel Bay ASBS.

The City also takes part in the Monterey Regional Storm Water Management Program (MRSWMP) water quality monitoring modeled after the Monterey Bay National Marine Sanctuary’s (MBNMS) Dry Run/First Flush monitoring program, utilizing volunteers to collect water samples which are analyzed for common urban pollutants. “The MRSWMP water quality monitoring program promotes volunteer participation, stewardship, and environmental education while providing important data regarding the quality of water flowing into MBNMS. This monitoring program is designed to meet E.8.ii requirements under the Phase II Stormwater Permit, satisfying public involvement and participation elements of the permit. This monitoring program does not fulfill the E.13 requirements pertaining to Areas of Special Biological Significance (ASBS) Monitoring, Total Maximum Daily Load (TMDL) Monitoring, 303(d) Monitoring, or Receiving Water Monitoring, which are completed by permittees individually or through regional programs.” (2023-24 MRSMWP Report, 2025). The First Flush program has measured copper exceedances in Carmel outfalls/drainages every year since 2015.

In 2022, a report completed by Applied Marine Sciences, Inc. (AMS) was commissioned on behalf of the City of Carmel to help identify potential pollution sources. The report describes the results from four years of monitoring from 2018-2022 tracing source pollution and exceedance of particulate and dissolved copper as well as fecal indicator bacteria. The results of the 2022 AMS report determined that the source of total copper exceedances in Carmel-by-the-Sea watersheds are likely contributed by architectural copper. According to the authors, copper concentrations in watershed and storm drain samples were dominated by dissolved copper. Total copper concentrations were significantly higher in watershed and storm drain samples than in ocean samples, indicating the high copper concentrations in some of the ocean samples originate from sources on land. The samples that were collected from copper roof gutters and downspouts revealed higher concentrations of copper than those measured from the watershed or storm drain samples. Additionally, the copper downspout samples were dominated by dissolved copper, suggesting that high dissolved copper amounts arise from rainfall flowing across architectural copper located on buildings and infrastructure. • A sample collected on December 23, 2021, from a downspout at the Sunset Center had a total copper concentration of 169 µg/L.
• A sample collected on the same date from a downspout at City Hall had a total copper concentration of 139 µg/L.

Samples collected from watershed and storm drain sites during wet weather had lower total copper concentrations, 75.6 µg/L at the SD (storm drain) site and 56.6 µg/L at the WS2 site on December 13, 2021 (a storm event).

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Results of the 2023-24 and 2024-25 Dry Run and First Flush Monitoring Reports (Attachment #2)
For the First Flush event conducted on November 18th, 2023, copper exceeded the Basin Plan WQO of 30 µg/L (micrograms per liter) in all samples at both 4th Avenue and Ocean Avenue. The Basin Plan WQO refers to the Water Quality Control Plan for the Central Coast Basin Water Quality Objective. These objectives are set by the RWQCB for the protection of marine or aquatic life. At the 4th Avenue site, the copper results were 325 µg/L and 65.3 µg/L for the first and second time series samples, respectively. The highest single sample copper result from all 2023 First Flush sites was from 4th Avenue at 325 µg/L during the first time series. At the Ocean Avenue site, the copper results were 54.3 µg/L and 55.9 µg/L for the first and second time series samples, respectively. The RWQCB considers the acceptable limit to be 30 µg/L (micrograms per liter) for total copper (dissolved + particulate). The report for the year 2024/2025 was recently released. Carmel continued to test above recommended levels in the storm drains, at 140 and 112 µg/L during the First Flush monitoring at 4th Avenue, and 115 and 112 µg/L at Ocean Avenue.

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2022-23 and 2023-24 Applied Marine Sciences Technical Memos Consistent with actions proposed in the City of Carmel by the Sea Stormwater Compliance Plan for Areas of Special Biological Significance (ASBS), two storms are sampled during the rainy seasons (Attachment #3). In 2022-23 the sampling occurred in late December and March, and the following year in January and February — this is contrary to the MRWMP sampling, which occurs before the rains and during the first storms in the fall.

In each storm, samples are collected from eight sites; watersheds 2 and 3 (WS2, WS3), subwatersheds 3a and 3b (WS3a, WS3b), the 4th Ave storm drain (SD), receiving water (RW), and 2 ocean water sites (OW, OW2). The point of compliance for stormwater discharges is receiving water. Determining the effects of storm drain discharge on receiving water requires estimates of increased concentrations in receiving water due to storm drain discharges. Increased receiving water concentrations due to storm drain discharges were estimated for each storm by using dissolved copper in storm drain samples as a conservative parameter (Table 2). The dilution factors change for each sample collection based on the concentrations measured at SD, RW, and OW. On 1/22/2024, very high initial dilution occurred because the RW sample was at low background concentrations (Applied Marine Science, 2024).

Table 2. Calculation of dilution factors of storm drain water in ocean receiving water 2023 & 2024

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The Impact of Copper on Aquatic Life
“Copper is commonly found in aquatic systems as a result of both natural and anthropogenic sources. Copper is an essential nutrient at low concentrations, but is toxic to aquatic organisms at higher concentrations. In addition to acute effects such as mortality, chronic exposure to copper can lead to adverse effects on survival, growth, reproduction as well as alterations of brain function, enzyme activity, blood chemistry, and metabolism” (EPA, 2025).
“Dissolved copper (dCu) is a ubiquitous surface water pollutant that causes a range of adverse effects in fish as well as in aquatic invertebrates and algae. Fish behaviors can be disrupted at concentrations of dCu that are at or slightly above ambient concentrations. Sensory system effects are generally among the more sensitive fish responses and underlie important behaviors involved in growth, reproduction, and (ultimately) survival (i.e., predator avoidance). Recent experiments on the sensory systems and corresponding behavior of juvenile salmonids contribute to more than four decades of research and show that dCu is a neurotoxicant that directly damages the sensory capabilities of salmonids at low concentrations” (Hecht, et al., 2007). “Copper is a naturally occurring element and an essential micronutrient. It does not degrade, but rather enters a complex biogeochemical cycle. In the water column, copper can exist bound to both organic and inorganic species and as free or hydrated copper ions. Water column chemistry affects copper speciation and bioavailability. In all water types (saltwater, brackish water, and freshwater), organic ligands in the water column can sequester the majority of dissolved copper, and therefore, organic ligands play the largest role in copper bioavailability. In freshwater, however, the geochemistry of a particular location, including water column characteristics such as water hardness and pH, is a significant factor that can increase copper bioavailability and toxicity. In Date SD Cu
dissolved,
µg/L
RW Cu
dissolved,
µg/L
OW Cu
dissolved,
µg/L
Dilution
Factor
(SD/(RWOW))
12/27/2022 13.7 6.43 1.94 3.05
3/21/2023 37.1 0.131 0.117 2650
1/22/2024 31.8 0.085 0.084 31,800
2/01/2024 23.9 0.312 0.229 287.95

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most cases, organic ligand concentrations greatly exceed copper ion concentrations in the water column and therefore provide a large buffering capacity. Hence, copper bioavailability can be grossly overestimated if it is based on total dissolved copper (TDCu) concentrations alone. Other factors that influence copper concentrations include location in the water column, season, temperature, depth, and level of dissolved oxygen. For example, concentrations of bioavailable copper may be significantly higher in the bottom waters and sediment pore waters, where organic ligands degrade much faster and dissolved copper is constantly resuspended and recycled into the aquatic system” (Kiaune & Singhasemanon, 2011).

Current Policy, Carmel-by-the-Sea
Following the water sampling reports and environmental programs presentations, the City incorporated policy language on architectural copper within the design review process; conditions of approval, special conditions, effectively prohibiting copper gutters and downspouts.

14. Gutters & Downspouts. As applicable, prior to issuance of a building permit, the applicant shall submit a revised plan for review and approval by the Planning Division identifying the material and color of any proposed gutters and downspouts. Copper gutters and downspouts are prohibited due to environmental impacts on Carmel Bay.

Many cities, including San Diego and Portland, discourage the use of architectural copper. Of several cities researched, only Palo Alto was found to have a specific ordinance banning architectural copper. The City of Palo Alto adopted the policy and municipal code in 2002.

Regional Example
In 2002, the City of Palo Alto banned architectural copper. They codified the ordinance (Attachment #4). In speaking with City officials, they have wide acceptance of the policy and do not experience pushback from residents. Officials could not offer information on current or historical copper levels in their storm drains. Their Stormwater Annual Reports document the effort to keep the bay contaminant free. The decision to approve an architectural copper ban policy was fueled by a comprehensive study commissioned by the Palo Alto Regional Water Quality Control Plant in 2000 - Architectural uses of copper: An evaluation of stormwater pollution loads and BMPs, November 2000. The report evaluates several criteria, including the total Cu and dCu runoff from actual roofs and gutters in Palo Alto, the environmental benefits from choosing different materials or converting away from copper, and the economic impact of making those changes.

Palo Alto Ordinance Text (Municipal Code Section 16.09.160(b)) 2 (b) Copper roofing materials
On and after January 1, 2003, copper metal roofing, copper granules containing

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asphalt shingles and copper gutters shall not be permitted for use on any residential, commercial or industrial building for which a building permit is required. Copper flashing for use under tiles or slates and small copper ornaments are exempt from this prohibition. Replacement roofing and gutters on historic structures are exempt, provided that the roofing material used shall be prepatinated at the factory. For the purposes of this exemption, the definition of "historic" shall be limited to structures designated as Category 1 or Category 2 buildings in the current edition of the Palo Alto Historical and Architectural Resources Report and Inventory.

Conclusions
• Dissolved copper amounts are significantly higher when measured directly off copper gutters (Applied Marine Sciences 2022 Report, Weston Solutions San Diego Study, and Palo Alto Regional Water Quality Report). • Levels of total copper in Carmel watersheds and storm drains were measured above acceptable levels of 30 µg/L in all 10 years monitored, from 2014-2015 to 2024-2025 as part of the First Flush Report. Carmel has the highest concentrations of total copper compared to the other regional cities every year. • Applied Marine Science reports measured dissolved copper levels near or above unacceptable levels in the storm drains after later season storm events in 2023 and 2024, with the receiving waters testing below acceptable level limits. • There is variability in determining the true level of toxicity of total or dissolved copper as water chemistry changes the bioavailability of copper. o We do not have specific information on how the water chemistry of Carmel soil, sand, watersheds and storm drains (throughout the wet and dry seasons) influences the actual toxicity impact on a particular species or general marine life in the Carmel Bay or freshwater life in the watersheds, Mission Creek, or the Carmel River.
o We know that copper does not degrade but enters a complex biogeochemical cycle.
• The EPA and NOAA have determined that only slightly above ambient levels of dissolved copper are neurotoxic and detrimental to aquatic life. o One study cited for this report demonstrates significant negative effects of dissolved copper on juvenile salmonids' neurological function. • The California Association of Stormwater Quality Association (CASQA) prefers a True Source Control (the elimination of a pollutant at its source) approach.

Additional Considerations
• Enforceability: Without a codified ordinance, and with gutter replacement work exempt from building permit requirements, the current architectural copper prohibition is difficult to enforce.
• Filtration: Recent studies highlight the potential effectiveness of biochar for removing dCu, and of a combination of sand and activated charcoal in removing PFAS. BioChar filters are available on a residential and commercial scale (see

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Resources).
• Biofiltration: Rerouting stormwater to biorientation designed landscaping (often installed in ROWs) can help filter numerous pollutants. • Gutter lining: Done retroactively at the Monterey Bay Aquarium, recommended by the City of Pacific Grove under their metal pollution avoidance recommendations.
• Sanitary sewer treatment of dry season and first storm runoff through CAWD:

The Carmel Area Wastewater District Plant could, theoretically, collect and treat a certain volume of storm water. This could greatly reduce dCu levels and levels of other pollutants that build up on the streets and in the storm drains during the dry season. A proposal from 2018 estimates the cost to divert dry season and first flush runoff along San Antonio near $1,000,000.
• Pacific Grove’s urban diversion stations, which don't cover all the outfalls, are designed to run during the dry season and are engineered to capture 100% up to the 85th percentile storm event. PG has decided in recent years to keep them on all year, during the wet and dry season. There are ongoing O&M costs associated with the system.

Draft Architectural Copper Policy Language:
“Architectural copper shall not be permitted for use on any residential, commercial or industrial building for which a building permit is required, nor on gutter replacement or similar projects where a permit is not required. Architectural copper is defined as copper gutters, downspouts, roofing, rain chains, chimney caps, copper granule asphalt shingles, exposed flashing, and other water conveying features excluding flashing under tiles and slates, and small copper ornaments.”
City Council Direction Requested:
• Make recommendations for draft policy changes and guidance for:
o New construction/remodels
o Historic buildings with historical use of copper
o Buildings with existing architectural copper
• Consider presentation of the draft policy to the Planning Commission for recommendations, and
o Definitions of architectural copper (functional and decorative elements). • Consider creating a Municipal Code Ordinance
o Staff recommends adding 17.43 Water Quality Protection, and/or o 15.04 Administration of Building Codes.
• Consider directing staff to explore alternatives or additional protection measures (filters, linings, sewer diversion).

FISCAL IMPACT:

No Fiscal Impact

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PRIOR CITY COUNCIL ACTION:

ATTACHMENTS:

1. Central Coast Regional Monitoring Program Water Quality Report 2013-2016

2. 2024 MRSWMP First Flush Monitoring Report

3. Applied Marine Sciences Final Report Copper & FIB 2022

4. Palo Alto Ordinance Press Release - Prohibiting Copper Roofing Materials

5. References Page (Architectural Copper Policy SR 2025)

6. NEW - Carmel MST Technical Memos - 2022-2025

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Annual Report
2013–2014
May 13, 2015
Central California
Regional Monitoring Program
Stormwater Discharges into
Areas of Special Biological Significance
Final Report
2013–2016
August 1, 2016
Central Coast
Regional Monitoring Program
Water Quality in
Areas of Special Biological Significance
ATTACHMENT 1

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Final Report
2013–2016
Central Coast Regional Monitoring Program
Water Quality in Areas of Special Biological Significance Submitted to:

Monterey Regional Water Pollution Control Agency
Central Coast ASBS Management Committee
5 Harris Court
Monterey, CA 93401
Submitted by:
911 Center Street, Suite A
Santa Cruz, CA 95060
August 29, 2016
ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 i
Table of Contents

1.0 EXECUTIVE SUMMARY ................................................................................................................... 4 ARE THERE NORTH-TO-SOUTH DIFFERENCES IN REFERENCE CONDITIONS? ...............................................................7 ARE THERE NORTH-TO-SOUTH DIFFERENCES IN PRE-STORM WATER QUALITY AT ASBS SITES?.....................................7 DO STORM DISCHARGES ALTER RECEIVING WATER QUALITY? ................................................................................8 ARE ALTERATIONS OF RECEIVING WATER QUALITY DUE TO ANTHROPOGENIC WASTE?................................................8 ARE MARINE BIOLOGICAL RESOURCES BEING AFFECTED BY ASBS STORM DISCHARGES? .............................................9 Rocky Intertidal Monitoring.................................................................................................................9 Mussel Bioaccumulation Monitoring.................................................................................................10 Toxicity Testing ..................................................................................................................................11 Nutrient Effects on Algal Blooms.......................................................................................................12 REGULATORY CONSIDERATIONS ....................................................................................................................12

2.0 PROGRAM BACKGROUND.............................................................................................................14

2.1 REGULATORY HISTORY...........................................................................................................................14

2.2 CENTRAL CALIFORNIA REGIONAL PROGRAM DEVELOPMENT.........................................................................19

3.0 REPORT ORGANIZATION AND SCOPE ............................................................................................20

4.0 MONITORING METHODS...............................................................................................................27

5.0 FINDINGS......................................................................................................................................30

5.1 QUESTION 1: ARE THERE NORTH-TO-SOUTH DIFFERENCES IN REFERENCE CONDITIONS? ....................................30

5.1.1 Conclusion: Are there north-to-south differences in reference conditions?..............................33

5.2 QUESTION 2: ARE THERE NORTH-TO-SOUTH DIFFERENCES IN PRE-STORM WATER QUALITY AT ASBS SITES? .........34

5.2.1 Conclusion: Are there north-to-south differences in Pre-Storm water quality at ASBS sites?...34

5.3 QUESTION 3: DO STORM DISCHARGES ALTER RECEIVING WATER QUALITY?......................................................35

5.3.1 Conclusion: Do storm discharges alter receiving water quality? ..............................................58

5.4 QUESTION 4: ARE ALTERATIONS OF RECEIVING WATER QUALITY DUE TO ANTHROPOGENIC WASTE?.....................61

5.4.1 Conclusion: Are alterations of receiving water quality due to anthropogenic waste? .............68

5.5 QUESTION 5: ARE MARINE BIOLOGICAL RESOURCES BEING AFFECTED BY ASBS STORM DISCHARGES? ..................69

5.5.1 Rocky Intertidal Monitoring......................................................................................................70

5.5.1.1 Rocky Intertidal Conclusions................................................................................................................................ 70

5.5.2 Mussel Bioaccumulation Monitoring........................................................................................71

5.5.2.1 Mussel Bioaccumulation Conclusions.................................................................................................................. 78

5.5.3 Toxicity Testing .........................................................................................................................78

5.5.3.1 Toxicity Testing Conclusions................................................................................................................................ 81

5.5.4 Nutrient Effects on Algal Blooms..............................................................................................81

5.5.4.1 Nutrient Effects on Algal Blooms Conclusion ...................................................................................................... 82

5.5.5 Conclusion: Are marine biological resources being affected by ASBS storm discharges?.........82

6.0 REGULATORY CONSIDERATIONS ...................................................................................................84

6.0 REFERENCES CITED........................................................................................................................88 APPENDIX A. SCOPE OF WORK............................................................................................................92 APPENDIX B. LABORATORY QA SUMMARIES ....................................................................................101 APPENDIX C. CHARACTERIZATION OF THE ROCKY INTERTIDAL ECOLOGICAL COMMUNITIES ASSOCIATED WITH CENTRAL CALIFORNIA AREAS OF SPECIAL BIOLOGICAL SIGNIFICANCE.................133 ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 ii
Figures
FIGURE 1. SPECIAL PROTECTIONS FLOWCHART TO DETERMINE COMPLIANCE WITH NATURAL WATER QUALITY. ....................................17 FIGURE 2. CENTRAL CALIFORNIA REGIONAL ASBS STUDY AREA. ................................................................................................22 FIGURE 3. DUXBURY REEF ASBS WITH MONITORED DISCHARGE INDICATED.................................................................................23 FIGURE 4. FITZGERALD MARINE RESERVE ASBS WITH MONITORED DISCHARGES INDICATED............................................................24 FIGURE 5. PACIFIC GROVE ASBS WITH MONITORING SITES INDICATED........................................................................................25 FIGURE 6. CARMEL BAY ASBS WITH MONITORING SITES INDICATED...........................................................................................26 FIGURE 7. CONCENTRATIONS OF TRACE METALS (G/L EXCEPT FOR MERCURY = NG/L) IN DIFFERENT SAMPLE TYPES............................36 FIGURE 8. CONCENTRATIONS OF FIBS (MPN/100 ML) AND NUTRIENTS (MG/L) IN DIFFERENT SAMPLE TYPES....................................38 FIGURE 9. MAGNITUDE OF RECEIVING WATER CONCENTRATIONS FOR ARSENIC, CADMIUM, CHROMIUM AND MERCURY ABOVE AND BELOW THE OVERALL 85TH PERCENTILE IN RECEIVING WATER SAMPLES DURING EACH STORM AT EACH SITE. .........................................45 FIGURE 10. MAGNITUDE OF RECEIVING WATER CONCENTRATIONS FOR NICKEL, SELENIUM, AND SILVER ABOVE AND BELOW THE OVERALL 85TH PERCENTILE IN RECEIVING WATER SAMPLES DURING EACH STORM AT EACH SITE. ...........................................................46 FIGURE 11. MAGNITUDE OF RECEIVING WATER CONCENTRATIONS FOR COPPER, LEAD AND ZINC ABOVE AND BELOW THE OVERALL 85TH PERCENTILE IN RECEIVING WATER SAMPLES DURING EACH STORM AT EACH SITE. ..................................................................47 FIGURE 12. MAGNITUDE OF RECEIVING WATER CONCENTRATIONS FOR A) E. COLI, B) ENTEROCOCCUS AND C) FECAL COLIFORM, ABOVE AND BELOW THE OVERALL 85TH PERCENTILE IN RECEIVING WATER SAMPLES DURING EACH STORM AT EACH SITE. ........................48 FIGURE 13. MAGNITUDE OF RECEIVING WATER CONCENTRATIONS FOR A) NITRATE, B) AMMONIA, C) UREA, D) ORTHOPHOSPHATE, AND E) TSS ABOVE AND BELOW THE OVERALL 85TH PERCENTILE IN RECEIVING WATER SAMPLES DURING EACH STORM AT EACH SITE. ........49 FIGURE 14. REGRESSIONS OF CHANGES IN RECEIVING WATER CONCENTRATIONS OF ALL TRACE METALS DURING STORMS (DELTA) AGAINST EACH METAL’S ESTIMATED RESPECTIVE LOAD WITHIN EACH STORM.. .................................................................................59 FIGURE 15. RELATIONSHIP BETWEEN A) E. COLI (CIRCLES) DELTA VERSUS LOAD, DELTA (MPN/100 ML)=1.55X10-8(LOAD, MPN)+1163, R2
=0.54, P=4.9X10-4; B) ENTEROCOCCUS (TRIANGLES) DELTA VERSUS LOAD, DELTA (MPN/100 ML)=9.1X10-8(LOAD, MPN)- 4322, R2
=0.84, P=1.1X10-7; C) FECAL COLIFORM (SQUARES) DELTA VERSUS LOAD; DELTA (MPN/100 ML)=1.89X10-8(LOAD, MPN)+1012, R2=0.72, P=6.9X10-6; AT SITES C (RED SYMBOLS), D (GREEN SYMBOLS), AND F (BLUE SYMBOLS).....................60 FIGURE 16. RELATIONSHIPS BETWEEN TRACE METAL CONCENTRATION (µG/L EXCEPT MERCURY=NG/L) AND TSS CONCENTRATIONS (MG/L) ACROSS ALL STATIONS BY SAMPLE TYPE........................................................................................................................62 FIGURE 17. PLOTS OF A) COPPER CONCENTRATION (µG/L) VERSUS TSS CONCENTRATION (MG/L) AND B) LEAD CONCENTRATION (µG/L) VERSUS TSS CONCENTRATION (MG/L) BY SITE (A – H)...................................................................................................64 FIGURE 18. PLOTS OF A) MERCURY CONCENTRATION (NG/L) VERSUS TSS CONCENTRATION (MG/L) AND B) ZINC CONCENTRATION (µG/L) VERSUS TSS CONCENTRATION (MG/L) BY SITE (A – H)...................................................................................................65 FIGURE 19. LOCATIONS OF MUSSEL BIOACCUMULATION MONITORING SITES. ...............................................................................73 FIGURE 20. WET-WEIGHT (A) AND LIPID-WEIGHT (B) CONCENTRATIONS OF DIELDRIN MEASURED IN MUSSELS DURING THE WET SEASON FROM 5 CCLEAN SITES IN THE MONTEREY BAY AREA AND 1 SITE AT POINT REYES NATIONAL SEASHORE.................................75 FIGURE 21. WET-WEIGHT (A) AND LIPID-WEIGHT (B) CONCENTRATIONS OF CHLORDANES MEASURED IN MUSSELS DURING THE WET SEASON FROM 5 CCLEAN SITES IN THE MONTEREY BAY AREA AND 1 SITE AT POINT REYES NATIONAL SEASHORE......................76 FIGURE 22. WET-WEIGHT (A) AND LIPID-WEIGHT (B) CONCENTRATIONS OF DDTS MEASURED IN MUSSELS DURING THE WET SEASON FROM 5 CCLEAN SITES IN THE MONTEREY BAY AREA AND 1 SITE AT POINT REYES NATIONAL SEASHORE. ........................................76 FIGURE 23. WET-WEIGHT (A) AND LIPID-WEIGHT (B) CONCENTRATIONS OF PCBS MEASURED IN MUSSELS DURING THE WET SEASON FROM FIVE CCLEAN SITES IN THE MONTEREY BAY AREA AND 1 SITE AT POINT REYES NATIONAL SEASHORE......................................77 FIGURE 24. WET-WEIGHT (A) AND LIPID-WEIGHT (B) CONCENTRATIONS OF PBDES MEASURED IN MUSSELS DURING THE WET SEASON FROM FIVE CCLEAN SITES IN THE MONTEREY BAY AREA AND 1 SITE AT POINT REYES NATIONAL SEASHORE. ............................77 FIGURE 25. THE RELATIONSHIPS BETWEEN SUMMED CONCENTRATIONS OF THE TRACE METALS THAT EXHIBITED SIGNIFICANT NEGATIVE ASSOCIATIONS WITH NUMERICAL ENDPOINTS FOR URCHIN FERTILIZATION SUCCESS (SEE TABLE 18) FOR TESTS THAT PASSED AND FAILED THE TOXICITY TEST.........................................................................................................................................80 ATTACHMENT 1

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Tables
TABLE 1. RESULTS OF SUB-REGIONAL COMPARISONS OF CONSTITUENT CONCENTRATIONS AT REFERENCE SITES USING ANALYSIS OF VARIANCE AND A NON-PARAMETRIC WILCOXON TEST...................................................................................................................31 TABLE 2. AVAILABLE OCEAN PLAN WATER QUALITY OBJECTIVES AND CALCULATED 85TH PERCENTILES OF CONSTITUENT CONCENTRATIONS FOR REFERENCE SITES GROUPED OVER THE ENTIRE REGION AND GROUPED BY NORTHERN AND SOUTHERN SUB-REGIONS. .............32 TABLE 3. RESULTS OF REGRESSIONS BETWEEN TSS AND CONSTITUENTS IN SUB-REGIONAL GROUPS OF REFERENCE SITES. ......................33 TABLE 4. RESULTS OF SUB-REGIONAL COMPARISONS OF CONSTITUENT CONCENTRATIONS IN PRE-STORM SAMPLES USING ANALYSIS OF VARIANCE AND A NON-PARAMETRIC WILCOXON TEST.....................................................................................................35 TABLE 5. RESULTS FROM COMPARISONS OF CONSTITUENT CONCENTRATIONS AMONG SAMPLE TYPES................................................39 TABLE 6. NUMBER OF SAMPLES ABOVE OVERALL 85TH PERCENTILE THRESHOLDS / NUMBER OF SAMPLES WITH GREATER CONCENTRATIONS IN RECEIVING WATER SAMPLES THAN IN PRE-STORM SAMPLES..........................................................................................41 TABLE 7. PERCENTAGE OF SAMPLES ABOVE OVERALL 85TH PERCENTILE THRESHOLDS FOR CONSTITUENTS IN RECEIVING WATER SAMPLES AT EACH ASBS SITE.....................................................................................................................................................42 TABLE 8. MEAN PERCENTAGE ABOVE OVERALL 85TH PERCENTILE THRESHOLDS ([CONCENTRATION – 85TH PERCENTILE]/85TH PERCENTILE) FOR CONSTITUENTS IN RECEIVING WATER SAMPLES AT EACH ASBS SITE. ............................................................................43 TABLE 9. RAINFALL FOR EACH STORM PRIOR TO SAMPLE COLLECTION AT EACH SITE (INCHES). ..........................................................48 TABLE 10. RESULTS FROM MATCHED-PAIR (PRE-STORM VS. RECEIVING WATER) STATISTICAL TESTS TO DETERMINE WHETHER RECEIVING WATER CONCENTRATIONS WERE HIGHER THAN PRE-STORM CONCENTRATIONS FOR EACH CONSTITUENT ACROSS ALL ASBS SITES...51 TABLE 11. RESULTS FROM MATCHED-PAIR (PRE-STORM VS. STORM) STATISTICAL TESTS FOR EACH CONSTITUENT ACROSS INDIVIDUAL SITES. (CON’T ON NEXT PAGE)............................................................................................................................................53 TABLE 12. MEAN LOADS PER STORM OF CONSTITUENTS FROM EACH ASBS SITES WITH DISCHARGE >36 INCHES. ................................55 TABLE 13. RESULTS FROM REGRESSIONS OF TRACE METAL LOAD VS DELTA. (CONTINUED ON NEXT PAGE) ..........................................57 TABLE 14. RESULTS FROM COMPARISONS AMONG SAMPLE TYPES OF CONSTITUENT CONCENTRATIONS PER TSS..................................63 TABLE 15. RESULTS FROM 2-WAY ANOVA TO TEST FOR THE EFFECTS OF SITE, TSS AND INTERACTIONS OF SITE AND TSS ON TRACE METAL CONCENTRATIONS IN DISCHARGE SAMPLES...................................................................................................................64 TABLE 16. PERCENT OF METALS IN THE DISSOLVED FRACTION FROM DISCHARGE SAMPLES COLLECTED DURING 2 STORMS IN 2016. ........67 TABLE 17. ACID-POSITIVE PHARMACEUTICALS DETECTED IN MUSSELS IN 2014 AND 2015..............................................................74 TABLE 18. PERCENTAGE OF FAILED TOXICITY TESTS AT EACH ASBS AND ALL REFERENCE SITES. ........................................................79 TABLE 19. RESULTS OF STEP-WISE LINEAR REGRESSION OF URCHIN FERTILIZATION NUMERICAL ENDPOINTS VERSUS CONSTITUENT CONCENTRATIONS IN ALL SAMPLES. ............................................................................................................................79 TABLE 20. MAXIMUM CONCENTRATIONS (G/L) OF PYRETHROID PESTICIDES DETECTED IN DISCHARGE SAMPLES.................................81 TABLE 21. PERCENTAGE OF SAMPLES ABOVE A REFERENCE 95TH PERCENTILE THRESHOLD FOR CONSTITUENTS IN RECEIVING WATER SAMPLES AT EACH ASBS SITE.................................................................................................................................................86 TABLE 22. NUMBER OF SAMPLES ABOVE OCEAN PLAN WATER QUALITY OBJECTIVE FOR INSTANTANEOUS MAXIMUM. ..........................87 ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 4 Central Coast Regional ASBS Monitoring Program
Final Report 2013–2016

1.0 Executive Summary
In the 1970’s, 34 Areas of Special Biological Significance (ASBS) were designated by the California State Water Resources Control Board (State Board) to protect valuable or sensitive biological communities. Regulations prohibited discharges of waste to these ASBS. More recently, stormwater was recognized to contain contaminants from anthropogenic sources and enforcement of the waste discharge prohibition was broadened to include storm runoff.

Following nearly a decade of dialogue among the Water Board, participants, and other interested parties, the State Board adopted a set of requirements called Special Protections for Areas of Special Biological Significance, Governing Point Source Discharges of Storm Water and Nonpoint Source Waste Discharges (Special Protections).

The Special Protections laid out the requirements to be met by participants in order to qualify for an exception to the prohibition against discharge of wastes carried by stormwater into ASBS. These requirements included collection and reporting of monitoring data using methods and sampling designs prescribed in the Special Protections. The Special Protections at numerous sites required collection of water quality data during a minimum of 6 storms (3 storms per year) from the following types of samples:

1. ASBS stormwater discharges (discharges) in 2 categories, a. Outfalls 18 – 36 inches
b. Outfalls >36 inches (Unless otherwise indicated, discharge samples refer to large outfalls

2. ASBS pre-storm ocean receiving water (pre-storm) collected from near discharges,

3. ASBS storm ocean receiving water (receiving water) collected in knee-deep water at the point where discharges enter the ocean,

4. Reference storm ocean receiving water (reference) at the mouths of coastal reference streams (i.e., streams with <95% human development in their watersheds), and

5. Reference dry weather (reference pre-storm) samples collected at reference sites during the dry season (not following storms).

In the Central California Regional ASBS Monitoring Program, an additional category of sites was sampled. Two background (background) sites were sampled along the shore within Monterey Bay distant from any ASBS in order to determine whether water quality in ASBS receiving water samples was similar to that in non-ASBS receiving water samples, which could indicate that ASBS receiving water quality was affected by water quality problems existing throughout Monterey Bay.

The Special Protections define the 85th percentile of constituent concentrations at reference sites as the upper bounds of natural water quality. In order to qualify for an exception to the waste discharge prohibition, storm samples must have contaminant concentrations below the 85th percentile threshold or have storm concentrations that do not exceed pre-storm ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 5 concentrations. If exceedances of this threshold occur, the Special Protections require the following:
“Best management practices to control storm water runoff discharges (at the end-of-pipe) during a design storm shall be designed to achieve on average the following target levels: (1) Table B Instantaneous Maximum Water Quality Objectives in Chapter II of the Ocean Plan1; or (2) A 90% reduction in pollutant loading during storm events, for the applicant’s total discharges.” The Special Protections also require assessments of the condition of biological communities in ASBS through monitoring of rocky intertidal organisms, measurement of contaminants accumulated in the tissues of resident mussels, and the toxicity of stormwater discharges and receiving water to test organisms.

The Special Protections require measurement of a broad list of contaminants in water and biological organisms, with comparison of concentrations in storm samples to concentrations in reference samples. These contaminants include:

1. Trace metals, arsenic (As), silver (Ag), cadmium (Cd), chromium (Cr), copper (Cu), mercury (Hg), nickel (Ni), lead (Pb), selenium (Se), and zinc (Zn). Trace metals are sometimes called heavy metals and they can be toxic at elevated concentrations. They are found naturally in rocks and soils and also can be elevated in association with architectural, construction, and automotive sources.

2. Polynuclear aromatic hydrocarbons (PAHs). These compounds are included in petroleum and combustion products and can be toxic at elevated concentrations. PAHs can originate from petroleum spills, natural seeps, automobile leakage, and various combustion sources.

3. Pyrethroid and Organophosphate pesticides. These pesticides are known to cause toxicity to aquatic organisms in urban streams. Pyrethroid pesticides are a fairly recent introduction to replace organophosphate pesticides, which are noted for causing toxicity in ambient waters. Pyrethroids are widely applied in agricultural and residential land uses.

4. Bioaccumulation. Bioaccumulation refers to the accumulation of contaminants into the tissues of living organisms, such as fish or shellfish. If these contaminants reach sufficiently high concentrations, the organisms can be negatively affected and the health of animals or humans that consume them can be at risk.

5. Toxicity. To measure toxicity, aquatic organisms are exposed to samples of discharges and receiving water to determine whether the sample water impairs natural biological processes. Using standardized procedures, success of sea urchin egg fertilization, normal development of bivalve embryos, germination and growth of kelp are compared between controls and sample water to determine whether sampled waters are toxic. 1 The California Ocean Plan includes various water quality objectives that differ according to contaminant types: 1) Trace metals, ammonia and some pesticides = 6-month median, daily maximum, and instantaneous maximum. 2) Organic contaminants (e.g., petroleum hydrocarbons) = 30-day average.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 6 6. Nutrients and conventional constituents. Nutrients include the nitrogen sources nitrate, ammonia and urea, and the phosphorus source orthophosphate, all of which can contribute to the growth of harmful algae. Sources of nutrients include runoff of residential, urban, and agricultural fertilizers, as well as metabolic excretory waste products from animals. Total Suspended Solids (TSS), and Oil and Grease are conventional constituents that can be associated with erosion (reducing water clarity) and improper maintenance of grease traps, respectively.

7. Fecal Indicator Bacteria (FIBs). Three FIBs are measured, including Fecal Coliforms, Enterococcus, and E. coli. They are used as indicators of fecal contamination. FIBs can be elevated due to sewage leakage and domestic animal and wildlife feces.

The Central California Regional ASBS Monitoring Program was implemented to satisfy the monitoring requirements associated with implementation of the ASBS Special Protections. The program includes Duxbury Reef, Fitzgerald, Pacific Grove, and Carmel Bay ASBS, and spans the coast from Marin County to Big Creek, south of Big Sur. Program participants include Marin County, San Mateo County, Monterey County, Monterey Bay Aquarium, Hopkins Marine Station of Stanford University, City of Monterey, City of Pacific Grove, City of Carmel by the Sea, Pebble Beach Company, and Caltrans.

Monitoring began in the fall of 2013. Because it was necessary to sample a minimum of 6 storms over at least 2 years in order to thoroughly characterize water quality conditions at each sampling location, the prevailing drought required that the Central California discharges request a program extension into a third year of monitoring. Permission to extend the program was granted by State Board staff. The extension was particularly helpful for expanding our description of reference conditions, which are the basis of criteria for describing natural water quality.

Program participants have individually submitted Compliance Plans intended to address constituent concentrations in receiving water samples that have been appreciably above the relevant 85th percentile threshold. The process of notifying Regional and State Boards of sites that have storm water quality outside of natural water quality thresholds will be directly from participants to the Water Board. Wherever specific discharges are discussed in this report, they are identified by randomly assigned letters. Consequently, this report focuses on whether there are spatial patterns in constituent concentrations in reference and pre-storm samples, and whether there are associations among constituents that would help determine whether discharge constituents have anthropogenic sources and constitute waste. In particular, the following questions are addressed:

1. Are there north-to-south differences in reference conditions?

2. Are there north-to-south differences in pre-storm water quality at ASBS sites?

3. Are storm discharges altering Natural Water Quality, as defined by the 85th percentile and higher concentrations in storm samples than in pre-storm samples?

4. Are alterations of Natural Water Quality likely due to anthropogenic waste?

5. Are marine biological resources being measurably affected by ASBS storm discharges? Major findings are as follows:

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 7 Are there north-to-south differences in reference conditions? An important consideration in comparisons of reference water quality between northern and southern areas is whether similar storm conditions were sampled throughout the region. If there are north-to-south differences in ambient and reference constituent concentrations, an inability to sample large storms in some areas could bias the calculated 85th percentile threshold. In fact, there were several large storms during which safe access was not possible for sites along the Big Sur coast, requiring that smaller storms be sampled in this area when smaller waves and stream flow allowed access. Consequently, effects of these large storms, while they were captured at northern reference sites, were not captured for the Big Sur coast. ANOVA was performed on each constituent to determine whether there were significant differences in concentrations between reference sites grouped for the northern and southern portions of the study area.

There are clear differences between northern and southern sub-regions in constituent concentrations. Every trace metal, except silver, exhibited significant differences between subregions, with northern sites having higher concentrations. In the case of the kelp germination toxicity test, there were also higher rates of germination in tests done at northern references sites than at southern reference sites. There were also differences between northern reference sites and southern reference sites in the associations between total suspended solids (TSS) and various constituents.

These geographic differences in reference water quality should be considered in determining whether a particular ASBS site conforms to natural water quality. The significant associations between TSS and other constituents in reference samples suggest that comparisons using TSSconstituent associations in other sample types (i.e., discharge, pre-storm, receiving water) could help determine whether some constituents in non-reference samples are derived from natural sources, such as native sediments.

Are there north-to-south differences in pre-storm water quality at ASBS sites?
This question seeks to determine whether non-storm concentrations of constituents at ASBS sites were consistent throughout the region. If north-to-south differences in non-storm ambient conditions exist, such differences could mean that receiving water samples in some areas have a smaller margin between pre-storm concentrations and the overall 85th percentile threshold, thus resulting in more values above the threshold than in areas with lower pre-storm concentrations.

Pre-storm samples have significantly higher trace metal and TSS concentrations at ASBS sites in the northern area of the study region than in the southern area. Concentrations of FIBs, nutrients, PAHs, and organophosphate and pyrethroid pesticides were mostly higher in the south than in the north, but none of the differences was significant in both of the statistical tests used. Potential causes are differences in geology, soil erodibility and trace metal concentrations, and differing proximities to anthropogenic sources associated with large urban ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 8 areas. These results suggest that, if all discharges were equal, the difficulties of achieving natural water quality would not be the same across the entire study region.

Do storm discharges alter receiving water quality?
Concentrations of constituents in receiving water samples were usually below overall 85th percentile thresholds. For some constituents, the concentrations measured at reference sites were greater than the highest concentrations measured in ASBS receiving water and there were reference samples above the overall 85th percentile thresholds. There were generally similar concentrations between sample types and high variability within sample types. Nevertheless, concentrations in discharge samples were usually significantly greater than in other sample types, while receiving water samples were not statistically different from concentrations in prestorm or reference samples when tested with analysis of variance (ANOVA). When all sites were tested together, matched-pair tests between pre-storm and receiving water concentrations indicated most constituents had higher concentrations in receiving water than in pre-storm samples. When examined site-by-site, with attendant lower sample sizes, these differences were not universally observed and those that were significant did not necessarily correlate with site differences in the percentage of receiving water samples above the overall 85th percentile threshold, their magnitude above the threshold or the estimated loads of these constituents.

Selenium and silver are illustrative of these apparent contradictions. Selenium and silver in receiving water were above their respective 85th percentile thresholds in 11% and 15% of all samples, respectively. Moreover, 40% and 33% of receiving water samples were above the selenium and silver thresholds, respectively, at 1 site. Nevertheless, their average concentrations in receiving water samples were 88% and 62% below their respective 85th percentile thresholds and neither one exhibited significant differences between pre-storm and receiving water samples in matched-pair tests, either across all sites or within any site.

Regressions of estimated constituent loads versus changes in concentrations from pre-storm to receiving water (delta) were mostly significant and explained substantial variation in delta, although this results did not necessarily mean receiving water concentrations were less than overall 85th percentile thresholds.

Are alterations of receiving water quality due to anthropogenic waste?
Determining whether trace metals in discharges are from anthropogenic or natural sources is challenging. Trace metals are ubiquitous in the natural environment and are contained in sediments and geologic formations even in pristine environments. An analysis was performed using the relationships between trace metals and TSS in an effort to distinguish between natural and anthropogenic sources of trace metals. For most trace metals, the concentrations per TSS in discharge samples were elevated above other sample types. Exceptions to this pattern were evident for arsenic and silver, in which the relationship between TSS and arsenic was very similar among all sample types and silver concentrations relative to TSS were often lower in discharge samples than in other sample types. The relationships between trace metals and TSS in reference samples were consistent with concentrations of all trace metals increasing with increasing TSS concentrations, except for silver.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 9 Analysis of variance (ANOVA) revealed that the amounts of various constituents per unit of TSS were similar among all sample types, except for discharges. Discharge samples often had significantly increased constituent concentrations per unit of TSS. Moreover, another ANOVA showed that the relationship of TSS to copper, lead, mercury, and zinc differed among sites.

Some sites exhibited relationships between these trace metals and TSS in their discharges that paralleled the positive slopes of these relationships in other sample types, but with elevated trace metals per unit of TSS. Other sites exhibited elevated trace metals in their discharges that had no relationship to TSS concentrations, and which were often accompanied by elevations of the trace metals per unit of TSS in receiving water samples. Discharges of trace metals with high percentages in the dissolved fraction indicate different processes controlling their release into the environment from the processes that controlled reference trace metal concentrations, and suggests anthropogenic sources. Moreover, several other studies have found high loads of dissolved copper, zinc, and lead in runoff from building roofs made of copper, zinc-coated metal and slate.

FIBs and nutrients are also ubiquitous in the environment, but the available data do not allow determinations of sources. Nevertheless, FIBs stand out because their maximum concentrations in receiving water samples were greater than those at reference sites. If not strictly anthropogenic, their concentrations were highest in receiving water samples, although not significantly, and they also exhibited significant associations between estimated loads and changes in receiving water concentrations. Thus, it appears that storm receiving waters at the base of watersheds affected by human development tend to have high concentrations of FIBs, although it is unknown whether these FIBs were from anthropogenic sources.

Nutrients cannot be chemically directly linked to anthropogenic sources. They are present in soil and natural organic matter. Moreover, there were no significant increases in receiving water concentrations over pre-storm concentrations at any site and no relationship between loads and changes in receiving water concentrations.

PAHs are naturally present in the marine environment. Along the California coastline from near San Simeon southward into the Santa Barbara Channel, there are natural seeps that result in tar balls on beaches and rocky intertidal areas. Nevertheless, we are not aware of any natural seeps onshore within the study area. Consequently, PAHs detected in the discharges and receiving water samples are presumed to be from anthropogenic sources, such as motorized vehicles and other types of combustion processes.

Organophosphate and pyrethroid pesticides are exclusively man-made compounds that have no natural sources. Although they were infrequently detected, their presence in any sample, including receiving water, is presumed to derive from an anthropogenic source.

Are marine biological resources being affected by ASBS storm discharges?
Rocky Intertidal Monitoring
Rocky intertidal monitoring was performed under the direction of Dr. Peter Raimondi of University of California, Santa Cruz. Methods were identical with those used for regional ASBS ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 10 monitoring programs in other parts of California. Sampling was conducted in the fall of 2014 at the following sites:

1. Alder Creek discharge (Duxbury Reef ASBS)

2. Fitzgerald Marine Reserve discharge

3. Año Nuevo discharge

4. Hopkins discharge (Pacific Grove ASBS)

5. Stillwater discharge (Carmel Bay ASBS)

6. Point Lobos discharge (Point Lobos State Marine Reserve)

7. Bolinas Point reference

8. Pigeon Point reference
Data from each site were compared with current and historic data from numerous sites along the central California coast. Sites were selected using broad criteria to ensure adequate similar substrate among sites and safe access. Sessile and mobile organisms were quantified using random quadrats and point contact methods, respectively Based on the results of these analyses, there is no support for the idea that discharges along the central California coast generate impacts to diversity or community composition in the nearby rocky intertidal habitats. Other attributes such as individual growth and reproduction could be affected with no subsequent impact to diversity or composition.

Some sites stood out as differing substantially from what was expected for biological communities in the region. In particular, Fitzgerald Marine Reserve was an outlier with respect to sessile species composition. It is likely that this difference in community structure is the result of the geomorphology at the site. The intertidal zone at Fitzgerald Marine Reserve is a very wide and flat bench surrounded by sand and subject to considerable scour. In addition, the reef tends to hold water because it is flat and the key mid intertidal species, Chthamalus spp., Mytilus californianus and Mastocarpus spp., which are species that dominate on hard rock surfaces with extended periods of emersion are all uncommon at this site.

Mussel Bioaccumulation Monitoring
For the past 2 years, the Central California Regional ASBS monitoring program has collaborated with the Central California Long-term Environmental Assessment Program (CCLEAN) on mussel bioaccumulation monitoring. CCLEAN has measured several persistent organic pollutants (POPs) polychlorinated biphenyls (PCBs), the flame retardants polybrominated diphenyl ethers (PBDEs), and chlorinated pesticides in mussels at 5 sites around Monterey Bay for over 15 years and the long database permits analysis for spatial and temporal patterns. This collaboration provided the ASBS program participants with access to a long-term dataset on the condition of an important biological resource in rocky intertidal communities around Monterey Bay, including ASBS.

In the collaboration between this project and CCLEAN a site was added at Point Reyes National Seashore and the list of analytes normally measured by CCLEAN was expanded to include organophosphate pesticides, pyrethroid pesticides and acid-positive pharmaceuticals. None of the organophosphate or pyrethroid pesticides were detected in any of the samples. Acidpositive refers to the type of extraction to recover the compounds from the sample matrix.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 11 Concentrations of POPs in mussels have been declining over recent years around Monterey Bay and have been consistently low at Carmel River Beach. Dieldrin in mussels along the northern shore of Monterey Bay have remained below the USEPA recreational fisher screening value at all sites for the sixth year in a row, although Dieldrin still exceeds the subsistence fisher screening level at several sites. DDTs also remain below human health alert levels. PBDEs also have declined significantly over time at all sites, except for The Hook. Acid-positive pharmaceuticals detected in the mussels consisted entirely of compounds with both human and veterinary or animal husbandry uses, suggesting runoff from pets and livestock operations.

More pharmaceuticals were detected at The Hook than at other sites. The broad-spectrum antibiotic Lomefloxacin was detected in more samples than any other pharmaceutical.

Concentrations of contaminants measured in mussels from Point Reyes National Seashore were generally lower than at the other CCLEAN sites around Monterey Bay, except for PCBs, which were higher at Point Reyes. The mussels at Carmel River Beach have very low concentrations of contaminants compared to other locations in the Monterey Bay area, which indicates that water quality is sufficient to protect this biological resource in the Carmel Bay ASBS.

Toxicity Testing
Toxicity tests are widely accepted laboratory procedures that are intended to indicate whether a particular sample of water could cause harm to aquatic organisms. They often rely on measurements of physiological responses, such as egg fertilization, embryonic development, gametophyte germination, and growth that are likely to be more sensitive than survival as a test endpoint. Being conducted in the laboratory, the test conditions, such as temperature, oxygen concentration, and water quality, can be monitored in order to minimize the effects of uncontrolled variables on test outcomes. Bringing samples into the laboratory for testing allows a specific set of organisms to be observed throughout the course of the test, which is very difficult under ambient conditions.

Toxicity was not presumed to be a normal feature of natural water quality (Schiff et al, 2016).

Consequently, the occurrence of toxicity failures in <2% of reference samples is notable and indicates the that some toxicity could be naturally occurring. The 3 toxicity tests that exhibited failures at reference sites were the kelp growth, mussel embryonic development, and mussel embryo survival tests. These 3 tests also failed in 8%, 2%, and 3% of receiving water samples.

The urchin fertilization test exhibited a higher rate of failure in receiving water samples, with 2 samples at 1 site and single samples at 2 other sites failing. Discharge samples tested with the urchin fertilization test failed in 24% of samples overall. The high rates of failure in the discharge samples at several sites were not consistently associated with large numbers of failures in receiving water samples. Discharges smaller than 36 inches failed the urchin fertilization test in 17% of samples.

A statistical test revealed that 39% of the variation in the numerical endpoints of urchin fertilization toxicity tests was accounted for by a combination of trace metals and pesticides.

The negative effects of zinc and pyrethroid pesticides accounted for most of the variation, while the apparent positive effects of nickel and PAHs, and the negative effects of arsenic and silver were less important. The results of the stepwise linear regression modeling reveal statistical associations and do not establish causal links between the significant constituents and toxicity.

Nevertheless, they provide guidance for any future toxicity identification evaluations ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 12 Toxicity measured in receiving water samples suggest that marine biological resources could be affected by ASBS discharges. Toxicity in discharge and receiving water samples has been statistically associated with some trace metals and pyrethroid pesticides. Toxicity associated with dissolved trace metals will be challenging to attribute and control.

Nutrient Effects on Algal Blooms
It is assumed that the measurement of nutrients in this program was required because of their potential effects on algal blooms. Harmful algal blooms have become a global problem. Last year saw an extraordinary bloom along the entire west coast of the United States of Pseudonitzschia, which is a diatom that produces the neurotoxin domoic acid. Kudela et al (2008) linked seasonal red tides along the northern bight of Monterey Bay to discharges of agricultural nutrients from the Pajaro River.

Annual loads of nitrogen in nitrate, ammonia, and urea from rivers and wastewater discharges average 3,400,000 kg. Average loads of these nutrients from the ASBS discharges monitored in this program were 14.5 kg/site/storm, which amounts to 0.00043% of the annual load from rivers and wastewater. Nutrients discharged into ASBS have had no noticeable effect on algal blooms or nuisance growths.

Regulatory Considerations
Given that monitoring has demonstrated that there are significant geographic differences in natural water quality at reference sites in this study, the overall 85th percentile does not necessarily reflect local natural water quality at a given ASBS. The primary water quality threshold for judging whether natural water quality is being achieved in ASBS is the overall 85th percentile of values from reference sites in the ocean at the mouths of streams with <5% of their watersheds under human development. This threshold essentially requires ASBS participants to achieve better water quality than is present in the ocean at the mouths of these clean reference streams. It is far from certain that this level of water quality is achievable. It seems a very daunting task to ensure that water quality along a city shoreline be better than the best water quality available along undeveloped shoreline of the state. If we can assume that the water quality at reference sites fully supports sensitive marine life, then requiring the same, and not necessarily better, water quality should provide a robust level of protection for marine life in ASBS.

If this approach were utilized, a more reasonable threshold would be the 95th percentile. This would ensure that any value falling outside the bounds of most reference values would become the focus of corrective measures. Such a threshold would have a profound effect on the number of constituents potentially being flagged for mitigation measures, while still leaving plenty of room for improving water quality.

Notwithstanding consideration of a revised threshold for natural water quality, the water quality objectives in the Ocean Plan were specifically developed to protect marine resources and human health. The toxicities of constituents were considered and appropriate safety margins were added to ensure that constituent concentrations falling under Ocean Plan objectives would not cause toxicity. In the case of organic compounds, objectives were set to protect human health based upon assumptions about bioaccumulation of compounds into seafood consumed by people and added health risks. Consequently, these compounds do not ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 13 have instantaneous maxima for the protection of marine life. FIB Ocean Plan objectives also were developed to protect human health from diseases transmitted via contact with water.

They were established from epidemiological studies that determined the increased risks of becoming infected after swimming in water with increased FIB concentrations and also include built-in safety factors.

A comparison of receiving water data with Ocean Plan objectives reveals sporadic occurrences of concentrations above objectives. There was a single receiving water sample at Site B with a concentration of copper above the Ocean Plan objective. Chromium and nickel Ocean Plan objectives were each exceeded in a single reference sample. Fecal coliform and Enterococcus concentrations were above Ocean Plan objectives at most sites, ranging from 17% to 100% of samples. These 2 FIBs were above Ocean Plan objectives in 6% and 22% of reference samples, respectively. PAHs were above the Ocean Plan 30-day average objective for the protection of human health at most ASBS sites, ranging from 17% to 50% of samples per site. Four percent of reference samples were also above the 30-day average objective for PAHs. If an instantaneous maximum is estimated for PAHs using the 10:1 ratio used for instantaneous maximum to 6- month median concentrations for other constituents, an estimated instantaneous maximum for PAHs would approximate 0.088 µg/L and the percentage of samples above the objective would decrease substantially across all ASBS and reference sites. Moreover, if receiving water is not meeting natural water quality according to the Compliance Flowchart of the Special Protections (Figure 1), actions can be required that either bring offending constituents below Ocean Plan objectives or reduce their loads by 90%.

Comparisons of ASBS receiving water data with pertinent thresholds (e.g., 95th percentile and Ocean Plan), while reducing the number of samples above the Special Protections 85th percentile threshold, have emphasized that identifying sources and reducing anthropogenic loads of FIBs and PAHs into ocean waters should be a high priority, along with determining sources of and reductions in toxicity.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 14 2.0 Program Background

2.1 Regulatory History
The regulation of stormwater runoff as a discharge of waste has its genesis in the passage of the Porter-Cologne Water Quality Control Act (PCA) in the State of California in 1969. Parallel Federal legislation, known as the Clean Water Act (CWA), was passed in 1972. Under provisions of the CWA, the State of California was given authority to manage federally mandated waste discharge permits within California. The PCA defines waste as follows:
“……….. sewage and any and all other waste substances, liquid, solid, gaseous, or radioactive, associated with human habitation, or of human or animal origin, or from any producing, manufacturing, or processing operation, including waste placed within containers of whatever nature prior to, and for purposes of, disposal.

Over time, with the recognition that stormwater can contain high concentrations of various pollutants, the CWA has been amended to include requirements for permits to discharge stormwater from point sources (pipes, ditches or channels) into water of the United States (lakes, rivers or oceans). The stormwater permit process has been implemented in a tiered approach, in which larger municipalities were the first to be regulated, followed recently by smaller municipalities.

Also in 1972, the State Water Resources Control Board (State Board) adopted the California Ocean Plan (Ocean Plan), which established numeric and narrative water quality objectives for ocean waters along the coast of California. These water quality objectives are designed to protect the beneficial uses of ocean waters. Beneficial uses include 20 diverse potential uses, such as municipal supply, industrial process supply, agricultural supply, navigation, marine habitat, rare, threatened and endangered species, water contact recreation, commercial and sport fishing, etc. In each case, waters must be of sufficient quality to support the beneficial uses designated for the water body in question.

One of the designated beneficial uses is “Areas of Special Biological Significance” (ASBS), which can be nominated by Regional Water Boards and approved for implementation by the State Board. The definition of the ASBS beneficial use is as follows:

Areas of Special Biological Significance (ASBS) - are those areas designated by the State Water Resources Control Board as requiring protection of species or biological communities to the extent that alteration of natural water quality is undesirable.

Numerous Areas of Special Biological Significance were nominated and approved in 1974 and 1975, based upon biological surveys. There currently are 34 coastal areas in California designated as Areas of Special Biological Significance. In 2000, sections were added to the Public Resources Code (PRC) of California that placed ASBS into the general classification of State Water Quality Protection Area, which were defined as “a non-terrestrial marine or estuarine area designated to protect marine species or biological communities from an undesirable alteration in natural water quality, including, but not limited to, areas of special ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 15 biological significance that have been designated by the State Water Resources Control Board through its water quality control planning process.” The PRC further states: “In a state water quality protection area point source waste and thermal discharges shall be prohibited or limited by special conditions. Nonpoint source pollution shall be controlled to the extent practicable.” To our knowledge, none of the reports nominating coastal areas for designation as ASBS included water quality data.

In the early 2000s, a not-for-profit environmental advocacy group threatened a suit against the State Water Boards for failure to enforce the prohibition against discharge of waste into ASBS via stormwater. This action prompted issuance of Cease and Desist Orders (CDOs) in 2004 to several municipalities by Regional Water Boards charging violations of the Ocean Plan. The CDOs were subsequently withdrawn and a process was initiated by the State Board, Ocean Division, to engage participants in the development of a regulatory framework for issuing exceptions to the prohibition against the discharge of waste into ASBS. Beginning on January 13, 2005 at Scripps Institution of Oceanography, meetings were held throughout coastal California by State Board staff to engage stakeholders. In 2010, the State Water Board passed Resolution No. 2010-0057, which directed State Board staff “to prioritize ongoing work related to exceptions for current discharges to ASBS ahead of new work related to designation of new ASBS and State Water Quality Protected Areas (SWQPA) until all of the current ASBS discharge issues are resolved through the exception process, and all of the Marine Protected Areas are designated and implemented statewide.” The development of the exception process culminated in the adoption of Resolution 2012-0031 on June 19, 2012, which included the following provisions:

2. Approves the exceptions to the Ocean Plan prohibition against waste discharges to ASBS for discharges of storm water and nonpoint source waste by the applicants listed in Attachment A to this resolution provided that:
a. The discharges are covered under an appropriate authorization to discharge waste to the ASBS, such as an NPDES permit and/or waste discharge requirements;
b. The authorization incorporates all of the Special Protections, contained in Attachment B to this resolution, which are applicable to the discharge; and c. Only storm water and nonpoint source waste discharges by the applicants listed in Attachment A to this resolution are covered by this resolution. All other waste discharges to ASBS are prohibited, unless they are covered by a separate, applicable Ocean Plan exception.

The Special Protections mentioned in Item 2.b. (SWRCB, 2012) included monitoring requirements designed to determine whether stormwater discharges to ASBS are causing an undesirable “alteration of natural water quality.” In support of the development of the Special Protections, the State Water Board provided funding in 2005 to the Southern California Coastal Water Research Project (SCCWRP) to determine the feasibility of defining “natural water quality.” With Water Board participation, SCCWRP convened a working group, which became ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 16 known as the Natural Water Quality Committee. This committee was composed of water quality and ecological experts from southern California. Over several years, the committee met and considered how to define “natural water quality” so that water quality criteria could be created that would enable determinations of whether stormwater discharges to ASBS were causing an undesirable “alteration of natural water quality.” Ultimately, the Natural Water Quality Committee determined that natural water quality could be generally characterized by an absence of significant amounts of the following:

1. Man-made constituents (e.g., DDT),

2. Other chemical (e.g., trace metals), physical (temperature/thermal pollution, sediment burial) and biological (e.g., bacteria) constituents at levels that have been elevated due to man’s activities above those resulting from the naturally occurring processes that affect the area in question, and

3. Non-indigenous biota (e.g., invasive algal bloom species) that have been introduced either deliberately or accidentally by man.

The Committee also recognized that the oceans are no longer free from man-made constituents with trace contaminants being measureable worldwide. Consequently, it considered that defining natural water quality with specified constituent concentrations was impractical, and recommended comparisons of ASBS water quality to water quality measured at reference sites (i.e., in the ocean at the mouths of streams whose watersheds were >90% undeveloped land) in order to gauge whether stormwater discharges cause “alteration of natural water quality.” Moreover, the Committee established a statistical indicator of natural water quality based on the concentrations of pollutants at reference sites. The Committee recommended that ocean concentrations of a pollutant at a stormwater discharge in an ASBS would be considered to have altered natural water if it exceeded the 85th percentile of measurements of that pollutant in reference site samples.

To determine compliance with natural water quality, the Special Protections require measurement of numerous constituents in designated stormwater discharges, pre-storm ocean receiving water at these discharges, storm ocean receiving water at these discharges, and storm ocean receiving water at the mouths of reference streams. A total of six storms were to be sampled over several years during the initial phase of monitoring required by the Special Protections. The decision as to whether ASBS water quality does not conform to natural water quality requires several steps, as indicated in Figure 1 (Attachment 1 to the Special Protections).

Because the ASBS beneficial use is for the protection of marine life, the point of compliance was established as the ocean receiving water and not the stormwater discharge.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 17 * = When an exceedance of natural water quality occurs, the participants must comply with section I.A.2.h. Note, when data are available, end-of-pipe discharge concentrations will be considered by the Water Boards in making this determination.

Figure 1. Special Protections flowchart to determine compliance with natural water quality. !"
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!"#$%&"'&"%()%%*'&)%"+,"&'-./'0"1'-%/"2.'03-4"+))./56"-$%"*35)$'/7%/"8.5-")+8904"13-$"5%)-3+&":;<;=;$">,+/"9%/83--%*"5-+/8" 1'-%/?"+/"5%)-3+&":; ;=;)">,+/"&+&9+3&-"5+./)%5?;"!+-%6"1$%&"5'8903&7"*'-'"35"'"'30'#0%6"%&*$+,$939%"%,,0.%&-")+&)%&-/'-3+&5" 1300"#%")+&53*%/%*"#4"-$%"#'-%/" +'/*5"3&"8'%3&7"-$35"*%-%/83&'-3+&; Is post-storm Compliance with natural water quality
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Receiving Water sample similar to local
background - No Action
Exceedance of natural water quality!
Compare receiving water post-storm sample concentration to the 85% threshold of reference sample concentrations
Resample receiving water pre- and post-storm (during the next feasible storm event) and analyze per Water Board approval Compare receiving water post-storm to pre-storm sample
concentration
Is post storm
receiving water
sample > prestorm
concentration?
Attachment 1
Special Protections Sections I(A)(3)(e) and I(B)(3)(e)
Flowchart to Deteremine Compliance with Natural Water Quality ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 18 The Compliance Flowchart (Flowchart; Figure 1) relies on comparisons between pre-storm ocean concentrations and post-storm (storm) concentrations and comparisons between the storm concentrations and the reference 85th percentile threshold. If a constituent in a storm sample exceeds the 85% threshold, the storm concentration is to be compared to the prestorm concentration. If the storm concentration is greater than the pre-storm concentration, sampling must be repeated during the next feasible storm. If the constituent concentration in the next storm sample still exceeds the 85th percentile threshold and is greater than the concentration in the pre-storm sample, an exceedance of natural water quality is declared.

Samples with slightly higher concentrations than the 85th percentile threshold would apparently be considered to have exceeded natural water quality, even if their concentrations fall within the range of all reference values. Although the role of discharge samples in determining an exceedance (i.e., compliance) is not specified in the flowchart, the footnote to the chart suggests that Water Boards would consider “end-of-pipe effluent concentrations” in making a determination of whether water quality is in compliance with natural water quality.

If an exceedance of natural water quality is determined, corrections must be proposed in a Compliance Plan that each participating entity submitted in September 2015. The Compliance Plan was required to include management practices to ensure that either 1) the identified constituent is reduced below the Ocean Plan instantaneous maximum allowable concentration in storm ocean samples or 2) the load to the ocean of the target constituent is reduced by 90% from all sources under the authority of the responsible party. Due to prevailing drought conditions that limited the available data before the Compliance Plan due date, State Board Staff granted the Central Coast ASBS participants leeway in providing complete details of planned best management practices, and an opportunity to re-submit updated final compliance plans by September 2016.

The Ocean Receiving Water and Reference Area Monitoring Program described in the Special Protections required the collection of at least three samples from each site for each storm season over at least two years (i.e. six samples from each site) in order to characterize the receiving water condition and to establish the 85th percentile threshold. For this reason, any determination of exceedance based on single samples before that program was complete and the natural water quality definition was established would have been premature. This final report summarizes the characterization of program ASBS receiving water samples and the full complement of reference data providing the program participants the information needed to complete the flowchart to evaluate exceedances of natural water quality.

In reviewing this final report and the final program data, if a participant determines that their discharge is causing or contributing to an exceedance of natural ocean water quality in the ASBS, they will submit a report to the State and Regional Water Board within 30 days. The individual reports will identify additional management practices to be implemented as outlined in Section I.A.2.h of the Special Protections.

Because the 85th percentile thresholds are statistical estimates derived from the available population of reference values, which differ among sub-regions and vary naturally over time, the thresholds also have uncertainty associated with them, as the “true” 85th percentile is assumed to fall within a range of estimates (Smith, 2002). Accordingly, a conservative approach to determining exceedances may be justified by focusing on the constituents with significant ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 19 associations between discharges and higher corresponding concentrations in receiving water, those with the greatest rates of exceedances (e.g., >15% of samples; see Schiff et al, 2016), those with the greatest magnitudes of exceedances (e.g., >15% above the 85th percentile threshold), and those trace metals that diverge from the relationships between suspended sediments and constituent concentrations observed in reference samples. Moreover, an effort has been made to identify those constituents with the most likely anthropogenic sources and that can be characterized as waste following the precedent of Singarella and Richardson (2008).

2.2 Central California Regional Program Development
In 2007 and 2008, ASBS participants on the Monterey Peninsula began meeting to consider options for designing a monitoring program to satisfy anticipated Special Protection requirements. These meetings ultimately included representatives from Marin County, San Mateo County, Monterey County, City of Monterey, City of Pacific Grove, Carmel-by-the-Sea, Monterey Bay Aquarium, Hopkins Marine Station, Pebble Beach Company, California State Parks, Caltrans, US Air Force Pillar Point facility, and National Park Service Point Reyes National Seashore. Support was expressed for a regional approach that would incorporate or leverage other regional monitoring efforts to help address larger water quality management issues of interest to stakeholders other than just ASBS stormwater discharges. State Board staff encouraged a proactive regional approach for developing a monitoring program, implying that there could be more flexibility before the Special Protections were formally adopted.

When the State Board formally adopted the Special Protections they included incentives for participants to organize themselves into regional monitoring groups. A group that ultimately included Marin County, San Mateo County, Monterey County, City of Monterey, City of Pacific Grove, City of Carmel-by-the-Sea, Monterey Bay Aquarium, Hopkins Marine Station, Pebble Beach Company, and Caltrans executed a Memorandum of Agreement to jointly fund a regional monitoring program, and a final Scope of Work for the Central California ASBS monitoring program (Appendix A) was negotiated with the State Board by late November 2012.

In February 2013, the consulting firm Applied Marine Sciences was selected to conduct the monitoring program. Based upon the progress made by the Central California regional ASBS group in organizing themselves and getting a monitoring program approved, as well as the drought conditions that were developing at that time, State Board staff gave permission for sampling to begin with the 2013 – 2014 storm season.

The State Board provided grant funding to support reference site sampling during the first year of the program. This funding came through a grant to Sothern California Coastal Water Research Program (SCCWRP), which was then divided among the three regional monitoring efforts (northern, central and southern California). Schiff et al (2016) includes evaluations of reference site water quality in all three regions, with the understanding that some regions had not yet completely characterized reference conditions.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 20 3.0 Report Organization and Scope
This report analyzes the results from the 2013–2016 storm seasons. Program participants are in the process of finalizing Compliance Plans intended to address maintenance of natural water quality within their respective ASBS. The notification to State and Regional Water Boards of sites that have receiving water quality outside of natural water quality thresholds will be directly from participants to the Water Board. Accordingly, randomly assigned letter are used to identify specific discharges that are discussed in this report. All data from this program will be delivered digitally to the California Environmental Data Exchange Network (CEDEN) by the end of October 2016, where it will be publically available. This report focuses on whether there are spatial patterns in constituent concentrations in reference and pre-storm samples that could inform discussions of what constitutes natural water quality, whether receiving water is being altered regardless of whether constituent concentrations are above or below 85th percentile thresholds, and whether there are associations among constituents that could help determine if discharge constituents have anthropogenic sources and constitute waste. In particular, the following questions are addressed:

1. Are there north-to-south differences in reference conditions? a. The answer to this question could help participants select reference sites that are particularly relevant to the conditions prevailing at their discharge(s).

2. Are there north-to-south differences in Pre-Storm water quality at ASBS sites? a. This question examines conditions at ASBS receiving water sites approximately 24 hours before storm events in order to determine whether different ambient conditions between sub-regions could affect the number of constituent concentrations measured above the 85th percentile threshold. If pre-storm concentrations are elevated in an area, participants in that area have a smaller margin in receiving water quality before concentration are >85th percentile threshold.

3. Do storm discharges alter receiving natural water quality? a. Answering this question requires comparing water quality conditions at ASBS sites to water quality at reference sites. The answer to this question can help determine whether or not stormwater discharges are directly responsible for increases in receiving water constituent concentrations that fall above the 85th percentile threshold.

4. Are alterations of receiving water quality due to anthropogenic waste? a. The answer to this question can help determine whether any alterations to natural water quality identified in Question 3 could be addressed with management practices.

5. Are marine biological resources being affected by ASBS storm discharges? a. The sole aim of the ASBS beneficial use is ensure water quality necessary to protect important marine biological resources.

In order to obtain answers to these questions, this report focuses on analysis and interpretation of data collected at the large stormwater outfalls prescribed in the Scope of Work (SOW; Appendix A) and compares data from those sites with data from the reference sites (Appendix A). The four ASBS included in this program and all associated sampling sites are distributed along the coastline from Marin County to the southern Big Sur coast (Figure 2).

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 21 The line demarking the northern and southern sub-regions was placed geographically, in order to help balance the numbers of samples between sub-regions for subsequent statistical analyses. Its placement makes no assumptions about ambient or receiving water conditions on either side of the line. The northern reference sites span the coastline from San Mateo County into Monterey Bay. Also included in the northern sub-region is Año Nuevo ASBS, which was monitored by Caltrans. Those data and data from other sites sampled by Caltrans in the region covered by the Central California Region Monitoring Program were not analyzed in this report.

The southern reference sites are distributed along the open coast from Malpaso Creek to Big Creek. The Little Sur River was originally listed as a reference site in the SOW (Appendix A), but access could not be obtained and Soberanes Creek was substituted in its place. The northernmost ASBS included is Duxbury Reef in Marin County (Figure 3). Along the San Mateo County coastline, Fitzgerald Marine Reserve is the next ASBS to the south (Figure 4). The Monterey Peninsula Includes the Pacific Grove ASBS (Figure 5, including the Hopkins Marine Life Refuge) and the Carmel Bay ASBS (Figure 6). The sites along the Pacific Grove ASBS shoreline are the regulatory responsibilities of the City of Monterey, City of Pacific Grove, Monterey Bay Aquarium, and Hopkins Marine Station. The sites in Carmel Bay ASBS are the regulatory responsibilities of Pebble Beach Company, City of Carmel-by-the-Sea, and County of Monterey.

As described in Appendix A, different sampling activities occurred at different sites depending on their designated purpose and the size of the stormwater discharge at the site. State Board staff allowed two sites at sandy beaches in Monterey Bay to serve as background sites for gauging the general conditions of nearshore waters in the bay distant from ASBS. These sites at La Selva Beach and Marina State Beach were credited to the monitoring requirements of the Central California regional monitoring effort with the condition that the sites would not be used to calculate 85th percentile reference threshold values. Consequently, they are only discussed relative to data from receiving water samples.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 22 Figure 2. Central California regional ASBS study area.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 23 Figure 3. Duxbury Reef ASBS with monitored discharge indicated.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 24 Figure 4. Fitzgerald Marine Reserve ASBS with monitored discharges indicated.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 25 Figure 5. Pacific Grove ASBS with monitoring sites indicated.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 26 Figure 6. Carmel Bay ASBS with monitoring sites indicated.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 27 4.0 Monitoring Methods
Collections were made at numerous sites during a minimum of 6 storms from the following types of samples:

1. ASBS stormwater discharges (discharges) in 2 categories, a. Outfalls 18 – 36 inches
b. Outfalls >36 inches (Unless otherwise indicated, discharge samples in this report refer to outfalls >36 inches.

2. ASBS pre-storm ocean receiving water (pre-storm) collected from near discharges

3. ASBS storm ocean receiving water (receiving water) collected in knee-deep water at the point where discharges enter the ocean

4. Reference storm ocean receiving water (reference) at the mouths of coastal reference streams (i.e., streams with <95% human development in their watersheds)

5. Reference samples collected during the dry season

6. Background non-urban samples collected outside ASBS during storms The following numbers of samples are included in the analyses in this report:

1. Large ASBS discharges - 52 samples from 10 sites

2. Small ASBS discharges – 46 samples from 23 sites

3. Pre-storm samples – 48 samples from 8 sites

4. Receiving water samples – 48 samples from 8 sites

5. Reference samples – 54 samples from 9 sites

6. Reference dry samples – 11 samples from 11 sites

7. Background – 12 samples from 2 sites
All sampling and analytical methods were prescribed by a Quality Assurance Program Plan (AMS, 2014), Sampling and Analysis Plan (AMS, 2013), and Standard Operating Procedures approved following review by the State Board QA Officer. All procedures satisfy the State’s Surface Water Ambient Monitoring Program (SWAMP) requirements and include appropriate data quality objectives. Sampling methods include “clean hands, dirty hands” protocols to minimize sample contamination and compositing samples from multiple discrete grabs of sample water to minimize effects of small-scale temporal or spatial variation. Chemical analyses include the following quality assurance samples: field blanks, laboratory blanks, field duplicates, matrix spikes and matrix spike duplicates, and analysis of certified reference materials or laboratory control samples. Data are submitted to the California Environmental Data Exchange Network (CEDEN). All data underwent a thorough QA evaluation (Appendix B).

The following laboratories performed analyses for data presented in this report:
• California Department of Fish and Wildlife Water Pollution Control Laboratory: PAHs, organophosphate pesticides, and pyrethroid pesticides
• Physis: trace metals in saltwater
• Marine Pollution Studies Laboratory: mercury
• Alpha Labs: fecal indicator bacteria (FIBs) for sites in Marin and San Mateo counties • Monterey Bay Analytical Services: FIBs from all other sites, nutrients, and TSS ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 28 • Granite Canyon: toxicity
• Axys Analytical: chlorinated pesticides, PCBs, PBDEs, and acid-positive pharmaceuticals in mussels
One element of the program involved collaboration with the Central Coast Long-term Environmental Assessment Network (CCLEAN). The CCLEAN mussel bioaccumulation program has measured contaminants in resident mussels at 5 locations along the central California coast for 13 years. Initially, samples were collected twice per year, in the wet season and in the dry season. In 2008, sampling frequency was reduced to annually in an index period during the wet season, when the highest concentrations of contaminants had been measured in previous years. As part of this collaboration, State Board staff required addition of a mussel bioaccumulation reference site at Point Reyes and also required the addition of acid-positive pharmaceuticals to the CCLEAN analyte list, based on previous detection of an antibiotic in mussels from Point Reyes.

Loads per storm and loads per acre for each storm were calculated for the discharges that were associated with receiving water monitoring. These calculations were made using catchment areas, percentage impervious area in each catchment and rainfall from the nearest available precipitation gauge. The rainfall was multiplied by the amount of impervious area to arrive at an estimate of storm-specific runoff. The runoff volume was then multiplied by the concentration of each constituent measured in the corresponding discharge samples.

Analysis of trace metals presented some problems during the first year of the program. The laboratory that was originally contracted to provide trace metal analyses eventually determined that its high resolution Inductively Coupled Plasma Mass Spectrometry (ICP-MS) machine had become degraded to the point that it could not provide accurate measurements for saltwater samples. This problem was identified in early 2014 when there was sufficient sample material remaining from all samples collected after December 2013 so that those samples could be transferred to another laboratory for analysis. Freshwater samples (i.e., discharges) were not affected and neither was analysis of mercury. Concerns that the degradation of the high resolution ICP-MS could have begun before it was clearly apparent resulted in a decision to disregard saltwater trace metal data from samples collected during October and November 2013, except for mercury, which was analyzed with a different instrument.

Another data presentation issue concerned how to include non-detected concentrations in data analysis and compare them to the 85th percentile threshold. There are various conventions for handling non-detected concentrations (Helsel, 2006; Lee and Helsel, 2005; Kayhanian et al, 2002; EPA 2004), including non-detects represented as 0, non-detects represented as ½ the method detection limit, and non-detects represented as the detection limit. Each of these approaches has its proponents and is preferable over the others, depending on the purpose of the sampling program. There are also a number of ways to estimate the mean value of a measurement in a population of samples with non-detected values. The ASBS Special Protections present unique challenges in determining how to handle non-detected values. In particular, it is a regulatory program that determines compliance based on comparisons of single samples to a threshold that is statistically derived from a set of reference values.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 29 A feature of many chemical analyses is that general sample properties, such as the dissolved organic matter, can affect detection limits (Bruzzoniti et al, 2000; Hajšlová and Zrostlíková, 2003; Niessen et al, 2006; Shahin, 2004; Yamamoto et al, 2003), these properties are generally termed “matrix effects.” Matrix effects especially affect the analysis of organic compounds. For example, lower detection limits are often achievable in samples that have less dissolved organic material in them. This means that the reported method detection limit for each analyte is not necessarily a static value. It can vary by location and by sampling event, depending on ambient conditions. If non-detected values were revised to the method detection limit or a fraction thereof, a non-detected concentration could exceed the 85th percentile threshold because that particular sample had a higher detection limit. This exact situation arose in this program in the analysis of PAHs. Consequently, it was determined that non-detected values would be set to 0 in order to avoid the situation in which an exceedance is caused by a non-detected concentration. Because individual organophosphate and pyrethroids pesticides were infrequently detected, they were considered as summed concentrations for each type of pesticide.

A number of statistical procedures were used to analyze data. These procedures included matched-pair t-tests, linear regressions, correlations, nonparametric tests for differences (Wilcoxon), analysis of variance, and a posteriori tests (each pair Student’s t-test) to determine between which groups of samples statistically significant differences occurred. Because tests were not performed to confirm that the data satisfied assumptions for parametric statistical tests, the Wilcoxon test was used for confirmation, when available. Nevertheless, studies confirm the robustness of analysis of variance (ANOVA) to violations of the assumption that data have a normal distribution (Schmider et al, 2010). All statistical procedures were run using JMP statistical software (SAS Institute Inc., 100 SAS Campus Drive, Cary, NC 27513-2414, USA).

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 30 5.0 Findings

5.1 Question 1: Are there north-to-south differences in reference conditions?
An important consideration in comparisons of reference water quality between northern and southern areas is whether similar storm conditions were sampled throughout the region. If there are north-to-south differences in ambient and reference constituent concentrations, an inability to sample large storms in some areas could bias the calculated 85th percentile threshold. In fact, there were several large storms during which safe access was not possible for sites along the Big Sur coast, requiring that smaller storms be sampled in this area when smaller waves and stream flow allowed access. Consequently, effects of these large storms, while they were captured at northern reference sites, were not captured for the Big Sur coast. ANOVA was performed on each constituent to determine whether there were significant differences in concentrations between reference sites grouped for the northern and southern portions of the study area.

There were clear differences between northern and southern sub-regions in constituent concentrations (Table 1). Every trace metal, except silver, exhibited significant differences between sub-regions, with northern sites having higher concentrations. The results for lead and zinc were not confirmed by the Wilcoxon test, but both had higher means in the north than in the south. In fact, all constituents had higher mean concentrations in the north than in the south, with unambiguous significant differences also for fecal coliform, E. coli, and the numerical endpoint for the kelp germination toxicity test. A higher numerical endpoint equates to a higher percentage of kelp germination. These results indicate that ocean waters sampled during storms at the mouths of reference streams in the northern sub-region have higher concentrations of these constituents than do ocean waters sampled at reference sites in the southern sub-region, as reflected in calculated 85th percentiles for each constituent (Table 2).

This result could be due to geological differences that manifest as different trace metal concentrations, differences in the vegetation coverage in the reference watersheds that could create different percolation rates for storm runoff or differences in ambient ocean concentrations, or the aforementioned differences in accessibility, therefore excluding large storm events from the southern reference data. Regardless of the reasons for these north-tosouth differences, they will inform discussions between participants and the Water Board regarding determinations of the appropriate reference sites for setting the 85th percentile threshold. All subsequent comparisons to 85th percentile thresholds in this report are based on the overall 85th percentiles.

A follow-up ANOVA was performed to determine whether there were north-to-south differences in constituent concentrations in ocean water at reference sites that were not affected by storm runoff (i.e., reference dry weather samples. This test found no differences between sub-regions, although its power was limited by a small sample size (i.e., 3 samples in the north and 6 samples in the south). This result lends credence to the idea that exclusion of large storm data from southern reference sites affected the significant north-south difference in reference site data.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 31 Another important aspect of data from reference sites is the relationships among constituents that could suggest patterns indicative of natural sources, as opposed to anthropogenic sources of measured constituents. This consideration is especially important for trace metals because they are ubiquitous, frequently detected and are found in natural geological formations and soils. Exploration of constituent relationships began with tests to determine whether there were correlations between trace metal concentrations and total suspended solids (TSS) in reference samples.

Table 1. Results of sub-regional comparisons of constituent concentrations at reference sites using analysis of variance and a non-parametric Wilcoxon test.

Constituent ANOVA Wilcoxon
R2 p p1 Result2
Arsenic 0.16 0.005 0.013 N > S
Cadmium 0.20 0.001 <0.001 N > S
Chromium 0.09 0.035 0.002 N > S
Copper 0.11 0.019 0.021 N > S
Lead 0.12 0.015 0.172 N ≥ S3
Nickel 0.13 0.010 <0.001 N > S
Mercury 0.13 0.009 0.045 N > S
Selenium 0.11 0.018 0.013 N > S
Silver 0.00 0.910 0.476 N = S
Zinc 0.11 0.018 0.136 N ≥ S3
TSS 0.10 0.018 0.004 N > S
Oil & Grease -
4 - - -
Fecal Coliform 0.13 0.009 0.001 N > S
Enterococcus 0.05 0.092 0.008 N ≥ S3
E. coli 0.12 0.011 0.024 N > S
Nitrate 0.02 0.370 0.363 N = S
Orthophosphate 0.06 0.084 0.074 N = S
Ammonia 0.00 0.796 0.743 N = S
Urea 0.01 0.457 0.445 N = S
Urchin Fertilization NE5 0.04 0.162 0.130 N = S
Kelp Germination NE 0.09 0.023 0.002 N > S
Kelp Growth NE 0.00 0.830 0.420 N = S
Mussel Development NE 0.02 0.338 0.441 N = S
Mussel Survival NE 0.01 0.637 0.628 N = S
Sum of PAHs - - - -
Sum of OPs - - - -
Sum of Pyrethroids - - - - 1 = P ≤ 0.05 is statistically significant. 2 = N is northern sub-region, S is southern sub-region, sub-region on left has the higher mean. 3 = One test gave a non-significant result.
4 = Constituent not detected in any sample.
5 = Numerical endpoint of the test.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 32 Table 2. Available Ocean Plan water quality objectives and calculated 85th percentiles of constituent concentrations for reference sites grouped over the entire region and grouped by northern and southern sub-regions.

Constituent
Ocean
Plan
Objective
Overall
85th
percentile
Northern
85th
percentile
Southern
85th
percentile
Arsenic, µg/L 80 1.6410 4.9504 1.5963
Cadmium, µg/L 10 0.0607 0.2407 0.0427
Chromium, µg/L 20 1.7450 13.2756 0.9686
Copper, µg/L 30 1.1115 11.8123 1.0045
Lead, µg/L 20 0.2194 3.0201 0.1775
Mercury, ng/L 400 4.2275 25.9000 3.1560
Nickel, µg/L 50 1.6666 26.8870 0.7471
Selenium, µg/L 150 0.1135 0.3429 0.0767
Silver, µg/L 7 0.6000 0.3730 0.6160
Zinc, µg/L 200 2.6577 31.7608 1.7507
TSS, mg/L None 24 560.3 19.8
Fecal Coliform, MPN/100ml 400 143 1023.95 83.9
Enterococcus, MPN/100ml 104 229 476.65 188.55
E. coli, MPN/100ml None 125.5 670.75 84.35
Nitrate, mg/L None 0.675 1.145 0.6
Orthophosphate, mg/L None 0.08 0.1635 0.05
Ammonia, mg/L 6 0 0 0
Urea, µg/L None 10 10.45 4.5
Sum of PAHs, µg/L 0.00881 0 0.0037 0
Sum of OPs, µg/L None 0 0 0
Sum of Pyrethroids, µg/L None 0 0 0
1 = Ocean Plan objective for 30-day average concentration When reference samples from the entire project region were considered, all constituents, except silver and urea, were found to be significantly associated with TSS concentrations (Table 3). This association explained 74–99% of the variation in trace metals concentrations, whereas TSS explained only 23–81% of variation in concentrations of fecal indicator bacteria (FIBs), nutrients and polynuclear aromatic hydrocarbons (PAHs). The same patterns were found for reference sites in the northern sub-region with similar R2 values, except that the association between TSS and Enterococcus was not significant. At the southern reference sites, only copper, lead, mercury, zinc, fecal coliform, E. coli, nitrate and ammonia were significantly associated with TSS. These results suggest that silver and urea are nearly exclusively found in the dissolved phase throughout the region and that copper, lead, mercury and zinc are primarily found in the particulate phase, throughout the region. The lower number of significant correlations between TSS and other constituent in the south than in the north is probably due to lower ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 33 concentrations of TSS and most other constituents in the south (Table 1). The significant associations between TSS and other constituents suggest a background condition, in which constituents could be derived from native soils in the reference watersheds.

Table 3. Results of regressions between TSS and constituents in sub-regional groups of reference sites.

Constituent Overall North Sub-region South Sub-region
R2 p1 R2 p R2 p
Arsenic 0.89 <0.001 0.96 <0.001 0.00 0.893
Cadmium 0.74 <0.001 0.74 <0.001 0.01 0.588
Chromium 0.92 <0.001 0.98 <0.001 0.01 0.589
Copper 0.93 <0.001 0.99 <0.001 0.19 0.014
Lead 0.97 <0.001 0.97 <0.001 0.65 <0.001
Nickel 0.98 <0.001 0.99 <0.001 0.03 0.352
Mercury 0.94 <0.001 0.94 <0.001 0.51 <0.001
Selenium 0.86 <0.001 0.89 <0.001 0.11 0.07
Silver 0.00 0.939 0.00 0.878 0.00 0.914
Zinc 0.99 <0.001 0.99 <0.001 0.82 <0.001
Oil & Grease -
2 - - - - -
Fecal Coliform 0.44 <0.001 0.39 0.006 0.16 0.017
Enterococcus 0.23 <0.001 0.19 0.066 0.10 0.060
E. coli 0.60 <0.001 0.57 <0.001 0.16 0.019
Nitrate 0.26 <0.001 0.62 <0.001 0.55 <0.001
Orthophosphate 0.81 <0.001 0.82 <0.001 0.08 0.100
Ammonia 0.30 <0.001 0.82 <0.001 0.53 <0.001
Urea 0.00 0.673 0.00 0.920 0.00 0.907
Sum of PAHs 0.35 <0.001 0.31 0.017 - -
Sum of OPs - - - - - -
Sum of Pyrethroids - - - - - - 1 = P ≤ 0.05 is statistically significant. 2 = Not detected.

5.1.1 Conclusion: Are there north-to-south differences in reference conditions?
There are clear differences between northern and southern sub-regions in constituent concentrations. Every trace metal, except silver, exhibited significant differences between subregions, with northern sites having higher concentrations. In the case of the kelp germination toxicity test, there were also higher rates of germination in tests done at northern references sites than at southern reference sites. There were also differences between northern reference sites and southern reference sites in the associations between total suspended solids (TSS) and various constituents.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 34 These geographic differences in reference water quality should be considered in determining whether a particular ASBS site conforms to natural water quality. The significant associations between TSS and other constituents in reference samples suggest that comparisons using TSSconstituent associations in other sample types (i.e., discharge, pre-storm, receiving water) could help determine whether some constituents in non-reference samples are derived from natural sources, such as native sediments.

5.2 Question 2: Are there north-to-south differences in Pre-Storm water quality at ASBS sites?
Question 1 asked whether reference sites throughout the study region responded similarly to storms. Question 2 seeks to determine whether non-storm concentrations of constituents at ASBS sites were consistent throughout the region. If north-to-south differences in non-storm ambient conditions exist, such differences could mean that receiving water samples in some areas have a smaller margin between pre-storm concentrations and an 85th percentile threshold, thus resulting in more values above the threshold than in areas with lower pre-storm concentrations.

The analytical approach to this question was identical to that for Question 1. Pre-storm concentrations of all trace metals (except silver) and TSS were higher in the northern part of the study area than in the southern sub-region (Table 4). Conversely, the concentrations of FIBs, nutrients (except urea), PAHs, organophosphate pesticides, and pyrethroid pesticides were higher in the south, although none of the differences was unequivocally significant.

The reasons for these north-to-south differences are unknown. Differences in soil erodibility and trace metal concentrations, and differing proximities to anthropogenic sources associated with large urban areas are potential causes. Moreover, differences between areas in ocean currents and wave action could also affect differences in ambient conditions. Regardless, these differences in ambient conditions suggest that the study region is not homogeneous. They also provide important context for discussions of ways to achieve natural water quality.

5.2.1 Conclusion: Are there north-to-south differences in Pre-Storm water quality at ASBS sites?
Pre-storm samples have significantly higher trace metal and TSS concentrations at ASBS sites in the northern area of the study region than in the southern area. Concentrations of FIBs, nutrients, PAHs, and organophosphate and pyrethroid pesticides were mostly higher in the south than in the north, but none of the differences was significant in both of the statistical tests used. Potential causes are differences in geology, soil erodibility and trace metal concentrations, and differing proximities to anthropogenic sources associated with large urban areas. These results suggest that, if all discharges were equal, the difficulties of achieving natural water quality would not be the same across the entire study region.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 35 Table 4. Results of sub-regional comparisons of constituent concentrations in pre-storm samples using analysis of variance and a non-parametric Wilcoxon test.

Constituent ANOVA Wilcoxon
R2 p1 p Result2
Arsenic 0.14 0.001 0.001 N > S
Cadmium 0.36 <0.001 0.002 N > S
Chromium 0.63 <0.001 <0.001 N > S
Copper 0.15 0.007 0.001 N > S
Lead 0.01 0.44 0.013 N ≥ S3
Nickel 0.70 <0.001 <0.001 N > S
Mercury 0.28 <0.001 <0.001 N > S
Selenium 0.10 0.031 0.035 N > S
Silver 0.00 0.646 0.779 N = S
Zinc 0.18 0.003 0.003 N > S
TSS 0.39 <0.001 <0.001 N > S
Oil & Grease - - - -
Fecal Coliform 0.03 0.238 <0.001 S ≥ N3
Enterococcus 0.03 0.235 0.177 S = N
E. coli 0.03 0.216 <0.001 S ≥ N3
Nitrate 0.00 0.670 0.802 S = N
Orthophosphate 0.01 0.472 0.291 S = N
Ammonia - - - -
Urea 0.00 0.802 0.539 N = S
Sum of PAHs 0.01 0.591 0.586 S = N
Sum of OPs - - - -
Sum of Pyrethroids - - - - 1 = P ≤ 0.05 is statistically significant. 2 = N is northern sub-region, S is southern sub-region, sub-region on left has the higher mean. 3 = One test gave a non-significant result.

5.3 Question 3: Do storm discharges alter receiving water quality? Answering this question requires a detailed evaluation of data from discharge, pre-storm, and receiving water samples at the 8 ASBS discharges monitored in this program. As the stated point of compliance in the Special Protections is the receiving water, those data receive most of the attention. The 85th percentile threshold that is referenced in the following sections is calculated from the full set of program reference sites. Given that monitoring has demonstrated that there are significant geographic differences in natural water quality at reference sites in this study, the overall 85th percentile does not necessarily reflect local natural water quality at a given ASBS.

There was substantial variation in trace metal concentrations among samples types (Figure 7).

Discharge samples were above the maximum reference concentrations of copper, lead, mercury, selenium, and zinc. For all other trace metals, the ranges of concentrations ATTACHMENT 1

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 36 Figure 7. Concentrations of trace metals (µg/L except for mercury = ng/L) in different sample types. The horizontal line indicates the 85th percentile threshold for all reference sites. Circles indicate northern sites and triangles indicate southern sites for each sample type.

Reference pre-storm samples were collected once in October 2013 and all traces metal data, except mercury, were deleted due to instrumentation problems.

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Central Coast Regional ASBS Monitoring Program
37 overlapped. In the cases of arsenic, cadmium, chromium, mercury, nickel, and selenium, the maximum reference concentrations were above the maxima for both pre-storm and receiving water samples. Another relevant feature of these data is that numerous reference samples were above the overall 85th percentile threshold for all trace metals, except selenium and silver.

Maximum concentrations of trace metals at the 2 background sites were usually lower than those at receiving water sites, especially for copper, lead, and zinc, which suggests that the concentrations of these 3 trace metals in ASBS receiving waters were not reflected by storm conditions throughout Monterey Bay nearshore areas.

There was also a large range in FIB concentrations (E. coli, fecal coliforms and Enterococcus spp.), particularly in discharge and receiving water samples (Figure 8). There was also a large range in bacterial concentrations at the reference sites. Lowest concentrations were detected at the southern reference sites, whereas highest concentrations were detected at the northern reference sites. The highest receiving water concentrations for all bacterial types were greater than concentrations at reference sites. In turn, the highest bacterial concentrations in discharges were substantially above concentrations in receiving waters.

The picture was different with respect to dissolved nutrients (ammonia, nitrate, urea, and orthophosphate) where large numbers of samples had no detectable concentrations within any sample type, including reference sites (Figure 8). Method detection limits were partly responsible for the small number of detections. For example, the method used to analyze ammonia had a high detection limit relative to ambient ammonia concentrations and the 85th percentile threshold was zero. Therefore, all receiving water concentrations above zero were above the threshold. For nitrate, urea and orthophosphate, the 85th percentiles were above zero. In general, nutrient concentrations in receiving waters were low and within the same range as those measured at the reference sites. With respect to nitrate and orthophosphate, a few of the reference site concentrations were above the highest receiving water concentrations. That was also the case for TSS, where concentrations measured at northern reference sites were above receiving water concentrations and similar to concentrations measured in discharges (Figure 8).

ANOVA was performed using all samples in each sample type to test for differences in constituent concentrations among discharge, pre-storm, receiving water, background, reference pre-storm, and reference samples. Discharge samples had significantly higher concentrations of all chemical constituents, except for arsenic, silver, and TSS (Table 5). In fact, concentrations of silver were significantly lowest in discharge samples. Reference samples had the highest concentrations of TSS, but it was not possible to determine between which sample type differences were significant. Receiving water samples had the second highest concentrations of arsenic, copper, lead, mercury, zinc, FIBs, nitrate, ammonia, and urea, but receiving water samples were not significantly different from reference samples for any constituent.

The numerical endpoints of the 4 toxicity tests also exhibited significant differences among sample types (Table 5), regardless of whether the samples passed or failed. Urchin fertilization was significantly lower in discharge samples than in reference, background, and receiving water samples, although discharge results were not different from reference pre-storm samples.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 38 Figure 8. Concentrations of FIBs (MPN/100 ml) and nutrients (mg/L) in different sample types. The horizontal line indicates the 85th percentile threshold for all reference sites. Circles indicate northern sites and triangles indicate southern sites for each sample type.

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Central Coast Regional ASBS Monitoring Program
39 Table 5. Results from comparisons of constituent concentrations among sample types.

ANOVA Wilcoxon
Constituent R2 p1 p
A posteriori
Result2
Arsenic 0.03 0.191 0.053 D Rw Rf P B
Cadmium 0.22 <0.001 <0.001 D Rf Rw P B
Chromium 0.06 0.014 <0.001 D Rf B Rw P
Copper 0.28 <0.001 <0.001 D Rw Rf B P
Lead 0.28 <0.001 <0.001 D Rw Rf P B
Nickel 0.12 <0.001 <0.001 D Rf Rw B P
Mercury 0.42 <0.001 <0.001 D Rw Rf B P Pr
Selenium 0.13 <0.001 <0.001 D Rf Rw P B
Silver 0.13 >0.001 <0.001 B Rf Rw P D
Zinc 0.57 <0.001 <0.001 D Rw Rf B P
TSS 0.03 0.255 <0.001 Rf D Rw Pr P B3
Oil & Grease 0.08 0.002 <0.001 D B P Pr Rw Rf
Fecal Coliform 0.07 0.003 <0.001 D Rw Rf B P Pr
Enterococcus 0.12 <0.001 <0.001 D Rw Rf B P Pr
E. coli 0.08 0.001 <0.001 D Rw Rf B P Pr
Nitrate 0.15 <0.001 <0.001 D Rw Rf P B Pr
Orthophosphate 0.21 <0.001 <0.001 D Rf P Rw B Pr
Ammonia 0.19 <0.001 <0.001 D Rw Rf B Pr P
Urea 0.44 <0.001 <0.001 D Rw P Pr Rf B
Urchin Fertilization 0.14 <0.001 <0.001 Rf B Rw Pr D
Kelp Germination 0.26 <0.001 <0.001 B Rw Rf Pr
Kelp Growth 0.03 0.405 0.262 Pr Rf Rw B
Mussel Development 0.07 0.067 0.157 Pr Rf Rw B
Mussel Survival 0.00 0.953 0.805 Rf Rw B
1 = P ≤ 0.05 is statistically significant. If p >0.05, there is no statistical difference. 2 = D is Discharge, P is Pre-storm, Pr is Reference Pre-storm (Dry Weather), and Rf is Reference, and Rw is storm Receiving Water. Sample type on left has the highest mean. There were no results for trace metals in Pr samples. PAHs, organophosphate pesticides and pyrethroid pesticides were detected too infrequently to provide reliable results. Urchin fertilization is the only toxicity test performed in discharge samples and mussel survival was not measured in reference pre-storm samples. 3 = One test gave a non-significant result
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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 40 receiving water and reference samples, indicating the presence of toxicity in reference waters in the absence of storm runoff. Neither rates of mussel embryo normal development nor embryo survival differed among reference, receiving water, and background samples.

Differences among sites were observed in the number and percentage of receiving water samples with constituent concentrations above the overall 85th percentile threshold (Table 6 and Table 7). There were also several cases in which receiving water concentrations were above the threshold when pre-storm concentrations were equal to or greater than receiving water concentrations, and also cases in which receiving water constituents above the threshold were not detected in the discharge. There were a total of 7 samples across 5 sites whose constituent concentrations in receiving water were above the overall 85th percentile threshold and were preceded by higher pre-storm concentrations. Single samples at sites C, F, and G, and 2 samples at site H had higher pre-storm than receiving water concentrations of urea. A single sample at Site D exhibited this pattern for TSS and a single sample at Site F exhibited this pattern for E. coli. A single sample at Site A had the same concentrations of nitrate in a pre-storm sample with an equivalent concentration in the receiving water sample. Site H had single receiving water samples that were above the threshold for Enterococcus and E. coli, with corresponding non-detection in the discharge sample. Site A had 3 samples and Site D had a single sample in which PAHs were detected in receiving water but not in discharge samples. Sites C and D had detections of pyrethroid and organophosphate pesticides, respectively, in single receiving water samples for which there were no detections in the discharge. The sites with the greatest overall percentages of receiving water samples above the overall 85th percentile threshold were A (20%), C (19%), D (24%), and F (21%). Site E had the lowest percentage of samples (4%) above the threshold. Across all sites and constituents, 16% of receiving water samples had concentrations of at least 1 constituent above the threshold.

A literal interpretation of the Special Protections flowchart for determining compliance, in which 1 out of 2 samples were above the threshold, suggests that >50% of samples with concentrations above the 85th percentile threshold for any given constituent would be interpreted as exceeding natural water quality. Overall, this hypothetical guideline was exceeded for copper, lead, zinc, fecal coliform, Enterococcus and PAHs (Table 7). E. coli was close to this threshold with 48% of all receiving water samples over the overall 85th percentile.

Sites A and C had the most constituents (i.e., 11) with ≥50% of values above the overall 85th percentile threshold. Next came sites D and F, with 9 constituents with ≥50% of values over the threshold. Sites G, B, H, and E followed with 7, 5, 4, and 0 samples, respectively, over the hypothetical guideline.

In addition to the numbers of receiving water samples with concentrations above 85th percentile thresholds, analysis of the relative magnitudes of concentrations above the threshold is informative (Table 8). For example, whereas 39% of all samples were above the 85th percentile threshold for arsenic, the average concentration was only 3% above the threshold. Moreover, although 40% of receiving water samples at site H were above the threshold for cadmium, the average concentration of cadmium at that site was 20% below the threshold. Such comparisons can also highlight sites with constituent concentrations very much above 85th percentile thresholds. For example, sites D and F had FIB concentrations in receiving water that were above the thresholds in 83–100% of samples (Table 7) and those samples also averaged 2,665–10,598% above the thresholds (Table 8).

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 41 Table 6. Number of samples above overall 85th percentile thresholds / number of samples with greater concentrations in receiving water samples than in pre-storm samples.

Site Arsenic Cadmium Chromium Copper Lead Mercury Nickel Selenium Silver Zinc TSS A 4/4 3/3 3/4 3/4 3/4 2/6 4/5 2/4 0/2 3/5 4/4
B 2/4 1/3 0/5 3/6 3/6 1/5 0/5 1/4 1/4 2/5 1/5
C 4/5 1/6 0/5 4/5 5/6 3/5 0/6 0/2 2/3 5/6 2/6
D 2/4 2/6 1/5 6/6 5/6 4/6 1/3 0/4 1/2 5/6 1/4*
E 0/3 0/1 0/4 0/5 0/5 0/5 0/4 0/2 1/2 0/2 1/5
F 0/2 1/5 1/6 5/6 6/6 2/6 0/5 1/2 1/2 6/6 1/5
G 0/4 1/4 0/5 5/6 1/5 2/5 0/5 0/3 0/0 2/6 1/6
H 1/3 2/4 1/5 1/5 3/4 1/6 2/4 0/3 0/3 2/5 4/6
Site
Fecal
Coliform Enterococcus E. coli Nitrate Orthophosphate Ammonia Urea PAHs Organophosphate
Pesticides Pyrethroids
A 3/6 3/6 2/4 2/3x 0/1 2/2 0/0 4/4+++ 0/0 0/0
B 2/6 4/6 3/6 0/1 1/1 1/1 2/3 2/2 0/0 0/0
C 3/4 3/5 3/4 1/1 0/2 1/1 3/3* 2/2 0/0 2/2+
D 6/6 6/6 6/6 1/3 2/2 1/1 4/4 4/4+ 1/1+ 1/1
E 0/4 1/5 0/2 1/1 0/1 0/0 0/0 1/1 0/0 0/0
F 6/6 6/6 5/5* 1/1 0/0 1/1 4/4* 3/3 1/1 0/0
G 3/5 4/5 3/5 1/1 3/4 1/1 3/3* 0/0 0/0 2/2+
H 2/5 1/4+ 1/4+ 0/0 0/2 0/0 1/1** 3/3 0/0 0/0 * = A single case of a value above the overall 85th percentile threshold being disregarded due to a higher value in the Pre-storm sample. + = A single case of a value above the overall 85th percentile threshold with the constituent not being detected in the discharge sample. x = A single case of a value above the overall 85th percentile threshold with the constituent having equal concentrations in the pre-storm and receiving water samples.

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Central Coast Regional ASBS Monitoring Program Final Report 2013–2016 42 Table 7. Percentage of samples above overall 85th percentile thresholds for constituents in receiving water samples at each ASBS site.

Site Arsenic Cadmium Chromium Copper Lead Mercury Nickel Selenium Silver Zinc TSS
A 80% 80% 60% 60% 60% 33% 80% 40% 20% 60% 67%
B 33% 17% 0% 67% 50% 17% 0% 17% 17% 50% 17%
C 67% 17% 0% 67% 83% 50% 0% 0% 33% 83% 33%
D 33% 33% 17% 83% 83% 67% 33% 0% 17% 83% 17%
E 0% 0% 0% 17% 0% 0% 0% 0% 17% 0% 17%
F 17% 17% 17% 83% 100% 50% 0% 33% 17% 100% 17%
G 0% 0% 0% 83% 17% 33% 0% 0% 0% 50% 17%
H 80% 40% 40% 20% 60% 17% 40% 0% 0% 40% 67%
Overall 39% 23% 17% 60% 57% 33% 19% 11% 15% 58% 31%
Site
Fecal
Coliform Enterococcus E. coli Nitrate Orthophosphate Ammonia Urea PAHs Organophosphate
Pesticides Pyrethroids Overall
A 50% 50% 33% 17% 0% 33% 0% 67% 0% 0% 18%
B 33% 67% 50% 0% 20% 20% 40% 33% 0% 0% 12%
C 50% 50% 50% 17% 0% 17% 50% 33% 0% 33% 16%
D 100% 100% 100% 17% 33% 17% 67% 50% 17% 17% 22%
E 0% 17% 0% 17% 0% 0% 0% 17% 0% 0% 3%
F 100% 100% 83% 17% 0% 17% 67% 50% 17% 0% 20%
G 50% 67% 50% 17% 33% 17% 50% 0% 0% 33% 11%
H 33% 17% 17% 0% 0% 0% 17% 0% 0% 0% 11%
Overall 52% 58% 48% 13% 11% 15% 36% 50% 4% 10% 14%
ATTACHMENT 1

Page 475 of 747 ends

Carmel-by-the-Sea City CouncilNovember 4, 2025

Carmel-by-the-Sea City Council
November 4, 2025