Laguna Beach City Council
June 23, 2026

Figure 1. Project Location Map
FMZ 16 (Lower Hobo). FMZ 16, an approximately 13.7-acre zone, predominantly borders residential single-family and mobile home communities along the western part of Nyes Place, then curves above Ashton Drive and Alexander Road, behind the Laguna Beach Community and Recreation Center and future location of the Laguna Beach Fire Department administrative offices, and along the north and south sides of Laguna Terrace North, M Street, and K Street (see Figure 1). The single-family homes in this neighborhood are adjacent to large portions of densely vegetated steep hillsides and are susceptible to wildfire hazards. FMZ 16 contains a variety of native and disturbed habitat and contains an intact population of big-leaved crownbeard, a State- and federally-listed threatened species and intermediate mariposa-lily, a State-listed threatened species.
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Robert Montaghami, Fire Marshal

Figure 2. Project Location Topographic Map
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Robert Montaghami, Fire Marshal

Other plant species within FMZ 16 include bigpod ceanothus, laurel sumac, California buckwheat, California brittlebush, California sagebrush, black sage, toyon, holly leaf redberry, coast live oak, scrub oak, heart leaved keckiella, blue elderberry, sticky monkeyflower, Victorian box, ngaio tree, garden nasturtium, lemonade berry, redberry, deerweed, fountain grass, coastal wattle, bank catclaw, athel, American century plant, glossy privet, and pride of madeira. Big-leaved crownbeard, a federal and state threatened species, occurs along Nyes Place and K Street. Additionally, several patches of Coulter’s Matilija Poppy (included in the California Native Plant Society Inventory of Rare and Endangered Plants as limited distribution) were observed in FMZ 16 adjacent to residential development. Special-status species would be flagged, and a 15-foot buffer installed during fuel management activities.

FMZ 19 (Diamond Crestview). Similar to FMZ 16, FMZ 19 is located on steep, densely vegetated slopes that pose the risk of wildfire hazards to nearby structures. FMZ 19 consists of approximately 25.4 acres bounded by Diamond Street to the west, Summit Drive to the north, and La Mirada Street and Alta Vista Way to the east and is surrounded by residential single-family homes (see Figure 3). According to the City of Laguna Beach’s GIS Constraints layers, large portions of FMZ 16 are designated as High/Very High Value Habitat and Seismic Hazard Landslide Areas (City of Laguna Beach, 2023). The heavily vegetated steep slopes within and around FMZ 19 pose a risk of wildfire damage to adjacent homes and valuable habitat.

FMZ 19, like FMZ 16, is also moderately impacted by non-native ornamental plants, such as Victorian box, ngaio tree, garden nasturtium, coastal wattle, bank catclaw, athel, American century plant, glossy privet, and pride of madeira, likely established by homeowners. The areas with relatively intact native habitat contain laurel sumac, California buckwheat, California brittlebush, California sagebrush, black sage, sweetclover, Italian thistle, coyote brush, toyon, holly leaf redberry, coast live oak, scrub oak, heat leaved keckiella, blue elderberry, sticky monkeyflower, Spiny redberry, and deerweed. Big-leaved crownbeard, intermediate mariposa lily, and decumbent goldenbush, all special-status species, occur in FMZ 19.

Additionally, Fish’s milkwort (included in the California Native Plant Society Inventory of Rare and Endangered Plants as limited distribution) occurs in the southern portion of FMZ 19. Portions of FMZ 19 that have been categorized as High/Very High Value Habitat or have had rare plant sightings were surveyed by a qualified biologist in June and September 2023 and the project design refined to avoid rare plants and minimize vegetation clearance in these areas.

Methods
Investigation methods included geologic mapping, a paleontological record search through the Natural History Museum of Los Angeles County, a site visit, and a paleontological literature search.

Results
Geologic mapping of the area shows FMZ 16 to be underlain primarily by the San Onofre Breccia with a small area in its midsection underlain by Old Quaternary paralic deposits, units 2-6, undifferentiated (Qop 2-6) (Morton and Miller, 1981). The same mapping shows the northern part of FMZ 19 to be within the Topanga Group, with the southern part in the San Onofre Breccia and the southwestern part in Qop 2-6 (Figure 3). The San Onofre Breccia is a middle Miocene marine deposit containing abundant broken pieces of metamorphic and sedimentary rocks. The Topanga Group is a middle Miocene marine sandstone. It has historically been regarded as a formation but is recognized as a group by Morton and Miller. The Old Quaternary paralic deposits, units 2-6, undifferentiated are intertongued marine and continental coastal deposits of late to middle Pleistocene age. They have been uplifted since they were deposited at or near sea level.
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Figure 3. Geologic Setting
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The paleontological resources records search done by the Natural History Museum of Los Angeles County for the Lower Hobo and Diamond Crestview Fuel Modification Project (see Attachment A) covers the area.

The records search yielded four known nearby Topanga Formation localities (middle Miocene) and two nearby San Onofre Breccia localities (Early-Middle Miocene). Two Topanga Formation localities produced specimen of an extinct aquatic mammal known as Desmostylus. Another produced a dugong fossil. The other one produced mollusk and brachiopod fossils. Both of the San Onofre Breccia localities produced unspecified invertebrate fossils.

A search of paleontological literature, both published and unpublished, did not yield any localities pertinent to this study.

Aspen paleontologist Joe Stewart attempted to survey the project area on October 12, 2023. Much of the project area was inaccessible because of steep slopes and dense vegetation. In the few areas that were accessible, no paleontological resources were located. In all the areas accessed, the Topanga Formation was a moderately indurated sandstone. The San Onofre Breccia is an indurated breccia. No exposures of the Old Quaternary paralic deposits were accessed. No fossils were detected at any of the sites.

Impacts
The Lower Hobo and Diamond Crestview Fuel Modification Project would involve minor ground disturbances to remove and reduce vegetation exclusively using hand crews. All cuttings would be removed and hauled off site with the exception of the majority of roots of perennial plants to be left in place to minimize erosion. The sediments that would be impacted are fairly or very loose. In some areas, they are mixed with humus and dead vegetation. There is no clear evidence that paleontological resources of the Topanga Formation would be impacted and would at most be impacted only by pedestrian traffic.

The likelihood of impacting significant paleontological resources that are not already disturbed by vegetation is negligible.

Conclusion
Impacts to paleontological resources within FMZ 16 and FMZ 19 would be negligible. No mitigation is required.

Attachments
Attachment A – Paleontological Resources Records Search Attachment B – Joe Stewart Resume
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Robert Montaghami, Fire Marshal

References
City of Laguna Beach. 2023. Public GIS Map Viewer. [Online]: https://gis.lagunabeachcity.net/ Html5Viewer/index.html?viewer=LagunaBeachPublicGIS. Accessed August 13, 2023.

Morton, P.K., and R.V. Miller. 1981. Geologic Map of Orange County California, Showing Mines and Mineral Deposits. California Division of Mines and Geology Bulletin 204, plate 1. Scale 1:48,000.

Morton, P.K., and R.V. Miller. 2006. Geologic map of the San Bernardino and Santa Ana 30’60’quadrangles, southern California. U.S. Geological Survey Open File Report OF-99-172.

Scale 1:100,00.md
Vedder, J. G., R. F. Yerkes, and J. E. Schoellhamer. 1957. Geologic map of the San Joaquin Hills – San Juan Capistrano area, Orange County, California. U.S. Geological Survey Oil and Gas Investigations Map OM-193. Scale: 1:24,000.

Society of Vertebrate Paleontology (SVP). 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. 11 p. [Online]: http://vertpaleo.org/ The-Society/Governance-documents/SVP_Impact_Mitigation_Guidelines.aspx 231
Attachment A
Record Search Results
232
Research & Collections
e-mail: [email protected]
October 1, 2023
Aspen Environmental Group
Attn: Lauren DeOliveira
re: Paleontological resources for the FMZ 16/19 Project Dear Lauren:

I have conducted a thorough search of our paleontology collection records for the locality and specimen data for proposed development at the FMZ 16/19 project area as outlined on the portion of the Laguna Beach USGS topographic quadrangle map that you sent to me via e-mail on September 21, 2023. We do not have any fossil localities that lie directly within the proposed project area, but we do have fossil localities nearby from the same sedimentary deposits that occur in the proposed project area, either at the surface or at depth.

The following table shows the closest known localities in the collection of the Natural History Museum of Los Angeles County (NHMLA).

Locality
Number Location Formation Taxa Depth
LACM IP 5835
East side of Aliso Creek bank;
approximately 1 mile inland
from Pacific Coast Highway; on
west side of prominent spur
trending northwest from Niguel
Hill
Topanga Formation
(shale)
abundant mollusks
and brachiopods
(Glotidia albida) Surface
LACM VP 3222
Two miles north of South
Laguna; west of the drainage of
Aliso Creek; southeast of
Temple Hill
Topanga Formation
(brecciated
conglomeratic
sandstone)
marine mammal
(Desmostylia) surface
LACM VP 4007
In the head of Rim Rock
Canyon south of Temple Hill
Drive & west of Top of the
World on Temple Hill Topanga Formation
Marine mammal
(Desmostylus) Unknown
LACM VP 7249
Ridge between Temple Hill and
Wood Canyon, south side of
wash on cliff face Topanga Formation
Marine mammals
(Dugongidae) Unknown
LACMIP 24377 Dana Point
San Onofre Breccia
(Red and gray;
sandy and earthy
schist breccia)
Invertebrates
(unspecified) Unknown
233
LACMIP 6997
S slope of ridge adjacent to
Laguna RidgeTrail, near end of
Seaway Dr; Laguna Hills San Onofre Breccia
Invertebrates
(unspecified) Unknown
VP, Vertebrate Paleontology; IP, Invertebrate Paleontology; bgs, below ground surface This records search covers only the records of the NHMLA. It is not intended as a paleontological assessment of the project area for the purposes of CEQA or NEPA. Potentially fossil-bearing units are present in the project area, either at the surface or in the subsurface. As such, NHMLA recommends that a full paleontological assessment of the project area be conducted by a paleontologist meeting Bureau of Land Management or Society of Vertebrate Paleontology standards.

Sincerely,
Alyssa Bell, Ph.D.

Natural History Museum of Los Angeles County
enclosure: invoice
234
Attachment B
Resume
235
Joe Stewart, Ph.D.

PALEONTOLOGIST
PROFILE: Dr. Stewart is a vertebrate paleontologist with over 40 years of experience in paleontology and 33 years with the geology and paleontology of California. His main experience is with the paleontological resources of California, but also has experience with projects in Wyoming, Utah, Colorado, Arizona, Nevada, Idaho, and Nebraska, and a substantial research history in Kansas. Dr. Stewart has extensive experience with permitting projects subject to CEQA and NEPA and is on the list of approved paleontologist for Orange County. His expertise includes the identification of fish fossils and Pleistocene microvertebrate faunal remains. He recently completed the paleontological mitigation work for a project for the County of Orange on Newport Bay. He directed the paleontological monitoring and mitigation program for Path 15, a major transmission line project, and the paleontological aspects of permitting for the Gateway West transmission line project in Wyoming and Idaho. Joe has multiple BLM permits. He has published over 40 peer reviewed paleontology articles in scientific books and journals.

He is also a Research Associate at the Natural History Museum of Los Angeles County.

EDUCATION:
n PhD, Systematics and Ecology, University of Kansas, 1984 n MA, Systematics and Ecology, University of Kansas, 1979

PROFESSIONAL EXPERIENCE

REVIEW OF IVANPAH-CONTROL PROJECT
California Public Utilities Commission,
Reviewed paleontological resource aspects of Southern California Edison’s Ivanpah-Control Project environmental assessment filing for California Public Utilities Corporation.

TECHNICAL REVIEW OF ALAMITOS BAY PUMP STATION INITIAL STUDY Los Angeles County Flood Control District,
Reviewed paleontological documents for the Initial Study for the Los Angeles County Flood Control District.

STRAUSS WIND ENERGY PROJECT
Santa Barbara County Planning Dept,
Reworking paleontological resource sections of an earlier EIR for Santa Barbara County Planning Department.

PUERCO CANYON CAMP AND TRAILHEAD PROJECT
Mountains Recreation and Conservation Authority,
Surveyed the project footprint and wrote the Paleontological Resources Mitigation and Monitoring Plan.

PREVIOUS EXPERIENCE
n ISEC West Solar Project (2013-2016). Dr. Stewart supervised paleontological monitoring on private lands. n BrightSource Sonoran West Solar Project (2012-2013). Dr. Stewart supervised paleontological survey on BLM and private lands. Worked on AFC and wrote final report when project was terminated. n TerraGen Project (2012). Dr. Stewart Performed pedestrian paleontological survey of project site and wrote the Paleontological Resources section for the AFC.
n BrightSource Rio Mesa Solar Project (2011-2013). Dr. Stewart supervised paleontological survey on BLM and private lands. Wrote the Paleontological Resources section for the AFC. 236
Joe Stewart, Ph.D., page 2
n Pio Pico Energy Center (2010-2011). Dr. Stewart supervised paleontological survey and wrote the Paleontological Resources section for the AFC.
n Mesquite Nevada Replacement General Aviation Airport (2009). Dr. Stewart wrote the paleontological Resource Assessment for the Federal Aviation Administration. n Marsh Landing Generating Station Application for Certification (2008- 2013). Dr. Stewart performed paleontological pedestrian survey of project area in Contra Costa County and wrote the paleontological resource section of the AFC. Served as Paleontological Resource Specialist for construction. Wrote final report. n Imperial Valley Solar Application for Certification (2008-2010). Dr. Stewart directed paleontological pedestrian survey of project area in San Bernardino County and wrote the paleontological resource section of the AFC. n Calico Solar Application for Certification (2008-2010). Dr. Stewart participated in paleontological pedestrian survey of project area, edited the paleontology section of the AFC, and am served as Paleontological Resource Specialist.
n Starwood Power-Midway, LLC Peaking Project Construction (2008-2009). Dr. Stewart wrote mitigation plan for paleontological resources, oversaw monitoring for paleontological resources, and wrote final report. n Calnev Pipeline Project (2008-2009). Dr. Stewart directed paleontological survey of 234-mile-long project area in San Bernardino County, California and Clark County, Nevada and wrote the paleontological assessment. n Willow Pass Generating Station Application for Certification (2008-2009). Dr. Stewart participated in paleontological pedestrian survey of project area in Contra Costa County and wrote the paleontological resource section of the AFC.
n San Joaquin One and Two Application for Certification (2008). Dr. Stewart directed paleontological pedestrian survey of project area in Fresno County and wrote the paleontological resource section of the AFC. n Carrizo Energy Solar Farm (Ausra) Application for Certification (2007). Dr. Stewart participated in paleontological pedestrian survey of project area and edited the paleontology section of the AFC. n Starwood Power-Midway, LLC Peaking Project Application for Certification (2007). Dr. Stewart participated in the responses to the CEC Provisional Staff Assessments. n Path 15 500-kV Power Transmission Line between Los Banos and Gates substations (2003-2005). Dr. Stewart supervised paleontological resource monitoring, excavations, specimen preparation, specimen identification, and report writing for 80-mile power line.

PREVIOUS EMPLOYMENT
n URS Corporation, Principal Paleontologist, San Diego, California, 2007-2015 n PCR Services Corporation, Principal Paleontologist, Irvine, California, 2005-2007 n Jones and Stokes, Project Paleontologist, Sacramento, California, 2003-2005 n Brian F. Smith & Associates, Project Paleontologist, Poway, CA, 2003-2005 n Natural History Museum of Los Angeles County, California, Assistant Curator of Vertebrate Paleontology, 1985-2003

PROFESSIONAL SOCIETIES AND AFFILIATIONS
n Society of Vertebrate Paleontology

SPECIAL CERTIFICATIONS
n Hazardous Waste Operations and Emergency Response 40 Hr. n General Site Worker
n Certified paleontologist in Orange County
n Certified paleontologist in Riverside County
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Joe Stewart, Ph.D., page 3

PUBLICATIONS
n Stewart, J. D., and M. E. Hakel. 2017. First record of vertebrate fossils in the Searles Basin: in another desert paleosol. California State University Desert Symposium Proceedings 2017:341. n Stewart, J. D., and M. E. Hakel. 2016. Pleistocene paleosol developed on ancestral Mojave River sediments near Hinkley, California. Paleobios 33 Supplement: 15.
n Stewart, J. D., and M. E. Hakel. 2015. Remanié Desmostylus fossils in the Tulare Formation. PaleoBios 32:
15-16.
n Stewart, J. D., and Marjorie E. Hakel. 2013. New observations on Pachyrhizodus species of North America.

Abstracts, 6th International Meeting on Mesozoic Fishes, Diversification and Diversity Patterns, Vienna, Austria, August 4–10, 2013, p. 62.
n Smith, G. R., J. D. Stewart, and N. E. Carpenter. 2013. Fossil and Recent mountain suckers, Pantosteus, and significance of introgression in catostomine fishes of western United States. Occasional Papers of the Museum of Zoology, University of Michigan 743:1-39.
n Smith, G. R., R. E. Reynolds, and J. D. Stewart. 2013. Hydrographic significance of fishes from the Early Pliocene White Narrows Beds, Clark County, Nevada. California State University Desert Symposium Proceedings 2013:171-180.
n Friedman, M., K. Shimada, M. J. Everhart, K. J. Irwin, B. S. Grandstaff, and J. D. Stewart. 2013. Geographic and stratigraphic distribution of the late Cretaceous suspension feeding bony fish Bonnerichthys gladius (Teleostei, Pachycormiformes). Journal of Vertebrate Paleontology 33:35-47. n Stewart, J. D., M. Williams, M. Hakel, and S. Musick. 2012. Was it washed in? New evidence for the genesis of Pleistocene fossil vertebrate remains in the Mojave Desert of southern California. California State University Desert Symposium Proceedings 2012:140-143.
n Bell, M. A., J. D. Stewart, and J. Park. 2009. The world's oldest fossil threespine stickleback. Copeia 2009:256-265.
n Tseng, J.Z., X. Wang, and J.D. Stewart. 2009. A new otter-like immigrant mustelid (Carnivora, Mammamlia) from the middle Miocene Temblor Formation of Central California. PaleoBios 29:13-23. n Kelly, T. S., and J. D. Stewart. 2008. New records of Middle and Late Miocene Perissodactyla and Artiodactyla from the western border of the San Joaquin Valley, Diablo Range, Fresno County, California. Los Angeles County Museum of Natural History Contributions in Science 516:1-29. n Tseng, Z., X. Wang, and J. D. Stewart. 2007. Tough New World. Discovery of an unusual immigrant mustelid with crushing dentition from the middle Miocene of coastal California. Journal of Vertebrate Paleontology 27:160A.
n Stewart, J. D. and M. Hakel. 2006. Ichthyofauna of the Mowry Shale (Early Cenomanian) of Wyoming. New Mexico Museum of Natural History & Science Bulletin 35:161- 163. n Stewart, J. D., E. Zaborsky, and M. Hakel. 2006. A new Middle Miocene terrestrial fauna from the Temblor Formation of Central California. New Mexico Museum of Natural History & Science Bulletin 34:40. n Stewart, J. D. 2003. Quantifiable change in the Isurus hastalis populations in Middle and Late Miocene rocks of California. Journal of Vertebrate Paleontology 23:101A. n Stewart, J. D., and F. Perry. 2002. The first paleomagnetic framework for the Isurus hastalis–Carcharodon transition in the Pacific Basin: the Purisima Formation, Central California. Journal of Vertebrate Paleontology 22:111A.
n Hakel, M., and J. D. Stewart. 2002. First fossil Molidae (Actinopterygii: Tetraodontiformes) in western North America. Journal of Vertebrate Paleontology 22:62A.
n Geist, N. R., S. Carpenter, and J. D. Stewart. 2002. Chemical and morphological analysis of soft tissue preservation in a mosasaur. Journal of Vertebrate Paleontology 22:75A. n Stewart, J. D., and V. Friedman. 2001, Oldest American records of Saurodontidae (Teleostei:

Ichthyodectiformes). Journal of Vertebrate Paleontology 21:104A. 238
Joe Stewart, Ph.D., page 4
n Stewart, J. D. 2000. Late Miocene ontogenetic series of true Carcharodon teeth. Journal of Vertebrate Paleontology 20:71A.
n Martin, L. D., and J. D. Stewart. 1999. Implantation and replacement of bird teeth. Smithsonian Contributions to Paleobiology 89:295-300.
n Stewart, J. D., and R. Raschke. 1999. Correlation of stratigraphic position with Isurus-Carcharodon tooth serration size in the Capistrano Formation and its implication for the ancestry of Carcharodon carcharias.

Journal of Vertebrate Paleontology 19:78A.
n Stewart, J. D. 1999. A new genus of Saurodontidae (Teleostei: Ichthyodectiformes) from the Upper Cretaceous rocks of the Western Interior of North America. P. 335-360 in: G. Arratia (ed.) Mesozoic Fishes – Systematics and the Fossil Record. Verlag Dr. Friedrich Pfeil, Munich. 576 p. n Fielitz, C., J. D. Stewart, and J. Wiffern. 1999. Aethocephalichthys hyrainarhinos n. gen. and n. sp., a new and enigmatic Late Cretaceous actinopterygian from North America and New Zealand. P. 95-106 in: G. Arratia (ed.) Mesozoic Fishes – Systematics and the Fossil Record.
n Barnes, L. G., M. Berkhoff, D. P. Domning, S. K. Jarvis, S. A. McLeod, E. D. Mitchell, R. E. Raschke, J. D. Stewart, C. C. Swift, and H. W. Thomas. 1999. The Middle Miocene Sharktooth Hill local fauna and paleoecology of the Sharktooth Hill Bonebed, Kern County, California. Paleobios 19:2A. n Stewart, J. D., and F. Govean. 1998. The first Cenozoic record of Symphurus (Pleuronectiformes:

Cynoglossidae) and the first North American Cenozoic cynoglossid fosils. Journal of Vertebrate Paleontology 18:79A-80A.
n Stewart, J. D., and S. B. Hunter. 1997. Deprandus lestes Jordan is a synonym of Thyrsocles velox (Jordan) (Teleostei: Perciformes) and is not an eel. Journal of Vertebrate Paleontology 17:79A. n Cumbaa, S. L., T. T. Tokaryk, C. Collom, J. D. Stewart, T. S. Ercit, and R. G. Day. 1997. A Cenomanian age bond bed of marine origin, Saskatchewan, Canada. Journal of Vertebrate Paleontology 17:40A. n Schwimmer, D. R., J. D. Stewart, and G. D. Williams. 1997. Xiphactinus vetus and the distribution of Xiphactinus species in the eastern United States. Journal of Vertebrate Paleontology 17:610-615. n Stewart, J. D. 1997. Nuevos peces del Miocene Tario de la Formación Almejas de Isla Cedros, Baja California, México. [New late Miocene fishes from the Almejas Formation of Cedros Island, Baja California, Mexico.] Abstract, Memorias de la IV Réunion Intermational sobre Geologia de la Peninsula de Baja California, Ensenada, Baja California, México, 6-9 April, 1997.
n Schwimmer, D. R., J. D. Stewart, and G. D. Williams. 1997. Scavenging by sharks of the genus Squalicorax in the late Cretaceous of North America. Palaios 12:71-83. n Stewart, J. D. 1996. Cretaceous acanthomorphs of North America. P. 383-394 in: Arratia, G., and G. Viohl (eds,), Mesozoic Fishes – Systematics and Palaeoecology, Verlag Dr. Friedrich Pfeil, Munich. 576 p. 382-294 n Stewart, J. D. 1996. The validity of Saurodon pygmaeus Loomis 1900 (Teleostei: Ichthyodectiformes) and its relationship to other Ichthyodectiformes. Journal of Vertebrate Paleontology 16(3):67A. n Feige, S. F., and J. D. Stewart. 1996. Preliminary findings concerning increase in size through time of the clupeiform teleost, Xyne grex. San Bernardino County Museum Association Quarterly 43:149. n Stewart, J. D., and J. E. Martin. 1996. Osteichthyes of the Turonian deposits in the Ortonville-Milbank Granite Quarries, Grant County, South Dakota. Geological Society of America Abstracts With Programs 28(4):39. n Schwimmer, D. R., J. D. Stewart, and G. D. Williams. 1995. Evidences of scavenging by selachian genus Squalicorax in the Late Cretaceous of North America. Geological Society of America Abstracts with Programs 2:A368.
n Stewart, J. D. 1995. Confirmation of pomatomid affinities of Pseudoseriola David (Teleostei: Percifrormes).

Journal of Vertebrate Paleontology 15:54A-55A.
n Everhart, M. J., P. A. Everhart, and J. D. Stewart. 1995. Notes on the biostratigraphy of a small coelacanth from the Smoky Hill Member of the Niobrara Chalk (Upper Cretaceous) of western Kansas. Abstracts, Kansas Academy of Science 14:18.
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n Alexander, C. K., S. Feige, D. Foley, E. Topping, D. K. Valdez, and J. D. Stewart. 1995. Temporal trends in fossil guitarfish Rhinobatos teeth from Upper Cretaceous rocks of the U. S. Western Interior. Journal of Student Research 1:99.
n Stewart, J. D, S. A. Bilbey, D. J. Chure, and S. K. Madsen. 1994. Vertebrate fauna of the Mowry Shale (Cenomanian) in northeastern Utah. Journal of Vertebrate Paleontology 14:47A. n Schwimmer, D. R., J. D. Stewart, and D. Williams. 1994. Giant fossil coelacanths from the Late Cretaceous in the Eastern United States. Geology 22:503-506. Stewart, J. D., and G. L. Bell, Jr. 1994. North America's oldest mosasaurs are teleosts. Los Angeles County Museum of Natural History Contributions in Science 441:1-9. n Hunter, S. B., and J. D. Stewart. 1994. Resurrection of Sarda stocki David, 1943. Paleobios 16:9. n Stewart, J. D., and J. E. Martin. 1993. Late Cretaceous selachians and associated marine vertebrates from the Dakota Rose Granite Quarry, Grant County, South Dakota. Proceedings of the South Dakota Academy of Sciences 72:241-248.
n Stewart, J. D., and J. E. Martin. 1993. A snowshoe hare, Lepus americanus, from the Lange Ferguson Clovis Kill Site, Shannon County, South Dakota. Current Research in the Pleistocene 10:110-112. n Stewart, J. D. 1993. A skeleton of Platecarpus sp. (Lacertilia: Mosasauridae) with stomach contents and extensive integument. Journal of Vertebrate Paleontology 13:58A-59A. n Stewart, J. D. 1993. The case of the sword-swallowing shark. Terra 31:42-43. n Stewart, J. D., and M. Roeder. 1993. Razorback sucker (Xyrauchen) fossils from the Anza Borrego Desert and the Ancestral Colorado River. Special Publication of the San Bernardino County Museum Association 93:94-96. n Stewart, J. D., and F. J. Aranda-Manteca. 1993. Nuevos teleosteos del Miembro Los Indios de la Formacion Rosarito Beach, Baja California (new teleosts from the Los Indios member of the Rosarito Beach Formation, Baja California). lI Reunion Internacional de Geologia de la Peninsula de Baja California, p. 79. n Barradas, H., and J. D. Stewart. 1993. Posible contenido estomacal de un pinipedo del Mioceno Medio de la Mision, Baja California, México (Possible Middle Miocene pinniped gut contents from La Mision, Baja California, Mexico). II Reunion Internacional de Geologia de la Peninsula de Baja California, p. 24-25. n Stewart, J. D. 1992. First Mississippi records of Holocentrites ovalis (Beryciformes: Holocentridae), and confirmation of its myripristin affinities. Journal of Vertebrate Paleontology 12:53A. n Schwimmer, D. R., J. D. Stewart, and D. Williams. 1992. Late Cretaceous Xiphactinus fossils in eastern United States are not necessarily X. audax. Journal of Vertebrate Paleontology 12:51A. n Stewart, J. D., and J. M. Harris. 1992. Acquisitions. Terra 30:44-45. n Schwimmer, D. R., J. D. Stewart, and D. Williams. 1991. Upper Cretaceous coelacanths in eastern Alabama:
suggestion of a Gondwanan-Eastern Gulf lineage. Abstract, Geological Society of America Abstracts with Programs 23:A169.
n Stewart, J. D., P. A. Everhart, and M. J. Everhart. 1991. Small coelacanths from Upper Cretaceous rocks of Kansas. Abstract, Journal of Vertebrate Paleontology 11:56A. n Stewart, J. D. 1991. Fossil teeth tell part of the story. Terra 30:34-35. n Espinosa-Arrubarena, L. G. Barnes, S. P. Applegate, S. A. McLeod, F. J. Aranda-Manteca, and J. D. Stewart. 1991. Depredadores y mamiferos marinos: la evidencia del registro fosil. Programa y Resumenes, Abstracts, XVI Reunion Internacional para el Estudio de los Mamiferos Marinos, Nuevo Vallarta, Nayarit, México, p. 5 n Stewart, J. D. 1990. Niobrara Formation symbiotic fish in inoceramid bivalves, p. 31-41 in: S. C. Bennett (ed.), Niobrara Chalk Excursion Guidebook. Kansas Geological Survey, Lawrence. n Stewart, J. D. 1990. Niobrara Formation vertebrate stratigraphy. P. 19-30 in: S. C. Bennett (ed.), Niobrara Chalk Excursion Guidebook. Kansas Geological Survey, Lawrence. n Stewart, J. D., C. Bennett, and R. J. Zakrzewski. 1990. Road log from Lawrence to the type area of the Niobrara Chalk, October 9-10, 1990. p. 3-12 in: S. C. Bennt (ed), Niobrara Chalk Excursion Guidebook. Kansas Geological Survey, Lawrence.
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Joe Stewart, Ph.D., page 6
n Stewart, J. D. 1990. Niobrara Formation vertebrate biostratigraphy. Journal of Vertebrate Paleontology 10:44A.
n Stewart, J. D. 1990. Niobrara Formation symbiotic fish in inoceramid bivalves. Journal of Vertebrate Paleontology 10:44-44A.
n Stearley, R. F., and J. D. Stewart. 1990. Phylogenetic significance of Onchorhynchus rastrosus. Journal of Vertebrate Paleontology 10:43A.
n Schwimmer, D., J. D. Stewart, and G. D. Williams. 1990. A giant Upper Cretaceous coelacanth form eastern Alabama. Journal of Vertebrate Paleontology 10:41A.
n Stewart, J. D., and K. Carpenter. 1990. Examples of vertebrate predation on cephalopods in the Late Cretaceous of the Western Interior. p. 203-207 in: A. J. Boucot (ed.), Evolutionary paleobiology of behavior and evolution. Elsevier.
n Stewart, J. D. 1990. Examples of Late Cretaceous commensalism from Kansas. p. 51-57 in: A. J. Boucot (ed.), Evolutionary paleobiology of behavior and evolution. Elsevier. n Stewart, J. D. 1989. Paleontology and paleoecology of the 1987 excavation of the North Cove Site, 25HN164. p. 63-106 in: M. J. Adair (ed.), Archaeological investigations at the North Cove Site, Harlan County Lake, Harlan County Nebraska. Report submitted to U. S. Army Corps of Engineers, Kansas City District, CACW41-86-0167, Modification P00003.
n Stewart, J. D., and G. Bell, Jr. 1989. The earliest North American mosasaur records are not mosasaurs. Journal of Vertebrate Paleontology 9:39A.Coney, C. C., and J. D. Stewart. 1989. Comparative shell morphometrics in some related species of fossil and Recent Gastrocopta (Pulmonata: Pupillidae). The Western Society of Malacologists Annual Report 22:10.
n Anonymous. 1989. The fossil fish that almost got away. Terra 27(5-6):48. n Whistler. D. W., and J. D. Stewart. 1989. A Late Pleistocene (Rancholabrean) assemblage from the northwestern Mojave Desert. San Bernardino County Museum Quarterly 36:67-68. n Stewart, J. D. 1988. Paleoecology and the first North American West Coast record of the shark genus Ptychodus. Journal of Vertebrate Paleontology 8:27.
n Stewart, J. D. 1988. Stratigraphic distribution of Cretaceous Protosphyraena in Kansas and Alabama. Fort Hays Studies, third series, Science series, no 10:80-94.
n Stewart, J. D. 1987. Paleontology and paleoecology of the North Cove Site, 25HN164. p. 298-335 in: M. J. Adair and K. L. Brown (eds.), Prehistoric and Historic Cultural Resources of Selected Sites at Harlan County Lake, Harlan County, Nebraska. Report submitted to U. S. Army Corps of Engineers, Kansas City District. n Stewart, J. D. 1987. Late Cretaceous fish-pelecypod symbiosis. Ningxia Geology 1:14-17. n Stewart, J. D. 1987. Late Wisconsinan biota and artifacts from the Kansas-Nebraska border. Journal of Vertebrate Paleontology 7:27A.
n Wells, P. V., and J. D. Stewart. 1987. Cordilleran-boreal taiga and fauna on the Central Great Plains of North America, 14,000-18,000 years ago. American Midland Naturalist 118:94-106. n Stewart, J. D. 1987. Latitudinal effects in Wisconsinan mammalian faunas of the Plains. p. 153-158 in: W. C.

Johnson (ed.), Quaternary environments of Kansas. Kansas Geological Guidebook Series 5. n Wells, P. V., and J. D. Stewart. 1987. Spruce charcoal, conifer macrofossils, and landsnail and small-vertebrate faunas in Wisconsinan sediments on the High Plains of Kansas. p. 129-140 in: W. C. Johnson (ed.), Quaternary environments of Kansas. Kansas Geological Guidebook Series 5. n Martin, L. D., W. V. Koenigswald, and J. D. Stewart. 1986. Pleistocene Phenacomys from Kansas and the fossil history of the genus. Transactions of the Nebraska Academy of Science 14:35-39. n Johnson, W. C., G. G. Fredlund, P. V. Wells, J. D. Stewart, and W. Dort Jr. 1986. Late Wiconsinan biogeography of south central Nebraska: the North Cove site. American Quaternary Association – Program and Abstract of the ninth biennial meeting, p. 89.
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n Cross, F. B., R. L. Mayden, and J. D. Stewart. 1986. Fishes in the western Mississippi drainage. P. 363-412 in:

C.H. Hocutt and E. O. Wiley, (eds.), Zoogeography of North American Freshwater Fishes. Wiley and Sons, New York.
n Dort, W. Jr., W. C. Johnson, G. G. Fredlund, R. A. Rogers, L. D. Martin, J. D. Stewart, and P. V. Wells. 1985.

Evidence for an open conifer woodland in the Central Great Plains during the Late Wisconsin glacial maximum.

Abstract, Canadian Quaternary Association Abstracts, p. 23. Lethbridge. n Johnson, W. C., L. D. Martin, W. Dort, Jr., C. J. Sorensen, R. A. Rogers, and J. D. Stewart. Evidence for a pine parkland in Central and Western Kansas and adjacent Nebraska during Mid- and Late-Wisconsinan time.

TER-QUA Symposium Series 1:197.
n Martin, L. D., and J. D. Stewart. 1985. Homologies in the avian tarsus. Nature 315:159. n Stewart, J. D. 1984. The montane vole in the Late Pleistocene of the Plains. Annual Plains Conference, Programs and Abstracts p.41-42.
n Stewart, J. D. 1984. Taxonomy, paleoecology, and stratigraphy of the halecostsome-inoceramid associations of the North American Upper Cretaceous epicontinental seaways. Ph.D. dissertation, University of Kansas, Lawrence, 201 p.
n Stewart, J. D., and L. D. Martin. 1984. Bird teeth and avian origins. One hundred second stated meeting of the American Ornithologists' Union: Abstracts no. 95.
n Martin, L. D., and J. D. Stewart. 1984. The avian pretibial bone and the relationship between ratites and carinates. One hundred second stated meeting of the American Ornithologists' Union: Abstracts no. 13. n Stewart, J. D. 1984. Snowshoe hare, Lepus americanus, from the Peoria Loess of Kansas. Abstracts, Kansas Academy of Science 3:39.
n Stewart, J. D., and R. A. Rogers. 1984. Analysis of pollen from the Trapshoot local fauna quarry (Rancholabrean) of Kansas. American Midland Naturalis 112:198-200.
n Schultze, H.-P., J. D. Stewart, A. M. Neuner, and P. M. Coldiron. 1982. Type and figured specimens of fossil vertebrates in the collection of the University of Kansas Museum of Natural History. Part I. Fossil Fishes.

Miscellaneous Publications of the University of Kansas Museum of Natural History No. 73, 53 p. n Martin, L. D., and J. D. Stewart. 1982. An ichthyornithiform bird from the Campanian of Canada. Canadian Journal of Earth Sciences 19:324-327.
n Stewart, J. D. 1982. Actinopterygian – pelecypod commensalism in Kansas Cretaceous deposits. Abstracts, Kansas Academy of Science 1:52-53.
n Wiley, E. O., and J. D. Stewart. 1981. Urenchelys abditus, the first undoubted eel from the Cretaceous of North America (Teleostei: Anguilliformes). Journal of Vertebrate Paleontology 1:43-47. n Stewart, J. D. 1980. Reevaluation of the phylogenetic position of the Ptychodontidae. Transactions of the Kansas Academy of Science 83:154.
n Martin, L. D., J. D. Stewart, and K. N. Whetstone. 1980. The origin of birds: structure of the tarsus and teeth.

The Auk 97:86-93.
n Stewart. J. D. 1979. Paleontology and paleoecology of the Trapshoot local fauna, Rooks County, Kansas. M.A. thesis, University of Kansas, Lawrence. 146 p.
n Stewart, J. D. 1979. A new Late Blancan local fauna from Rooks County, Kansas. Transactions of the Kansas Academy of Science 82:100.
n Stewart, J. D. 1979. Biostratigraphic distribution of species of Protosphyraena (Osteichthyes: Actinopterygii) in the Niobrara and Pierre formations of Kansas. Proceedings of the Nebraska Academy of Sciences and Affiliated Societies 1979:51-52.
n Stewart, J. D. 1978. Mammals of the Trapshoot local fauna, Late Pleistocene of Rooks County, Kansas.

Proceedings of the Nebraska Academy of Sciences and Affiliated Societies 1978:45-46. n Stewart, J. D. 1978. Earliest record of the Toxochelyidae. Transactions of the Kansas Academy of Sciences 81:9-16.
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n Stewart, J. D. 1978. Enterospirae (fossil intestines) from the Upper Cretaceous Niobrara Fromation of western Kansas. Kansas University, Paleontological Contributions paper 89:9-16. n Wiley, E. O., and J. D. Stewart. 1977. A gar (Lepisosteus sp.) from the marine Cretaceous Niobrara Formation of western Kansas. Copeia 1977:761-762.
n Martin, L. D., and J. D. Stewart. 1977. Oldest (Turonian) mosasaurs from Kansas Journal of Paleontology 51:973-975.
n Martin, L. D., and J. D. Stewart. 1977. Teeth in Ichthyornis (Class: Aves). Science 195:1331-1332. n Stewart, J. D. 1976. Teuthids of the North American Late Cretaceous. Transactions of the Kansas Academy of Science 79:94.
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Appendix G
Policy Consistency Memorandum
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A

PROJECT MEMORANDUM
Date: January 15, 2024
To: Robert Montaghami, Fire Marshal, Laguna Beach Fire Department From: Avery Robinson, Environmental Scientist
Subject: Lower Hobo and Diamond Crestview Fuel Modification Project The City of Laguna Beach Fire Department (LBFD) proposes to apply fuel management practices within the City of Laguna Beach, California. The project would include two fuel management zones (FMZs) within the City of Laguna Beach. FMZ 16 (Lower Hobo) measures approximately 13.7 acres and predominantly borders residential single-family and mobile home communities along Nyes Place, Ashton Drive, Alexander Road, Terry Road, Laguna Terrace North, M Street, and K Street as well as the Laguna Beach Community and Recreation Center and Laguna Beach Fire Department administrative offices. FMZ 19 (Diamond Crestview) consists of approximately 25.4 acres bounded by Diamond Street to the west, Summit Drive to the north, and La Mirada Street and Alta Vista Way to the east and is surrounded by residential single-family homes. Both FMZs would be within the jurisdiction of the City of Laguna Beach and planning boundary for the City of Laguna Beach General Plan, except for the southwestern section of FMZ 19 which is within the City of Laguna Beach’s specific planning area for the Diamond/Crestview subdivisions and the southeastern section of FMZ 19 which is within the City’s specific planning area for the Arch Beach Heights subdivision.

This technical memorandum demonstrates the proposed project’s consistency with the California Coastal Act, City of Laguna Beach Local Coastal Program (City of Laguna Beach, 2023), Diamond/Crestview Specific Plan (City of Laguna Beach, 2010), and Arch Beach Heights Specific Plan (City of Laguna Beach, 2023b) that provide policies for managing and monitoring the lands associated with the proposed project.

California Coastal Act
The California Coastal Act establishes a comprehensive approach to govern land use planning along the entire California coast. The coastal zone is defined in Section 30103 of the Coastal Act as the following:
(a) "Coastal zone" means that land and water area of the State of California from the Oregon border to the border of the Republic of Mexico . . . extending seaward to the state's outer limit of jurisdiction, including all offshore islands, and extending inland generally 1,000 yards from the mean high tide line of the sea. In significant coastal estuarine, habitat, and recreational areas it extends inland to the first major ridgeline paralleling the sea or five miles from the mean high tide line of the sea, whichever is less, and in developed urban areas the zone generally extends inland less than 1,000 yards (California Coastal Commission, 2023).

The Coastal Act sets forth general policies (Public Resources Code Section 30200 et seq.) that are used by the California Coastal Commission (Coastal Commission) to review permit applications and local plans. Development activities within the coastal zone generally require a coastal permit. In the case of recreational facilities, Section 30600 of the Coastal Act states:
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(a) Except as provided in subdivision (e), and in addition to obtaining any other permit required by law from any local government or from any state, regional, or local agency, any person, as defined in Section 21066, wishing to perform or undertake any development in the coastal zone, other than a facility subject to Section 25500, shall obtain a coastal development permit (CDP) (California Coastal Commission, 2021).

In addition to the regulatory oversight of the Coastal Commission, Coastal Act policies are implemented through the preparation of Local Coastal Programs (LCPs) by the cities and counties located in whole or in part within the coastal zone. LCPs include a land use plan and a local implementation program that specify the relevant planning policies and zoning ordinances specific to the coastal zone within that jurisdiction. Once an LCP is certified, coastal development permit authority is delegated to the appropriate local government, except for certain specific lands for which the Coastal Commission retains original permit jurisdiction (City of Laguna Beach, 2020).

The proposed fuel modification activities would primarily occur within the planning boundary of the City of Laguna Beach LCP. Figures 2 and 3 in the Initial Study illustrate the location of specific fuel modification activities within FMZ 16 and FMZ 19.

The entire City of Laguna Beach is encompassed within the coastal zone, except for the Sycamore Hills area (City of Laguna Beach, 2012). The City’s LCP constitutes the following planning and policy documents, and any amendments to these documents require Coastal Commission approval as LCP Amendments (City of Laguna Beach, 2012; City of Laguna Beach, 2023):
 Coastal Land Use Plan Technical Appendix
 Laguna Beach General Plan Land Use Map
(excluding Blue Lagoon and Three Arch Bay)
 Laguna Beach Zoning Map
 General Plan Land Use and Zoning Map
Amendments
 Laguna Beach General Plan Land Use and
Open Space-Conservation Elements
 Post-LCP Certification Permit and Appeal
Jurisdiction
 Downtown Specific Plan
 Laguna Canyon Annexation Specific Plan
 Treasure Island Specific Plan
 Title 12.08 (Preservation of Heritage Trees
Ordinance)
 Title 14.78 (Geology Reports - Preparation
and Requirements Ordinance)
 Title 16 (Water Quality Control)
 Title 21 (Plats and Subdivision)
 Title 22 (Excavation and Grading)
 Title 25 (Laguna Beach Zoning Code, including
the Coastal Development Permit Ordinance)
 Shoreline Protection Guidelines (as adopted
by Resolution 88.43)
 Design Guidelines- A Guide to Residential
Development
 Design Guidelines for Hillside Development
(as adopted by Resolution 89.104)
 South Laguna Community Design and
Landscape Guidelines (as adopted by
Resolution 89.104)
 Fuel Modification Guidelines of the Laguna
Beach Safety General Plan Element (as
adopted by Resolution 89.104)
 Summer Festival Parking Agreements.

The City of Laguna Beach LCP was certified in 1993, and an amendment to the LCP was certified in 2004.

The certified LCP provides permitting authority to the City of Laguna Beach within its respective coastal zone.
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California Coastal Act Consistency Determination
The proposed fuel modification activities would be consistent with the California Coastal Act based on the following review of this project with respect to the Coastal Act and the City of Laguna Beach LCP.

This discussion identifies the applicable requirements from the Coastal Act along with the relevant policies from the City’s LCP, Diamond/Crestview Specific Plan, and Arch Beach Heights Specific Plan and provides a justification for project consistency with each.

Article 3: Recreation Policies
Coastal Act Section 30223
“Upland areas necessary to support coastal recreational uses shall be reserved for such uses, where feasible.”
Laguna Beach General Plan: Land Use Element
 Policy 7.1: Protect dedicated and accepted open space.

Justification for Fuel Break Activities. The fuel modification activities in FMZ 16 and FMZ 19 would increase protection, reduce fire intensity and flame length, and reduce potential for wildfire to spread to residential, institutional, public, and valuable recreational areas. These activities are consistent with the Coastal Act Section 30223 regarding protection and support of coastal recreational uses. They are also consistent with the Laguna Beach General Plan (Policy 7.1) regarding protection of open space.

Article 5: Land Resource Policies
Coastal Act Section 30240
“a) Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values, and only uses dependent on those resources shall be allowed within those areas. (b) Development in areas adjacent to environmentally sensitive habitat areas and parks and recreation areas shall be sited and designed to prevent impacts which would significantly degrade those areas, and shall be compatible with the continuance of those habitat and recreation areas.” Laguna Beach General Plan: Land Use Element
 Policy 2.6: Require the preservation of significant trees in conjunction with development proposals.

The Design Review Board may grant exceptions to this provision when its strict enforcement would deny a property owner reasonable use of his/her property.  Policy 7.6: Implement individualized fuel modification programs for existing legal building sites whenever environmentally sensitive resources are present.

Laguna Beach General Plan: Open Space/Conservation Element  Policy 8C: Identify and maintain wildlife habitat areas in their natural state as necessary for the preservation of species.
 Policy 8G: Detailed biological assessments shall be required for all new development proposals, including all subdivisions and fuel modification proposals, located within or adjacent to areas 247
Lower Hobo and Diamond Crestview Fuel Modification Project

designated high or very high value on the Biological Values Map. Such biological assessments shall utilize the biological value criteria specified in the Biological Resources Inventories (1983, 1992 and 1993).
 Policy 8N: Prohibit intrusion of fuel modification programs into environmentally sensitive areas, including chaparral and coastal sage scrub.

Diamond/Crestview Specific Plan
Vegetation and Wildlife Resources Policies
 1. Protect, preserve and restore streams, watercourses and riparian habitats in their natural state.  2. Protect mule deer watershed, cross-ridge dispersion corridors, and major bedding, fawning and foraging areas to the greatest extent feasible.
 3. Promote the preservation of corridor connections north and south to link preserved lands onsite with the large off-site open spaces of Upper Bluebird/Rancho Laguna and Arch-Porta-Fina Canyons for maintenance of animal migration opportunities.
 6. Protect endangered and candidate species of plants and animals.  7. Protect significant mature vegetation.
 8. Protect high and very high value habitats.

Justification: Appendix A to the Initial Study includes a comprehensive list of the treatment protocols for fuel modification zones within the coastal zone. The fuel modification actions would follow strict vegetation removal protocols based on the sensitivity of species found in the FMZs, utilizing careful hand crew treatment to avoid and preserve sensitive species in a Moderate or High Value Habitat area.

This procedure would ensure consistency with Coastal Act Section 30240, the Laguna Beach General Plan (Policies 7.6, 8C, 8G, and 8N), and Diamond/Crestview Specific Plan (Vegetation and Wildlife Policies 1, 2, 3, 6, 7, and 8).

Some areas within FMZ 16 and FMZ 19 are moderately disturbed by non-native and invasive annual species, rendering removal necessary for both fire protection and invasive management. In these areas, hand crews would remove the majority of non-native plants (non-native roots may remain in erosionprone areas to minimize erosion), and in some instances, herbicide may be applied as spot treatments for non-native and/or invasive plants when necessary. Surveys by professional biologists have been completed to determine prescribed treatments for areas within each FMZ based on the species surveyed. Healthy native trees within the FMZs would not be removed, but simply pruned to clear dead branches and any other flammable material. Targeted removal of non-native and/or invasive species would be conducted within and surrounding the zones, consistent with Laguna Beach General Plan Policy 2.6 and Diamond Crestview Specific Plan Vegetation and Wildfire Resources Policies 6 and 8.

These individualized treatments ensure that the project would be consistent with the aforementioned policies. Furthermore, continuing existing fire control methods, encouraging cooperation among residents, and annually monitoring FMZs would be consistent with Laguna Beach General Plan Policy 2.6 and Diamond Crestview Specific Plan Vegetation and Wildfire Resources Policies.

Coastal Act Section 30244
“Where development would adversely impact archaeological or paleontological resources as identified by the State Historic Preservation Officer, reasonable mitigation measures shall be required.” 248
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Laguna Beach General Plan: Open Space/Conservation Element  Policy 12D: Preserve cultural/scientific sites, including geologically unique formations having archaeological significance.

Diamond/Crestview Specific Plan
Historic Preservation Policies
 1. Encourage the preservation of historic structures through the City's Historic Preservation Ordinance  2. Inventory the neighborhood for significant historic structures.

Justification: The project would utilize the treatment protocols listed in Appendix A to the Initial Study, which require that FMZ 16 and FMZ 19 be evaluated for archaeological and paleontological resources in accordance with CEQA requirements. Per these treatment protocols, areas determined to have a presence of identified archaeological and/or paleontological resources may require modification or elimination of fuels treatment. Site-specific evaluations have been documented in Appendix D and Appendix F to the Initial Study, and no cultural and paleontological resources were found in FMZ 16 or FMZ 19 where surveys were feasible. Additionally, a Worker Environmental Awareness Training would be completed for cultural resources prior to project implementation, and a qualified archaeological monitor would be present when vegetation removal occurs on slopes less than 30 degrees to avoid impacts to unidentified potential cultural resources. A professional archaeologist would also be available on-call to identify and evaluate any previously unidentified cultural resources discovered during construction activities, and avoidance measures would be implemented. If human remains, or potential human remains are discovered, construction activities within 100 feet of the find would be immediately halted and the appropriate responsible public agency and the County Coroner would be immediately notified. These measures would ensure project consistency with Coastal Act Section 30244, the Laguna Beach General Plan (Policy 12D), and the Diamond Crestview Specific Plan Historic Preservation policies.

Article 6: Development Policies
Coastal Act Section 30251
“The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance. Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural landforms, to be visually compatible with the character of surrounding areas, and, where feasible, to restore and enhance visual quality in visually degraded areas. New development in highly scenic areas such as those designated in the California Coastline Preservation and Recreation Plan prepared by the Department of Parks and Recreation and by local government shall be subordinate to the character of its setting.” Laguna Beach General Plan: Land Use Element
 Policy 3.9: Maintain the landscape guidelines set forth in the City’s Landscape and Scenic Highways Resource Document.

Laguna Beach General Plan: Open Space/Conservation Element  Policy 7G: The Design Review process for an individual project shall include criteria for treatment of the urban edge between existing development and open space in areas designated 249
Lower Hobo and Diamond Crestview Fuel Modification Project

“Residential/Hillside Protection” on the Land Use Plan Map. The criteria shall be developed to reflect topographic constraints and shall include at a minimum:
a. Treatments to screen development, including the use of vegetation, variable setbacks and modified ridgelines or berms;
b. Fuel modification techniques for new development which provide the following: result in graduated fuel modification zones in which the minimum amount of native vegetation is selectively thinned; prohibit grading or discing for fuel modification; confine fuel modification to the development side of the urban open space edge to the maximum extent; avoid fuel modification encroachment into environmentally sensitive areas; locate structures with respect to topographic conditions to incorporate setbacks, minimize fuel modification requirements and maximize hazards; and provide requirements for ongoing maintenance.
c. Treatments for fuel modification and maintenance techniques for existing development consistent with standards in (b) above to the maximum extent feasible.

Justification: The fuel modification project is consistent with Coastal Act Section 30251 and the Laguna Beach General Plan (Policies 3.9 and 7G). FMZ 16 and FMZ 19 are located directly along the wildlandurban interface along residential and institutional development. Urban structures adjacent to undeveloped land are considered at high risk during fire season due to their proximity to heavily vegetated hillsides and steep slopes. The fuel breaks would provide defensible space for structures in the City of Laguna Beach from heavy-load chaparral fuels, reduce potential wildfire intensity and flame length, and reduce the risk of wildfire from spreading to high value habitat. Fuel modification activities would only occur within their respective zones and be limited to 100-foot widths. Once fuel breaks are established, annual maintenance of approved methods (mowing and hand crew removal in appropriate locations) would occur. Furthermore, consistent with Policy 7G, the proposed project would target full removal of non-native species, with selective thinning of native vegetation and avoidance of sensitive and rare species such as Coulter’s Matilija poppy and big-leaved crownbeard.

Coastal Act Section 30253
“New development shall do all of the following:
(a) Minimize risks to life and property in areas of high geologic, flood, and fire hazard. (b) Assure stability and structural integrity, and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding area or in any way require the construction of protective devices that would substantially alter natural landforms along bluffs and cliffs. (c) Be consistent with requirements imposed by an air pollution control district or the State Air Resources Board as to each particular development.
(d) Minimize energy consumption and vehicle miles traveled. (e) Where appropriate, protect special communities and neighborhoods that, because of their unique characteristics, are popular visitor destination points for recreational uses.” Laguna Beach General Plan: Land Use Element
 Policy 9.3: Ensure that the City is adequately prepared for potential hazards and natural disasters. 250
Lower Hobo and Diamond Crestview Fuel Modification Project

 Policy 10.6: Require all fuel modification to be located within the site being developed. Exceptions may be granted for existing legal building sites when findings can be made by the approval authority that other alternatives are not available, and a strict application of this provision would endanger environmentally sensitive resources or deny a property owner reasonable use of an already existing legal building site. Fuel modification performed by private property owners cannot go beyond property lines without agreement by the adjacent property owners. Fuel modification on public land to protect existing development should be avoided whenever feasible; if avoidance isn’t feasible, measures must be employed to minimize the amount of fuel modification necessary on public land.

Laguna Beach General Plan: Open Space/Conservation Element  Policy 10G: Fuel modification plans, where appropriate shall be included within the boundary of the developed land use zone.

Laguna Beach General Plan: Safety Element
 Policy 4B: Review and continually maintain each year the City’s fuel modification program.  Policy 4C: Work with adjacent local jurisdictions and agencies on the ongoing implementation of the City’s fuel modification program.
 Policy 4G: Educate and inform the public on fire safety, especially regarding landscaping installation and maintenance in urban areas, to further protect the community and the environment from unnecessary fire hazards.
 Policy 4H: Require that new development located within wildland interface areas reduce the threat of wildfires through fuel modification, fire resistive construction and defensible space management consistent with the following Fuel Modification Guidelines and in compliance with the Fuel Modification Exhibit (Figure IV-1):
(a) Prohibit combustible structures, including but not limited to wood decks, sheds, gazebos and wood fences, within the 20-foot minimum width of Zone A.
(b) Require irrigation systems to be installed and operated within Zone A to ensure a reasonable moisture content in planted areas.
(c) Discourage the planting of trees and vegetation which produce excessive fuel or litter within Zone A.
 Policy 4N: As a condition of new development, require private responsibility for development and maintenance of fuel modification zones and programs, including a recorded deed restriction acknowledging the fire hazard potential and maintenance responsibility by the developer or his successors and assigns.
 Policy 4O: Encourage property owners to create defensible space surrounding their homes, including providing access for firefighters, maintenance of plantings and outdoor areas and minimizing combustible structures.
 Policy 4P: Encourage property owners to consider “fire-wise” planting, especially in landscapes in areas adjacent to the wildlands interface.
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Diamond/Crestview Specific Plan
Natural Hazards Policies
 1. Development in potential geologic hazard areas shall be permitted, only if a comprehensive geological and soils report is prepared pursuant to Title 22 of the City's Municipal Code, and adequate mitigation measures, which have been approved by the City, are implemented. Building in geologically unstable areas, flood-prone lands, and slopes subject to erosion and slippage should be avoided if at all possible.
 2. Require site-specific geotechnical investigation for all future development. These site investigations should include subsurface investigation, characterization of geological site conditions, analysis of slope stability, and recommendations for appropriate foundation and grading design.  4. Evaluate possible increased erosion along canyon bottoms and resultant destabilization of adjacent properties by undercutting of canyon side slopes on a site-specific basis.  5. Before development occurs, establish the capacity of downstream drainage systems and where necessary, construct off-site improvements so that downstream capacity is not adversely impacted.  6. Promote the use of fire protection techniques such as appropriate building materials, protective devices, interior and exterior sprinkler systems and fuel modification.  7. Assure emergency access at all times.
 8. Restrict pedestrian access to slopes steeper than 1 to 1 in order to safeguard health and safety by reducing slope erosion and falling hazards.
 9. Encourage the use of fire retardant and drought resistant landscaping that requires less water.

Justification: The project would utilize the treatment protocols listed in Appendix A to the Initial Study, which require that FMZ 16 and FMZ 19 be evaluated by a qualified geologist for geological stability and flood/debris movement potential. Per these treatment protocols, areas determined to be geologically unstable may require modification or elimination of fuels treatment. Site-specific evaluation has been documented in Appendix B to the Initial Study, and subsequent modifications to fuels treatment have been incorporated into the project as mitigation to avoid impacts resulting from geological instability or erosion and ensure project consistency with Coastal Act Section 30253.

The proposed project is consistent with the requirements of the Laguna Beach General Plan (Policies 4B and 4C) regarding annual maintenance of the City’s fuel modification program and coordinating with local jurisdictions and agencies. FMZ 16 and FMZ 19 would be annually maintained into perpetuity using approved methods to control invasive vegetation. Furthermore, the proposed fuel modification satisfies the requirements of the Laguna Beach General Plan (Policies 9.3, 10.6, 10G, 4G, 4H, 4N, 4O, and 4P) and Diamond/Crestview Specific Plan Natural Hazards Policies 6 and 9 regarding increasing safety from fire hazards and creating defensible space around development. FMZ 16 and FMZ 19 would be located around development that is vulnerable to wildfire hazards, as the surrounding environment consists of heavily vegetated steep topography. FMZ 16 and FMZ 19 would provide defensible space between manmade structures and wildfires, reducing thermal outputs and flame lengths. Additionally, the proposed fuel modification is consistent with the Diamond/Crestview Specific Plan (Natural Hazards Policies 1, 2, 4, 5, 7, and 8) regarding identifying geologic hazards and establishing precautions and maintaining drainage system capacity and emergency access. 252
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References
California Coastal Commission. 2023. Public Resources Code Division 20, California Coastal Act. [online]:
https://www.coastal.ca.gov/coastact.pdf. Accessed October 12, 2023.

City of Laguna Beach. 1992. Resolution No. 92.014: A Resolution of the City Council of the City of Laguna Beach Approving and Adopting its Local Coastal Program Pursuant to the California Coastal Act of 1976. Adopted February 18. [online]: http://www.lagunabeachcity.net/civicax/filebank/ blobdload.aspx?t=41949.64&BlobID=23490. Accessed December 12, 2023. _____. City of Laguna Beach. 2010. Diamond/Crestview Specific Plan. Accessed November 11, 2023. [Online]:
https://www.lagunabeachcity.net/home/showpublisheddocument/260/637360447937670000. _____. 2012. City of Laguna Beach General Plan, Land Use Element. Adopted by the City Council on February 7, 2012. [online]:
https://www.lagunabeachcity.net/home/showpublisheddocument/8146/638001338428230000 . Accessed October 12, 2023.
_____. 2020. Informational Guide for a Coastal Development Permit. Revised December 30. [online]:
http://www.lagunabeachcity.net/civicax/filebank/blobdload.aspx?blobid=8761. Accessed October 15, 2023.
_____. 2023a. City of Laguna Beach Local Coastal Program. [online]:
https://www.lagunabeachcity.net/government/departments/communitydevelopment/planning-zoning/land-use-plans/local-coastal-program. Accessed October 16. _____. 2023b. Arch Beach Heights Specific Plan. Accessed November 7, 2023. [Online]:
https://ecode360.com/42900648?highlight=&searchId=8385970954419183#42900650. 253
Response to Comments
State Clearinghouse No. 2024090959
Lower Hobo and Diamond
Crestview Fuel Modification Projects
Prepared for:

City of Laguna Beach
Robert Montaghami, Laguna Fire Department
505 Forest Avenue
Laguna Beach, California 92651
949.497.0352
Prepared by:

Aspen Environmental Group
Contact: Lisa Blewitt, Project Manager
5020 Chesebro Road, Suite 200
Agoura Hills, California 91301
818.338.6759
January 2025
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Contents

1. Introduction ................................................................................................................ 1-1

1.1 Introduction............................................................................................................................. 1-1

1.2 Document Format.................................................................................................................... 1-1

1.3 CEQA Requirements Regarding Comments and Responses.................................................... 1-1

2. Response to Comments ............................................................................................... 2-1 Comment Set A1 – California Coastal Commission............................................................................ 2-2 Comment Set B1 – Matt Lawson........................................................................................................ 2-6 Comment Set B2 – Jerry Myers.......................................................................................................... 2-9 Comment Set B3 – Rebecca and Frank Visconti .............................................................................. 2-11 Comment Set B4 – J. Rex Theobald.................................................................................................. 2-13 Comment Set B5 – Evgeniy Krasko................................................................................................... 2-15 Appendix 1: Mitigation Monitoring and Reporting Program ....................................... App 1-1 255
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1. Introduction

1.1 Introduction
This document includes a compilation of the public comments received on the Lower Hobo and Diamond Crestview Fuel Modification Projects Mitigated Negative Declaration and Initial Study (collectively, “MND”; State Clearinghouse No. 2024090959) and City of Laguna Beach (City) responses to the comments.

Under the California Environmental Quality Act (CEQA), a lead agency has no affirmative duty to prepare formal responses to comments on a MND. The lead agency, however, should have adequate information in the record explaining why comments received do not affect the conclusion of the MND and that there are no potentially significant environmental effects. In the spirit of public disclosure and engagement, the City has responded to all written comments submitted during the 40-day MND public review period, which began September 20, 2024, and ended October 30, 2024.

1.2 Document Format
This document is organized as follows:

Section 1, Introduction. This section describes CEQA requirements and content of this document.

Section 2, Response to Comments. This section provides a list of agencies and individuals that commented on the MND (no comments from organizations were received), copies of comment letters received during the public review period, and individual responses to written comments. To facilitate review of the responses, each comment letter has been reproduced and assigned a number. Individual comments have been numbered for each letter, and the letter is followed by responses with references to the corresponding comment number.

Appendix 1, Mitigation Monitoring and Reporting Program. The Mitigation Monitoring and Reporting Program (MMRP) lists all the mitigation measures required for implementation of the project, the phase in which the measures would be implemented, and the enforcement agency responsible for compliance.

The monitoring program provides (1) a mechanism for giving the lead agency staff and decision makers feedback on the effectiveness of their actions; (2) a learning opportunity for improved mitigation measures on future projects; and (3) a means of identifying corrective actions, if necessary, before irreversible environmental damage occurs.

1.3 CEQA Requirements Regarding Comments and Responses
CEQA Guidelines Section 15204(b) outlines parameters for submitting comments on negative declarations and reminds persons and public agencies that the focus of review and comment should be “on the proposed finding that the project will not have a significant effect on the environment. If persons and public agencies believe that the project may have a significant effect, it should: (1) Identify the specific effect, (2) Explain why they believe the effect would occur, and (3) Explain why they believe the effect would be significant.”
CEQA Guidelines Section 15204(c) further advises, “Reviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered significant in the absence of substantial evidence.” 256
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Section 15204(d) also states, “Each responsible agency and trustee agency shall focus its comments on environmental information germane to that agency’s statutory responsibility.” Section 15204(e) states, “This section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section.” Finally, CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to potentially significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the environmental document. 257
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2. Response to Comments
This section provides all written comments received on the circulated MND and the City’s response to each comment.

Number
Reference Commenting Person/Agency
Date of
Comment
Page
Number
A1 California Coastal Commission October 24, 2024 2-2
B1 Matt Lawson October 5, 2024 2-6
B2 Jerry Myers October 8, 2024 2-9
B3 Rebecca and Frank Visconti October 10, 2024 2-11
B4 J. Rex Theobald October 19, 2024 2-13
B5 Evgeniy Krasko October 28, 2024 2-15
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Comment Set A1 – California Coastal Commission
A1-1
A1-2
A1-3
A1-4
A1-5
A1-6
A1-7
LGB FMZS 16 & 19 MND CCC STAFF COMMENTS
10/24/2024
The MND recognizes that a CDP from the CCC is required for the southern portion of FMZ 16 located in the Hobo Canyon ADC. If the applicant (LBFD) and City prefer, a single consolidated CDP can be processed by the CCC for the entirety of FMZ 16.

The MND does not recognize that at least portions of FMZ 19 fall within the CCC appeals jurisdiction as it appears to include area within 100’ of a watercourse (pdf p. 6 of MND states that approximately 2.82 acres of FMZ 19 fall within 25’ of a blue line drainage or stream).

Slight modifications to the Treatment Protocols document since approval the Treatment Protocols document pursuant to CDP 5-21-0641 appear to have occurred. Some ccc staff comments and questions are included in the version of the Treatment Protocol document included in the MND as Appendix A and attached to the 10/24/2024 ccc staff comment email.

MND pdf p. 6:

Fuel management methods would rely exclusively on hand crews due to the presence of special-status species and the steep topography.

Just confirming that for the proposed project in FMZs 16 & 19, no goats will be used, right?
MND pdf p. 7 (hand crew removal):
“b. Hand crew fuel modification conducted in High or Very High Value Habitat shall generally be limited to a width of 100 feet.”
Are there areas where vegetation removal would exceed 100’ in width? Where are these located? What would trigger the need for vegetation removal widths greater than 100’? Is there a maximum width beyond which fuel modification vegetation removal would not occur?
MND pdf p. 9, 3rd paragraph, 1st sentence:

Refers to the conclusion of the grant term. What “grant term” is this referring to? The CDP application should include, but I not limited to, the following:

Recent biological surveys of the FMZ areas.

A written explanation, by a qualified biologist, of plant removal hierarchy.

A written description and explanation, by a qualified biologist, of the basis for the proposed use of herbicide in drainage courses, prepared. 259
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Comment Set A1: California Coastal Commission (continued) A1-8
A1-9
A1-10
A1-11
A1-12
A1-13
A1-14

Will a biological monitor be present during all FMZ vegetation removal work? Or, if not, how will it be decided when one is required to be present? The MND indicates that there will be a 25-foot buffer from both edges of any blue-line ephemeral drainages or stream courses. How will the edges of the watercourses be determined? Will the buffer extend 25 feet away from the watercourse edge or will the 25 feet be taken from the centerline of the watercourse? Or is some other method proposed? A written explanation, prepared by a qualified biologist, describing how this buffer distance and location relative to the watercourse will be determined should be included with the CDP application.

If there are discrepancies between the project as described in the body of the MND and the Treatment Protocols included in Appendix A, which will take precedence? How much time is each FMZ vegetation removal activity expected to take? Is the subsequent maintenance expected to take less time? When is the expected timing of each FMZ vegetation removal activity expected to occur (time of year/season, outside nesting season, etc.)? How will the timing be determined? For what time period is the CDP being requested? Is it for a one year period only? Or in perpetuity, with annual or biannual maintenance, as with CDP 5-21-0641? Or something else?
The CDP application should include a Habitat Mitigation Plan to address unavoidable impacts to habitat, prepared by a qualified biological professional. Biological Mitigation Measure 10 requires preparation of an HMP for the FMZs project.

A project staging and storage plan should be provided with the CDP application.

Proof of legal ability to perform the work should be provided with the CDP application. A1-15 260
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Responses to Comment Set A1 – California Coastal Commission A1-1 The City prefers to process FMZ 16 under a single consolidated Coastal Development Permit.

A1-2 The Final IS/MND has been revised to clarify that the proposed project is within CCC’s appeals jurisdiction due to activities falling within 100 feet of a watercourse.

A1-3 Final IS/MND Appendix A has been revised to include the updated version of the Treatment Protocols for Fuel Modification Zones Subject to Coastal Development Permitting (City’s fuel modification treatment protocols).

A1-4 The proposed project does not include goat grazing or any other prescribed herbivory. Due to the steep topography and presence of special-status species in the project area, hand crews will be used exclusively.

A1-5 City’s revised fuel modification treatment protocols provide examples of instances where vegetation removal may exceed 100 feet in width (Final IS/MND Appendix A):

Exceptions to the 100-foot clearance may include when topographic conditions may accentuate wildfire behavior such as in steep gullies which may “chimney” or accentuate fire effects towards development. Other cases may include where islands of native vegetation are retained as buffers for sensitive species within the fuel modification zone and allow fuel continuity to exist that would allow wildfire to transition readily through the zone. In these or similar conditions, the fuel modification width may be extended to 150 feet when required to mitigate expected fire behavior on structures above the site.

A1-6 The “grant term” refers to the Federal Emergency Management Agency (FEMA) Hazard Mitigation Grant Program (HMGP). The City intends to finance the proposed project through the FEMA HMGP.

A1-7 The City will submit a CDP application that will include recent biological surveys of the Project area, a written explanation of plant removal hierarchy, and a written description of the basis for proposed use of herbicides, as requested. Per Mitigation Measure (MM) BIO-1, preconstruction surveys would be conducted. The City’s fuel modification treatment protocols include a plant hierarchy list for instances where there is still over 50 percent vegetative cover after removal of non-native plants and dead or dying material. The treatment protocols also include the basis for the prudent use of herbicides on invasive plant species.

A1-8 A biological monitor will not be present during all FMZ vegetation removal work. As recommended in MM BIO-1, the City shall assign a qualified biologist (Project Biologist) to the project to conduct pre-construction surveys (MM BIO-2). If any nesting birds, special-status plants, or other special-status species are found, the Project Biologist shall flag these areas for avoidance. In addition, per MM BIO-4, the Project Biologist shall be present as needed on the project site during vegetation clearing done by hand crews to document compliance with the avoidance and minimization measures and to provide guidance in avoiding or minimizing impacts to biological resources. The Project Biologist shall also conduct quarterly monitoring of the project site for 12 months after the completion of the fuel treatment. 261
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A1-9 The 25-foot blue-line buffer would be established on either side of the edges of the drainage or to the edge of riparian vegetation, whichever is a greater distance. A written explanation prepared by a qualified biologist describing these practices will be included with the CDP application.

A1-10 The Final IS/MND incorporates the most recent version of the City’s fuel modification treatment protocols as Appendix A. The Project Description has been revised to be consistent with the latest treatment protocols. All project activities are subject to the City’s fuel modification treatment protocols.

A1-11 Vegetation removal activities are anticipated to occur over approximately six months. Per MM GEO-1, fuel modification activities would be conducted in the spring and summer and allow for some re-establishment of the native canopy prior to the next rainy season. Maintenance activities would continue annually in perpetuity. Per the City’s fuel modification treatment protocols, fuel modification zones are subject to multiple treatments each year to maintain prescribed conditions. The number of annual treatments would vary and are determined by annual growth, seasonal conditions, and other factors and may be conducted as often as necessary to maintain fire prevention benefits. Per MM BIO-3, project activities shall be completed outside the nesting bird breeding season (between January 1 through September 1), or after a pre-construction nesting bird survey has been completed. If native birds are nesting on the site, then project activities shall be postponed until nesting is completed or the Project Biologist shall designated appropriate avoidance buffers around nests to protect nesting birds.

A1-12 The CDP is being requested in perpetuity, with maintenance of the FMZs anticipated to be performed annually.

A1-13 The CDP application will include a Habitat Mitigation Plan prepared by a qualified biologist.

A1-14 The CDP application will provide the project staging and storage plan.

A1-15 The CDP application will provide proof of legal ability to perform fuel modification. 262
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Comment Set B1 – Matt Lawson
Matt Lawson
P.O. Box 5245
Laguna Beach, CA 92652
October 5, 2024
Mr. Robert Montaghami, Fire Marshal
Laguna Beach Fire Department
City of Laguna Beach
505 Forest Avenue
Laguna Beach, CA 92651
Support for Draft Mitigated Negative Declaration (MND) for FMZ 16 & 19 Dear Robert:

Having lived in the Diamond/Crestview neighborhood since completing construction of our home in 2003, my wife and I are very much aware of the extreme wildfire hazard presented by the unmaintained vegetation in Diamond Canyon, adjacent to where we live. The sane is also true in Hobo Canyon, a bit further from our home but yet another overgrown interior canyon that presents an extreme wildfire hazard to our entire at-risk community.

We are very pleased that the City is moving forward with both much-needed fuel mod projects.

The Draft MND, which resulted from the CEQA Initial Study, is an important “first step” to address any environmental concerns around these essential fire hazard mitigation projects. In view of the far more aggressive and lethal fire incidents experienced throughout California starting in 2018, it’s clear that wildfire poses an extreme, existential danger throughout Laguna Beach, nearly 90% of which has been classified as “Very High Fire Hazard Severity Zone” by the California Department of Forestry & Fire Protection (CalFIRE).

Laguna’s severe wildfire hazard has been exhaustively documented in multiple studies and reports commissioned by the City but developed and/or reviewed by public safety professionals in fire and disaster management agencies at the federal, state and municipal levels, including:
• Community Risk Assessment & Standards of Cover recommendations, received by Council June 11, 2024.
• Local Hazard Mitigation Plan, approved by the Governor’s Office of Emergency Services (CalOES) and the Federal Emergency Management Agency (FEMA), then adopted by Council December 12, 2023.
• General Plan Safety Element, approved by CalFIRE, adopted by Council October 19, 2021.
• Council’s Wildfire Mitigation & Fire Safety Plan, adopted by Council July 23, 2019.

The severity of our local wildfire hazard is further underscored by the number of established insurance carriers that have either declined to renew longstanding homeowners insurance policies on properties in Laguna Beach and/or have substantially increased the annual premiums on such properties to reflect the increased risk from more aggressive wildfire behavior in recent years. The insurance industry’s response to our escalating wildfire threat level was discussed at length during an August 27, 2024 presentation at City Hall by Julia Juarez, Deputy Director of the CA Department of Insurance.

B1-1
B1-2
B1-3
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Mr. Robert Montaghami, Fire Marshal

The fire danger from unmanaged vegetation in Diamond Canyon, in very close proximity to several densely developed neighborhoods has been recognized for decades. The Environmental Hazards section of the Diamond/Crestview Specific Plan (DCSP), adopted by Council in July 1999, states: “Wildfires. The City of Laguna Beach General Plan designates the Diamond/Crestview area as an extreme fire hazard area and states that it is probably the most difficult area of the City in which to provide fire protection. The rugged terrain and steep walled, heavily vegetated canyons provide the elements for a high fire hazard area.” (emphasis added)
Diamond/Crestview residents are at such extraordinary risk from the dangerous combination of extreme wildfire hazard and impaired circulation, that ours’ is the only neighborhood in the City where street parking is strictly limited to marked spaces to keep vehicles off the streets. Since 2015, Diamond/Crestview is also the only neighborhood in Orange County with stringent, LAstyle “ticket and tow” parking restrictions under Red Flag wildfire alert conditions.

In recent years, approximately 12% of CA’s land area has been devastated by wildfires. Beyond the loss of hundreds of lives and tens of billions of dollars in property, the environmental damage has been immense. The cost of remediating the millions of tons of toxic ash just in the City of Paradise, a veritable “witch’s brew” of PCBs, dioxin and heavy metals, was estimated at $3 billion by the federal National Institute for Standards & Technology (NIST). That compares with about $400 million to clean up Love Canal, the worst Super Fund site in American history. The aftermath of a devastating wildfire in a coastal hillside community like Laguna Beach would be far worse. Millions of tons of toxic contaminants could find their way onto our beaches and into the ocean with environmental consequences as bad as those from a major oil spill.

In addition, a team climate research scientists from UCLA and the University of Chicago determined that the enormous quantity of greenhouse gases (GHGs) generated by California wildfires in 2020 alone offset 2X the GHG reduction from ALL of the state’s regulatory efforts to during the preceding 20 years!
Fortunately, the Laguna Beach Fire Dept. has developed a system of vegetation management protocols to protect High and Very High Value Habitat containing special-status plant species.

All fuel modification activities in FMZ 16 and 19 would be conducted in accordance with the City’s Treatment Protocols for Fuel Modification Zones.

Following the CA Coastal Commission’s 11-0 rejection of an appeal of the City’s Coastal Development Permit for a very similar fuel modification project in 2022, then Coastal Commission Executive Director Jack Ainsworth praised the City’s “measured and reasonable” approach to fuel modification, adding “This is the most sensibly designed fuel modification plan that I’ve ever seen…It should be used as a model across the state.” That’s why I support moving forward with FMZ 16 and 19 and other important wildfire hazard mitigation measures to protect our residents, our homes and our community as well as our air, land and water resources.

Cordially,
B1-4
B1-5
B1-6
Comment Set B1: Matt Lawson (continued)
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Responses to Comment Set B1 – Matt Lawson
B1-1 The comment describes the existing wildfire hazard conditions in the Diamond Crestview and Hobo Canyon neighborhoods. No further response is needed.

B1-2 The comment expresses support for the proposed project and describes the City’s various studies and plans documenting wildfire hazards. The Final IS/MND acknowledges the project area falls within the Very High Fire Hazard Severity Zone and aims to reduce potential wildfire ignition of primarily residential properties, increase the evacuation time for residents, provide better access for firefighters to protect structures, reduce fire line intensity, reduce wildfire rates of spread, and improve occupant safety.

B1-3 The comment describes the effect of severe wildfire hazards on homeowner insurance policies. While insurance is not a topic addressed under CEQA, the proposed project intends to reduce wildfire risk in the City and improve safety for homeowners.

B1-4 The comment highlights the high risk of fire in Diamond Crestview due to the steep topography and limited evacuation access routes in the area. During fuel modification activities, work vehicles would either be parked along residential roads or private roads that would require coordination with property owners and would not impede on emergency access.

Access through private roads and driveways would be coordinated with homeowners. Access along public roadways would be maintained, and no road closures would be required. The proposed project would improve access for firefighters and increase evacuation times by reducing fuel loads and reducing the risk of ignition of properties.

B1-5 The comment states that wildfires create large amounts of hazardous waste, requiring extensive remediation to remove contaminants. The comment expresses concern with potential wildfire contaminants entering the marine environment as well as the large quantities of greenhouse gases (GHGs) generated by wildfires.

Final IS/MND Section 8 (Greenhouse Gas Emissions) and Section 9 (Hazards and Hazardous Materials) evaluate the proposed project’s construction impacts on GHG emissions and hazardous materials. No known hazardous materials sites were found within the project footprint. Construction equipment such as trucks, crew vehicles, and power tools would generate a relatively small amount of GHG emissions well below the South Coast Air Quality Management District’s thresholds. The proposed project aims to reduce the risk of wildfire and thus reduce the amount of hazardous byproducts and GHG emissions resulting from wildfires.

B1-6 The comment summarizes the City’s goals of balancing vegetation management and protecting special-status plant species, expressing support for the City’s fuel treatment protocols.

The proposed project is designed in accordance with the latest fuel treatment protocols (Final IS/MND Appendix A).
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Comment Set B2 – Jerry Myers
Jerry Myers
1333 Terrace Way, Laguna Beach, Ca, 926511 [email protected] Tuesday, October 8, 2024
Mr. Robert Montaghami, Fire Marshal
Laguna Beach Fire Department
City of Laguna Beach
505 Forest Avenue
Laguna Beach, CA 92651
Dear Robert:

As a 52-year Laguna Beach resident and whose home is in Rimrock Canyon I am extremely aware on how important it is to maintain safe brush clearances to protect our homes from wildfire. Having a brush clearance program that maintains healthy vegetation while also protecting the environment is critical to the safety of our residents and property owners.

Our wildfire hazard in Laguna Beach is categorized as severe and maintaining homeowners fire insurance is becoming difficult or if non-renewed, nearly impossible to find that is affordable. For the reasons stated in this letter, I support the Draft Mitigated Negative Declaration (MND) for Fuel Modification Zones 16 & 19.

Sincerely,
onny)
Q.�\j
ber Emergency Disaster Preparedness Committee (EDPC)
Director, Laguna Beach Community Emergency Response Team (CERT B2-1
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Responses to Comment Set B2 – Jerry Myers
B2-1 The comment expresses support for the proposed Project. No further response is necessary. 267
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Comment Set B3 – Rebecca and Frank Visconti
Lower Hobo and Diamond Crestview Fuel Modification Project Email From: Rebecca Visconti <[email protected]>
Sent: Thursday, October 10, 2024 8:13 AM
To: Montaghami, Robert FD <[email protected]> Subject: Hobo Canyon / Diamond Canyon
Dear Fire Marshal Robert Montaghami, City of Laguna Beach Fire Department, I support our Fire Dept. proposal to improve fire safety by thinning out the dangerously overgrown dense brush in Diamond Canyon and Hobo Canyon through the very careful process of creating "Fuel Modification Zones," FMZ 16 (in Hobo Canyon) and FMZ 19 in Diamond Canyon.

As homeowners at 341 Diamond St., our insurance carrier (Farmers) has discontinued our coverage. We were able to find another policy at double the rate.

Most importantly we are concerned about the safety of the people, property and community here in Laguna Beach.

We fully support this proposal. We are grateful for all that you do.

Respectfully yours,
Becky & Frank Visconti
341 Diamond St.
702-338-3137
B3-1
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Responses to Comment Set B3 – Rebecca and Frank Visconti B3-1 The comment expresses support for the proposed project. No further response is necessary. 269
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Comment Set B4 – J. Rex Theobald
J. Rex Theobald
1984 Del Mar Avenue
Laguna Beach, CA 92651
October 19, 2024
Mr. Robert Montaghami, Fire Marshal
Laguna Beach Fire Department
City of Laguna Beach
505 Forest Avenue
Laguna Beach, CA 92651
Dear Mr. Montaghami,
I'm writing to support the Draft Mitigated Negative Declaration (MND) for FMZ 16 & 19.

I live in Arch Beach Height, so I'm always pleased to see the fire mitigation efforts conducted by the city.

We tend to think of fire risk in terms of Santa Ana winds, but we learned in the disastrous Coastal Fire of 2022 that even moderate onshore wind can drive fire uphill resulting in the destruction of homes. Arch Beach Heights was under voluntary evacuation during that incident but was spared only because the wind drove the fire into Laguna Niguel instead.

I note that the fuel modification in FMZ 19 (Diamond Crestview) is immediately upwind (in prevailing westerly winds) and downslope from the densely populated Arch Beach Heights neighborhood. Many of the houses in this neighborhood are built with open eaves, sided with wood, and have other architectural features that make them vulnerable to ignition by embers. The houses are very close together. And the streets are narrow. So I fear that a fire in FMZ 19 could quickly turn into historic disaster.

The Hobo Canyon FMZ 16 also threatens this neighborhood as well as the homes to the southwest, which would be downwind in Santa Ana conditions.

In light of these risks and the current wildfire environment in California, it is urgent to do everything practical to mitigate the hazards before it's too late.

Yours truly,
fWJ� J. Rex Theobald
B4-1
B4-2
B4-3
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Responses to Comment Set B4 – J. Rex Theobald
B4-1 The comment expresses support for the proposed project. No further response is necessary.

B4-2 The comment describes the existing fire hazards in the project area due to prevailing winds, steep topography, density of homes, flammability of structures, and narrow roads. The proposed project aims to reduce potential wildfire ignition of primarily residential properties, increase the evacuation time for residents, provide better access for firefighters to protect structures, reduce fire line intensity, reduce wildfire rates of spread, and improve occupant safety. During fuel modification activities, work vehicles would either be parked along residential roads or private roads that would require coordination with property owners and would not impede on emergency access. Access through private roads and driveways would be coordinated with homeowners. Access along public roadways would be maintained, and no road closures would be required. The proposed project would improve access for firefighters and increase evacuation times by reducing fuel loads and reducing the risk of ignition of properties.

B4-3 The comment expresses support of addressing wildfire hazards. The proposed project aims to reduce wildfire risk in the City of Laguna Beach.
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Comment Set B5 – Evgeniy Krasko
Evgeniy Krasko
785 Gainsborough Dr.

Laguna Beach, CA 92651
October 28, 2024
Mr. Robert Montaghami, Fire Marshal
Laguna Beach Fire Department
City of Laguna Beach
505 Forest Avenue
Laguna Beach, CA 92651
Support for Lower Hobo and Diamond Crestview Fuel Modification Project (FMZ 16 and 19)
Dear Robert,
I am writing in support of the Lower Hobo and Diamond Crestview Fuel Modification Project. I live in the Diamond/Crestview neighborhood in Laguna Beach, and I am very much aware of the elevated risks of fire in my neighborhood.

There is a large amount of unmaintained vegetation in the canyons that could ignite any time, and the access for fire trucks and evacuation vehicles is very much limited in Diamond/Crestview, where Diamond street serves as the only evacuation route for the residents.

I have witnessed for myself the devastating impact of recent fires around Irvine, and I've heard stories of Laguna Fire in 1993, which destroyed a large fraction of my neighborhood.

Implementing the project would, in my opinion, go a long way in ensuring the safety for Laguna Beach residents, and could potentially save lives, prevent injuries, and also save not only beautiful, but also quite expensive homes in the area.

The project has been very thoughtfully planned with care for our natural resources and protected species, and I fully support it.

Best,
Evgeniy Krasko
B5-1
B5-2
B5-3
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Responses to Comment Set B5 – Evgeniy Krasko
B5-1 The comment expresses support for the proposed project. No further response is necessary.

B5-2 The comment describes the existing fire hazards in the project area due to the density of vegetation and narrow roads. The proposed project aims to reduce potential wildfire ignition of primarily residential properties, increase the evacuation time for residents, provide better access for firefighters to protect structures, reduce fire line intensity, reduce wildfire rates of spread, and improve occupant safety. During fuel modification activities, work vehicles would either be parked along residential roads or private roads that would require coordination with property owners and would not impede on emergency access. Access through private roads and driveways would be coordinated with homeowners. Access along public roadways would be maintained, and no road closures would be required. The proposed project would improve access for firefighters and increase evacuation times by reducing fuel loads and reducing the risk of ignition of properties
B5-3 The comment expresses support for the proposed project. No further response is necessary. 273
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January 2025 App 1-1
Appendix 1: Mitigation Monitoring and Reporting
Program
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Table A-1. Mitigation Monitoring Program for Fuel Breaks in FMZ 16 and FMZ 19 Environmental
Factor
Reference
Number Mitigation Measures
Responsible
Party Timing

4. BIOLOGICAL

RESOURCES
4(a) BIO-1 The City of Laguna Beach (City) shall assign a qualified biologist to the project (i.e., Project Biologist). The qualified biologist shall be responsible for conducting pre-construction surveys (MM BIO-2), implementing nesting bird avoidance (MM BIO-3), monitoring project activities (MM BIO-4), and conducting worker training (MM BIO-5). The "qualified biologist" is defined as a person with appropriate education, training, and experience to conduct the required surveys, monitor project activities, provide worker education programs, and supervise or perform other monitoring-related actions. The Project Biologist shall be authorized by the City to temporarily halt project activities, if needed, to prevent take of listed species or harm to any other special-status species.

City of Laguna
Beach Fire Chief
Prior to and during
fuel modification
activities
4(a) BIO-2 Prior to start of project activities, the Project Biologist shall survey the work area to determine if any special-status species are present. During the survey, the Project Biologist shall search for nesting birds, special-status plants, and other special-status species. Pre-clearing surveys shall be performed during the appropriate blooming period for special-status plants to ensure species present are identified. Any specialstatus species or sensitive resources shall be flagged and avoided, in coordination with the Project Biologist.

If big-leaved crownbeard are located within the project site, they shall be flagged, and a 50-foot buffer installed. Plants with a CRPR of 1B or 2B shall be flagged and a 15-foot buffer installed. Any willow canopy that falls outside the 25-foot buffer around “blue-line” drainages (per the City’s fuel modification treatment protocols), shall be avoided. San Diego desert woodrat nests shall be avoided with a 15-foot buffer. No work shall be permitted within these buffers. The Project Biologist shall also flag coast live oak seedlings and western sycamore seedlings for avoidance, as feasible. The Project Biologist shall also search for shot hole borers on all oak and sycamore trees that are proposed for pruning. If shot hole borers are found, the Project Biologist shall notify the City who will then coordinate with CDFW, and the U.S. Fish and Wildlife Service.

All pruning tools shall be cleaned and disinfected prior to use within the project area and at least weekly during the project to further reduce the spread of pathogens. To the extent practicable, thinning within coastal sage scrub and chaparral habitats shall be limited to winter months outside the growing season.

City of Laguna
Beach Fire Chief
Prior to and during
fuel modification
activities
4(a, d) BIO-3 Vegetation removal and initial ground disturbance shall be completed outside the breeding season (i.e., no removal of potential nesting habitat from January 1 through September 1), or after a pre-construction nesting bird survey has been completed. The Project Biologist shall confirm that no birds are nesting in or adjacent to areas to be disturbed. If native birds are nesting on the site, then project activities shall be postponed until nesting is completed or the Project Biologist shall designate appropriate avoidance buffers around nests to protect nesting birds. No project related disturbance shall be allowed within these buffers.

City of Laguna
Beach Fire Chief
Prior to fuel
modification
activities outside of
bird breeding
season
4(a) BIO-4 The Project Biologist shall be present as needed on the project site during vegetation clearing done by hand crews to document compliance with the avoidance and minimization measures and to provide guidance in avoiding or minimizing impacts to biological resources. The Project Biologist shall also conduct quarterly monitoring of the project site for 12 -months after the completion of the fuel treatment. During this post-treatment monitoring the Project Biologist shall inspect the mulched plant material for Argentine ants and will also note wildlife use of the treatment areas. If Argentine ants are found within the mulched plant City of Laguna
Beach Fire Chief
During fuel modification activities
and continuing for
at least 12 months
following completion of activities
275
Lower Hobo and Diamond Crestview Fuel Modification Projects Mitigation Monitoring and Reporting Program
January 2025 App 1-3
Table A-1. Mitigation Monitoring Program for Fuel Breaks in FMZ 16 and FMZ 19 Environmental
Factor
Reference
Number Mitigation Measures
Responsible
Party Timing
material, the City shall implement an ant control program to remove them from these areas. If any new non-native plants are found within the project area, the City shall implement a control program for these species to ensure they are eradicated and not allowed to spread into adjacent natural lands. 4(a)
BIO-5 The Project Biologist shall conduct training to ensure that all workers on the project site are aware of all applicable mitigation measures for biological resources. Specifically, workers shall be required to (1) limit all activities to approved work areas; (2) report any special-status species; (3) report any bird nests; (4) avoid contact with any wildlife that may approach a work area, and be aware of potential venomous reptile bites from carelessness or unnecessary harassment; (5) pick up and properly dispose of any food, trash, or construction refuse; and (6) report any spilled materials (e.g., oil, fuel, solvent, engine coolant, raw concrete, or other material potentially hazardous to wildlife) to the supervisor. During the training, the Project Biologist shall briefly discuss special-status species that may occur in the work areas, their habitats, and requirements to avoid or minimize impacts. In addition, all workers shall be informed of civil and criminal penalties for violations of the federal Endangered Species Act, California Endangered Species Act, and the Migratory Bird Treaty Act.

City of Laguna
Beach Fire Chief
Prior to fuel
modification
activities

5. CULTURAL

RESOURCES

18. TRIBAL

CULTURAL

RESOURCES
5(a, b)
18(a)(i)
CUL-1 A qualified professional archaeologist and local Native American monitor shall be retained to provide monitoring services when crews are working in areas on slopes less than 30 degrees. If any such resources are discovered when the monitor is not present, contractors should stop work in the immediate area of the find and contact the archaeologist to assess the nature of the find and determine if future monitoring is appropriate. If deemed appropriate, monitoring should continue until vegetation removal activities are complete, or until the monitoring archaeologist, based on field observations, is satisfied there is no likelihood of encountering intact archaeological deposits. Upon completion of any monitoring activities, the archaeologist should prepare a report to document the methods and results of monitoring activities. This report should be submitted to the South Central Coastal Information Center.

City of Laguna
Beach Fire Chief
During fuel
modification
activities
5(a, b)
18(a)(i)
CUL-2 Prior to the initiation of construction, all construction personnel shall be trained by a qualified archaeologist regarding the recognition of possible buried cultural resources (i.e., prehistoric and/or historical artifacts, objects, or features) and protection of all archaeological resources during construction.

Training shall inform all construction personnel of the procedures to be followed upon the discovery of cultural materials. All personnel shall be instructed that unauthorized removal or collection of artifacts is a violation of State law. Any excavation contract (or contracts for other activities that may have subsurface soil impacts) shall include clauses that require construction personnel to attend the Workers’ Environmental Training Program, so they are aware of the potential for inadvertently exposing buried archaeological deposits.

City of Laguna
Beach Fire Chief
Prior to fuel
modification
activities
5(c)
CUL-3 All human remains discovered are to be treated with respect and dignity. Upon discovery of human remains, all work within 50 feet of the discovery area must cease immediately, nothing is to be disturbed, and the area must be secured. The County Coroner’s Office must be called. The Coroner has two working days to examine the remains after notification. The appropriate land manager/owner of the site (i.e., City of Laguna
Beach Fire Chief
During fuel
modification
activities
276
Lower Hobo and Diamond Crestview Fuel Modification Projects Mitigation Monitoring and Reporting Program
January 2025 App 1-4
Table A-1. Mitigation Monitoring Program for Fuel Breaks in FMZ 16 and FMZ 19 Environmental
Factor
Reference
Number Mitigation Measures
Responsible
Party Timing
Orange County Parks) is to be called and informed of the discovery. It is very important that the suspected remains, and the area around them, are undisturbed and the proper authorities called to the scene as soon as possible, as it could be a crime scene. The Coroner will determine if the remains are archaeological/ historic or of modern origin and if there are any criminal or jurisdictional questions.

After the Coroner has determined the remains are archaeological/historic-era, the Coroner will make recommendations concerning the treatment and disposition of the remains to the person responsible for the excavation, or to his or her authorized representative. If the Coroner believes the remains to be those of a Native American, he/she shall contact the Native American Heritage Commission (NAHC) by telephone within 24 hours.

The NAHC will immediately notify the person it believes to be the most likely descendant (MLD) of the remains. The MLD has 48 hours to make recommendations to the landowner for treatment or disposition of the human remains. If the descendant does not make recommendations within 48 hours, the landowner shall reinter the remains in an area of the property secure from further disturbance. If the landowner does not accept the descendant’s recommendations, the owner or the descendant may request mediation by NAHC.

According to the California Health and Safety Code, six (6) or more human burials at one (1) location constitute a cemetery (Section 8100), and willful disturbance of human remains is a felony (Section 7052).

7. GEOLOGY

AND SOILS

20. WILDFIRE
7(a, c)
20(d)
GEO-1 The City of Laguna Beach shall adhere to the following fuel modification protocols in landslideprone areas in FMZ 16 and FMZ 19:
• Fuel modification activities shall be conducted in the spring and summer and allow for some reestablishment of the native canopy prior to the next rainy season. • Fuel modification efforts shall be limited to the canopy and seasonal grasses and should minimize damage to the existing root systems.
• Spray adhesives, fiber rolls, or jute matting shall be used in areas with a thick accumulation of soil on slopes between a 2:1 to 1:1 (horizontal:vertical) ratio prior to winter.

City of Laguna
Beach Fire Chief
During fuel
modification
activities

9. HAZARDS
AND

HAZARDOUS

MATERIALS
9(a)
HAZ-1 The City of Laguna Beach shall include the following provisions or similar in the contractor bid contract for hand clearing:
• All power tools shall be fueled in an area clear of fire hazards. • Fueling of power tools in the fuel modification zones shall occur over a containment system (e.g., plastic tray or tub) to catch and prevent spills. • Any fuel spills shall be cleaned up immediately and properly disposed. • All trucks and larger equipment, such as chippers, shall be fueled off site. • Engine fuel shall not be used as a cleaning solvent.

City of Laguna
Beach Fire Chief
Prior to fuel
modification
contract signing
277
CITY OF LAGUNA BEACH 505 Forest Ave. Phone: (949) 497-0700 Laguna Beach, CA 92651 Fax: (949) 497-0784

FIRE DEPARTMENT ADDENDUM
DATE: 5/4/26

TO: ALL BIDDERS SUBMITTING PROPOSALS FOR WILDFIRE MITIGATION

VEGETATION REDUCTION SERVICES
FROM: CITY OF LAGUNA BEACH, FIRE DEPARTMENT
SUBJECT: ADDENDUM NO. 1
This Addendum forms a part of the Request for Proposals identified above. All portions of the proposal documents not specifically mentioned or otherwise revised by this Addendum remain in full force and effect. Acknowledgment of this Addendum is required and must be included with the proposal submission. Failure to acknowledge this Addendum may render the proposal non-responsive. Please note the following clarification:

1. Updated Submittal Information and Instructions, Tentative RFP Schedule and Project Timeline (Section III, A)
The tentative RFP schedule and project timeline is hereby revised to include the option to schedule a non-mandatory pre-bid meeting/walkthrough as highlighted below. The pre-bid meeting is optional and is provided for informational purposes only. Proposers are encouraged, but not required, to attend.

Description Date
Advertise for Proposals April 29, 2026, 09:00 am PDT
Deadline for Written Questions May 4, 2026, 5:00 pm PDT City Response to Questions May 5, 2026, 5:00 pm PDT
Non-Mandatory Pre-Bid
Meeting/Walkthrough
Upon request and at the
convenience of the Fire Prevention
Division: May 7, 2026 – May 12, 2026
Bid Closing May 13, 2026, 5:00 pm PDT
Interviews (as applicable) May 14, 2026
City Council Award of Contract TBD (Prior to July 1, 2026)

ACKNOWLEDGMENT
Proposers shall acknowledge receipt of this Addendum in their proposal submission.

END OF ADDENDUM NO. 1
278