Santa Cruz City Council
December 9, 2025

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc Categorical exemption: CEQA Guidelines Sections 15301(c) and (g), 15307,
15308, and 15061(b) (14 CCR sections 15301(c) and (g), 15307, 15308, and 15061(b).)
Mandatory Action Date: 60 days after acknowledgement of Environmental Exemption Planning Staff: Timothy Maier, Senior Planner

PROJECT DESCRIPTION
The City’s existing street sweeping program serves public streets Citywide. The proposed Street Sweeping Pilot Program encompasses 1) a prohibition of vehicular parking from the hours of 5:00 a.m. until 9:00 a.m. on six routes within three designated areas throughout the City and 2) placement of new signage in locations adjacent to areas in which parking is proposed to be limited, as a means of alerting motorists to the intended parking restrictions and including warning symbols that vehicles parked on-street during designated street-sweeping hours may be towed. Streets included in the Pilot Program include Delaware Avenue, Natural Bridges Drive, Swanton Boulevard, and Mission Street. Should the program be approved and proven effective, expansion of the program to further areas of the City may ensue.

One of three areas designated for proposed limitation of hours of public parking and placement of signage falls within the Coastal Zone, necessitating approval of a Coastal Permit pursuant to City of Santa Cruz Municipal Code (SCMC) Section 24.08.210, which requires authorization of such permit for development within the Coastal Zone that is not specifically exempted. The project scope of work constitutes “development” per the City’s Local Coastal Plan, as a restriction on hours of available parking holds the potential for alteration to intensity of use of the ocean and adjacent shoreline or access thereto. As a “public project in the Coastal Zone”, a Design Permit with review by the Zoning Administrator is required pursuant to SCMC Sections 24.08.410-430.

On February 22, 2024, the City’s Transportation and Public Works Commission (TPWC) recommended that the City Council approve limitation of hours of parking and proposed placement of signage to facilitate implementation of the City Street Sweeping Pilot Program.

Please see the attached staff report presented to the TPWC.

The Street Sweeping Pilot Program includes six routes occupying three distinct areas in various locations throughout Santa Cruz, including land in the Upper Westside, Seabright, and Far (Lower) Westside, with designated areas and proposed signage locations exhibited below.

35.26 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc For the project scope of work as considered herein, the area within the Far Westside (Routes 5 and 6) requires approval of a Coastal Permit and Design Permit by virtue of its inclusion within the Coastal Zone, as depicted in the maps above and below.

In the below image, the dark purple line represents the boundary of the City’s Coastal Zone, while the orange-colored regions depict areas in which discretionary land-use applications allow for appeal of any decision made by the City to the California Coastal Commission.

Routes 1 and 2
Routes 3 and 4
Routes 5 and 6
Subject to
Coastal Permit,
Design Permit

35.27 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc Street-sweeping routes within the Coastal Zone and subject to review under this permit application are further illustrated below. As proposed, street sweeping would occur on one side of select streets on Tuesdays (Route 5, shown in turquoise) and on the opposing side of the street on Thursdays (Route 6, depicted in navy blue).

Mission St. Ext.

Delaware Ave.

Swanton Blvd.

Natural Bridges Dr.

35.28 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc An image of proposed signage, including provisions for towing of non-compliant vehicles, appears below:

ANALYSIS
Regulatory Requirements
Urban runoff and other "non-point source" discharges are regulated by the 1972 Federal Clean Water Act (CWA) through the National Pollutant Discharge Elimination System (NPDES) permit program, administered by the Regional Water Quality Control Board (“Water Board”). Among other activities, the City’s NPDES regulates municipal street-sweeping operations.

For several years, in accordance with its NPDES permit, the City has retained a third-party consultant to monitor the volumes of debris remaining uncollected on City streets, which, if unchecked, eventually migrate to Monterey Bay. The City’s consultant prepares an annual “report card” evaluating the effectiveness of the municipal street sweeping program. To date, such assessments have characterized most areas investigated as “low” in litter buildup; however, past report cards have categorized several areas as “moderate” in debris accumulation, including primarily those streets in which static on-street parking hampers sweepers’ capacity to access the curb and gutter in order to effectively gather accumulated refuse. Streets designated with “moderate” trash levels include corridors on the Far Westside, primarily Delaware Avenue and Mission Street Extension.

Municipal Street Sweeping Operations
To ensure compliance with requirements of the City’s NPDES permit and to enhance the cleanliness of City streets, the Public Works (PW) Resource Recovery Division supplies streetsweeping services to the City. Currently, street-sweeping operations provide service once per week for commercial areas and on alternating weeks in residential areas utilizing a fleet of three street

35.29 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc sweepers, with daily functions conducted by two sweepers operating simultaneously. Sweeping operations generally commence at 5:00 a.m. and last until 12:00 p.m. Debris collected by the sweepers is consolidated at the City’s Corporation Yard and then deposited in the City landfill.

Few restrictions currently limit the parking of motor vehicles on public rights-of-way along existing street-sweeping routes. Under existing conditions, street-sweeping vehicles often cannot access substantial spans, often several car lengths’, of curb area for each parked vehicle presenting an obstruction, where most trash accumulates. Incomplete sweeping of City streets inevitably results in movement of debris into storm drains and, eventually, into the Monterey Bay. Further, intermittent spacing of parked vehicles compels City street sweepers to maneuver around such vehicles into flowing traffic, with potentially adverse impacts to public safety and congestion.

Effectiveness of the Existing Street Sweeping Program
Staff of the Public Works Department reports that past experience in implementing programs incorporating restrictions on hours of parking has revealed that the success of such programs hinges upon the effectiveness of enforcement. Without a strong incentive for compliance, such as the prospect of towing of offending vehicles, the likelihood for adherence by members of the public to posted parking restrictions remains limited. Thus, the proposed Street-Sweeping Pilot Program incorporates the option for towing of vehicles to facilitate access by sweepers to street curbs for effective collection of debris.

For a thorough and effective street-sweeping program, the Public Works Department seeks to prohibit the parking of vehicles during the hours of 5:00 a.m. until 9:00 p.m. weekly on Tuesdays and Thursdays on alternating sides of affected streets. For instance, on Natural Bridges Avenue, parking would be restricted on the east side of the street every second Tuesday and prohibited on the west side of the road on Thursday of the same week. Such a strategy would consolidate operations, establish predictability in scheduling, and minimize loss of on-street parking capacity to the extent feasible.

The following lists areas affected by street-sweeping activities within the Costal Zone, subject to the application for Coastal Permit and Design Permit:

Sweeping
Zone
Day of
Sweeping
Streets Affected Number of Parking Spaces
Potentially Impacting Effective
Street Sweeping
5 Tuesdays Mission Street Extension from
Swift Street to Natural Bridges
Dr.
67 spaces
Natural Bridges Dr. to
Delaware Ave.
80 spaces
Delaware Ave. from Shaffer
Rd to Swift St.
140 spaces
Swanton Blvd from Delaware 79 spaces

35.30 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc Ave to West Cliff Dr.
6 Thursdays Natural Bridges Dr. from
Delaware Ave. to Mission St.

Extension
66 spaces
Mission St. from Western Dr.
to Swift St.
77 spaces
Delaware Ave. From Swift St.
to Shaffer Rd.
147 spaces
Swanton Blvd. from West Cliff
Drive to Delaware Ave.
45 spaces
Interface with Oversized Vehicle Ordinance
The proposed Street Sweeping Pilot Program would remain completely independent from actions related to the City’s Oversized Vehicle Ordinance, approved by the City Council on March 12, 2024, which restricts parking of oversized vehicles (defined as motor vehicles exceeding 20 feet in length, or eight feet in width and seven feet in height) along with unattached trailers, on City streets between the hours of midnight and 5 AM, consistent with Coastal Development Permit A3-STC-22-0018 authorized by the California Coastal Commission. Entitlements associated with the Oversized Vehicle Ordinance address adverse impacts associated with the entrenchment of oversized vehicles, whereas the proposed Street Sweeping Pilot Program intends to limit vehicular parking for short durations on alternating weeks in order to improve the effectiveness of City debris collection operations.

Potential Future Program Modifications
As proposed, the proposed Street-Sweeping Pilot Program will address commercial areas with designated “moderate” levels of trash accumulation. A condition of approval has been added, allowing the Planning and Community Development Director, in conjunction with the Public Works Director, to make minor modifications to the proposed program as necessary. Further, assessment of the success of the Pilot will allow for consideration for potential future expansion of the proposed program into residential areas with similarly high levels of trash accumulation and with more severe limitations on parking capacity.

ENVIRONMENTAL REVIEW
Placement of new signage on existing street posts, and limitation of hours of parking for short durations at regular intervals to facilitate sweeping of City streets hold little, if any, potential for impact to the environment based on established thresholds of significance.

Further, the proposed actions remain statutorily exempt from environmental review under Article 19 of the California Environmental Quality Act (CEQA) Guidelines, Section 15282(j), related to restriping of City streets, and categorically exempt under Section 15301(c) and (g), 15307, 15308 and 15061(b), related to alteration of City streets not involving addition of lanes.

35.31 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc The California Environmental Quality Act (CEQA) establishes several “categorical exemptions” applicable to classes of projects and varieties of activities which generally avoid inducing risk of significant impacts to the environment. Section 15307 of the CEQA Guidelines
“consists of actions taken by regulatory agencies... to assure the maintenance, restoration, or enhancement of a natural resource where the regulatory process involves procedures for protection of the environment.” Section 15308 of the CEQA Guidelines
“consists of actions taken by regulatory agencies… to assure the maintenance, restoration, enhancement, or protection of the environment where the regulatory process involves procedures for the protection of the environment.” Placement of new signage and limited-duration restrictions of hours of on-street public parking, with minor modifications as potentially required, will not likely result in any new construction, or need for building of additional facilities for public services such as Police, Parks, or Fire. As the proposed actions would facilitate the improvement of street-sweeping operations for more effective removal of debris from City streets, the proposed project will bring about beneficial, rather than detrimental, environmental outcomes. The proposed project complies with all the foregoing criteria and demonstrates eligibility for implementation of both statutory and categorical exemptions as afforded by CEQA.

SUMMARY
The City of Santa Cruz seeks to improve the effectiveness of its existing street-sweeping program, intended to reduce the environmental impacts derived from accumulation of debris along public rights-of-way while minimizing impacts associated with loss or parking capacity on City streets. As proposed, and, with recommended conditions of approval implemented, the enhanced street-sweeping program will remain consistent with applicable goals and policies of the General Plan and provisions of the Zoning Ordinance. The program will additionally enable the City to render informed decisions about potential expansions of its street-sweeping program into further areas, fostering enhanced aesthetics and promoting a cleaner environment, creating the conditions for a more welcoming City and encouraging public access to the coast. Staff recommends that the Zoning Administrator recognize the environmental determination and approve the project based on the attached findings subject to conditions listed as Exhibit “A”.

FINDINGS
Coastal Permit, Section 24.08.250

1. Maintain views between the sea and the first public roadway parallel to the sea.

35.32 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc With the scope of work encompassing limitation of hours of public parking and placement of new signage on existing signposts, the proposal will not induce adverse impact to coastal views.

2. Protect vegetation, natural habitats and natural resources consistent with the Local Coastal Land Use Plan.

The proposed actions are consistent with the California Environmental Quality Act (CEQA) and the City’s environmental review and protection procedures. No disturbance of any vegetation, natural habitats, or natural resources will accompany the actions included in the subject Coastal Permit.

3. Be consistent with any applicable design plans and/or area plans incorporated into the Local Coastal Land Use Plan, in that it implements policies therein.

Actions included under the requested Coastal Permit remain consistent with the General Plan and Local Coastal Program in that the proposed scope of work advances, and serves to implement, relevant goals and policies related to promotion of enhanced aesthetics and protection of the natural environment.

The proposed actions address policies and programs of the Local Coastal Program, including, but not limited to, the following:
 Water Quality Policy 2.1: Meet or exceed State Water Resources Control Board standards for discharge of sewage and storm waters to the Monterey Bay.  Open Space Lands Policy 3.5: Protect coastal recreation areas, maintain all existing coastal access points open to the public, and enhance public access, open space quality and recreational enjoyment in a manner that is consistent with the California Coastal Act.
 Open Space Lands Policy 3.7: Recognize and protect the Pacific Ocean and Monterey Bay as a valuable open space, natural resource, and National Marine Sanctuary.  Natural Setting and Scenic Resources Program 2.1.3: Protect the Monterey Bay National Marine Sanctuary and the shoreline and views to and along the ocean, recognizing their value as natural and recreational resources.  Open Space Lands Program 3.5.5: Develop and implement plans to maximize public access and enjoyment of recreations areas along the coastline.  Biotic Diversity and Stability Program 4.2.5: Protect and minimize the impact of development on bird, fish and wildlife habitat in and adjacent to waterways.  Biotic Diversity and Stability Program 4.1.5: Protect the quality of water discharged into the Bay and allow no dumping of materials into the Monterey Bay.

An evaluation of the project’s potential for generation of environmental impacts in accordance with the provisions of the California Environmental Quality Act (CEQA) and the City’s Environmental Review Guidelines and procedures has resulted in the conclusion that all actions included qualify for established categorical and/or statutory

35.33 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc exemptions and the determination that the subject application holds no potential for generation of significant environmental impact, but, rather, will improve both the visual and natural environment.

The subject Coastal Permit application provides for ongoing implementation of the City’s Street-Sweeping Program which seeks to minimize detrimental environmental impacts associated with accumulation of refuse along City street curbs.

The proposed actions remain statutorily exempt from environmental review under Article 19 of the California Environmental Quality Act (CEQA) Guidelines, Section 15282(j), related to restriping of City streets, and categorically exempt under Section 15301(c) and (g), 15307, 15308 and 15061(b), related to alteration of City streets not involving addition of lanes.

Placement of new signage and limited-duration restrictions of hours of on-street public parking, with potential future minor modifications as deemed necessary, will not likely result in any new construction, or need for building of additional facilities for public services such as Police, Parks, or Fire. As the proposed actions would allow for more effective street-sweeping operations providing for removal of debris from City streets, implementation of an enhanced street-sweeping pilot program will bring about beneficial, rather than detrimental, environmental outcomes.

4. Maintain public access to the coast along any coastline as set forth in the Local Coastal Land Use Plan.

The proposed scope of work would prohibit parking for a limited duration on alternating sides of affected streets on differing days, affording adequate access to the curb and gutter for street-sweeping vehciles to remove accumulate trash which would otherwise eventually migrate into the Monterey Bay, where its environmental impact would be exacerbated. Short-duration limitation of hours of parking and placement of signage as proposed will not substantively impact availability of vehicular parking which would obstruct or impair access to the Coast. The subject application will enhance cleanliness and safety by facilitating proper disposal of litter, with associated benefits to preservation of community character and aesthetics. The project will enable the general public to experience coastal access to the ocean and adjacent shore in an environment of improved cleanliness, rendering visitation to oceanside lands more attractive and thereby encouraging public access to the coast.

5. Be consistent with the Local Coastal Land Use Plan goal of providing visitorserving needs as appropriate.

Placement of signage alerting members of the public to restriction of hours of on-street parking associated with municipal street-sweeping operations provides the public, including visitors, with valuable information which avoids potential towing of vehicles

35.34 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc while facilitating greater success of City street-sweeping efforts. No impact to recreational beach access would result from the proposed actions.

6. Be consistent with the Local Coastal Land Use Plan goal of encouraging coastal development uses as appropriate.

Placement of signage related to municipal street-sweeping operations and restriction of hours of public on-street parking remain consistent with the Local Coastal Land Use Plan and hold no appreciable impact to coastal development while enhancing City street sweeping operations to effect improved aesthetic and environmental conditions promoting public coastal access.

Shoreline Protection Overlay District, Section 24.10.2430

7. The project protects trees and vegetation and sensitive wildlife habitat.

The proposed limited-duration restriction of vehicular parking and placement of signage will not negatively affect trees, vegetation, or sensitive wildlife habitat. By reducing litter accumulation, improved street sweeping operations will have a positive effect on trees, vegetation, and sensitive habitat.

8. The project is consistent with the following criteria for bluff or cliff development:
a. The development is sited and designed to assure stability and structural integrity of its expected economic life span and minimize alterations to natural landforms.
b. The development will not create or contribute significantly to problems of erosion or geologic instability on the site or on surrounding geologically hazardous areas.
c. The development minimizes alteration of cliffs, bluff tops, faces or bases, and will not interfere with sand movement.
d. The development which proposes use of retaining walls shall be allowed only to stabilize slopes. Sea walls at the toe of sea cliffs to check marine erosion shall be allowed only where there is no less environmentally damaging alternative.
e. The development within one hundred feet of any cliff or bluff line shall follow the recommendations of an approved geologic report by a registered geologist. The area where such a report is required may be increased where the issue of slope stability requires a greater distance from any cliff or bluff line.

35.35 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc The proposed signage will be installed on existing sign posts to the extent possible and will not physically affect any cliff or bluff.

9. The project provides maximum erosion protection, using accepted engineering practices and other methods and specifications set forth in this title.

The proposed signage will be placed on existing sign posts to the degree feasible and will not result in any detrimental impact related to accelerated erosion.

10. The project maintains public view corridors between the sea and the first public roadway parallel to the sea and maintain natural views of the coastline.

The proposed actions will not result in impact to any cliff or bluff, and the above finding remains inapplicable. To the extent possible, installation of signage associated with parking limitations will occur on existing signposts, without physical effects to any cliff or bluff.

11. The project protects paleontological resources as prescribed in the Land Use Plan.

The proposed actions do not encompass any subsurface excavation and therefore will not impact paleontological resources as prescribed in the Land Use Plan. The above finding remains inapplicable.

12. The project protects and enhances free public access to or along the beach, and sign such access when necessary.

The proposed actions will not reduce the capacity of, or access to, free public parking or bona fide recreational use of the shore.

13. The project includes mitigation measures prescribed in any applicable environmental document.

No mitigation measures apply, and the above finding remains inapplicable.

14. The project is compatible with the established physical scale of the area.

The proposed actions will not impact the established physical scale of the area, and the above finding remains inapplicable. Installation of signage associated with parking limitations will occur on existing signposts to the degree practicable, without physical effects to any cliff, bluff, or mapped sensitive habitat.

15. The project is consistent with the design review guidelines of this title and the policies of any applicable area plan.

35.36 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc All signage will remain consistent with relevant criteria of the Public Works and Police departments.

16. The project is consistent with the policies of the Local Coastal Program, the General Plan, and the California Coastal Act.

The proposed actions demonstrate consistency with the policies of the Local Coastal Program, the General Plan, and the California Coastal Act in that the proposed limited-duration restriction of vehicular parking and placement of signage will result in continued benefits to the community along spans of the coast affected by accumulation of trash and debris, with attendant enhancements to health and safety. The proposed actions will address the policies of the LCP as listed below:
 Water Quality Policy 2.1: Meet or exceed State Water Resources Control Board standards for discharge of sewage and storm waters to the Monterey Bay.  Open Space Lands Policy 3.5: Protect coastal recreation areas, maintain all existing coastal access points open to the public, and enhance public access, open space quality and recreational enjoyment in a manner that is consistent with the California Coastal Act.
 Open Space Lands Policy 3.7: Recognize and protect the Pacific Ocean and Monterey Bay as a valuable open space, natural resource, and National Marine Sanctuary.  Natural Setting and Scenic Resources Program 2.1.3: Protect the Monterey Bay National Marine Sanctuary and the shoreline and views to and along the ocean, recognizing their value as natural and recreational resources.  Open Space Lands Program 3.5.5: Develop and implement plans to maximize public access and enjoyment of recreations areas along the coastline.  Biotic Diversity and Stability Program 4.2.5: Protect and minimize the impact of development on bird, fish and wildlife habitat in and adjacent to waterways.  Biotic Diversity and Stability Program 4.1.5: Protect the quality of water discharged into the Bay and allow no dumping of materials into the Monterey Bay.

Recreational access to the beach will remain unaffected, and the proposed actions will avoid negative impacts to availability of free public parking and access to the shore.

Placement of signage on existing signposts will not detrimentally affect any mapped high-impact, environmentally sensitive sites within the Coastal Zone.

Design Permit, Section 24.08.430

17. The site plan shall be consistent with physical development policies of the General Plan, any required or optional element of the General Plan, any area plan or specific plan or other city policy for physical development. If located in the Coastal Zone, a site plan shall also be consistent with policies of the Local Coastal Program.

35.37 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc The proposed project retains the residential density of the subject site and neighborhood, conforms to all applicable General Plan policies in place, and conforms to the intent of the General Plan for maintenance of compatibility in form to surrounding land uses and complementarity to neighboring structures with regard to proposed scale, materials, and use. The project site is located in the Coastal Zone, and the project remains consistent with applicable policies of the Local Coastal Program.

18. The exterior design and appearance of buildings and structures and the design of the site plan shall be compatible with design and appearance of other existing buildings and structures in neighborhoods which have established architectural character worthy of preservation.

The above finding remains inapplicable.

19. Design of the site plan shall respect design principles in terms of maintaining a balance of scale, form and proportion, using design components, which are harmonious, materials and colors that blend with elements of the site plan and surrounding areas. Location of structures should take into account maintenance of view; rooftop mechanical equipment shall be incorporated into roof design or screened from adjacent properties. Utility installations such as trash enclosures, storage units, traffic-control devices, transformer vaults and electrical meters shall be accessible and screened.

The above finding remains inapplicable.

20. Where a site plan abuts, or is in close proximity to, uses other than that proposed, the plan should take into account its effect on other land uses. Where a nonresidential use abuts or is in close proximity to a residential use, the effect of the site plan should maintain the residential quality of adjacent or nearby areas.

The above finding remains inapplicable.

21. The orientation and location of buildings, structures, open spaces and other features of the site plan shall be such as to maintain natural resources including significant trees and shrubs to the extent feasible, maintain a compatible relationship to and preserve solar access of adjacent properties, and minimize alteration of natural land forms, building profiles, location, and orientation must relate to natural land forms.

The above finding remains inapplicable.

22. The site plan shall be situated and designed to protect views along the ocean and of scenic coastal areas. Where appropriate and feasible, the site plan shall restore and enhance visual quality of visually degraded areas.

35.38 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc The above finding remains inapplicable.

23. The site plan shall minimize the effect of traffic conditions on abutting streets through careful layout of the site with respect to location, dimensions of vehicular and pedestrian entrances, exit drives and walkways; through the adequate provision of off-street parking and loading facilities; through an adequate circulation pattern within the boundaries of the development; and through the surfacing and lighting of off-street parking facilities.

The above finding remains inapplicable.

24. The site plan shall encourage alternatives to travel by automobile where appropriate, through the provision of facilities for pedestrians and bicyclists, including covered parking for bicycles and motorcycles where appropriate. Public transit stops and facilities shall be accommodated as appropriate, and other incentive provisions considered which encourage non-auto travel.

The above finding remains inapplicable.

25. The site shall provide open space and landscaping which complement buildings and structures. Open space should be useful to residents, employees, or other visitors to the site. Landscaping shall be used to separate and/or screen service and storage areas, separate and/or screen parking areas from other areas, break up expanses of paved area, and define open space for usability and privacy.

The above finding remains inapplicable.

26. The site plan shall reasonably protect against external and internal noise, vibration and other factors, which may tend to make the environment less desirable. The site plan should respect the need for privacy of adjacent residents.

The above finding remains inapplicable.

27. Signs shall complement the site plan and avoid dominating the site and/or existing buildings on the site or overwhelming the buildings or structures to which they are attached. Multiple signs on a given site should be of a consistent theme.

The above finding remains inapplicable.

28. Building and structures shall be so designed and oriented to make use of natural elements such as solar radiation, wind, and landscaping for heating, cooling and ventilation.

The above finding remains inapplicable.

35.39 AGENDA REPORT
ZA Meeting of April 17, 2024
SUBJECT: City Street Sweeping in Coastal Zone– Application No. CP23-0144

P:\_Public\PACKETS\2024\4 - ZA\4-17-24\Public ROW in Costal Zone - Street Sweeping\CP23-0144 Staff Report.doc

29. The site plan shall incorporate water-conservation features where possible, including in the design of types of landscaping and in the design of water-using fixtures. In addition, water restricting showerheads and faucets shall be used, as well as water-saving toilets utilizing less than three gallons per flush.

The above finding remains inapplicable.

30. In all projects in Industrial (I) Zones, all buildings and structures shall be so designed and oriented to make use of natural lighting wherever possible.

The above finding remains inapplicable.

Submitted by:

Timothy Maier
Senior Planner
Approved by:

Brittany Whitehill
Senior Planner
Attachments:

1. Conditions of Approval

2. Project Plans, prepared by staff of the City’s Public Works Department dated January 2024

3. Staff Report to Transportation and Public Works Commission of January 22, 2024

4. Presentation to Transportation and Public Works Commission dated February 26, 2024

35.40 City Council

AGENDA REPORT
DATE: 08/08/2024
AGENDA OF: 08/27/2024
DEPARTMENT: Public Works
SUBJECT: No-Parking Street Sweeping Pilot Program (PW)
RECOMMENDATION: Motion to:
1) Adopt a resolution to approve parking restrictions for the pilot street sweeping program in Zones 1-4 during posted hours and direct the City Manager or designee to implement the 1-year pilot program;
2) Provide support and recommend parking restrictions for the pilot street sweeping program in Zones 5-6 and adopt a resolution to approve parking restrictions for the pilot street sweeping program in Zones 5-6 during posted hours and direct the City Manager or designee to implement the 1-year pilot program upon approval of the Coastal Development Permit. Zones 5-6 are located within the Coastal Zone, the Coastal Development Permit will be subject to a Coastal Commission appeal period following approval by the Council; and 3) Direct staff to return before the conclusion of the No-Parking Street Sweeping Pilot Program with findings and recommendations.

BACKGROUND: This pilot program aims to improve street sweeping effectiveness, reduce trash from entering the Monterrey Bay National Marine Sanctuary, and ensure compliance with State Stormwater permit regulations by implementing No-Parking/Tow-Away zones during specific hours. Historically, the Public Works Resource Recovery division has provided street sweeping services citywide. The program attempts to sweep all commercial zones at least weekly and residential zones twice a month. Streets are typically swept following the refuse collection days. The City of Santa Cruz (City) has limited parking restrictions in place for street sweeping and parked vehicles often obstruct the sweepers’ access to the curb and gutter areas which reduces the effectiveness of the City’s sweeping operation. The street sweeper regularly needs to navigate around parked vehicles which results in missing 20-30 feet of curb on either side of the car. The trash accumulated in these curb and gutter areas eventually flows into the storm drains and ultimately to the Monterey Bay. The City is mandated by the State Stormwater permit and State Trash Amendment to reduce trash levels within city streets.

For several years, the City has utilized a third-party organization to access trash levels on city streets in accordance with the State Stormwater permit. These third-party trash assessments also provide staff data on the effectiveness of our sweeping program. While most of the city is categorized with “low” trash levels, several areas were identified with “moderate” trash levels.

35.41 These moderate trash areas are primarily the Ocean Street corridor, Soquel Drive and Water Street areas, the Harvey West area, and the far westside, primarily Delaware and Mission Stret Extension areas.

The No-Parking Street Sweeping Pilot Program was developed as a low cost/high impact tool to improve street sweeping efficiency in targeted areas. This pilot will also help assess how the program could be implemented in remaining moderate trash areas including residential areas with high street parking demand. The streets of concern and focus were initially organized into six sweeping zones to form the basis of pilot.

The No-Parking Street Sweeping Pilot program applies to all vehicle types and the program’s goal is to enhance street sweeping efficiency and reduce trash levels within City streets.

The Pilot Program was initially presented at the Transportation and Public Works Commission (TPWC) held on February 26, 2024. The TPWC passed a motion to recommend to City Council to adopt parking restrictions for the pilot street sweeping program in Zones 1-6, with the addition that staff provide an implementation plan that includes more details on enforcement and outreach and that staff provide an update on the project at some point in the pilot to the commission. The draft enforcement and outreach plan is attached for reference.

Zones 5 and 6 are located within the Local Coastal Zone therefore changes to parking require a Coastal Permit. On April 17, 2024, the City Zoning Administrator (ZA) approved the Coastal Permit and Design Permit (CP23-0144) for proposed limitation of hours of public parking and placement of new signage for sweeping of City streets within Zones 5-6 of the pilot program which are located within the Coastal Zone. The City will file a new FLAN (Final Local Action Notice) with the Coastal Commission after the 8/27 Council meeting. The Coastal Development Permit will be subject to a Coastal Commission appeal period following approval by the Council.

DISCUSSION: The pilot program has established six zones using the alternate side of the streets:
- Zones 1 and 2 are in the Harvey West area;
- Zones 3 and 4 are along the Ocean, Soquel, and Water Street corridors; and - Zones 5 and 6 are in on the far Westside in the Delaware area.

These areas are all currently swept, however parked cars restrict street sweeper access to the curb, gutter and bike lane, where most of the trash accumulates. The specific streets affected, along with the number of parking spaces impacted during the two-hour timeframe are listed below:

Zone 1 Wednesday:

Encinal Street from River Street to Dubois Street (30 spaces) Dubois Street to Harvey West Boulevard (23 spaces)
Harvey West Boulevard to Coral Street (58 spaces)
Coral Street to River Street (68 spaces)
Zone 2 Friday:

Coral Street from River Street to Harvey West Boulevard (30 spaces) Harvey West Boulevard from Coral Street to Dubois Street (61 spaces)

35.42 Dubois Street from Harvey West Boulevard to Encinal Street (30 spaces) Encinal Street to River Street (28 spaces)
Zone 3 Tuesday:

Ocean Street from Ocean Street Extension to Soquel Avenue (66 spaces) Soquel Avenue to Morrissey Boulevard (80 spaces)
Water Street from Morrissey Boulevard to North Branciforte Avenue (43 spaces) Zone 4 Thursday:

Water Street from Market Street to Poplar Avenue (41 spaces) Soquel Avenue from Poplar Avenue to Ocean Street (46 spaces) Ocean Street from Soquel Avenue to Plymouth Street (50 spaces) Zone 5 Tuesday (located in Coastal Zone):

Mission Street Extension from Swift Street to Natural Bridges Drive (67 spaces) Natural Bridges Drive to Delaware Avenue (80 spaces)
Delaware Avenue from Shaffer Road to Swift Street (140 spaces) Swanton Boulevard from Delaware Avenue to West Cliff Drive (79 spaces) Zone 6 Thursday (located in Coastal Zone):

Natural Bridges Drive from Delaware Avenue to Mission Street Extension (66 spaces) Mission Street from Western Drive to Swift Street (77 spaces) Delaware Avenue from Swift Street to Shaffer Road (147 spaces) Swanton Boulevard from West Cliff Drive to Delaware Avenue (45 spaces) As previously stated, Zones 5 and 6 are located within the California Coastal Commission coastal jurisdiction zone and required an administrative coastal permit. The coastal permit application (CP23-0144) was approved by the City’s Zoning Administrator. The Coastal Development Permit will be subject to a Coastal Commission appeal period following approval by the Council.

Communications and Outreach: Outreach elements will include use of a dedicated pilot program City website, warning signs on barricades prior to launch, and notices to businesses.

Parking Restrictions: The street sweeping pilot program will temporarily restrict parking for a 2- hour maximum period between the hours of 5AM and 7AM on alternate days. For example, the south side of the street would be swept on Tuesday and the north side would be swept on Thursdays. This would still allow some parking on the alternate side of the street during a sweeping day. The City has selected the 2-hour period from 5AM to 7AM to minimize the impact on residents, students, employers and coastal access. Timeframes may be adjusted within this 2-hour period. The pilot program will also exclude parking restrictions during holidays. To assure that the sweepers have access to these areas during this time period the areas would be posted with “No Parking Tow Away” signage. Signs will be posted on the existing signposts in all the areas wherever possible.

Citations: During the pilot program, the City intends to issue warning citations for all first-time violations of the program to assist with public outreach and education of the new parking restrictions. The City will be issuing parking citations with a $48.00 base violation amount for any subsequent parking violation related to the pilot street sweeping program. The City is also

35.43 developing an escalating citation fee schedule (example shown below) associated with this violation as a method to help reduce improper parking and will return to Council for future consideration of the fee schedule should initial efforts under current practices be deemed unsuccessful. Citations are eligible for appeal by the registered owner or operator of the vehicle.

While the City reserves the right to tow vehicles (Municipal Code 10.12.100) impeding access to properly conduct street sweeping operation at any time, towing is intended as a last resort outside of emergency situations or in advance of inclement weather events that pose a potential risk to safety and flooding.

Example of the escalating fee schedule:

Citation Description: NO PARKING AREA
Violation Code 10.40.040
- Base Violation Amount: $48.00
-1st Violation: Reduced to Warning
- 2nd Violation: $48.00
- 3rd Violation: $96.00
- 4th Violation and Beyond: $144.00
The No-Parking/Tow Away street sweeping pilot program is intended to be implemented in Fall of 2024 and last for a one-year period from the date of implementation. A 1-year minimum pilot is recommended to ensure sufficient data collection. The program will be evaluated throughout the implementation. Evaluation will include the successes and challenges with the pilot program locations. Metrics for evaluation include trash reduction levels, enforcement actions, findings and observations from street sweeper vehicle operators and public feedback during pilot program. Staff will also provide an update midway through the pilot to the TPWC.

The pilot is estimated to cost $50,000 for the manufacture and installation of the no-parking signs associated with this project. Since this program falls under current sweeping operation, there should be no increase in sweeping costs, it’s anticipated that it will improve the efficiency of the current sweeping efforts. There may be some increased costs related to parking control and towing, but those additional costs should be offset by the fines generated by noncompliance.

Plans and signage can be found at: www.cityofsantacruz.com/publicworksprojects FISCAL IMPACT: Funds are available in the FY 2025 operating budget in the Refuse Fund.

There is no impact to the General Fund.

Prepared By:

Eric Dhakni
Associate Planner II
Submitted By:

Nathan Nguyen, P.E.

Director of Public Works
Approved By:

Matt Huffaker
City Manager
ATTACHMENTS:

1. RESOLUTION.DOCX

2. IMPLEMENTATION AND OUTREACH PLAN.PDF

3. COASTAL DEVELOPMENT PERMIT (CP23-0144).PDF

4. STREET SWEEPING PILOT PLANS 2024.PDF

35.44 STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION CENTRAL COAST DISTRICT
725 FRONT STREET, SUITE 300
SANTA CRUZ, CA 95060
PHONE: (831) 427-4863
EMAIL: [email protected]
WEB: WWW.COASTAL.CA.GOV
Th13a
Appeal Filed: 10/2/2024
Action Deadline: 12/13/2024
Staff: Kiana Ford - SC
Staff Report: 10/25/2024
Hearing Date: 11/14/2024

STAFF REPORT

SUBSTANTIAL ISSUE DETERMINATION ONLY
Appeal Number: A-3-STC-24-0044
Applicant: City of Santa Cruz
Appellant: Reginald Meisler
Local Government: City of Santa Cruz
Local Decision: Coastal development permit application number CP23-0144 approved by the City of Santa Cruz Zoning Administrator on April 17, 2024.

Location: Delaware Avenue, Natural Bridges Drive, Swanton Boulevard, and Mission Street Extension within the City of Santa Cruz.

Project Description: Implementation of a one-year pilot project to prohibit public parking between 5am and 7am twice a week (on Tuesdays
and Thursdays, one side of the street each) to facilitate street sweeping along such streets, and related measures (i.e., signage, enforcement, etc.).

Staff Recommendation: No Substantial Issue

IMPORTANT HEARING PROCEDURAL NOTE
Please note that this is a substantial issue only hearing, and testimony will be taken only on the question of whether the appeal raises a substantial issue. Such testimony is generally limited to three minutes total per side (although the Commission’s Chair has the discretion to modify these time limits), so please plan your testimony accordingly.

Only the Applicant, persons who opposed the application before the local government, the local government, and their proxies/representatives are allowed to testify during this substantial issue phase of the hearing. Other interested parties may submit comments

35.45 A-3-STC-24-0044 (Street Sweeping Program)

in writing. If the Commission finds that the appeal raises a substantial issue, then the Commission takes jurisdiction over the underlying coastal development permit (CDP) application and will then review that application at a future Commission meeting, at which time all persons are invited to testify. If the Commission finds that the appeal does not raise a substantial issue, then the local government CDP decision stands, and is thus final and effective.

SUMMARY OF STAFF RECOMMENDATION
The City of Santa Cruz approved a CDP for a one-year pilot project to limit parking along four city streets (Mission Street Extension, Natural Bridges Drive, Swanton Boulevard, and Delaware Avenue) within the coastal zone between the hours of 5am and 7am on one side of the street on Tuesday and on the opposite side of the street on Thursday (i.e., vehicles would be allowed to park on the opposing side of the street during those hours). The City contends that the parking restrictions are necessary in order to allow the City’s street sweeping vehicles to access debris and trash that accumulates between parked vehicles and the curb, where normally parked vehicles impede such access and lead to refuse accumulation along areas linked to storm drainage systems. The City contends that the approved project will not negatively impact public access in those areas because the implementation is limited to a two-hour period in the very early morning where the majority of coastal access users are asleep, and because the subset of coastal access users that do utilize those parking spots during that time may park on the opposite side of the street. Further, the pilot project is intended to improve coastal resources by removing debris and trash and preventing such refuse from entering storm drainage systems and potentially migrating out into Monterey Bay.

The Appellant contends that the City’s approval of the project raises LCP and Coastal Act consistency questions relating to public access, environmental justice, and water quality. Specifically, the Appellant argues that the program’s parking restrictions do not maximize public access and would in fact limit public access; that the program violates Coastal Act environmental justice provisions and the Commission’s Environmental Justice Policy because the program would disproportionately affect unhoused individuals who reside in their vehicles; and that the City’s justification for such a program (i.e., higher trash levels on select streets that affect water quality) is not justified. After reviewing the local record, Commission staff recommends that the Commission find that the City’s CDP approval does not raise a substantial issue with respect to the project’s conformance with the City LCP and Coastal Act.

Overall, staff agrees that restrictions on public coastal access are not something to be taken lightly, including because the Coastal Act and LCP speak to maximizing public access, and arguably restrictions inherently do not do that. At the same time, the Coastal Act and LCP do not stand for such access at all costs, and instead provide for management, and sometimes restrictions, to address issues related to overuse, natural resource protection, and other needs. It is through this review lens that the Commission typically evaluates public access restrictions, including whether it is narrowly tailored to address the particular impact/goal it seeks to address. In this case staff believes that the City’s pilot program meets such tests and can be found Coastal Act and LCP compliant.

35.46 A-3-STC-24-0044 (Street Sweeping Program)

Here, the public access question before the Commission is whether the City-approved program affects the public’s ability to access and recreate in the coastal zone. As noted, the project would operate between 5am and 7am twice a week, a time when public access pursuits are typically quite limited and would still allow all coastal access users to park on one side of the street during those hours (put another way, the program would only impact half of the street’s parking for a limited time two times per week).

Thus, the effect of the City’s action on public access is minimal in staff’s view and the design of the program allows for continued coastal access in the area during those times.

And in terms of water quality, staff believes that the City justified their action based off of independent evaluation of street cleanliness, including efforts initiated as a part of their obligations to comply with State Water Resources Board Clean Water Act requirements.

Arguably, allowing street sweeping vehicles to better access street curbs will invariably lead to reductions in trash accumulation and help to avoid impacts to water quality; whether that reduction is meaningful or not is part of the evaluation of this one-year pilot program. And finally, while the program will require vehicles parked on those sides of the streets to relocate between 5am and 7am (whether to the other side of the street or elsewhere), such an impact is minimal in terms of coastal resource impacts, as the pilot program still allows for such individuals to access the coast. Here, the City is seeking to evaluate improvements to its existing street sweeping program and has other programs (including the City’s Oversized Vehicle and Safe Parking Program) that are intended to address the ongoing homelessness epidemic and provide services/resources to persons experiencing homelessness, and the City’s approval does not represent disproportionate public access impacts to an environmental justice community (here, unhoused individuals who sleep in their vehicles).1
As a result, staff recommends that the Commission determine that the appeal contentions do not raise a substantial LCP and Coastal Act access conformance issue, and that the Commission decline to take jurisdiction over the CDP application for this project. The project at its core is a basic municipal street sweeping function, designed to be carried out in a manner that does not raise any significant public coastal access problems, and is only for an initial one year term to assess its efficacy at reducing trash and protecting the environment. The single motion necessary to implement this recommendation is found on page 5 below.
1 As it applies specifically to oversized vehicles, the City’s Oversized Vehicle and Safe Parking Program prohibits parking of oversized vehicles on City streets between midnight and 5am, and also provides free overnight safe parking locations with various services in the City for overnight vehicles (see City CDP CP23-0176). That safe parking program allows oversized vehicles to park until 8am, and so oversized vehicles that are already not allowed until 5am on these four streets have an alternative safe place to park even when street sweeping may occur. Thus, the Appellant’s observation that potential parking citations would lead to disproportionate public access impacts to unhoused individuals who sleep in vehicles at night is belied by the facts that all vehicles – whether used for habitation or not – have available alternatives for parking that avoids citations (and such alternatives are low-barrier for those with limited resources) during the 5am to 7am street sweeping time, including parking across the street, on other streets, or, in the case of oversized vehicles, availing themselves of the City’s free safe parking program; and the actual public access impact of street sweeping parking restrictions between 5am and 7am is negligible given the limited nature of such pursuits at that hour.

35.47 A-3-STC-24-0044 (Street Sweeping Program)

TABLE OF CONTENTS

1. MOTION AND RESOLUTION ................................................................................... 5

2. FINDINGS AND DECLARATIONS............................................................................ 5 A. Project Description and Location.......................................................................... 5 B. City of Santa Cruz CDP Approval......................................................................... 6 C. Appeal Procedures............................................................................................... 6 D. Summary of Appeal Contentions.......................................................................... 8 E. Substantial Issue Determination........................................................................... 8

1. Public Access.................................................................................................. 8

2. Environmental Justice ................................................................................... 12

3. Water Quality ................................................................................................ 17

4. Conclusion .................................................................................................... 18

3. APPENDICES.......................................................................................................... 20 A. Substantive File Documents............................................................................... 20 B. Staff Contacts with Agencies and Groups .......................................................... 20

EXHIBITS
Exhibit 1 – City-Approved Street Sweeping Area
Exhibit 2 – City’s Final Local CDP Action Notice
Exhibit 3 – Appeal of City CDP Approval

35.48 A-3-STC-24-0044 (Street Sweeping Program)

1. MOTION AND RESOLUTION
Staff recommends that the Commission determine that no substantial issue exists with respect to the grounds on which the appeal was filed. A finding of no substantial issue would mean that the Commission would not take jurisdiction over the underlying CDP application for the proposed project and would not conduct further hearings on this matter, and that the local government CDP decision stands and is thus final and effective. To implement this recommendation, staff recommends a yes vote on the following motion which, if passed, will result in the recommended no substantial issue finding. If the motion fails, then the Commission will have instead found a substantial issue and will instead take jurisdiction over the subject CDP application for future hearing and action. The motion passes only by an affirmative vote of a majority of the Commissioners present.

Motion: I move that the Commission determine that Appeal Number A-3-STC24-0044 raises no substantial issue with respect to the grounds on which the appeal has been filed under Section 30603, and I recommend a yes vote.

Resolution to Find No Substantial Issue. The Commission finds that Appeal Number A-3-STC-24-0044 does not present a substantial issue with respect to the grounds on which the appeal has been filed under Section 30603 of the Coastal Act regarding consistency with the certified Local Coastal Program and/or the public access policies of the Coastal Act.

2. FINDINGS AND DECLARATIONS
A. Project Description and Location
The City-approved project would prohibit parking of vehicles on certain sides of four public streets within the coastal zone between 5am and 7am on Tuesdays and Thursdays for a one-year “pilot” period to conduct street sweeping via the City’s array of street sweeping vehicles. Specifically, the project would affect four streets within the coastal zone on the City’s westside: Delaware Avenue, Natural Bridges Drive, Swanton Boulevard, and Mission Street Extension.2 The pilot program would prohibit parking on one side of the street on Tuesdays (but allow parking on the opposite side of the street) and prohibit parking on the other side of the street on Thursdays (again, with the ability to park on the opposite side of the street), thereby ensuring that at least one side of each affected street is available for public parking during such sweeping activities. The program would also install signage to alert the public of the program and indicate the penalties for parking during those sweeping times (i.e., towing and/or fines).

The City indicates that the reason for the City-approved program is to address ongoing public health and water quality issues associated with accumulated trash in these areas.

While the City already has a City-wide street sweeping program in place, the existing program does not prohibit cars from parking during street sweeping operations. The City asserts that trash and other debris frequently accumulates between parked cars and the 2 The City-approved program also includes four other routes outside of the coastal zone (see Exhibit 2).

35.49 A-3-STC-24-0044 (Street Sweeping Program)

curb and that the street sweepers are unable to reach such material during normal operations, leading to the eventual migration of material into storm drains and out into waterways. Thus, the one-year pilot program is intended to evaluate the effectiveness of modified street sweeping operations via the prohibition of parking (including via assessing the amount of trash picked up, evaluating street cleanliness, and determining the amount of enforcement necessary) and after a year, reassess whether to extend the program for subsequent years via a new CDP action.

See Exhibit 1 for a map of the City-approved parking restriction area and see Exhibit 2 for the City-approved project description and conditions.

B. City of Santa Cruz CDP Approval
On April 17, 2024 the City of Santa Cruz Zoning Administrator approved a CDP for the proposed pilot street sweeping program. The Zoning Administrator approval was subsequently followed by City Council approval on August 27, 2024. 3 The City’s Final
Local CDP Action Notice (see Exhibit 2) was received in the Coastal Commission’s Central Coast District Office on September 20, 2024, and the Coastal Commission’s ten-working-day appeal period for this action began on September 23, 2024 and concluded at 5 p.m. on October 4, 2024. One valid appeal (discussed below) was received during the appeal period.

C. Appeal Procedures
Coastal Act Section 30603 provides for the appeal to the Coastal Commission of certain CDP decisions in jurisdictions with certified LCPs. The following categories of local CDP decisions are appealable: (a) approval of CDPs for development that is located (1) between the sea and the first public road paralleling the sea or within 300 feet of the inland extent of any beach or of the mean high tide line of the sea where there is no beach, whichever is the greater distance, (2) on tidelands, submerged lands, public trust lands, within 100 feet of any wetland, estuary, or stream, or within 300 feet of the top of the seaward face of any coastal bluff, and (3) in a sensitive coastal resource area; or (b) for counties, approval of CDPs for development that is not designated as the principal permitted use under the LCP. In addition, any local action (approval or denial) on a CDP for a major public works project (including a publicly financed recreational facility and/or a special district development) or an energy facility is appealable to the Commission.

This City CDP decision is appealable to the Commission because some of the project sites are located between the first public road and the sea, and because it is a major public works project.

For appeals of a CDP approval, grounds for appeal are limited to allegations that the approved development does not conform to the LCP and/or to Coastal Act public access provisions. For appeals of a CDP denial, where allowed (i.e., such appeals are only allowed in extremely limited circumstances – see description of appealable actions, 3 The Zoning Administrator approved the CDP for the project, but the project’s overall implementation and enforcement (including for sites located outside of the coastal zone) required authorization by the City Council. Thus, the Council’s action constituted the final City action on the CDP application for the project.

35.50 A-3-STC-24-0044 (Street Sweeping Program)

above), the grounds for appeal are limited to allegations that the development conforms to the LCP and to Coastal Act public access provisions.

The Commission’s consideration of appeals is a two-step process. The first step is determining whether the appeal raises a substantial issue that the Commission, in the exercise of its discretion, finds to be significant enough to warrant the Commission taking jurisdiction over the CDP application. This step is often referred to as the “substantial issue” phase of an appeal. The Commission is required to begin its hearing on an appeal, addressing at least the substantial issue question, within 49-working days of the filing of the appeal unless the applicant has waived that requirement, in which case there is no deadline.

The Coastal Act and the Commission’s implementing regulations are structured such that there is a presumption of a substantial issue when the Commission acts on this question, and the Commission generally considers a number of factors in making that determination.4 At this stage, the Commission may only consider issues brought up by the appeal. At the substantial issue hearing, staff will make a recommendation for the Commission to find either substantial issue or no substantial issue. If staff makes the former recommendation, the Commission will not take testimony at the hearing on the substantial issue recommendation unless at least three Commissioners request it, and, if no such hearing is requested, a substantial issue is automatically found. In both cases, when the Commission does take testimony, it is generally (and at the discretion of the Commission Chair) limited to three minutes total per side, and only the Applicant, persons who opposed the application before the local government, the local government, and their proxies/representatives are allowed to testify, while others may submit comments in writing.

If, following testimony and a public hearing, the Commission determines that the appeal does not raise a substantial issue, then the first step is the only step, and the local government’s CDP decision stands. However, if the Commission finds a substantial issue, the Commission takes jurisdiction over the underlying CDP application for the proposed project, and the appeal heads to the second phase of the hearing on the appeal.

In the second phase of the appeal, the Commission must determine whether the proposed development is consistent with the applicable LCP (and in certain circumstances the Coastal Act’s public access and recreation provisions). This step is 4 The term substantial issue is not defined in the Coastal Act. The Commission's regulations simply indicate that the Commission will hear an appeal unless it “finds that the appeal raises no substantial issue…” (California Code of Regulations, Title 14, Section 13115(b)). Section 13115(c) of the Commission regulations provides, along with past Commission practice, that the Commission may consider the following five factors when determining if a local action raises a significant issue: (1) the degree of factual and legal support for the local government’s decision that the development is consistent or inconsistent with the certified LCP and the Coastal Act’s public access provisions; (2) the extent and scope of the development; (3) the significance of the coastal resources affected by the decision; (4) the precedential value of the local government’s decision for future interpretation of its LCP; and (5) whether the appeal raises only local issues, or those of regional or statewide significance. The Commission may, but need not, assign a particular weight to a factor, and may make a substantial issue determination for other reasons as well.

35.51 A-3-STC-24-0044 (Street Sweeping Program)

often referred to as the “de novo” review phase of an appeal, and it entails reviewing the proposed project in total. There is no legal deadline for the Commission to act on the de novo phase of an appeal. Staff will make a CDP decision recommendation to the Commission, and the Commission will conduct a public hearing to decide whether to approve, approve with conditions, or deny the subject CDP. Any person may testify during the de novo phase of an appeal hearing (if applicable).

D. Summary of Appeal Contentions
The Appellant contends that the City’s CDP approval raises LCP consistency questions relating to public access, environmental justice, and water quality. Specifically, the Appellant contends that the approved project would violate applicable LCP policies because (1) it does not maximize public access and would in fact limit public access via the program’s parking limitations and enforcement protocols; (2) it violates Coastal Act environmental justice provisions and the Commission’s Environmental Justice Policy because it would unfairly impact access to the coast for low-income individuals and individuals who use their vehicles for shelter; and (3) the City’s water quality concerns regarding trash accumulation on these specific streets are not justified. Please see Exhibit 3 for the full appeal document.

E. Substantial Issue Determination

1. Public Access
Applicable Coastal Act and LCP Provisions
The Appellant does not cite to specific LCP or Coastal Act public access policies, but applicable policies on this point include the following Coastal Act provisions:

Section 30210. In carrying out the requirement of Section 4 of Article X of the California Constitution, maximum access, which shall be conspicuously posted, and recreational opportunities shall be provided for all the people consistent with public safety needs and the need to protect public rights, rights of private property owners, and natural resource areas from overuse.

Section 30211. Development shall not interfere with the public's right of access to the sea where acquired through use or legislative authorization… Section 30212. (a) Public access from the nearest public roadway to the shoreline and along the coast shall be provided in new development projects … Section 30213. Lower cost visitor and recreational facilities shall be protected, encouraged, and, where feasible, provided. Developments providing public recreational opportunities are preferred …
Section 30214. (a) The public access policies of this article shall be implemented in a manner that takes into account the need to regulate the time, place, and manner of public access depending on the facts and circumstances in each case including, but not limited to, the following: (1) Topographic and geologic site characteristics. (2) The capacity of the site to sustain use and at what level of intensity. (3) The appropriateness of limiting public access to the right to pass

35.52 A-3-STC-24-0044 (Street Sweeping Program)

and repass depending on such factors as the fragility of the natural resources in the area and the proximity of the access area to adjacent residential uses. (4) The need to provide for the management of access areas so as to protect the privacy of adjacent property owners and to protect the aesthetic values of the area by providing for the collection of litter.
(b) It is the intent of the Legislature that the public access policies of this article be carried out in a reasonable manner that considers the equities and that balances the rights of the individual property owner with the public's constitutional right of access pursuant to Section 4 of Article X of the California Constitution.

Nothing in this section or any amendment thereto shall be construed as a limitation on the rights guaranteed to the public under Section 4 of Article X of the California Constitution.

Section 30223. Upland areas necessary to support coastal recreational uses shall be reserved for such uses, where feasible.

Section 30240(b). Development in areas adjacent to … 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 … recreation areas.

LCP public access provisions both reiterate and amplify these Coastal Act provisions, including stating in the LCP’s Land Use Plan (LUP):

LUP Parks and Recreation Policy 1.7. Develop plans to repair, maintain and maximize public access and enjoyment of recreational areas along the coastline consistent with sound resource conservation principle[s], safety, and rights of private property owners.

LUP Parks and Recreation Policy 1.7.1. Maintain and enhance vehicular, transit, bicycling and pedestrian access to coastal recreation areas and points.

LUP Land Use Policy 3.5. Protect coastal recreation areas, maintain all existing coastal access points open to the public, and enhance public access, open space quality and recreational enjoyment in a manner that is consistent with the California Coastal Act.

LUP Land Use Policy 3.5.3. Require new development and public works projects to provide public access from the nearest public roadway to the shoreline and along the coast, except where it is inconsistent with public safety, protection of fragile coastal resources, or where adequate access exists nearby.

LUP Land Use Policy 3.5.5. Develop and implement plans to maximize public access and enjoyment of recreation areas along the coastline.

In sum, Coastal Act Section 30210 and LCP Policy 3.5 require Coastal Act-authorized development to maximize public access and recreational opportunities. Coastal Act Section 30211 prohibits development from interfering with the public’s right of access to

35.53 A-3-STC-24-0044 (Street Sweeping Program)

the sea where acquired through use or by legislation. In approving new development, Section 30212 requires new development to provide access from the nearest public roadway to the shoreline and along the coast, save certain limited exceptions, such as existing adequate nearby access, and 30213 protects existing and encourages new lower cost forms of access. Section 30214 allows for public access policies to consider the unique characteristics of new development, and to allow for public access to be tailored in an appropriate manner in light of that context. Sections 30220, 30221, and 30223 protect coastal, oceanfront, and upland areas for public access and recreational uses. New development in areas adjacent to parks and recreational areas must protect those areas under Section 30240(b). Similarly, LUP Policies 1.7 and 3.5.5 direct the City to develop (and implement in terms of Section 3.5.5) plans to maintain and maximize public access and enjoyment of recreational areas along the coast. And LUP Policy 1.7.1 requires that all forms of access to recreational areas and destinations be maintained and even enhanced, including vehicular access. Finally, LUP Policy 3.5.3 requires new development, and explicitly public works projects such as this one, to provide public access from the nearest public roadway to the shoreline and along the coast unless it is already adequately provided, or where public safety or coastal resource concerns would demand otherwise.

Analysis
Coastal Act Section 30210 and LUP Policy 3.5 requirements to maximize recreational access opportunities represent a different threshold than to simply provide or protect such opportunities, and are fundamentally different from other like provisions in this respect: it is not enough to simply provide such opportunities to and along the coast, and not enough to simply protect such opportunities; rather such opportunities must also be maximized. These policies provide fundamental direction with respect to projects along the California coast when public access issues are raised, as here where the Appellant makes it a central theme of the appeal. Taken together, these overlapping policies require maximization of public access and recreation opportunities for the public and including explicitly vehicular access opportunities via the LCP.

At the same time, the Coastal Act and the LCP also require that such access not be maximized at all costs, and explicitly require that the public access provisions be implemented in a way that takes into account the “time, place, and manner of public access depending on the facts and circumstances in each case”, including evaluating the capacity of the area in question to sustain use and at what level of intensity, the potential need for “limiting public access to the right to pass and repass depending on such factors as the fragility of the natural resources in the area and the proximity of the access area to adjacent residential uses,” and “[t]he need to provide for the management of access areas so as to protect the privacy of adjacent property owners and to protect the aesthetic values of the area by providing for the collection of litter” (Section 30214). Similarly, the direction in LUP Policy 1.7 to maximize public access and enjoyment of recreational areas is tempered by the need for such maximizing to be consistent with “sound resource conservation principle[s], safety, and rights of private property owners”. And LUP Policy 3.5.3 similarly refers to the need to evaluate public safety, coastal resources, and the adequacy of nearby access when considering how the otherwise required access is to be provided. Thus, when the Commission considers development that may impact public access, as in this appeal, the Coastal Act and the

35.54 A-3-STC-24-0044 (Street Sweeping Program)

LCP require the Commission to analyze the impacts wholistically and not to focus only on maximizing public recreational access opportunities in a vacuum.

As noted above, the Appellant suggests that the City-approved street sweeping project runs afoul of Coastal Act and LCP provisions to maximize public coastal access. They argue that a program that limits parking inherently interferes with the public’s access rights, particularly for those who reside in their vehicles and have no other options to access coastal locales, and that enforcement of such a program would ultimately cause severe public access limitations.

In local jurisdictions, parking restrictions are often proposed because of recognized problems with parking related issues. In such cases, it is important that the problem be clearly identified and substantiated, and that the response be as focused as possible to address the problem while avoiding public access impacts as much as possible. In this case, the City evaluated its existing street sweeping program and found identifiable issues in regards to debris accumulation and cleanup that could be addressed by the proposed pilot project. In particular, the City street sweeping program does not currently prohibit parking during the hours of program operation, leading to cars being parked (sometimes for extended periods of time) between the street sweeping vehicle and the curb. When trash and other debris accumulates between the parked vehicle and the curb (and/or under the vehicle), the street sweeper is unable to reach such refuse; in areas where parked cars are parked for longer term periods, such refuse can compound over time and can adversely affect coastal waterways and other sensitive habitats, and ultimately the ocean.

The City identified a select number of streets, both within and outside the coastal zone, with identified higher levels of debris accumulation where increased measures to address such debris accumulation is appropriate. The City-approved project would affect the ability of all vehicles to park on select City streets (see Exhibit 2) between the hours of 5am and 7am on alternating sides of the street, two days per week (for example, between 5am and 7am vehicles will be able to park only on the west side of a street on Tuesdays and able to park only the east side of a street on Thursdays).5 Further, such a program would be limited to a one-year pilot term to allow for evaluation of the implementation of the program and its effects on reducing refuse levels on these streets. The City worked to avoid any significant coastal access impact by limiting the duration of the parking prohibition (for only two hours per day in the very early morning outside of any peak period visitation times and only twice a week) and the location of the parking prohibition (i.e., on one side of the street only, rather than both sides of the street), such that the majority of public access and recreation opportunities would not be affected, given that most people are asleep during the hours between 5am and 7am and that recreational access users seeking parking at that time need simply park on the other side of the street to access the area during those hours. Thus, the proposed pilot program appropriately balances the City’s interest in improving their existing street 5 In the Coastal Zone, the streets affected are Delaware Avenue, Natural Bridges Drive, Swanton Boulevard, and Mission Street Extension.

35.55 A-3-STC-24-0044 (Street Sweeping Program)

sweeping program while preserving and providing public access. It also should help reduce trash accumulation and avoid coastal resource harm in this regard.

The Appellant disagrees that the programs effect on public access is minimal and points to the compounding effects of this pilot program in conjunction with the City’s Oversized Vehicle Program.6 They argue that the City-approved pilot program would further displace individuals that reside in their vehicles from the coast, thereby limiting their access to the coast, including because the financial burden when found not in compliance (i.e., parking citations) is not feasible for many.7,8 In response, the Commission agrees that restrictions on public coastal access are not something to be taken lightly, and, in this case, must be considered in the context of other related parking restrictions. The Coastal Act and LCP do speak to maximizing public access, and arguably, restrictions on such access inherently do not do so. That being said, as explained above, the Coastal Act and LCP do not stand for access at all costs, and instead provide for management, and sometimes restrictions, to address issues related to overuse, natural resource protection, and other needs. It is through this review lens that the Commission typically evaluates public access restrictions, including whether such restrictions are narrowly tailored to address the particular impact/goal they seek to address. Here, the City’s program meets such tests, as the City’s street sweeping pilot program is a basic municipal function meant to clean our public spaces, and is being carried out in a narrowly tailored manner with specific limited hours and locations to avoid any significant coastal access impact. The City’s approval allows flexibility for those parking on the affected streets to still park on said streets, albeit on certain sides of the street during certain days. In short, the project should help clean the City’s streets without any significant coastal access impairment, and can be found consistent with the Coastal Act and LCP.

For the above reasons, the City’s approval of a CDP for the proposed project does not raise a substantial issue of LCP conformance with respect to public access.

2. Environmental Justice
Applicable Coastal Act Provisions
The Coastal Act explicitly identifies the need for equity and environmental justice and allows the Commission to consider coastal resource issues and impacts through that lens in appeal cases, like this, even if the LCP itself may be silent on such issues. The Coastal Act states:

Section 30013. The Legislature further finds and declares that in order to advance the principles of environmental justice and equality, subdivision (a) of Section 11135 of the Government Code and subdivision (e) of Section 65040.12 6 Authorized by City CDP CP23-0176.
7 On this, the City-approved pilot program would issue warnings to any first-time offenders of the street sweeping restrictions, followed by a citation of $48 for repeat offenders. 8 The Appellant points out that street sweeping parking citations are the most commonly issued citations in the State of California.

35.56 A-3-STC-24-0044 (Street Sweeping Program)

of the Government Code apply to the commission and all public agencies implementing the provisions of this division. As required by Section 11135 of the Government Code, no person in the State of California, on the basis of race, national origin, ethnic group identification, religion, age, sex, sexual orientation, color, genetic information, or disability, shall be unlawfully denied full and equal access to the benefits of, or be unlawfully subjected to discrimination, under any program or activity that is conducted, operated, or administered pursuant to this division, is funded directly by the state for purposes of this division, or receives any financial assistance from the state pursuant to this division.

Section 30107.3. (a) “Environmental justice” means the fair treatment and meaningful involvement of people of all races, cultures, and incomes, and national origins, with respect to the development, adoption, implementation, and enforcement of environmental laws, regulations, and policies. (b) “Environmental justice” includes, but is not limited to, all of the following: (1) The availability of a healthy environment for all people. (2) The deterrence, reduction, and elimination of pollution burdens for populations and communities experiencing the adverse effects of that pollution, so that the effects of the pollution are not disproportionately borne by those populations and communities. (3) Governmental entities engaging and providing technical assistance to populations and communities most impacted by pollution to promote their meaningful participation in all phases of the environmental and land use decision making process. (4) At a minimum, the meaningful consideration of recommendations from populations and communities most impacted by pollution into environmental and land use decisions.

Section 30604(h). When acting on a coastal development permit, the issuing agency, or the Commission on appeal, may consider environmental justice, or the equitable distribution of environmental benefits throughout the state.

To implement its Coastal Act environmental justice authority, the Commission adopted an Environmental Justice Policy (“EJ Policy”) to guide and inform its decisions and procedures in a manner that is consistent with the provisions in, and furthers the goals of, Chapter 3 of the Coastal Act and certified LCPs. The EJ Policy further articulates environmental justice concepts, including stating:

The term “environmental justice” is currently understood to include both substantive and procedural rights, meaning that in addition to the equitable distribution of environmental benefits, underserved communities also deserve equitable access to the process where significant environmental and land use decisions are made.

Thus, the Commission’s EJ Policy underscores the importance of both substance (i.e., evaluating whether projects do or do not disproportionately distribute environmental benefits and burdens) and process (i.e., ensuring that those potentially affected by proposed development have an equitable opportunity to participate in a transparent public process).

Analysis

35.57 A-3-STC-24-0044 (Street Sweeping Program)

The main point of the Appellant’s contentions with the City-approved project is not about public recreational access per se (as discussed in the previous section), but rather about the impacts that the City-approved parking restriction have on unhoused individuals who use vehicles as a place to sleep in overnight. The primary substantive concern identified is that while the 5am to 7am restriction is limited and would apply equally to all persons attempting to park on those streets during those hours, it disproportionately impacts unhoused individuals who sleep at night in their vehicles, and, coupled with the City’s Oversized Vehicle Program, further places parking restrictions on unhoused individuals living in oversized vehicles.

Identifying Environmental Justice Communities
The first step in this environmental justice analysis is to determine whether unhoused individuals that use a vehicle as a place to sleep at night constitute an “environmental justice” community to which the Coastal Act’s environmental justice provisions and the Commission’s EJ Policy apply. If so, the next step is to identify to what extent the Cityapproved project may adversely and disproportionately affect those individuals. In answering these questions, the Commission’s consideration necessarily focuses on how the project’s coastal resource impacts may disproportionately affect such individuals compared to others affected by the project.9 The Commission is also tasked with ensuring that communities of concern can access the process to make their views known and to help shape the debate on potential local government and Commission decisions.

Based on the evaluation criteria set forth above, the Commission finds that unhoused individuals10 that use a vehicle as a place to sleep at night are an environmental justice community. The Coastal Act’s definition of environmental justice as set forth in Section 30107.3 above commits the Commission to the fair treatment and meaningful involvement of people of all “races, cultures, and incomes … with respect to the development, adoption, implementation, and enforcement of environmental laws, regulations, and policies.” Unhoused individuals who use a vehicle as a place to sleep at night can generally be classified as a lower income segment of the population that are acutely struggling to attain some of society’s most basic needs, such as safe and secure housing, making them particularly vulnerable to outside environmental hazards.

And finally, as part of the Commission’s EJ Policy development, Commission staff consulted a number of environmental justice experts in California who uniformly advised that, based on the characteristics of this vulnerable population, unhoused individuals who use a vehicle as a place to sleep at night qualify as members of an environmental 9 This focus derives from the fact that the Coastal Commission is a coastal management agency charged with the protection and enhancement of the State’s coastal resources. Thus, the Commission’s review of environmental justice issues is necessarily rooted in its evaluation of coastal resource benefits and burdens, as opposed to non-coastal resource issues, such as broader societal issues associated with public health and general welfare, which are the purview of other government agencies and entities. 10 According to the U.S. Department of Housing and Urban Development, people experiencing homelessness may have access to shelter or may be considered “unhoused” if their primary nighttime residence is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings, including a car, park, abandoned building, bus or train station, airport, or camping ground. The analysis in this report focuses on unhoused individuals who sleep in vehicles at night.

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justice community. Thus, the Commission here finds that such unhoused individuals, in this case those who sleep in vehicles at night, are an environmental justice community of concern to which the Coastal Act’s environmental justice provisions and the Commission’s EJ Policy apply.11
Potential Environmental Justice Concerns
As discussed above, the Commission’s environmental justice analysis is two-pronged, and refers to both potential procedural and substantive concerns. In terms of the former, the City provided an open and inclusive public forum for interested parties to participate.

The City conducted two public hearings, including before the City Zoning Administrator and the City Council. The Commission’s process has likewise been open and transparent, and Commission staff has maintained open lines of communication with engaged parties, including ultimately in terms of the notice and outreach associated with this report and the Commission hearing scheduled to take place on November 14, 2024.

In sum, there have been opportunities for active public participation.

In terms of substantive concerns, the question becomes whether the project would result in disproportionate adverse coastal resource impacts on the unhoused community, here expressed in terms of public access opportunities. The Appellant suggests that this project is meant to intimidate people living in their vehicles, as opposed to mitigating for trash, arguing that parking citations from street sweeping will negatively impact low-income and unhoused individuals living in their vehicles. The City states that street sweeping hours are limited and the program is designed to reduce the burden of infraction, as the first violation is a warning, rather than a citation, while subsequent citations escalate with each violation.12 At its core, and because environmental justice is a lens that can be applied to coastal resource concerns, and is not a Chapter 3 policy of its own, the Appellant suggests that these types of impacts would be disproportionately felt by individuals who sleep in their vehicles at night, and that this is thus a disproportionate public access burden not felt by others.

As discussed previously in the “Public Access” section of this report, while the Coastal Act requires that public recreational access opportunities be maximized, it also allows for limitations on such opportunities for a variety of reasons. These include providing for public safety, protecting against overuse and coastal resource degradation, limiting intensity of use, and providing management measures to address these issues, among other things. Sections 30210 and 30214 allow for the regulation of the time, place, and manner in implementing Coastal Act public recreational access policies. Put another way, if the City has a reasonable basis for limiting public recreational access during certain hours, such as based on public health, safety, and welfare, this can be found consistent with Coastal Act and LCP public access provisions. 11 Santa Cruz County regularly conducts what is known as a “point-in-time” count of unhoused individuals, the last of which occurred between 4:30am and 10am on January 25, 2024, where 1,850 individuals were identified Countywide, and 659 in the City of Santa Cruz (“Santa Cruz County Homeless Point-In-Time Count & Report 2024”, by Applied Survey Research).
12 The City is developing an escalating citation fee model that begins with a warning for the first violation, second violation is $48 and caps at $144 on the fourth and beyond citation.

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And as described in the prior findings above, in this case, the overall public access impact is limited, and the parking impacts are mitigated by design (i.e., being able to park on the opposing side of the street during those program hours, as well as on other City streets, during that time). As it applies specifically to oversized vehicles, the City also operates a safe parking program at a number of locations in the City, where oversized vehicles can park until 8am,13 and so oversized vehicles that are already not allowed until 5am on these four streets have an alternative safe place to park even when street sweeping may occur. Thus, the Appellant’s observation that potential parking citations would lead to disproportionate public access impacts to unhoused individuals who sleep in vehicles at night is belied by the facts that all vehicles – whether used for habitation or not – have available alternatives for parking that avoids citations during the 5am to 7am street sweeping time, including parking across the street, on other streets, or, in the case of oversized vehicles, availing themselves of the City’s free safe parking program; and the actual public access impact of street sweeping parking restrictions between 5am and 7am is negligible given the limited nature of such pursuits at that hour. While any parking restriction inherently raises questions regarding consistency with the Coastal Act and LCP requirements to maximize public recreational access, here the City has sought to minimize and mitigate any such impacts by narrowly tailoring the parking restrictions to between the 5am and 7am and by impacting only one side of the street during those hours.

Thus, the Commission believes that this program is an appropriate response to coastal resource issues that have arisen from vehicles parked along the street during street sweeping operations. The City acknowledges that this pilot program is a change from the current status quo and that there may be need for adjustments in the future, including after evaluating the success of the implementation of the new parking restrictions and street sweeping operation. And while the program would add incrementally to the restrictions in the area already subject to the City’s Oversized Vehicle Program, the public access impact is minor, given that area users can park on the opposite side of the street, or, if need be, in the Safe Parking Program locations during street sweeping times. In addition, the program hours avoid the times when most coastal access users avail themselves of the free parking in this area.14 In this instance, the City-approved pilot program is meant to improve an existing street sweeping program that is intended to avoid accumulation of debris and refuse into waterways (and thus avoid impacts to water quality) while the Oversized Vehicle program is meant to address public safety, public health, and coastal resource issues that arise from longterm parking of oversized vehicles for habitation on public streets that are not equipped for such uses. And again, all users (whether in regular vehicles or oversized vehicles) may still park along the affected streets from 5am to 7am for five days a week, and may 13 The City operates an Oversized Vehicle Program that prohibits parking of oversized vehicles on City streets between midnight and 5am, and that provides free overnight safe parking locations with various services in the City for overnight vehicles (see City CDP CP23-0176). Such oversized vehicles, which are often used for habitation, can safely park overnight in the safe parking locations either temporarily or longer-term, where such vehicles can park in these areas until 8am. 14 Notably, this area is adjacent to the University of California Santa Cruz Coastal Science Campus. The City notes that the majority of students, staff, and faculty, get to campus at 8am or later and thus the restrictions would avoid these hours.

35.60 A-3-STC-24-0044 (Street Sweeping Program)

still park along the non-street sweeping side of the street from 5am to 7am during the other two street sweeping days.

Conclusion
In conclusion, while the Commission takes its environmental justice authorities seriously, including through ‘access for all’ requirements, the City’s street sweeping program here is a very minor and straightforward program to ensure clean public spaces and is undertaken in a manner that will not have a significant impact on public coastal access, and provides feasible alternatives in instances where there may be.

Additionally, given the proposed program will be temporary, the City has the opportunity to address any coastal access impacts for these populations in one year with supplementary data and public feedback for this pilot project. It does not raise any substantial LCP conformance issues.

3. Water Quality
The LCP broadly protects water quality, including meeting or exceeding the State Water Resources Control Board requirements for discharge into sewage and storm drain systems; protections to ensure that adjacent surface water quality is not degraded by new development; continuing increased storm drainage system cleaning during the fall rainy season and exploring increasing the capacity of street sweeping operations; and evaluating water quality in existing waterways:

LUP Environmental Quality Policy 2.1. Meet or exceed State Water Resources Control Board standards for discharge of sewage and storm waters to the Monterey Bay.

LUP Environmental Quality Policy 2.3. Ensure that new development or land uses near surface water and groundwater recharge areas do not degrade water quality.

LUP Environmental Quality Policy 2.3.1.8. Continue annual fall cleaning of the underground storm drainage system and investigate the feasibility of increasing street sweeping intervals.

LUP Environmental Quality Policy 2.4. Evaluate the water quality of natural springs and streams in the City and devise strategies to protect and restore these areas.

Analysis
The Appellant contends that there is not an adequate basis for the City to find that the streets identified for the pilot street sweeping program have elevated trash levels and, therefore, that the parking restrictions will actually improve marine water quality. The Appellant argues that the streets identified for the pilot program actually do not have elevated trash levels, and that the existing street sweeping program is sufficient to remove debris and refuse without imposing parking restrictions. Lastly, the Appellant points out that there are other ways to address street cleaning issues, such as more

35.61 A-3-STC-24-0044 (Street Sweeping Program)

trash and recycling receptacles, and expansion of existing community cleanup programs.15
The LCP requires the City to meet or exceed State Water Resources Control Board Clean Water Act requirements to ensure that the City sewer and storm drainage systems do not impact water quality in Monterey Bay. The City notes that discharges from urban runoff are regulated by the 1972 Clean Water Act through the National Pollutant Discharge Elimination System (NPDES) permit program; this program, in part, regulates municipal street-sweeping operations. The City, also through this program, evaluates the volume of debris remaining uncollected on City streets even when regular street sweeping operations are in use. The City notes that while most streets have been characterized as having “low” trash levels, certain streets (such as those identified as a part of this pilot program) have been characterized as having “moderate” trash levels.

The City’s NPDES permit requires that the City enhance the cleanliness of City streets, ideally bringing all “moderate” trash levels to “low” levels to avoid the migration of trash into Monterey Bay.

Further, the LCP specifically speaks to cleaning storm drainage systems during the fall rainy season and potentially increasing street sweeping operations to ensure urban runoff does not degrade water quality. Here, the City-approved project would occur during times when the existing street sweeping program already operates, but would allow the street sweeping vehicle to access debris that accumulates between parked cars and the curb, something that the current program is not capable of doing due to the presence of parked cars. Arguably, although no data currently exists on the amount of trash removed via regular street sweeping operations vs. the City-approved version here, such changes would invariably be expected to improve water quality in coastal areas. Further, the intent of the one-year pilot project is to evaluate the effectiveness of such a program, including by collecting such data.

In sum, the City-approved pilot program is consistent with the directives of the LCP to improve water quality in coastal areas. Such a program is one tool in the City’s collective toolbox to address issues related to trash and debris accumulation along City streets, and, coupled with other tools such as community clean up programs and regular trash/recycling programs, works to improve street cleanliness. Accordingly, the City appropriately followed the LCP to explore expanding their street sweeping operations, including in a way that allows for evaluation of the program after one year.

For the above reasons, the City’s approval of a CDP for the project does not raise a substantial issue of LCP conformance with respect to water quality.

4. Conclusion
When considering a project on appeal, the Commission must first determine whether the project raises a substantial issue of LCP conformity or Coastal Act public access 15 The Appellant points specifically to the Downtown Streets Team, a non-profit group which build teams composed of unhoused and at-risk individuals who received access to case management, system navigation, and employment placement services in exchange for engaging in community beautification and clean-up projects within the downtown area of Santa Cruz.

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conformity such that the Commission should assert jurisdiction over the CDP application for such development. At this stage, the Commission has the discretion to find that the project does or does not raise such a substantial issue (and, as indicated previously, is not tasked with making Coastal Act or LCP consistency findings). Section 13115(c) of the Commission regulations provides that the Commission may consider the following five factors when determining if a local action raises a significant issue: the degree of factual and legal support for the local government’s decision; the extent and scope of the development approved by the local government; the significance of the coastal resources affected by the decision; the precedential value of the local government’s decision for future interpretations of its LCP; and, whether the appeal raises only local issues as opposed to those of regional or statewide significance. The Commission may, but need not, assign a particular weight to a factor, and may make a substantial issue determination for other reasons as well. In this case, these five factors, considered together, support a conclusion that this project does not raise a substantial issue.

With respect to the degree of factual and legal support for the City’s decision, the City evaluated the existing street sweeping program and identified a coastal resource need for the modifications approved as a part of the pilot project, and has taken steps to limit the impacts of the program on coastal public access. As there is adequate factual and legal support for the project’s consistency with the LCP and Coastal Act, the first factor weighs in favor of a finding of no substantial issue.

As to the scope of the approved development, it is actually quite limited. It only applies to vehicles parked on one side of the street on Delaware Avenue, Natural Bridges Drive, Swanton Boulevard, and Mission Street Extension between the hours of 5am and 7am twice a week, which is not a time of significant public access pursuits in the City of Santa Cruz, and still allows for coastal access users to park in that area during those times. Thus, the second factor weighs towards no substantial issue as well.

In terms of the significance of the coastal resources affected by the City’s decision, public access and recreation, and water quality on the coast are paramount concerns of both the Coastal Act and LCP. However, for the reasons explained above, the pilot program will have minimal impacts on public access and is intended to improve water quality by allowing street sweeping operations to reach debris accumulated between parked cars and the curb, all of which argues for no substantial issue.

Regarding the precedential value of the City’s decision for future interpretations of its LCP, it should first be noted that any one case, like this one, is decided on its specific facts and its specific merits, and is not entirely dispositive as to how subsequent CDP decisions will be made. At the same time, there is always the potential that the City and/or other parties interested in the issues raised here might see the City’s action here as precedential in some way, despite each case being considered based on its own facts and context. In that context, the City did not stake out unusual or potentially problematic precedential positions in its action. This factor supports a no substantial issue finding.

Finally, while it is clear that issues related to public access and water quality are key statewide coastal resource issues, and while it is also clear that the plight of unhoused

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individuals who sleep in their cars at night are important societal issues facing not only this City, but other cities, as well as the state and nation as a whole, the reality is also that the City’s street sweeping program is also a fairly typical municipal function that here has been rather narrowly crafted in such a way as to limit any adverse impacts. As such, while the project involves matters of regional and statewide significance, the issues raised are actually quite limited, and this factor also weighs in favor of no substantial issue.

It is also important to note that while the five factors listed in Section 13115(c) of the Commission regulations are important and used frequently by the Commission, they are not an exhaustive list, and the Commission is not “limited” to using those factors. On the contrary, and as stated above, the Commission may use the five factors – and any weighting between them that it deems appropriate – but also may make a substantial issue determination for other reasons as well.

Taken together, and for the reasons stated above, the Commission finds that Appeal Number A-3-STC-24-0044 does not raise a substantial issue with respect to the grounds on which the appeal has been filed under Section 30603 of the Coastal Act, and declines to take jurisdiction over the CDP application in this case.

3. APPENDICES
A. Substantive File Documents16
 Commission CDP Files for A-3-STC-22-0018 (Nighttime Oversized Vehicle Parking Restrictions) and A-3-STC-24-0012 (Oversized Vehicle Ordinance).

B. Staff Contacts with Agencies and Groups
 City of Santa Cruz Public Works Department
 Santa Cruz Cares
16 These documents are available for review from the Commission’s Central Coast District office.

35.64 PLANNING COMMISSION

AGENDA REPORT
DATE: November 14, 2025
AGENDA OF: November 20, 2025
ITEM NO: CP25-0132
Council District: 6
Citywide at Select Locations in the Coastal Zone
RECOMMENDATION: That the Planning Commission acknowledge the environmental determination and approve the Coastal Permit (further to Application CP23-0144) for continuation, in perpetuity, of proposed limitation of hours of public parking in support of ongoing sweeping of City streets in the public right-of-way on land within the Shoreline Protection Overlay/Coastal Zone, based on the attached Findings and the Conditions of Approval listed in Exhibit “A”.

PROJECT DATA
APN: Various
Property Owner: City of Santa Cruz
Representative: Eric Dhakni, Public Works Department
Application Type: Coastal Permit for continuation, during limited hours in select areas of the Coastal Zone, of prohibition on public parking to facilitate improved effectiveness of the City’s existing Street Sweeping Program
Zoning: Select locations in the Coastal Zone within the public right-of-way, including Delaware Avenue, Natural Bridges Drive, Swanton Boulevard, and Mission Street
Project Consistency: With Coastal Permit approval, the project is consistent with the Zoning Ordinance.

General Plan: Various
Project Consistency: Consistent with the General Plan Land Use designations and policies.

Land Use - existing: Public streets and public parking
- proposed: Same with modified hours of allowable parking - surrounding: Various land uses and public rights-of-way Environmental Review: Statutory exemption: CEQA Guidelines Section 15282(j) (14 CCR Section 15282(j)).

35.65 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 2
Categorical exemption: CEQA Guidelines Sections 15301(c) and (g), 15307, 15308, and 15061(b) (14 CCR sections 15301(c) and (g), 15307, 15308, and 15061(b).)
Planning Staff: Timothy Maier

PROJECT LOCATION & BACKGROUND
The City’s existing street-sweeping program serves public streets Citywide. To improve the effectiveness of municipal street-sweeping operations, the City recently adopted a Street-Sweeping Pilot Program via file number CP23-0144 and subsequent City Council Resolution NS-30,379, encompassing a prohibition on vehicular parking from the hours of 5:00 a.m. until 7:00 a.m. on six routes within three designated areas throughout the City for a period of one year. The Council’s action was upheld by the Coastal Commission on appeal. In adopting the Pilot Program, the City pledged to pursue a new Coastal Permit for continuation of parking restrictions in the Coastal Zone beyond the one-year Pilot Program. The subject Coastal Permit application would thus allow for continuation of existing parking restrictions on City streets located in the Coastal Zone incorporated in the Pilot Program, including Delaware Avenue, Natural Bridges Drive, Swanton Boulevard, and Mission Street.

Brief History of Project
To date, several public hearings have taken place related to the Street-Sweeping Pilot Program.

On February 22, 2024, the City’s Transportation and Public Works Commission (TPWC) reviewed the Pilot Program as originally proposed and recommended that the City Council approve limitation of hours of parking, with enforcement through towing, and placement of signage to facilitate implementation of the program. On April 17, 2024, the Zoning Administrator considered, at public hearing, applications for Coastal Permit and Design Permit CP23-0144 for proposed limitation of hours of public parking and placement of new signage for sweeping of City streets in the public right-of-way on land within the Shoreline Protection Overlay/Coastal Zone.

Thereafter, on May 13, 2024, an appeal of the Coastal Permit approval was submitted to the California Coastal Commission.

Because proposed parking restrictions in support of the Pilot Program would take place both within and outside the Coastal Zone, and, due to the program’s implication for impacts to the General Fund, staff subsequently brought the program to the City Council for review. On August 27, 2024, the City Council considered the proposed one-year Pilot Program and adopted Resolution NS30,379, approving 1) parking restrictions for the pilot street-sweeping program in Zones 1-4 (located outside the Coastal Zone) during posted hours and 2) approving parking restrictions for the pilot street-sweeping program in Zones 5-6 (located in the Coastal Zone) during posted hours, directing the City Manager or designee to implement the one-year Pilot Program.

On October 7, 2024, an appeal of the City Council action enabling parking restrictions in the Coastal Zone was received by the California Coastal Commission, and, at its November 14, 2024 public hearing, the Coastal Commission made a determination of No Substantial Issue (NSI) via

35.66 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 3
Appeal Number A-3-STC- 24-0044, thereby allowing the City Council’s decision to remain effective.

Clarification Regarding City Commitments
In preparation of the hearing by the California Coastal Commission on November 14, 2024 to consider the appeal of the Coastal Permit, the City sent correspondence to the Coastal Commission, dated November 7, 2024, providing clarification regarding actions previously taken, emphasizing the following points: 1) the City's Street Sweeping Pilot Program is authorized for one year (with a Coastal Permit expiration date of December 31, 2025), where the intent is that it will be initially implemented in December 2024 or early 2025; 2) after the one-year pilot is complete, the City will issue a new Coastal Permit to continue the program if it chooses to do so; 3) during the one-year pilot period, the City will not change the hours of implementation (i.e., hours of street-sweeping will remain from 5 a.m. to 7 a.m. on Tuesdays and Thursdays); and 4) the City will not expand onto other City streets within the Coastal Zone without first issuing a new Coastal Permit.

Requested Action of the Planning Commission
In light of the above, the City’s Zoning Administrator would generally take action on the subject Coastal Permit application. However, the Zoning Administrator has referred review of the Coastal Permit to the Planning Commission for consideration pursuant to City of Santa Cruz Municipal Code Section 24.04.130(2), and, thus, the Planning Commission is requested to consider the merits of continuing the existing Pilot Program in perpetuity.

Street-Sweeping Routes Under Consideration
Street-sweeping routes incorporated within the one-year Pilot Program, in which parking restrictions are enforced, located both within and outside the Coastal Zone appear below:

35.67 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 4
In the below image, the dark purple line represents the boundary of the City’s Coastal Zone, while the orange-colored regions depict areas in which discretionary land-use applications allow for appeal of any decision made by the City to the California Coastal Commission.

Routes 1 and 2
Routes 3 and 4
Routes 5 and 6
Subject to
Coastal Permit

35.68 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 5
Street-sweeping routes within the Coastal Zone and subject to review under this permit application are further illustrated below. As proposed, continued street-sweeping, subject to parking restrictions, would occur on one side of specified streets on Tuesdays (Route 5, shown in turquoise) and on the opposing side of the street on Thursdays (Route 6, depicted in navy blue).

Mission St. Ext.

Delaware Ave.

Swanton Blvd.

Natural Bridges Dr.

35.69 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 6

ANALYSIS
Regulatory Requirements
Urban runoff and other "non-point source" discharges are regulated by the 1972 Federal Clean Water Act (CWA) through the National Pollutant Discharge Elimination System (NPDES) permit program, administered by the Regional Water Quality Control Board (“Water Board”). Among other activities, the City’s NPDES regulates municipal street-sweeping operations.

For several years, in accordance with its NPDES permit, the City has retained a third-party consultant to monitor the volumes of debris remaining uncollected on City streets, which, if unchecked, eventually migrate to Monterey Bay. The City’s consultant prepares an annual “report card” evaluating the effectiveness of the municipal street-sweeping program. To date, such assessments have characterized most areas investigated as “low” in litter buildup; however, past report cards have categorized several areas as “moderate” in debris accumulation, including primarily those streets in which static on-street parking hampers sweepers’ capacity to access the curb and gutter in order to effectively gather accumulated refuse. Streets designated with “moderate” trash levels include corridors on the far Westside, primarily Delaware Avenue, Natural Bridges Drive and Mission Street Extension.

Municipal Street Sweeping Operations
To ensure compliance with requirements of the City’s NPDES permit and to enhance the cleanliness of City streets, the Public Works Resource Recovery Division supplies street-sweeping services to the City. Currently, street-sweeping operations provide service once per week for commercial areas and on alternating weeks in residential areas. Public Works has a fleet of three street sweepers, with daily functions conducted by two sweepers operating simultaneously. Sweeping operations generally commence at 5:00 a.m. and last until 12:00 p.m. Debris collected by the sweepers is consolidated at the City’s Corporation Yard and then deposited in the City landfill.

Pre-Existing Conditions
Prior to approval of Coastal Permit and Design Permit CP23-0144, few restrictions limited the parking of motor vehicles on public rights-of-way along existing street-sweeping routes. Under preexisting conditions, street-sweeping vehicles often could not access substantial spans, often several car lengths, of curb area for each parked vehicle presenting an obstruction, where most trash accumulates.

Incomplete sweeping of City streets inevitably results in migration of debris into storm drains and, eventually, into the Monterey Bay. Further, intermittent spacing of parked vehicles compels City street sweepers to maneuver around such vehicles into flowing traffic, with potentially adverse impacts to public safety and congestion.

Effectiveness of the Existing Street Sweeping Program
Public Works staff report that the success of implementing parking restrictions hinges upon the effectiveness of enforcement. Without a strong incentive for compliance, such as the prospect of towing offending vehicles, the likelihood of adherence to posted parking restrictions remains limited.

35.70 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 7
Thus, the Coastal Permit continues the current operations of the Street-Sweeping Pilot Program, which incorporates the option for towing of vehicles to facilitate access by sweepers to street curbs for effective collection of debris.

For a thorough and effective street-sweeping program, as authorized by the City Council at its August 27, 2024 public hearing, the Public Works Department currently prohibits the parking of vehicles during the hours of 5:00 a.m. until 7:00 a.m. weekly on Tuesdays and Thursdays on alternating sides of affected streets. For instance, on Natural Bridges Avenue, parking is restricted to the east side of the street every second Tuesday and is prohibited on the west side of the road on Thursday of the same week. Such a strategy consolidates operations, establishes predictability in scheduling, and minimizes loss of on-street parking capacity to the extent feasible.

The following lists areas currently affected by street-sweeping activities within the Coastal Zone, which would remain unchanged with the application for new Coastal Permit:

Sweeping
Zone
Day of
Sweeping
Streets Affected Number of Parking Spaces
Potentially Impacting Effective
Street Sweeping
5 Tuesdays Mission St. Extension from
Swift St. to Natural Bridges Dr.
67 spaces
Natural Bridges Dr. to
Delaware Ave.
80 spaces
Delaware Ave. from Shaffer
Rd. to Swift St.
140 spaces
Swanton Blvd from Delaware
Ave to West Cliff Dr.
79 spaces
6 Thursdays Natural Bridges Dr. from
Delaware Ave. to Mission St.

Extension
66 spaces
Mission St. from Western Dr.
to Swift St.
77 spaces
Delaware Ave. From Swift St.
to Shaffer Rd.
147 spaces
Swanton Blvd. from West Cliff
Dr. to Delaware Ave.
45 spaces
Interface with Oversized Vehicle Ordinance
The proposed Street Sweeping Pilot Program remains completely independent from actions related to the City’s Oversized Vehicle Ordinance, approved by the City Council on March 12, 2024 and by the Coastal Commission on appeal in May of 2024, which restricts parking of oversized vehicles (defined as motor vehicles exceeding 20 feet in length, or eight feet in width and seven feet in height) along with unattached trailers, on City streets between the hours of midnight and 5 a.m., consistent with Coastal Development Permit A-3-STC-22-0018. Entitlements associated with the Oversized Vehicle Ordinance address adverse impacts associated with the entrenchment of

35.71 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 8
oversized vehicles, whereas the Street Sweeping Pilot Program limits vehicular parking for short durations on alternating weeks in order to improve the effectiveness of City debris collection operations.

Potential Future Program Modifications
As proposed, formalizing and making permanent parking restrictions of the one-year Street-Sweeping Pilot Program will allow for continued improvement in the cleanliness of commercial areas with designated “moderate” levels of trash accumulation. A Condition of Approval has been added allowing the Planning and Community Development Director, in conjunction with the Public Works Director, to make minor modifications to the proposed program as necessary. A further Condition of Approval allows consideration for potential future expansion of the proposed program into residential areas with similarly high levels of trash accumulation and with more severe limitations on parking capacity, along with installation of supporting signage, subject to approval of a new Coastal Permit.

Local Coastal Program Consistency
The proposed actions demonstrate consistency with the policies of the Local Coastal Program (LCP) in that the proposed limited-duration restriction of vehicular parking will result in continued benefits to the community along spans of the coast affected by accumulation of trash and debris, with attendant enhancements to health and safety. The proposed actions will address the policies and programs of the LCP as listed below:

Policies
 Water Quality Policy 2.1: Meet or exceed State Water Resources Control Board standards for discharge of sewage and storm waters to the Monterey Bay.  Open Space Lands Policy 3.5: Protect coastal recreation areas, maintain all existing coastal access points open to the public, and enhance public access, open space quality and recreational enjoyment in a manner that is consistent with the California Coastal Act.
 Open Space Lands Policy 3.7: Recognize and protect the Pacific Ocean and Monterey Bay as a valuable open space, natural resource, and National Marine Sanctuary.

Programs
 Open Space Lands Program 3.5.5: Develop and implement plans to maximize public access and enjoyment of recreations areas along the coastline.  Natural Setting and Scenic Resources Program 2.1.3: Protect the Monterey Bay National Marine Sanctuary and the shoreline and views to and along the ocean, recognizing their value as natural and recreational resources.  Biotic Diversity and Stability Program 4.2.5: Protect and minimize the impact of development on bird, fish and wildlife habitat in and adjacent to waterways.  Biotic Diversity and Stability Program 4.1.5: Protect the quality of water discharged into the Bay and allow no dumping of materials into the Monterey Bay.

35.72 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 9
Recreational access to the beach will remain unaffected, and the proposed actions will avoid negative impacts on the availability of free public parking and access to the shore. Limitations of on-street public parking will not detrimentally affect any mapped high-impact, environmentally sensitive sites within the Coastal Zone.

General Plan Consistency
The project further demonstrates consistency with and serves to implement several General Plan goals, policies, and actions promoting efficient transportation, ongoing maintenance of existing roadways, and prevention of urban runoff in an effort to foster clean beaches, watercourses, and ocean resources, as follows:

General Plan Goal M2 A safe, sustainable, efficient, adaptive, and accessible transportation system Policy M 3.2 Ensure road safety for all users.

Action M3.2.1 Maintain the condition of the existing road system.

Action M3.2.2 Ensure safe and efficient arterial operations.

General Plan Goal CC 5 A sustainable and efficient stormwater system Policy CC5.1 Develop and maintain a Stormwater Master Plan.

Action CC5.1.1 Implement the City’s stormwater quality program.

Action CC5.1.2 Maintain clear flow of the storm drain system.

Action CC5.1.7 Manage and maintain the San Lorenzo River floodway.

Action CC5.1.9 Reduce stormwater pollution.

Zoning Consistency
The area of land subject to Coastal Permit falls into various zone districts. As proposed, continuation of existing parking restrictions will not modify existing uses or involve any physical development, but, instead, will allow for vehicular parking limitations in public rights-of-way in order to allow for maximum removal of debris from City streets. Formalizing and making permanent the one-year Pilot Program will maintain efficient sweeping of City streets and uphold conformance with applicable regulations of the Municipal Code.

ENVIRONMENTAL REVIEW
Limitation of hours of parking for short durations at regular intervals to facilitate sweeping of City streets hold little, if any, potential for impact to the environment based on established thresholds of significance. Further, the proposed actions remain statutorily exempt from environmental review under Article 19 of the California Environmental Quality Act (CEQA) Guidelines, Section 15282(j), related to restriping of City streets, and categorically exempt under Section 15301(c) and (g), 15307, 15308, and 15061(b), related to alteration of City streets not involving addition of lanes.

35.73 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 10
The California Environmental Quality Act (CEQA) establishes several “categorical exemptions” applicable to classes of projects and varieties of activities which generally avoid inducing risk of significant impacts to the environment. Section 15307 of the CEQA Guidelines “consists of actions taken by regulatory agencies... to assure the maintenance, restoration, or enhancement of a natural resource where the regulatory process involves procedures for protection of the environment.” Section 15308 of the CEQA Guidelines
“consists of actions taken by regulatory agencies… to assure the maintenance, restoration, enhancement, or protection of the environment where the regulatory process involves procedures for the protection of the environment.” None of the exceptions to the exemptions under Section 15300.2 apply, in that the project site (public rights-of-way within the Coastal Zone) is not located in a mapped environmentally sensitive area, the project (continuation of parking restrictions on public streets for predefined periods on a predictable schedule) is not part of a larger project that could result in a cumulative impact, there are no unusual circumstances associated with the project or subject parcel, the project will not result in damage to resources associated with an officially designated scenic highway, the project site is not included on any lists compiled pursuant to Section 65962.5 of the Government Code related to Hazardous Waste Sites, and the project will not result in substantial adverse changes in the significance of a historical resource site in that there are no known historic resources on the property.

Implementation of limited-duration restrictions of hours of on-street public parking, with minor modifications as potentially required (including potential additions to or modification of existing signage), will not likely result in any new construction, or need for building of additional facilities for public services such as Police, Parks, or Fire. As the proposed actions would facilitate the improvement of street-sweeping operations for more effective removal of debris from City streets, the proposed project will bring about beneficial, rather than detrimental, environmental outcomes. The proposed project complies with all the foregoing criteria and demonstrates eligibility for implementation of both statutory and categorical exemptions as afforded by CEQA.

Health in All Policies (HiAP)
HiAP is a collaborative approach to improving the health of all people by incorporating health considerations into decision-making across sectors and policy areas. HiAP is based on 3 pillars:
equity, public health, and sustainability. The goal of HiAP is to ensure that all decision-makers are informed about the health, equity, and sustainability impacts of various policy options during the policy development process. The project is aligned with the goals of Health in All Policies in that it would provide for ongoing access to and improvement in the conditions of City streets, encouraging use of alternative modes of transportation, including walking and cycling; preventing

35.74 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 11
migration of debris into the storm drain system, thus preventing pollution of land and water resources; and improving aesthetics and environmental quality, thus enhancing the experience of Santa Cruz for all residents and visitors, thus supporting the goals of HiAP.

SUMMARY
The City of Santa Cruz seeks to ensure the ongoing effectiveness of its existing street-sweeping program, intended to reduce the environmental impacts derived from accumulation of debris along public rights-of-way while minimizing impacts associated with loss of parking capacity on City streets. As proposed and with recommended conditions of approval implemented, the enhanced street-sweeping program will remain consistent with applicable goals and policies of the Local Coastal Program and General Plan and with provisions of the Zoning Ordinance. The program will additionally enable the City to render informed decisions about potential expansions of its streetsweeping program into further areas, fostering enhanced aesthetics and promoting a cleaner environment, creating the conditions for a more welcoming City and ensuring public access to the coast. Staff recommends that the Planning Commission recognize the environmental determination and approve the project based on the attached findings subject to conditions listed as Exhibit “A”.

FINDINGS
Coastal Permit, Section 24.08.250

1. Maintain views between the sea and the first public roadway parallel to the sea.

With the scope of work not including limitations to parking on the first public roadway parallel to the sea, the proposal will not induce impact coastal views between the first public roadway parallel to the sea and the sea itself.

2. Protect vegetation, natural habitats and natural resources consistent with the Local Coastal Land Use Plan.

The proposed actions are consistent with the California Environmental Quality Act (CEQA) and the City’s environmental review and protection procedures. No disturbance of any vegetation, natural habitat, or natural resources will accompany the actions included in the subject Coastal Permit. Coastal Permit and Design Permit CP23-0144 authorized installation of supporting signage, anticipated to remain. Minor modifications to existing signage as allowed through the approved Design Permit and as accommodated by the subject Coastal Permit will result in no significant impact to vegetation, natural habitats, or nature resources, thus conforming to the Local Coastal Land Use Plan.

3. Be consistent with any applicable design plans and/or area plans incorporated into the Local Coastal Land Use Plan, in that it implements policies therein.

35.75 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 12
The subject Coastal Permit application provides for ongoing implementation of the City’s Street-Sweeping Program which seeks to minimize detrimental environmental impacts associated with accumulation of refuse along City street curbs. Actions included under the requested Coastal Permit remain consistent with the Local Coastal Program (and General Plan) in that the proposed scope of work advances, and serves to implement, relevant goals and policies related to promotion of enhanced aesthetics and protection of the natural environment.

The proposed actions address policies and programs of the Local Coastal Program, including, but not limited to, the following:
 Water Quality Policy 2.1: Meet or exceed State Water Resources Control Board standards for discharge of sewage and storm waters to the Monterey Bay.  Open Space Lands Policy 3.5: Protect coastal recreation areas, maintain all existing coastal access points open to the public, and enhance public access, open space quality and recreational enjoyment in a manner that is consistent with the California Coastal Act.
 Open Space Lands Policy 3.7: Recognize and protect the Pacific Ocean and Monterey Bay as a valuable open space, natural resource, and National Marine Sanctuary.
 Natural Setting and Scenic Resources Program 2.1.3: Protect the Monterey Bay National Marine Sanctuary and the shoreline and views to and along the ocean, recognizing their value as natural and recreational resources.  Open Space Lands Program 3.5.5: Develop and implement plans to maximize public access and enjoyment of recreations areas along the coastline.  Biotic Diversity and Stability Program 4.2.5: Protect and minimize the impact of development on bird, fish and wildlife habitat in and adjacent to waterways.  Biotic Diversity and Stability Program 4.1.5: Protect the quality of water discharged into the Bay and allow no dumping of materials into the Monterey Bay.

An evaluation of the project’s potential for generation of environmental impacts in accordance with the provisions of the California Environmental Quality Act (CEQA) and the City’s Environmental Review Guidelines and procedures has resulted in the conclusion that all actions included qualify for established categorical and/or statutory exemptions and the determination that the subject application holds no potential for generation of significant environmental impact, but, rather, will improve both the visual and natural environment.

The proposed actions remain statutorily exempt from environmental review under Article 19 of the California Environmental Quality Act (CEQA) Guidelines, Section 15282(j), related to restriping of City streets, and categorically exempt under Section 15301(c) and (g), 15307, 15308 and 15061(b), related to alteration of City streets not involving addition of lanes.

35.76 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 13
Limited-duration restrictions on hours of on-street public parking, with potential future minor modifications as deemed necessary, may require minor modifications to existing supportive signage (including new installation or revision to existing signs) but will not likely result in any new construction, or need for building of additional facilities for public services such as Police, Parks, or Fire. As the proposed actions would allow for more effective street-sweeping operations providing for removal of debris from City streets, implementation of an enhanced street-sweeping Pilot Program will bring about beneficial, rather than detrimental, environmental outcomes.

4. Maintain public access to the coast along any coastline as set forth in the Local Coastal Land Use Plan.

The proposed scope of work would prohibit parking for a limited duration on alternating sides of affected streets on different days, affording adequate access to the curb and gutter for street-sweeping vehicles to remove accumulated trash which would otherwise eventually migrate into the Monterey Bay, where its environmental impact would be exacerbated. Short-duration limitation on hours of parking will not substantively impact availability of vehicular parking in a manner that would obstruct or impair access to the coast. The subject application will enhance cleanliness and safety by facilitating proper disposal of litter, with associated benefits to preservation of community character and aesthetics. The project will enable the general public to experience coastal access to the ocean and adjacent shore in an environment of improved cleanliness, rendering visitation to oceanside lands more attractive and thereby encouraging public access to the coast.

5. Be consistent with the Local Coastal Land Use Plan goal of providing visitor-serving needs as appropriate.

No adverse impacts to bona-fide recreational beach access would result from the proposed actions.

6. Be consistent with the Local Coastal Land Use Plan goal of encouraging coastal development uses as appropriate.

The restriction on hours of public on-street parking remains consistent with the Local Coastal Land Use Plan and holds no appreciable impact to coastal development while enhancing City street-sweeping operations to effectuate improved aesthetic and environmental conditions promoting public coastal access.

Shoreline Protection Overlay District, Section 24.10.2430

7. The project protects trees and vegetation and sensitive wildlife habitat.

The proposed limited-duration restriction on vehicular parking will not negatively affect trees, vegetation, or sensitive wildlife habitat. By reducing litter accumulation, improved street-sweeping operations will have a positive effect on trees, vegetation, and sensitive habitat. Thoughtful consideration to the number and placement of signage will avoid the

35.77 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 14
need for removal of trees and remain limited in nature such that no adverse impacts to sensitive habitat will occur.

8. The project is consistent with the following criteria for bluff or cliff development:
a. The development is sited and designed to assure stability and structural integrity of its expected economic life span and minimize alterations to natural landforms.
b. The development will not create or contribute significantly to problems of erosion or geologic instability on the site or on surrounding geologically hazardous areas.
c. The development minimizes alteration of cliffs, bluff tops, faces or bases, and will not interfere with sand movement.
d. The development which proposes use of retaining walls shall be allowed only to stabilize slopes. Sea walls at the toe of sea cliffs to check marine erosion shall be allowed only where there is no less environmentally damaging alternative.
e. The development within one hundred feet of any cliff or bluff line shall follow the recommendations of an approved geologic report by a registered geologist. The area where such a report is required may be increased where the issue of slope stability requires a greater distance from any cliff or bluff line.

Continuation of existing limitations of on-street public parking will not physically affect any cliff or bluff.

9. The project provides maximum erosion protection, using accepted engineering practices and other methods and specifications set forth in this title.

The project will not result in any detrimental impact related to accelerated erosion.

10. The project maintains public view corridors between the sea and the first public roadway parallel to the sea and maintains natural views of the coastline.

Continuation of existing limitations of on-street public parking will not result in impact to any view corridor between the sea and the first public roadway parallel to the sea.

11. The project protects paleontological resources as prescribed in the Land Use Plan.

The proposed actions do not encompass any subsurface excavation, aside from potential minor ground disturbance for relocation and/or installation of signage and therefore will

35.78 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 15
not impact paleontological resources as prescribed in the Land Use Plan. The above finding remains inapplicable.

12. The project protects and enhances free public access to or along the beach, and sign such access when necessary.

The proposed actions will not adversely impact the capacity of, or access to, free public parking or bona fide recreational use of the shore. Hours and locations of the proposed parking restrictions are limited such that free public access is protected.

13. The project includes mitigation measures prescribed in any applicable environmental document.

No mitigation measures apply, and the above finding remains inapplicable.

14. The project is compatible with the established physical scale of the area.

The proposed actions will not impact the established physical scale of the area, and the above finding remains inapplicable. The project will not induce physical effect to any cliff, bluff, or mapped sensitive habitat.

15. The project is consistent with the design review guidelines of this title and the policies of any applicable area plan.

As the project proposes a continuation of existing limitation on hours of on-street public parking to enable more effective sweeping of City streets in the Coastal Zone, the above finding remains inapplicable.

16. The project is consistent with the policies of the Local Coastal Program, the General Plan, and the California Coastal Act.

The proposed actions demonstrate consistency with the policies of the Local Coastal Program, the General Plan, and the California Coastal Act in that the proposed limitedduration restriction of vehicular parking will result in continued benefits to the community along spans of the coast affected by accumulation of trash and debris, with attendant enhancements to health and safety. The proposed actions will address the policies of the LCP as listed below:
 Water Quality Policy 2.1: Meet or exceed State Water Resources Control Board standards for discharge of sewage and storm waters to the Monterey Bay.  Open Space Lands Policy 3.5: Protect coastal recreation areas, maintain all existing coastal access points open to the public, and enhance public access, open space quality and recreational enjoyment in a manner that is consistent with the California Coastal Act.
 Open Space Lands Policy 3.7: Recognize and protect the Pacific Ocean and

35.79 AGENDA REPORT
Planning Commission Meeting of November 20, 2025
SUBJECT: Various Locations in Coastal Zone– Application No. CP25-0132 PAGE 16
Monterey Bay as a valuable open space, natural resource, and National Marine Sanctuary.
 Natural Setting and Scenic Resources Program 2.1.3: Protect the Monterey Bay National Marine Sanctuary and the shoreline and views to and along the ocean, recognizing their value as natural and recreational resources.  Open Space Lands Program 3.5.5: Develop and implement plans to maximize public access and enjoyment of recreations areas along the coastline.  Biotic Diversity and Stability Program 4.2.5: Protect and minimize the impact of development on bird, fish and wildlife habitat in and adjacent to waterways.  Biotic Diversity and Stability Program 4.1.5: Protect the quality of water discharged into the Bay and allow no dumping of materials into the Monterey Bay.

Recreational access to the beach will remain unaffected, and the proposed actions will avoid negative impacts on the availability of free public parking and access to the shore. Limitations of on-street public parking will not detrimentally affect any mapped high-impact, environmentally sensitive sites within the Coastal Zone.

Submitted by:

Timothy Maier
Senior Planner
Approved by:

Lee Butler
Director of Planning & Community
Development
ATTACHMENTS:
 Conditions of Approval
 Project Plans, prepared by staff of the City’s Public Works Department dated January 2024  Staff Report to Transportation and Public Works Commission of January 22, 2024  Staff Report to Zoning Administrator of April 17, 2024 (CP23-0144)  Conditions of Approval of CP23-0144
 Staff Report to City Council of August 27, 2024
 Staff Report of Appeal to California Coastal Commission of November 14, 2024

35.80 From: Renee Golder
To: Bonnie Bush
Subject: Street Sweeping
Date: Friday, November 21, 2025 1:30:21 PM
Attachments: Outlook-3cned3hy.png
Hi Bonnie,
Per SCMC 24.04.175.1, I would like to call up the final action on the Coastal Permit for the street sweeping action to the City Council for final review. This is an important issue for a number of reasons, such as cleanliness of the Natural Bridges Beach area. Parking requirements are also of broad interest to constituents, and with the funding request for street sweeping coming to the Council on December 9, it makes sense for Council to consider the Coastal Permit for street sweeping and the funding allocation for continuation of street sweeping at the same meeting.

Renée Golder
City of Santa Cruz | Councilmember District 6
809 Center Street, Room 101, Santa Cruz, CA 95060
Web: cityofsantacruz.com
Need to Reach your other Representatives?
County of SC District 3 Representative Justin Cummings
State Assembly District 28 Assemblymember Gail Pellerin State Senate District 14 Senator John Laird

35.81 No-Parking Street
Sweeping Program
Coastal Permit Project No. CP25-0132
City Council December 9, 2025

35.82 Zones Zones 1-2
Harvey West
Zones 3-4
Ocean, Soquel, Water St.

Zones 5-6*
Westside area
*Zones 5-6 in the Westside area are within the Shoreline Protection Overlay/Coastal Zone

35.83 Outreach Efforts
City of Santa Cruz Communications
Fall 2024 Resource Recovery bill insert
Feb. 26 Press Release
Feb 28 CM Weekly story + social media posts
Street Sweeping Pilot Program webpage
Public hearing notices: onsite posters, resident
postcards, legal ads in the Sentinel, and email
outreach to interested parties
Open House outreach events: September 2024
and March 2025

35.84 Outreach Efforts
Media Coverage

11.16.24 Lookout: Coastal Commission says Santa Cruz can move forward with Westside street sweeping program

2.26.25 KSBW: Santa Cruz launches new street-sweeping pilot program

2.26.25 KION: New street sweeping pilot program launches in Santa Cruz

2.27.25 Event Santa Cruz: City of Santa Cruz Launches New Street Sweeping Pilot Program

3.3.25 Local News Matters: Santa Cruz launches street sweeping pilot program, enforcing parking rules this week

3.4.25 Santa Cruz Local: Where and when is street sweeping in the city of Santa Cruz?

4.4.25 Sentinel: Street sweeping pilot program begins in Santa Cruz

35.85 Results
Visual Trash
Assessments
Total Collected
Debris
Parking
Enforcement
Moderate trash level areas
decreased to low.

Exceptions along Coral
Street in Zones 1-2

92.55 cubic yards of trash
and sediment collected
between March 2025-
October 31, 2025
Parking Services issued
warnings & citations, has
not had to tow any
vehicles

35.86 Recommendations
Adopt a Resolution formalizing and making permanent the No-Parking Street Sweeping Pilot Program, allowing for
continuation, in perpetuity, and future expansion of
limitations on hours of public parking on lands in various locations throughout the City; and
Adopt a Resolution acknowledging the environmental
determination and approving a Coastal Permit for
continuation, in perpetuity, and future expansion of
limitations on hours of public parking in support of ongoing sweeping of City streets in the public right-of-way on land within the Shoreline Protection Overlay/Coastal Zone,
based on the attached Findings and Conditions of Approval.

1. 2.

35.87 Thank You
Eric Dhakni
Associate Planner II
Public Works Department
Timothy Maier
Senior Planner
Planning & Community Development

35.88 35.89

35.90 City Council

AGENDA REPORT
DATE: 11/19/2025
AGENDA OF: 12/09/2025
DEPARTMENT: Parks and Recreation
SUBJECT: Tree Appeal – 401 Ingalls Street (Tree Removal Permit #TR25-0087) (PR) LOCATION: District 6
RECOMMENDATION: Motion to adopt a resolution to deny the appeal and uphold the Parks and Recreation Commission’s approval of heritage tree removal permit application TR25-0087 submitted by property owner James Allen to remove two Coast Redwood trees (Sequoia sempervirens) located at 401 Ingalls Street.

BACKGROUND: On July 24, 2025, property owner James Allen submitted an application requesting the removal of two heritage-sized Coast Redwood trees located in the front yard of 401 Ingalls Street. The reason stated on the request for tree removal, in summary, was “Two large redwood trees destroying utilities and sidewalk.” Santa Cruz Municipal Code (SCMC) § 9.56.060(e) provides that the Director shall make findings of fact upon which he shall grant, conditionally grant or deny the permit. City Council Resolution No. NS-23,710, Exhibit A 1.(c) requires that one or more of the following findings for the alteration or removal of a Heritage Tree (Resolution NS-23,710 Exhibit A Standards for Tree Permit Approval.pdf):
1) The heritage tree or heritage shrub has, or is likely to have, an adverse effect upon the structural integrity of a building, utility, or public or private right of way; 2) The physical condition or health of the tree or shrub, such as disease or infestation, warrants alteration or removal; or
3) A construction project design cannot be altered to accommodate existing heritage trees or heritage shrubs.

After an initial site visit, appreciating the trees’ significance as a community resource, and to further evaluate the applicant’s removal request, staff explained to the applicant that the City would recommend that a private arborist report be prepared by a consulting arborist for a second opinion (Applicant Documentation-401 Ingalls St. Tree Removal.pdf). Additionally, the staff recommended that the owner obtain a statement from a registered professional engineer on the damage potential to the structural integrity of the building foundation (Applicant Documentation-401 Ingalls St. Tree Removal.pdf). Staff also recommended, for defensibility, that the applicant request an Underground Service Alert (USA) to identify and mark the utilities at the tree location, and that a licensed plumber camera the existing sewer lateral to confirm root

36.1 blockage, pipe damage and the ponding of effluent. Staff also recommended that a cost analysis be prepared to explore the feasibility and cost of rerouting the water and sewer versus the expense of tree removal, stump grinding and repair of the water and sewer repair in their current location (Applicant Documentation-401 Ingalls St. Tree Removal.pdf). Following the submittal of this additional information to the City, staff considered whether there was enough evidence to support a finding of criterium A.1.(c) 1: “The heritage tree or heritage shrub has, or is likely to have, an adverse effect upon the structural integrity of a building, utility, or public or private right of way, as submitted in the application by the property owner.” Based on the information provided by the applicant to defend sewer damage and rerouting complications and cost, the Director made the findings required by City Council Resolution No.

NS-23,710, Exhibit A and granted the requested permit pursuant to SCMC § 9.56.020(a) and §

9.56.060(e) and specifying mitigations outlined by City Council policy.

On July 24, 2025, after a refundable planting bond had been submitted by the property owner for on-site tree replacement, a “Notice of Action Heritage Tree Alteration/Removal Tentative Permit” was posted at 401 Ingalls Street. The deadline to appeal stated on the notice was August 4, 2025, at 5:00 PM.

On August 4, 2025, Ms. Gillian Greensite filed an appeal of the Director’s decision stating:
“The reason for this appeal is to save two redwood trees. The basis for the appeal is criterion 1(c)(1) of Criteria & Standards for heritage tree removal. The applicant’s claim trees are “destroying utilities and sidewalk” is not substantiated. The applicant’s Plumbing Engineer states that rerouting utilities is “technically possible.” Efforts must be made to save heritage trees.” Appellant Gillian Greensite, through City staff, requested access from the property owner to allow for her own plumber to prepare an estimate to reroute the sewer system. The property owner was not comfortable with the appellant’s plumber reviewing and preparing an estimate at the appellant’s expense on his private property, so access was denied.

In the absence of the appellant’s plumber inspecting the property owner’s sewer lateral, the applicant discussed rerouting with two additional plumbers, both declined to bid due to limitations including working in the street and concerns about water meter relocation by the City Water department.

The Parks and Recreation Commission held a public hearing to consider the appeal its regular meeting on October 13, 2025 (Meeting Summary, Parks and Recreation Commission, October 13 2025). By a vote of four to one, with two commissioners absent, the Commission upheld the Parks and Recreation Department staff decision to approve permit TR25-0087 for removal of the heritage tree.

On October 23, 2025 Ms. Greensite appealed the Parks and Recreation Commission’s decision to the City Council (Notice of Appeal Filed - 401 Ingalls Street Tree Appeal.pdf). The appeal states,
“Section 9.56.060 (e) of the Heritage Tree Ordinance requires the director to make findings of fact in order to grant a heritage tree removal permit. The public record contains only conjecture and unsupported assumptions with no evidence on which to grant a permit. Email exchanges confirm staff bias towards these trees removal. The commission majority failed to address these violations. Hence this appeal.”

36.2 DISCUSSION: Staff has determined that per City Council Resolution No. NS-23,710, Exhibit A 1.(c) findings have been established by the applicant and confirmed by the Director of Parks and Recreation that “The heritage tree or heritage shrub has, or is likely to have, an adverse effect upon the structural integrity of a building, utility, or public or private right of way”. The two trees are damaging utilities, including water and sewer laterals which meets the findings required by the City Council Resolution.

The City Urban Forester, also a certified arborist, concurs with the private consulting arborist that has prepared reports submitted by the applicant. A registered professional engineer has evaluated conditions and agrees that the building will likely be damaged by the large stature trees in the future. Staff recommends removal of the two Coast Redwood trees located in the front yard of 401 Ingalls Street to mitigate future additional damage to the structural integrity of utilities, including water and sewer utilities.

The two redwood trees measure 38 inches in diameter and are approximately 60 feet tall. The crowns are healthy with normal vigor. The crowns are pruned routinely by the utility Pacific Gas & Electric for high voltage utility line clearance. Splices are visible in the high voltage wires from previous limb failure. The owner has experienced minor branch failure in the past, which is typical, and is concerned about public safety. The owner states strong wind impacts the area of these trees.

The redwoods trunks are located near the public sidewalk, which is lifted and crowned by approximately 1.5-2.0 inches. The tree trunks are approximately 11-12 feet from the building foundation. The foundation type is a slab; slab foundations promote condensation and attract tree root development below them. As the trees increase in size, the private arborist and registered professional engineer agree root damage to the foundation is likely.

More critical to the staff’s approval of the tree removal permit is the existing sewer lateral that runs directly between the two redwood trunks. It would be challenging to excavate and repair the damaged pipe located between the two trees and within the root zone without compromised equipment access and destabilization of the trees. The pipe is no longer properly sloped to drain and ponds water and effluent in the pipe. Camera evidence documents the damaged pipe and ponding water near the foundation. Removal of the two Redwoods would allow the owner to replace the damaged sewer lateral in-kind. The owner has obtained an estimate for in-kind repairs, including tree and stump removal, and water and sewer repair at a cost of $10,200. Water service is also located near to the two trees and is leaking from tree roots. This utility would be repaired in-kind at the time of the sewer repairs.

At the City’s request, the applicant has explored rerouting the water and sewer utilities to a different location and abandoning the old utility systems to save the two trees. This proposal is complicated and expensive. Tree root zones are extensive throughout the frontage, including large buttress roots for tree stability and widespread feeder roots. The area is constricted by utilities, including water and gas lines to the north of the trees, and electrical, communication, additional gas lines, and a storm drain to the south. The applicant has obtained an estimate from Santa Cruz Utility to relocate the water and sewer at an estimate of $74,700 (Applicant Documentation-401 Ingalls St. Tree Removal.pdf). This effort would require opening the sidewalk and street, securing Public Works traffic control, and additional approvals for encroachment permits, building permits, and Water Department permits. Significant excavation for potholing, trenching and soil compaction would be required within the critical root zone

36.3 requiring project arborist supervision at additional cost. Additional utilities may require relocation. The public sidewalk and street would require repairs from construction and may require engineered fill if spoils are unsuitable for required compaction. Confirming utility damage is required by City Council Resolution to grant tree removal; staff has no mechanism to force costly relocation of utilities to save trees by Resolution.

Per Council policy requiring mitigation, the applicant is required to post a refundable bond of $250 per tree, $500 and replant either two (2) 24-inch box trees or six (6) 15-gallon sized trees on the property. The applicant is committed to mitigate with appropriate stature trees.

The City Urban Forester agrees with the findings and analysis prepared by the applicant. Staff has determined that this application meets stated criteria required for tree removal approval as specified by City Council Resolution No. NS-23,710, Exhibit A 1.(c): “The heritage tree or heritage shrub has, or is likely to have, an adverse effect upon the structural integrity of a building, utility, or public or private right of way” (Res. NS-23,710 Exhibit A Criteria & Standards for Tree Permit Approval.pdf).

Staff recommends City Council deny the appeal and uphold the Park and Recreation Commission’s approval of the permit to remove two Coast redwoods located at 401 Ingalls Street.

HEALTH IN ALL POLICIES (HiAP): The removal of the trees directly supports the condition of public safety by addressing damaged sewer system. While the removal of heritage trees is a loss to the urban forest, the required mitigation plan to plant replacement trees demonstrates a commitment to maintaining green infrastructure over the long term. The city's action, therefore, balances the immediate need for public safety with the long-term goal of fostering a healthy and resilient urban ecosystem.

FISCAL IMPACT:

1. The recommendation in this report impacts the General Fund: No

2. This recommendation requires a budget adjustment: No

3. The recommendation creates an on-going expenditure commitment: No FISCAL IMPACT DESCRIPTION: None.

Prepared By:

Leslie Keedy
Urban Forester
Submitted By:

Tony Elliot
Parks and Recreation Director
Approved By:

Matt Huffaker
City Manager
ATTACHMENTS:

1. RESOLUTION.DOCX

2. APPLICANT DOCUMENTATION.PDF

3. APPEAL TO COMMISSION DATED AUGUST 4, 2025.PDF

4. APPEAL TO COUNCIL DATED OCTOBER 23, 2025.PDF

5. TREE REMOVAL PERMIT APPLICATION.PDF

6. ALTERRA LETTER REGARDING WATER AND SEWER.PDF

7. HERITAGE TREE MITIGATION $500 BOND PAYMENT.PDF

8. EMAILS FROM PARKS AND RECREATION COMMISSION MEETING.PDF

9. HIGH WIND ZONE DIAGRAM PROVIDED BY APPLICANT.PDF

36.4 10. OW COMMERCIAL PROPERTY LETTER.PDF

11. RESOLUTION NO. NS-23,710 EXHIBIT A STANDARDS FOR TREE PERMIT APPROVAL.PDF

12. PUBLIC WORKS EMAIL REGARDING MOVING SEWER LATERAL.PDF

13. TENTATIVE TREE PERMIT NOTICE OF ACTION.PDF

14. WATER DEPARTMENT EMAIL REGARDING MOVING METER.PDF

15. CORRESPONDENCE WITH APPLICANTS - SEPTEMBER 10 AND 11.PDF

16. CORRESPONDENCE WITH APPLICANTS - MAY 16 - JUNE 4.PDF

36.5 RESOLUTION NO. NS-30,XXX

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CRUZ

DENYING THE APPEAL AND UPHOLDING THE PARKS AND RECREATION

COMMISSION'S DECISION TO APPROVE AN APPLICATION TO REMOVE TWO COAST REDWOOD TREES LOCATED AT 401 INGALLS ST, SANTA CRUZ, CALIFORNIA WHEREAS, James Allen has filed an application for a tree removal permit to remove two coast redwood trees located at 401 Ingalls Street, Santa Cruz; and WHEREAS, the application was approved and Gillian Greensite appealed the staff decision to approve the application and filed an appeal with the staff to the Parks and Recreation Commission; and
WHEREAS, on October 13, 2025 the Parks and Recreation Commission, upon consideration of the request and written reports on the subject of the 401 Ingalls Street Tree Appeal, upheld staff’s decision approving the removal of the trees; and
WHEREAS, a letter of appeal from Gillian Greensite was submitted to the City Clerk on October 23, 2025 following the Parks and Recreation Commission's decision to approve the request for the removal of two coast redwood trees; and
WHEREAS, the City Council of the City of Santa Cruz held a public hearing on the matter on December 9, 2025.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Santa Cruz that the Parks and Recreation Commission’s decision is upheld and authorization for the removal of two coast redwood trees located at 401 Ingalls Street is hereby granted.

PASSED AND ADOPTED this 9th day of December, 2025, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Fred Keeley, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator

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Sunra Group, INC. 1824 Soquel Ave, Santa Cruz, CA 95062 831-621-5115 sunragroupinc.com
Sunra Group, INC.

Plumbing and Mechanical
1824 Soquel Ave, Unit C
Santa Cruz, CA 95062
May 14, 2025
James Allen
Alterra Solar
401 Ingalls St
Santa Cruz, CA 95060
Dear Mr. Allen,
We have inspected both the 4" domestic waste line and the 1" domestic water line between the sidewalk and the building.

Sewer: Although it appears the sewer line has been lined, it runs directly through the root ball of a large tree. Over time, this has caused the line to become raised beneath the tree, resulting in a back-pitched sewer lateral. Unfortunately, this condition cannot be corrected using a liner or pipe bursting method. The sewer line will need to be excavated and regraded to function properly.

This will require removal of the tree and the associated stump/root ball.

Water: The domestic water service lateral between the meter and the building is leaking, likely due to root pressure from the same tree. This has been confirmed by capping the line at the building and pressurizing it where it passes through the affected area; the line does not hold pressure. To resolve this, the water line would need to be rerouted, which would require relocating the water meter. This remedy would result in substantial additional costs to the project. Alternatively, if the tree and stump were removed, the water meter would be able to remain and the water line could be replaced following the current path.

Please feel free to reach out if you have any questions, Sincerely,
Jonathan Schantz
Sunra Group, Inc.
(831) 334-4680
[email protected]

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36.58 From: Gillian Greensite
To: Parks & Recreation Commission
Subject: Letter for commissioners
Date: Friday, October 10, 2025 10:43:03 AM
Attachments: Tree appeal letter.docx
Good morning Lindsay,
Attached is a letter for the commissioners regarding the tree appeal item on Monday’s agenda. Since Mr.Roddick is in the field today I offered to send it in.

Appreciate a quick reply that you have received this submission timely enough so that it will go to commissioners today.

Best regards,
Gillian

36.59 R.Roddick Construction
p.o box 426
Soquel, Ca.95073
Ca.Lic# 592190
Tree Appeal For Two Redwoods at 401 Ingalls St
October 10, 2025
Santa Cruz, Ca.

Dear Sir or Madam,
I hope this letter finds you well. I am writing to you regarding a matter of importance and would appreciate your attention and consideration.

I would like to bring to your notice the concerns I have observed and kindly request your assistance in addressing them. Your support and prompt response would be greatly valued.

Item 1. From my review of the provided partial video I see no real or conclusive evidence to indicate a lateral line failure that would indicate damage from a tree root or multiple tree roots. This condition could have been preexisting and perhaps an initial installation error. Is there prior evidence this line was ever installed correctly?

2. The recommendations that the water and sewer lines be rerouted is not reasonably supported by any documented visual evidence, without further allowed investigation of the proposed damaged utilities. How and who determined there is a complete line failure that has resulted from the existing trees?

3. The cost estimates for such relocation are unreasonably high. The existing water meter is approximately 20’ from the nearest redwood tree and out of the drip line which would indicate that if there were roots from the tree that have migrated in and around the main water line from the water meter that these roots would be easily removed without damage to the existing trees. That being said, we can’t believe in the assessment that the meter and water line would need to be relocated when a simple trenching by hand to the building following the water line and clipping the roots that may have migrated would solve this problem.

4. We believe at this time there is No significant reason to remove these trees.

If you require any additional information or clarification, please do not hesitate to reach out to me. I look forward to your reply.

Thank you for your time and consideration.

36.60 R.Roddick Construction
p.o box 426
Soquel, Ca.95073
Ca.Lic# 592190
Sincerely,
[Brad Roddick ]

36.61 From: [email protected]
To: Parks & Recreation Commission
Subject: 401 Ingalls St Tree Removal
Date: Friday, October 10, 2025 1:49:42 PM
To Whom This Concerns,
My name is Julie and I am one of the business owners next door to 401 Ingalls St. Santa Cruz CA. We have concerns about the trees in front of the building. In the winter we have witnessed quite a few branches falling onto the sidewalk and has even hit a car. These are dangerous trees to have near the sidewalk, road and the businesses that are next to these trees. We agree these trees should be removed before someone or something gets seriously injured.

Thank you for your time,
Julie Lindenberger
Gordon Rogers and staff.

A & A Auction Gallery
411 Ingalls St Ste 1
Santa Cruz CA 95060
(831)226-2321

36.62 From: Leslie Keedy
To: Parks & Recreation Commission
Cc: Lindsay Bass
Subject: FW: 401 Ingalls Tree Removal Appeal
Date: Monday, October 13, 2025 11:58:02 AM
Attachments: 401 Ingalls - Tree Removal Appeal Letter.pdf Please add to file
From: Christian Nielsen <[email protected]>
Sent: Monday, October 13, 2025 11:46 AM
To: Leslie Keedy <[email protected]>
Subject: 401 Ingalls Tree Removal Appeal
****CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.**** Hi Leslie,
Please see my attached letter regarding the commission meeting today. Can you please forward this to the commissioners? Thanks.

Best,
Christian
Christian Nielsen
Principal Architect
831 621 3926 x101
831 345 5388 Mobile
1509 Seabright 2B • Santa Cruz • 95062
Instagram
Facebook

36.63 Date: 10/13/2025
To: Parks & Recreation Commission
City of Santa Cruz
Re: Support for Denial of Appeal – Tree Removal Permit #TR25-0087 (401 Ingalls Street) Dear Commissioners,
I am writing in support of the staff’s recommendation to deny the appeal and uphold the approval of the Heritage Tree Removal Permit for 401 Ingalls Street.

While we all value the importance of preserving Santa Cruz’s urban forest, there are times when the practical impacts of tree preservation must be weighed against the financial realities faced by local property and business owners. In this case, the documented damage to existing utilities and the extremely high cost of rerouting those utilities—estimated at more than $74,000—clearly outweigh the benefit of maintaining the two redwood trees in question.

Requiring business owners to incur such substantial, unnecessary expenses in order to retain trees that are demonstrably damaging essential infrastructure sends the wrong message to the local business community. These types of financial burdens discourage reinvestment, drive small businesses to relocate outside city limits, and ultimately harm the local economy.

The property owner in this case has acted in good faith by following all City procedures, commissioning licensed professionals—including arborists, engineers, and plumbers—to evaluate the situation and provide documented evidence. Upholding the original decision supports a balanced approach—one that protects both public infrastructure and the economic vitality of our community.

For these reasons, I strongly urge the Commission to deny the appeal and affirm the Director’s decision to allow removal of the two Coast Redwood trees at 401 Ingalls Street.

Thank you for your time and consideration.

Sincerely,
Christian Nielsen
Architect C-31888

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OW COMMERCIAL
1601 41ST AVE #202
CAPITOLA, CA 95010
OW COMMERCIAL | 831 247 1175 | [email protected]
October 2, 2025
Dear Santa Cruz Parks and Recreation Commissioners,
My name is Benjamin Ow and I am the real estate broker who represented James Allen in his purchase of 401 Ingalls Street in Santa Cruz.

I am writing this letter to ask that you please support Mr. Allen's application to remove the trees that are negatively impacting the utilities and building systems at 401 Ingalls Street.

Mr. Allen did a more thorough investigation of the building during his due diligence period than most buyers, including hiring a professional building inspector to inspect the property, and the utility damage from the trees was not identified as a problem prior to the close of escrow. Now that the problem has been identified, Mr. Allen has applied for the tree removal permit so he can repair and protect the utilities and building systems at the property.

Mr. Allen is a small business owner who has chosen to reinvest in his neighborhood, at a substantially higher cost than if he were to relocate outside of Santa Cruz. He plans to greatly improve 401 Ingalls Street and make it the new home of Allterra Solar, a company that provides high quality jobs and career opportunities and offers affordable, clean solar energy solutions for our community. Please support Mr.

Allen and approve his application.

Best regards,
Benjamin Ow

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From: Leslie Keedy
To: Lindsay Bass
Subject: FW: 401 Ingalls Sewer Lateral
Date: Monday, October 6, 2025 4:59:48 PM
Attachments: image001.png
Another email to be added to list of attachments on staff report & also added as an attachment to the agenda package
From: Katie Stewart <[email protected]>
Sent: Monday, October 06, 2025 8:42 AM
To: Leslie Keedy <[email protected]>
Subject: 401 Ingalls Sewer Lateral
Hi Leslie,
It may be feasible for 401 Ingalls St to re-route their sewer lateral, however I will note that the portion of the lateral which is in the public right of way was recently inspected as part of the City’s time of sale lateral inspection program. It is in good condition and meets City standards.

If the property owner at 401 Ingalls St chooses to move forward with a reroute they would need to:

Confirm that the new service location meets applicable design standards and codes for separation from other utilities (eg water, storm drains) Does not conflict with any existing utilities (eg water main, storm drain main, communication)
Cap and abandon the existing lateral in place
Install the new lateral in compliance with City standard details and specifications including but not limited to sewer laterals, trenches, and pavement restoration Any work in the public right of way must be completed with a permit issued by the public works engineering department and by an appropriately licensed contractor. A traffic control plan will be required. More details can be found here:
https://www.cityofsantacruz.com/government/city-departments/publicworks/engineering/public-works-permits-for-contractors-4139 Any questions regarding work on private property should be directed to the planning and building department. Thanks,
Katie Stewart
Senior Professional Engineer
City of Santa Cruz | Public Works Engineering Division
809 Center Street, Room 201 Santa Cruz, CA 95060
(831) 420-5442 [email protected]

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36.70 From: Leslie Keedy
To: Lindsay Bass
Subject: FW: Moving a meter ? 401 Ingalls St (APN 003-094-36) Date: Tuesday, October 7, 2025 11:48:11 AM
Attachments: image002.png
image003.png
Meter and Tree.jpg
Meter and Root.jpg
From: Lewis Kay <[email protected]>
Sent: Tuesday, October 07, 2025 11:01 AM
To: Leslie Keedy <[email protected]>
Cc: Heidi Luckenbach <[email protected]>; Isidro Rivera <[email protected]> Subject: RE: Moving a meter ? 401 Ingalls St (APN 003-094-36) Hi Leslie,
To move and abandon a water service a permit from the Water Dept is required and would be issued for a fee; in this case around $1,200, which includes inspection. Construction would be performed by a properly licensed and insured contractor, at the applicant’s expense, and likely be on the order of tens of thousands of dollars.

Generally the scope would be 1) making a new service connection at the main in the street along the property frontage 2) installing a new meter box in the sidewalk 3) abandoning the existing service connection in the street 4) removing the old meter box in the sidewalk 5) restoring the street, curb and gutter, and sidewalk, and 6) property side plumbing (city responsibility ends at the back side of the meter).

I defer the need for a building permit to Planning/Building.

Attached are two photos from yesterday, one that shows the meter box and tree, and one that shows the inside of the meter box and tree root. No water leak was observed inside the meter box.

Happy to discuss and please let me know if you need additional information.

Lewis Kay
Engineering Associate
City of Santa Cruz | Water Department
212 Locust Street, Suite C, Santa Cruz, CA 95060
Direct: 831-420-5218 Mobile: 831-359-3218
Email: [email protected]
Web: cityofsantacruz.com

36.71 From: Heidi Luckenbach <[email protected]> Sent: Sunday, October 05, 2025 11:06 AM
To: Isidro Rivera <[email protected]>
Subject: FW: Moving a meter ?
Hi Isidro
Would you forward this to someone to look into please.

Thanks.

HeidiHeidi R. Luckenbach, P.E.

Water Director
City of Santa Cruz Water Department
212 Locust St., Suite C / Santa Cruz CA 95060
831/420-5214 (direct) | 831/334-2939 (cell)
Get Outlook for iOS
From: Heidi Luckenbach <[email protected]>
Sent: Sunday, October 5, 2025 10:54:12 AM
To: Leslie Keedy <[email protected]>
Subject: RE: Moving a meter ?
Hi Leslie
It looks like there are two parcels with the same address, and both have (or had) service.

Can you let me know which service you’re referring to? The one highlighted in green? Or Pink? Thanks.

HeidiHeidi R. Luckenbach, P.E.

Water Director
City of Santa Cruz Water Department
212 Locust St., Suite C / Santa Cruz CA 95060
831/420-5214 (direct) | 831/334-2939 (cell)

36.72 From: Leslie Keedy <[email protected]>
Sent: Friday, October 03, 2025 6:25 PM
To: Heidi Luckenbach <[email protected]>
Subject: Moving a meter ?
Good evening, Gillian Greensite has appealed a Tree permit that I have issued on a redwood tree that is causing a water leak at 401 ingalls. It’s also destroyed a sewer so I’ll ask Rome about that process. Can you please tell me what it takes to move and abandon a water lateral ? Im sure commission will ask questions about the complexity of permits inspection and costs for this process. In order to repair leak and if trees are retained, I suspect the pipe and possibly box would require moving it outside of the trees root system to a location where it won’t cause leaks again. I’m thinking it might need a building permit from Planning and professional documentation etc, I’m not sure about the complexity of tying it into your water mains? If you could outline or have one of your staff people helped me out so I can be more informed to share with our commission and then likely City Council. . Thanks Heidi
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36.83 Brittany Inclan
From: Jean Brocklebank <[email protected]>
Sent: Sunday, December 7, 2025 12:30 PM
To: City Council
Subject: Agenda Item 36 - Heritage trees at 401 Ingalls Dear City Council ~
I reviewed all documents for agenda item 36. After doing so, I now wholeheartedly support the appeal before you.

The new owner of the building, a good business which I also support in our community, should have accepted the trees as part of the fabric of Santa Cruz when he decided to make his purchase of the building. I imagine that he was counseled that he could get rid of the trees.

This is a shame, because there is no reason to assume that two majestic Heritage Redwood trees and a well regarded solar business are mutually exclusive. Quite the contrary ... saving the trees can become a part of the business's ethics, which must certainly be based, in part, on the absolute connection of the trees to all things solar ~ creators of oxygen, homes to a myriad of nature's species (above and below ground), and an integral part of the earth's water cycle.

On top of this:
 "The applicant’s Plumbing Engineer states that rerouting utilities is ‘technically possible’. Efforts must be made to save heritage trees.” A letter was also submitted by R. Roddick Construction stating that after their review of the evidence, they could find no reason for the trees to be removed."
 "The Parks and Recreation Commission majority failed to address these early violations of the Heritage Tree Ordinance."
City Municipal Code Chapter 9.56 is titled PRESERVATION OF HERITAGE TREES AND HERITAGE SHRUBS.

Chapter 10 of the City's General Plan emphasizes "The tree is metaphor for sustainability ... a critical element element of a livable environment ... a part of the urban ecosystem ... provide significant community benefits ... provide the potential to ameliorate heat buildup." NRC5.1 of Chapter 10 further requires "Protect and manage tree resources in the urban environment, with emphasis on significant and heritage trees." Words matter! The General Plan matters. The title of Chapter 9.56 matters. Yet annually hundreds of Heritage trees in the City are felled.

36.84 What is wrong with this picture?
Please accept the appeal before you and send the application back to the property owner to reconsider what can be done to save these trees.

Sincerely,
Jean

36. Tree Appeal – 401 Ingalls Street (Tree Removal Permit #TR25-0087) (PR) LOCATION: District 6
Motion to adopt a resolution to deny the appeal and uphold the Parks and Recreation Commission’s approval of heritage tree removal permit application TR25-0087 submitted by property owner James Allen to remove two Coast Redwood trees (Sequoia sempervirens) located at 401 Ingalls Street.

36.85 Brittany Inclan
From: Michael Lewis <[email protected]>
Sent: Sunday, December 7, 2025 12:48 PM
To: City Council
Subject: Agenda Item 36 - Heritage trees at 401 Ingalls Dear City Council:

After careful study of City documents relating to Agenda Item 36 - Heritage trees at 401 Ingalls, I ask that you grant the appeal to save these signature Heritage Trees from destruction.

Experts agree that the trees are not threatening the sidewalk or the building, and the utilities can be rerouted. Therefor there is no justification for an exception to the City's Heritage Tree ordinance.

The rights of these trees to exist and thrive in their present location, plus their contribution to the environmental and scenic quality of the community clearly outweigh the personal desires of the building owner, who purchased the property in full knowledge of the trees prior existence.

Do the right thing. Accept the appeal and direct the building owner to do what is necessary to save these trees!
Michael Lewis

36.86 Brittany Inclan
From: Gillian Greensite <[email protected]>
Sent: Monday, December 8, 2025 8:15 AM
To: Fred Keeley; Shebreh Kalantari-Johnson; Gabriela Trigueiro; Scott Newsome; Sonja Brunner; Susie O'Hara; Renee Golder; City Council
Subject: For Tree Appeal Item #36 on council agenda for 12/9/25 Attachments: Roddick letter Ingalls Trees.pdf
Dear Mayor and Council members,
Since Mr. Roddick is in the field today, I am sending his submission for the tree appeal item #36 on tomorrow's council agenda. Please find his submission attached below.

Sincerely,
Gillian
Save Our Big Trees

36.87 R. Roddick Construction
P.0 BOX 426 SOQUEL, CA 95073
December 8, 2025 R.Roddick
Construction
P.O. BOX 426
Soquel, CA 95073
Dear Mayor and Council,
Regarding the proposed Tree Removal at 401 Ingalls St. Santa Cruz, we remain partially perplexed about the removal to facilitate the installation of a new sewer line and replacement of a water line for the following reasons:
1) Since you were able to expose a water line and the ABS sewer line up to a certain point, why isn’t it possible to continue that trenching and if needed cut the roots, if possible, to allow the sewer line to be repositioned as needed? This would save a large expense of relocating sewer lines and water line according to your report. Can it not be possible to use a vacuum excavation unit to trench around the lines and the tree roots allowing full exposure of the lines for closer inspection? I believe the city has a vacuum unit in its possession.
2) We find the stated need for replacement of the existing water line to be excessive. Why does the meter need to be completely relocated? It’s a pressurized line so if it’s a copper replacement line it can be moved with 90% and 45% fittings and routed around the existing trees without moving the actual meter, which we understand is what’s proposed. It seems like all the referenced quotes for replacement assume having to change connections in the street, which of course becomes a larger event. Can someone explain the logic around this? 3) The cost of relocating both water and sewer lines is quoted at $74,000 compared with the quoted cost of $10,200 for the removal and stump grinding of the two trees and a new sewer and water line in the existing location needs independent verification. The disparity between the two costs appears excessive.
4) We question the video provided since it is incomplete. The video stops next to the building, but the written notes go far beyond that point. If the sewer line was inserted at the cleanout in the sidewalk area and it has indicated standing water at 23 ft., h ow can we know

36.88 there hasn’t been some settlement of the actual building structure (1989 earthquake?) or the actual line between the building and the trees have not settled as well? The assumption in the report attributes the problem to tree roots without evidence, which could be obtained to dispel all doubt. According to the report the sewer line has already been lined. Are there any records as to why it was lined? It didn’t appear in the video it was lined. It was obvious at the fittings it was ABS. Or perhaps it was only partially lined? 5) The photos of the trench dug to expose the sewer and water line was done to demonstrate with a level that the sewer line has a back pitch. However, from the photos, the level is placed on the water line not the sewer line. This demonstration proves nothing about the pitch of the sewer line.

36.89 The result is that a lot of assumptions are being made. What the actual reality is needs further examination.Can the trees be saved if Vacuum Excavation efforts are used? We believe they can.

Sincerely,
Brad Roddick
CEO
R.Roddick Construction

36.90 Brittany Inclan
From: Ron Pomerantz <[email protected]>
Sent: Monday, December 8, 2025 9:08 AM
To: City Council
Subject: 12/9/2025 Council Agenda Item #36: Tree Appeal – 401 Ingalls Street (Tree Removal Permit #TR25-0087) (PR)
Re. 12/9/2025 Council Agenda Item #36: Tree Appeal – 401 Ingalls Street (Tree Removal Permit #TR25-0087) (PR)
Good day Mayor and Councilmembers.

As one who frequents this area of town I feel the need to speak up. I strongly encourage you to support upholding the appeal to protect and preserve these 2 healthy, beautiful heritage redwood trees. All possible means must be used to uphold the Heritage Tree Ordinance. The city arborist, by describing this as a “tree removal process” is not supporting city policy as outlined in the City's Heritage Tree Ordinance which is to protect and preserve heritage trees in the fullest extent possible. I strongly ask each of you Councilmembers and staff to visit the site to see the importance of these trees to beautify and support a healthy environment in this commercial area of town. Redwoods are special and add a distinct beauty and diversity to urban Santa Cruz. Nothing can do justice to replace them with mediocre dime-a-dozen street trees.

No evidence is presented that the apparent sewer and water problems are caused by tree roots. It is assumptions only. That is true for statements from the private arborist, the professional engineer, the city arborist and footage from the pipe video.

The property owner has stated he wants the trees removed with no evidence of problems to his foundation or utility lines caused by the tree roots. The Parks and Recreation staff position accommodates that aim, rather than exploring the causes of any sewer or water pipe problems. No determination was in the report whether tree roots are involved and if so, assessing how that situation can be remedied. Does the property owner plan to do a remodel or construct additional building space and is merely planning ahead?
Once these beautiful redwoods are removed there will never be others to take their place in this area. Please uphold the appeal and assure the Heritage Tree Ordinance is abided by to the maximum extent.

Thank you for your time and thoughtful consideration.

Ron Pomerantz

36.91 Brittany Inclan
From: James Allen <[email protected]>
Sent: Monday, December 8, 2025 11:07 AM
To: Fred Keeley; Shebreh Kalantari-Johnson; Gabriela Trigueiro; Scott Newsome; Sonja Brunner; Susie O'Hara; City Council; Renee Golder
Subject: Message from James P. Allen, Board Certified Master Arborist/Certified Urban Forester re: Ingall Street Tree Removal Appeal, Item #36
Attachments: IngallsStreet_TreeRemovalPermitAppeal_JPA_12.8.25.pdf Honorable Mayor and City Council,
Please find attached my submission for Agenda Item #36, the Tree Appeal on today’s council agenda.

Respectfully,
James
James P. Allen
Registered Consulting Arborist #390
Certified Urban Forester #120
Board Certified Master Arborist #625B
Qualified Tree Risk Assessor
119 Surfside Avenue
Santa Cruz, CA 95060
831.426.6603 office
831.234.7739 mobile
__________________________________________________________________________ This communication (including any attachments) may contain privileged or confidential information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this communication and/or shred the materials and any attachments and are hereby notified that any disclosure, copying, or distribution of this communication, or the taking of any action based on it, is strictly prohibited. Thank you.

36.92 Dedicated to the Preservation of Trees
119 Surfside Avenue
Santa Cruz, CA 95060
831.426.6603 office
831.234.7739 mobile
[email protected]
www.consultingarborists.com
Consulting Arborists
December 7, 2025
Santa Cruz City Council
809 Center Street
Santa Cruz, CA 95060
Re: Appeal of Proposed Removal of Two Coast Redwoods (Sequoia sempervirens) 401 Ingalls Street, Santa Cruz, California Honorable Mayor and Council Members:

I am an invested, supportive and committed community member, home and business owner in the City of Santa Cruz of 52-years. I write in formal opposition to the removal of the two coast redwoods at 401 Ingalls Street and respectfully urge you to uphold the appeal filed by Ms.

Gillian Greensite on behalf of Save Our Big Trees.

I am a Board-Certified Master Arborist and Certified Urban Forester with over fifty years of professional experience in urban tree risk assessment, infrastructure conflicts, utility interface, and construction protection of mature trees.

These trees are healthy, structurally stable, and fully manageable within accepted arboricultural and civil engineering standards. Their proposed removal is based on unsupported conclusions, exaggerated language, and post-hoc justifications that were not present when the permit was originally approved.

Background and Prior Inspection
In early May 2025, at the request of the applicant, Mr. James Allen of Alterra Solar, I conducted a Level 2 visual inspection and structural assessment of both redwoods. At that time:
• Both trees exhibited good vitality and fair structure. • No conditions were identified that would constitute:
o an elevated risk rating, or
o qualification for Heritage Tree removal under City ordinance. • The only hardscape impact observed was minor sidewalk uplift, easily correctable through standard shaving and infill—not replacement.
• No documentation of utility damage was presented to me. • I explicitly advised Mr. Allen that I would not support removal of these trees. • It was evident that the applicant intended to pursue removal regardless, as a tree removal contractor was scheduled immediately following my site visit.

36.93

December 8, 2025
Deficiencies in the Bosinger Arborist Report
The arborist report prepared by Mr. Henry Bosinger contains numerous unscientific and unsupported assertions, including:

1. “Overdeveloped root systems”
This is not a recognized arboricultural diagnostic term. Buttressed redwood root architecture is normal, not pathological.

2. Claims of sewer and water line damage
These statements are made without excavation, camera confirmation, pressure testing, or utility verification. This is conjecture, not evidence.

3. “Trees have a tendency to drop large limbs in storms” Photographs show minor twig and branch litter, not structural limb failure.

4. “Overdevelopment of branches due to lack of competition” This condition is resolved through routine structural pruning, not removal.

5. Repeated use of non-technical exaggerations such as:
o “gigantic root system”
o “enormity of the roots”
o “massive roots overwhelming the area”
These are advocacy phrases, not professional findings.

6. “Wrong tree, wrong place” conclusion
This is directly contradicted by decades of successful redwood performance throughout downtown Santa Cruz in equal or tighter conditions.

7. Mr. Bosinger states he is “not a plumber”, yet asserts:
o plumbing damage,
o obstruction to repair,
o ongoing structural conflict.

These statements exceed his disciplinary authority and lack evidentiary support.

City Staff Presentation Contradictions
The Parks and Recreation PowerPoint presentation presented to the Commission contains internal contradictions, including:
• Acknowledgement that the trees are vigorous and healthy, while simultaneously advocating removal.
• Reliance on documents created after the appeal was filed, not before permit issuance. • Assertion of utility damage that had not been verified at the time of permit approval.

I am aware that the Council will receive pre-appeal email exchanges between City staff and the applicant reflecting procedural bias in favor of removal rather than neutral evaluation.

This gives the strong impression of collusion between city staff and the applicant and a definite Conflict of Interest.

36.94

December 8, 2025
Infrastructure Conflict are Routinely & Safely Managed
Urban root-utility and sidewalk conflicts are not automatic justification for removal. Standard mitigation includes:
• Hand excavation
• Root isolation
• Root pruning with load redistribution
• Sidewalk shaving
• Utility sleeving
• Trench bridging
• Directional boring
• Alternative construction methods
As the Consulting Arborist for several divisions of the Santa Cruz County Public Works for the past 40+ years I have successfully managed tree conflicts with
infrastructure, roads, sidewalks and waste management
systems. I participated in the design, construction and continual monitoring of a sewer installation directly
beneath a mature coast redwood located at 439 Riverview Avenue in Capitola over 20 years ago. That tree remains in good condition today, verified through long-term, frequent inspection.

These are routine industry solutions and common elements of a responsible Urban Forestry Program, not
extraordinary engineering.

Economic and Community Value
The contributory landscape value of these two redwoods, once formally appraised using the Trunk Formula Technique (Guide for Plant Appraisal, 10th Edition), will reflect a six-figure valuation.

Beyond monetary value, these trees provide:
• Carbon sequestration
• Urban heat island reduction
• Stormwater interception
• Wildlife habitat
• Aesthetic and cultural identity
• Downtown microclimate regulation
Conclusion
These two Coast Redwoods:
• Do not pose risk
• Are structurally defensible
• Are biologically healthy
• Can be retained with standard mitigation
• Not interfering with development or the intended use

36.95

December 8, 2025
Conclusion, continued
• File documents give the strong impression of collusion between city staff and the applicant and exemplify a definite Conflict of Interest • City of Santa Cruz has a duty to preserve Heritage trees as codified in Municipal Code and strongly stated in CEQA
• Were expected to be able to be removed by Mr. Allen prior to his purchase of the property
• Mr. Allen’s engagement of my services and contact with tree removal contractors, verifies his intent to remove the trees prior to his purchase of the property • Tree Removal permit was applied for and approved through exaggerated reporting and unsupported conclusions
• Were approved for removal before crucial and objective diagnostic data existed Tree removal is irreversible. Utility mitigation is routine and repairable.

The scientific and professional record supports retention.

Request
I respectfully urge the City Council to:

1. Grant the appeal filed by Ms. Gillian Greensite on behalf of Save Our Big Trees;

2. Deny the removal permit;

3. Direct appropriate root protection and utility mitigation design;

4. Require independent third-party arboricultural, public works and utility review for all future tree removal permit applications absent of City Staff influence and direction; Respectfully submitted,
James P. Allen
American Society of Consulting Arborists,
Registered Consulting Arborist #390
Society of American Foresters,
Certified Urban Forester #120
International Society of Arboriculture,
Board Certified Master Arborist #625B
International Society of Arboriculture,
Qualified Tree Risk Assessor
American Society of Consulting Arborists,
Tree and Plant Appraisal, Qualified
Certified Line Clearance Tree Trimmer
California State Contractors License C-61/D-49 #608703

36.96 Brittany Inclan
From: Rebecca Supplee <[email protected]>
Sent: Monday, December 8, 2025 4:32 PM
To: Fred Keeley; Shebreh Kalantari-Johnson; Gabriela Trigueiro; Scott Newsome; Sonja Brunner; Susie O'Hara; Renee Golder; City Council
Subject: Tree Appeal – 401 Ingalls Street, Removal Permit #TR25-0087 Dear Mayor and City Councilmembers,
I am writing to support the Tree Appeal for Tree Removal Permit #TR25-0087. The property owner has failed to demonstrate that these beautiful, healthy trees are impacting the utilities, nor the foundation of the building. We are losing hundreds of our heritage trees each year under the Tree Removal Permit Process. We have a Heritage Tree Ordinance because our City has determined that these trees add value to the whole community. I urge you to uphold this appeal and begin enforcing the Heritage Tree Ordinance.

Thank you,
Rebecca Supplee

36.97 Brittany Inclan
From: Elise Casby <[email protected]>
Sent: Monday, December 8, 2025 4:52 PM
To: City Council
Cc: [email protected]
Subject: Item 36 Tree Appeal Email to City Council
Dear Mayor Keeley, Santa Cruz City Council Members,
We must question the entire permitting process as it was so far conducted.

In a letter written by the city arborist, also known as the, "urban forester", for the City of Santa Cruz, CA, (LK) to Tal Balkin and Rina Zhou, there is evidence included in this email that the city's arborist is working to get, "a very defensible file", from the applicant's managers, Mr. Balkan. These are the words that the city arborist uses in this email.

Is this acceptable for the city arborist who is supposed to be neutral and follow the law to be working with the applicant to get a, "very defensible file"?
I would think it would show an extreme compromise of her position as one who is supposed to follow the law, in this case the, Heritage Tree Law, and remain neutral through the process of granting a permit to remove the heritage trees on Ingalls Street.

This email letter from the City of Santa Cruz arborist, (LK), is included in the city's agenda packet and dated, May 16, 2025, (It is also included in today's city council agenda packet), and LK further states, "Thanks for helping me help you get thru the scruntinized tree removal process".

This shows, I believe, that the city arborist was working in effect, to undermine the, Heritage Tree Law, and that she sees herself as engaged, "in a tree removal process".

To me, this clearly shows, not only a bias on the part of the city's arborist (L.K.) that favors the applicant who is requesting the permit to remove the two heritage redwood trees, but a serious breech of her duty to uphold city laws and processes that are under the protection of the law.

I believe the city arborist is in dereliction of her duty.

I sincerely request that all of you members of Santa Cruz City Council and the Mayor, investigate the city arborist's permitting process in this particular heritage tree permitting process and others from the past for possible collusion with the applicant of this tree permit process and other subterfuge and legality under the law.

Sincerely,
Elise Casby

36.98 Parks and Recreation
Department
Presenter: Leslie Keedy, Urban Forester
Parks & Recreation
401 Ingalls Street
Appeal of staff approval of
Tree Removal Permit Application #TR25-0087 to
remove two (2) Coast Redwood trees
City Council | Tree Appeal

36.99 Chapter 9.56: City of Santa Cruz Municipal Code
• The Heritage Tree has, or is likely to have, an
adverse effect upon the structural integrity of a
building, utility, or public or private right of way;
• The physical condition or health of the tree,
such as disease or infestation, warrants
alteration or removal;
• A construction project design cannot be altered
to accommodate existing Heritage trees.

City Council | Tree Appeal

36.100
Overview: 401 Ingalls Street
The Heritage Tree has, or is likely
to have, an adverse effect upon the
structural integrity of a building,
utility, or public or private right of
way;
City Council | Tree Appeal

36.101
Overview: 401 Ingalls Street
City Council | Tree Appeal

36.102
Overview: 401 Ingalls Street
• One private certified arborist and the staff arborist have inspected the location and agree damaged
utilities are likely adversely impacted by trees and
tree roots
• One plumber has inspected the utilities including the water line and sewer lateral confirming utility damage
• Camera images of the sewer lateral confirms ponding
water in the line due to pipe uplift near the trees
• Root excavation has been performed, revealing roots
present at the depth of water and sewer lines
• The sewer pipe has incorrect and reverse fall (backpitched slope) at the root zone of the trees • An engineer has offered an opinion on a likelihood of slab foundation damage
City Council | Tree Appeal

36.103
Overview: 401 Ingalls Street
• A cost analysis has been prepared by the applicant with estimates confirming:
• In- kind repair of water and sewer systems are
estimated at 10,200 including tree removal, stump
grinding, and water and sewer repairs
• Complex rerouting repair of water and sewer systems is estimated at 74,000 and would include opening and
repairing the sidewalk and street, public works permits for encroachment, traffic control, water department
permits, planning building permits. Excavation in the
root zone, potholing, trenching, soil compaction and
possibly engineered fill, other utilities may require
relocation
• Relocation would require private arborist oversight
•
City Council | Tree Appeal

36.104
Overview: 401 Ingalls Street
Sewer Rerouting repair Public Works Department:
• Confirm that the new service location meets applicable design standards and codes for separation from other
utilities (eg water, storm drains) and does not conflict with any existing utilities (eg water main, storm drain main, communication)
• Cap and abandon the existing lateral in place
• Install the new lateral in compliance with City standard details and specifications including but not limited to sewer laterals, trenches, and pavement restoration
• Any work in the public right of way must be completed with a permit issued by the public works engineering
department and by an appropriately licensed contractor
• A traffic control plan will be required and encroachment permit
City Council | Tree Appeal

36.105
Overview: 401 Ingalls Street
Water Service Rerouting repair Water Department:

A permit from the Water Dept is required and would be
issued for a fee; $1,200, which includes inspections.

1. making a new service connection at the main in the street along the property frontage

2. installing a new meter box in the sidewalk

3. abandoning existing service connection in the street

4. removing the old meter box in the sidewalk

5. restoring the street, curb and gutter, and sidewalk

6. property side plumbing (city responsibility ends at the back side of the meter)
Construction would be performed by a properly licensed
and insured contractor, at the applicant’s expense, and likely be on the order of tens of thousands of dollars
City Council | Tree Appeal

36.106
Overview: 401 Ingalls Street
• The Heritage Tree has, or is likely to have,
an adverse effect upon the structural
integrity of a building, utility, or public or
private right of way;
• The physical condition or health of the
tree, such as disease or infestation,
warrants alteration or removal;
• A construction project design cannot be
altered to accommodate existing Heritage
trees.

Council Resolution does not mandate relocation
City Council | Tree Appeal

36.107
Staff Findings: Canopy
• Redwoods are vigorous and healthy
• Poor Crown Foliage Ratio North side from
ongoing utility pruning contributes to
limb failure
• Minor failed dead branches and moderate
diameter previous limb failures
• Medium diameter over hanging branches
over high voltage PG & E facilities
• Minor encroachment over structure
City Council | Tree Appeal

36.108
Staff Findings: Canopy
• Medium diameter branches
growing over high voltage
PG & E facilities
• Splices visible in high voltage
wires from previous branch
failure onto PG&E facilities
and guy wire
• Potential public safety
concern for pedestrians,
street & potential fire hazard
concerns
City Council | Tree Appeal

36.109
Staff Findings: Trunks & Root Zone
• The two trees are growing within
1-2 feet of the public sidewalk
• The sidewalk is lifted by 1.5-2
inches
City Council | Tree Appeal

36.110
Staff Findings: Trunks & Root Zone
• Western tree is close to the
water meter
• Western tree is growing on
top of the water lateral
• The water department
reports continuous usage
from a leak
• Tree roots are present in the
meter box on the sidewalk
City Council | Tree Appeal

36.111

36.112
Staff Findings: Trunks & Root Zone
• Western tree is close to the
property line and neighbor’s
gas line
• Western tree is relatively close
to neighbor’s water service
• Western tree is cracking
neighbor’s gutter and has a
minor lift of their sidewalk
City Council | Tree Appeal

36.113
Staff Findings: Trunks & Root Zone
• Two trees are growing on the
owner’s sewer lateral and
water line
• Water and sewer are together
in a portion of the trench then
diverge
City Council | Tree Appeal

36.114
Staff Findings: Trunks & Root Zone
• Owner’s sewer lateral runs
between and under both
trees
• Owner’s sewer later has
reverse fall (back –pitched
slope) and is ponding
water at the building
• Plumber camera imagery
shows ponding water at
the structure
City Council | Tree Appeal

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36.120
Staff conclusions: Trunks & Root Zone
• Two redwood trees are likely the cause
of the sewer damage/uplift and the water
leak
• The relatively narrow landscape frontage
area has numerous utilities including gas,
water, communications, underground
electric, site drainage, and sewer
• Relocating the sewer and water could
require additional utilities to be
relocated.
• Staff cannot mandate costly relocation
per Resolution
• Relocation would be an estimated 74,700
verses a 10,200 in kind repair
City Council | Tree Appeal

36.121
Chapter 9.56: City of Santa Cruz Municipal Code
• The Heritage Tree has, or is likely to have, an
adverse effect upon the structural integrity of a
building, utility, or public or private right of way;
• The physical condition or health of the tree,
such as disease or infestation, warrants
alteration or removal;
• A construction project design cannot be altered
to accommodate existing Heritage trees.

City Council | Tree Appeal

36.122
Staff Recommendation
Motion to:

Deny the appeal and uphold the Parks and
Recreation Staff decision to approve
Heritage Tree removal permit application
#TR25-0087 to remove two (2) Coast
Redwood at 401 Ingalls.

City Council | Tree Appeal

36.123
Tree Permit Application Form
City Council | Tree Appeal

36.124

TREE APPEAL
401 Ingalls St.

Santa Cruz
December 9, 2025
City of Santa Cruz Heritage Tree Ordinance- 94-01
c) Encourage and assure the continuation of
quality community development whereby
existing trees and shrubs are incorporated
into any development and accorded proper
maintenance and protection as part of the
city’s urban forest.

36.125
• Inaccuracies in Agenda Report
• The Agenda Report claims all the reports below were done prior to the issuance of the July 24 tree removal permit and were used as a basis to make that decision. Not true. Those reports in red were obtained after the appeal and after the decision by the city to grant the tree removal permit.
• Private arborist report. Henry Bosinger
• Professional engineer: damage potential to structural integrity of foundation (September 10)
• USA (Underground Service Alert) mark utilities at tree location. • Licensed plumber to camera existing sewer lateral to confirm root damage, pipe damage and ponding. (September 29)
• Cost analysis of rerouting water and sewer.

36.126
Evidence of city bias
May 16 Email from the city arborist to the site project manager, the site architect, and the city planner for the project for 401 Ingalls St. two months prior to the decision to grant the tree removal permit.

Please continue to explore rerouting of both to determine feasibility as if it goes to appeal all of this information will be necessary to explain and be requested. Last redwood tree appeal took professional letters, an engineer and 3 arborists to get thru 2 city council meetings. I need a very defensible file.

Thanks for helping me help you get thru the scrutinized tree removal process.

36.127
The application for the tree removal
permit stated that the trees are
“destroying utilities and sidewalk.”

36.128

36.129
• Arborist Bosinger: May 2015
“The area between the sidewalk and the building is not adequate for this species of tree.” “It is the wrong tree in the wrong place.”
“The root crown of one tree is less than 24 inches from the sidewalk. The other is less than 12 inches.”
“Gigantic root system overwhelming the area.”
• Professional Engineer Urfer & Associates
“The two trees are very close to the building and per the arborist reports, the roots of this type of tree can spread out over 100 feet horizontally. We have seen damage done to building foundations and walls leading to cracked windows etc. by tree roots before. There is no other way to mitigate this other than removing the tree, so we agree with the arborist that this is the only solution.” 36.130

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36.137
AI Overview
In the pipe bursting method, the new sewer pipe is seamless, typically made from fused High-Density Polyethylene (HDPE), which is a major advantage because it eliminates joints and seams that are common failure points, preventing future root intrusion and leaks.
“I will note that the portion of the lateral that is in the public right of way was recently inspected as part of the City’s time of sale lateral inspection program. It is in good condition and meets city standards,” October 6, 2025. Email to city arborist from Senior Professional Engineer, Public Works. 36.138

TREE APPEAL
401 Ingalls St. Santa Cruz
December 9, 2025
City of Santa Cruz Heritage Tree Ordinance-94-01
c) Encourage and assure the continuation of quality community development whereby existing trees and shrubs are incorporated into any development and accorded proper maintenance and protection as part of the city’s urban forest.

Each year, 300 to 400 heritage trees are cut down, with permit, in the 13 square mile city of Santa Cruz. 36.139

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