STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY EDMUND G. BROWN, JR., GOVERNOR

CALIFORNIA COASTAL COMMISSION South Coast Area Office 200 Oceangate, Suite 1000 Long Beach, CA 90802-4302 (562) 590-5071

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CDP NO. 5-17-0630 (BURKE FAMILY TRUST AND JOYCE FAMILY TRUST)

SEPTEMBER 13, 2018

EXHIBITS

Exhibit 1 – Vicinity Map and Project Location

Exhibit 2 – Site Plan

Exhibit 3 – Construction Access Plan

Exhibit 4 – Construction Plans

Exhibit 5 – Habitat Survey for 529 and 533 Paseo de la Playa, Coastal Development Permit Application No. 5-17-0630, prepared by Biologist Ann Dalkey on October 25, 2017

Exhibit 6 – Southern Coastal Bluff Scrub ESHA at 529 and 533 Paseo de la Playa, Torrance, CA, prepared by Dr. Jonna Engel, CCC Senior Ecologist, August 28, 2018

Exhibit 7 – Construction Path Alternative 3

Exhibit 8– Construction Path Alternative 4

LANDSCAPE DESIGN: SOILS ENGINEER/GEOLOGIST: CIVIL ENGINEER: APPLICANT: PROPERTY ADDRESS: LEGEND: EARTHWORK QUANTITIES: FLOOD ZONE:

Bolton Engineering Corp. 1 Civil Engineering and Surveying 25834 Narbonne Avenue Suite 210 Lomita, Ca. 90717 Ph: 310-325-5580 Fax: 310-325-5581

STATE OF CALIFORNIA -- THE RESOURCES AGENCY EDMUND G BROWN JR, Governor CALIFORNIA COASTAL COMMISSION SOUTH CENTRAL COAST AREA 89 SOUTH CALIFORNIA ST., SUITE 200 VENTURA, CA 93001 (805) 585-1800

M E M O R A N D U M

FROM: Jonna D. Engel, Ph.D., Senior Ecologist

TO: Mandy Revell, Coastal Program Analyst

SUBJECT: Southern Coastal Bluff Scrub ESHA at 529 and 533 Paseo de la Playa, Redondo Beach, California

DATE: August 28, 2018 Documents Reviewed:

Dalkey, A.M. June 8, 2018. El Segundo Blue Habitat Survey. Letter report to Ms. Monica R. Briseno, 2029 Century Park East, Suite 2100, LA, CA 90067.

Dalkey, A.M. April 23, 2018. Access Path Clearance. Letter report to Mr. Martin Burke, 533 Paseo de la Playa, Torrance, CA 90277.

Dalkey, A.M. October 2017. Habitat Survey for 529 and 533 Paseo de la Playa. Coastal Development Permit Application No. 5-17-0630.

Osborne, K.H. 2010. Surveys for El Segundo blue ( allyni) at Redondo/Torrance Beaches and Dockweiler State Beach, Los Angeles County, California. Prepared for Urban Wildlands Group, PO Box 24042, Los Angeles, CA 90024. 16 pp.

Longcore, T. and J. George (The Urban Wildlands Group, Inc.). 2001. Habitat evaluation and Surveys for El Segundo Blue Butterfly (Euphilotes bernardino allyni) at Malaga Bluffs. Prepared for USFWS Cooperative Agreement # 1448- 11430-1-J041.

U.S. Fish and Wildlife Service. 1998. Recovery Plan for the El Segundo Blue Butterfly (Euphilotes battoides allyni). Portland, Oregon. 67 pp.

I have been asked to examine the coastal bluff below homes located at 529 and 533 Paseo de la Playa to determine if the area supports environmentally sensitive habitat. The single family homes at these addresses sit along the edge of a relatively steep coastal bluff in Torrance, California. In October 2017 Anne M. Dalkey submitted a J. Engel memo re: SCBS ESHA at 529 & 533 Paseo de la Playa August 28, 2018

habitat survey of the coastal bluff area below the homes to the Coastal Commission. As Ms. Dalkey notes in her introduction, the habitat survey is necessary because “…information is needed regarding the El Segundo blue butterfly (Euphilotes battoides allyni) and its host plant sea-cliff buckwheat ( parvifolium).” In addition to surveying the bluff for their host plan, Ms. Dalkey also surveyed the native and non- native vegetation on the coastal bluff.

Policy 30107.5 of the Coastal Act defines environmentally sensitive habitat or ESHA as:

Environmentally sensitive area” means any area in which plant or life or their habitats are either rare or especially valuable because of their special nature or role in an ecosystem and which could be easily disturbed or degraded by human activities and developments.

There are three important elements to the definition of ESHA. First, a geographic area can be designated ESHA either because of the presence of individual species of plants or or because of the presence of a particular habitat. Second, in order for an area to be designated as ESHA, the species or habitat must be either rare or it must be especially valuable. Of course, all species play a role in their ecosystem that is arguably “special.” However, the Coastal Act requires that this role be “especially valuable.” Finally, the area must be easily disturbed or degraded by human activities.

The El Segundo blue butterfly is endemic to southwestern Los Angeles County in coastal southern California and was listed as endangered by the USFWS in 1976. The 1998 USFWS habitat recovery plan (‘recovery plan’) describes the historic range of the butterfly as likely extending over much of the El Segundo sand dunes and the northwestern Palos Verdes peninsula. The plan states that the historic range of the butterfly has been greatly reduced by urban development and that the species is also imperiled by invasive plants, over-collecting, and possibly off-road vehicles. The distribution of the butterfly is dependent on the presence of its host food plant, sea-cliff buckwheat. It also appears to be further limited to habitats with high sand content.

Four Recovery Units (RUs), areas known to be inhabited by the butterfly and that contain restorable habitat, were established by the recovery plan. The recovery plan identified a significant population of El Segundo blue in the Malaga Cove area, just south of 529 and 533 Paseo de la Playa, and considered Torrance one of the four targeted RUs. In 2001, three butterflies were observed on the bluff below 521 Paseo de la Playa, which is approximately 180 feet north of the subject parcels (Longcore, T. & J. George 2001). And 445 to 507 Paseo de la Playa, 1,000 feet north of the subject parcels, is a well-known hub of El Segundo Blue Butterfly habitat (Pers. Comm, Dr. Travis Longcore, Friday, August 2, 2018). Ms. Dalkey reported that a 2008 synoptic survey, conducted by K. H. Osborne (Osborne 2010), documented the existence of the butterfly at all sites with suitable habitat that was visible when looking through fencing at the base of the Paseo de la Playa residences.

2 J. Engel memo re: SCBS ESHA at 529 & 533 Paseo de la Playa August 28, 2018

The coastal bluff below the subject homes has a small patch of the butterfly’s host plant, sea-cliff buckwheat (Figure 1). Sea-cliff buckwheat is a native species that is endemic to dunes and coastal bluffs and terraces along the coast of central and southern California. It is found within Southern Coastal Bluff Scrub (SCBS) habitat which is dominated by low shrubs and prostrate herbaceous species found on exposed bluffs above the ocean. Southern Coastal Bluff Scrub cover may be dense or sparse depending on slope steepness and it typically grows in sandy or sandy loam soils. The species composition is similar to and intergrades with Coastal Sage Scrub but differs in containing species better adapted to the extreme wind, salt spray, and steep slopes of the bluffs. Southern Coastal Bluff Scrub is one of the rarest and most threatened habitats in California. It is considered critically imperiled by the California Department of Fish and Wildlife with a rarity ranking of G1 S1.1. This ranking means that this habitat is at very high risk of extinction due to extreme rarity (often 5 or fewer populations), very steep declines, or other factors.

The coastal bluff below the homes at 529 and 533 Paseo de la Playa is characterized by patches of native species, non-native species, and areas of bare sandy soil. The area of coastal bluff immediately below the subject homes is very steep as can be seen by the contour lines on Figure 1, lack of vegetation, and location of the slope failure. I do not know the vegetation history, but I suspect this area it is too steep to support much, if any, vegetation. The slope below the failure area is less steep and here there are patches of vegetation and bare sandy areas as expected for SCBS on a relatively steep slope. The native species include lemonade berry, Rhus integrifolia, salt bush, Atriplex lentiformis, desert-thorn, Lycium brevipes var. hassei, and sea-cliff buckwheat which are characteristic bluff scrub species. Lemonade berry is the dominant native on the bluff and it only occurs along the coast below Point Conception. Lemonade berry scrub is a vulnerable type of habitat with a rarity ranking of G3 S3 which means it is at moderate risk of extinction due to a restricted range, relatively few populations (often 80 or fewer), recent and widespread declines, or other factors. Ms. Dalkey found that the bluff was occupied by a significant cover of non-natives but the only species she identified by name was freeway iceplant, Carpobrotus edulis.

My professional opinion is that the section of coastal bluff, below the subject homes and below the slope failure, supports SCBS (Figure 2). This portion of the slope, which is not as steep, has patches of native bluff scrub species (interspersed with patches of non-native species) and bare areas, which is characteristic of SCBS on relatively steep slopes. Most native habitat in California is invaded by non-natives to one degree or another and the fact that the SCBS in this location is invaded by non-natives is not unusual given the proximity of ornamental landscaping within a residential urban setting. The SCBS below the subject homes is not a small, isolated patch of habitat but rather part of a large area, comprised of native bluff species, non-natives, and bare areas, that stretches from Torrance Beach to Malaga Cove (over 4,000 feet).

3 J. Engel memo re: SCBS ESHA at 529 & 533 Paseo de la Playa August 28, 2018

Ms. Dalkey reported that her survey could not determine whether the El Segundo blue butterfly was present on the coastal bluff below the subject parcels because it occurred after the butterfly’s flight season. However, she did say that while the butterflies could use their host plants on the site, she thought it was unlikely, because in her 10 year experience doing butterfly surveys, she had found that they prefer more pristine areas.

I find that the coastal bluff, below the homes at 529 and 533 Paseo de la Playa, and below the slope failure, as outlined on Figure 2, is ESHA because it supports SCBS habitat as defined above. SCBS is a very rare habitat type (G1 S1.1) that meets the rarity test for ESHA. And SCBS is easily disturbed and degraded by human activities and development such as the introduction of non-native ornamental and invasive species and clearing for trails. Furthermore, the SCBS in this area is within the Torrance RU for the endangered El Segundo blue butterfly and it does support a patch of sea-cliff buckwheat, the host plant for the butterfly. Therefore, it is possible the butterfly may occur on this site.

4 Figure 1. Figure 1 from Ann Dalkey’s October 2017 Habitat Survey for 529 and 533 Paseo de la Playa which depicts the significant vegetation stands on the coastal bluff below the subject Homes. ESHA

Figure 2. Figure 1 from Ann Dalkey’s October 2017 Habitat Survey for 529 and 533 Paseo de la Playa with the area of the bluff below the subject homes identified as ESHA outlined in red. fe qe U X a `re `a a hb cddUefc`gb p Ve U p X a `re `a a hs ra VU Vre p g b U c `Wp fc d a X Wa p e r`b a c h g tuVh v X wxc `g e gT e U VVWX a p b Y V`a b d h Vd a h g i X c WWh a p p b

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Bolton Engineering Corp. 1 Civil Engineering and Surveying 25834 Narbonne Avenue Suite 210 Lomita, Ca. 90717 Ph: 310-325-5580 Fax: 310-325-5581