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Planning commission allows applied bird‑safe treatments for Laguna Royale railing replacement, with inspection reporting requirement
Summary
After reviewing biological evidence and Coastal Commission guidance, the Planning Commission modified a prior condition to allow applied bird‑safe treatments (decals/dots) in lieu of ultraviolet-impregnated glass for new guardrails at Laguna Royale; approval includes biannual inspection and reporting requirements.
The Planning Commission on Wednesday approved a modification to condition 8 of its earlier approval for deck repairs and glass guardrail replacement at the Laguna Royale condominium complex, allowing the use of applied bird‑safe treatments (such as ClearDot/kaleidoscope dots) on new guardrails instead of requiring ultraviolet-impregnated OrnaLux glass.
Heather Stevens, senior planner, reviewed the project history: Laguna Royale (31423 Coast Highway) is a 78-unit oceanfront condominium complex where earlier approvals covered repair of approximately 15,600 square feet of elevated deck area, replacement of noncompliant metal railings, and installation of new guardrails. At the October 4, 2023 approval the commission required new visually permeable railings to be OrnaLux or equivalent with ultraviolet patterns incorporated into the glass; existing glass could be treated with aftermarket coatings or materials.
The project was appealed to the California Coastal Commission, which on May 8, 2024 found no substantial issue with the city's approval but later issued a post-action letter (May 16, 2024) interpreting condition 8 as requiring ultraviolet-patterned glass in new installations. City staff’s director subsequently confirmed that interpretation. The Laguna Royale HOA submitted contemporaneous biological evidence from Hamilton Biological and others that ClearDot/kaleidoscope applied dots are more effective at preventing bird strikes in their setting and are less costly. The applicant also noted practical timing concerns: the commission’s earlier requirement for existing glass to be treated within the two-year window means treatment must occur before any new panels are installed.
Rob Hamilton of Hamilton Biological provided a written analysis asserting applied dots are at least as effective as—or superior to—UV-impregnated glass in the conditions relevant to Laguna Royale (dusk/dawn, overcast coastal conditions and species sensitivities). Applicant representatives said the dots carry a 10-year manufacturer warranty and that they previously installed similar treatments on common-area panels without observed bird strikes.
Commissioners asked whether the prior condition requiring treatment of existing glass had been implemented; staff confirmed the requirement remains and that the current application seeks a modification for the new glass only. Commissioners discussed relative effectiveness, cost, and maintenance; several commissioners cited the Hamilton Biological analysis and national guidance noting decals/stickers can be highly effective. The commission added a condition requiring biannual inspections and reporting to the director to ensure applied treatments remain in place and effective.
By motion the planning commission approved Design Review 25-0707 and Coastal Development Permit 25-0708 to modify condition 8 of Planning Commission Resolution 23-0701, finding the action exempt from CEQA. The vote was unanimous (Commissioners Goldman, Whiting, Dubin, Chair Sadler voting yes). Chair Sadler noted a 14-day right of appeal to City Council; the Coastal Commission could also review any further appeal that follows city action.
The commission’s approval allows the Laguna Royale HOA to use applied dots/tapes on new and existing guardrails subject to the biannual inspection and reporting condition and the two-year implementation timeframe tied to the earlier approval window.
