HMB’s Q&A about AB1991 translated from spin into plain English


Posted by on Sat, May 3, 2008

1.  What is AB 1991?

AB 1991 is a special local rescue bill to help the City of Half Moon Bay avoid payment of an $18 million settlement for a $41.1 million court-imposed liability resulting from a dispute with the owner of property known as Beachwood. The bill is narrowly and carefully drafted to preserve the City’s and State’s commitments to protecting wetlands and the environment, and it sets no precedent for building on land with manmade wetlands. This is because AB 1991 is predicated on three facts unique to this situation only that combined into a perfect storm for the City: (1) the wetland conditions on Beachwood are man-made, accidentally resulting from a City drainage project; (2) development was approved in 1990 after a review found no environmental impact; and (3) the City faced a court-imposed liability that would have bankrupted the City. The bill explicitly states in its preamble that, without these three facts, it cannot be used as precedent.

AB1991 is a bill that will exempt a developer from all state and local environmental and planning laws in exchange for forgiving a debt of $18 million that the city of Half Moon Bay agreed to pay him.

2. What does AB 1991 do?

AB 1991 is a narrowly drafted bill that applies only to Beachwood and the adjacent property of Glencree, and it re-authorizes the subdivision maps for these properties originally approved in 1990 to help the City settle costly litigation and avoid payment of an $18 million settlement of a $41.1 million court-imposed liability.

It also provides a useful template for the future conversion of state and local environmental and planning laws into cash.

3.  Why didn’t Half Moon Bay appeal?

Although the City felt it had a strong appeal, litigation is costly and unpredictable, and the downside risk of having to pay a $41.1 million judgment was simply too great. With this settlement, the City now has only two options: (1) either AB 1991 passes; or (2) the City must pay the property owner $18 million, a cost that will seriously impact Cit y services, including public safety.

We’ve never opposed building out these lots beyond the legal maximum. And, although we’re telling you it will cost $18 million, we’re not talking about the indisputable fact that it will cost a lot less. That’s one reason we agreed to the settlement without consulting the Coastal Commission, the citizens of Half Moon Bay, our state Assemblyman, or Senator. Finally, although there’s no evidence that paying the settlement will affect public safety, you should take our word for it.

4. Is there some other way to pay the owner and save this property?

No. No organization, environmental or otherwise, has offered to pay the $18 million for the property or provide the City with the funds to do so. Furthermore, there’s nothing to save. Development of Beachwood and Glencree has always been a part of the City’s growth plan, and the properties are surrounded by residential subdivisions. Simply put, this is not the kind of property that the Coastal Act was meant to protect.

No. We’ve made that impossible.

5. How many authorizations and permits does AD 1991 bypass?

None. The proposed development received the required authorizations when the project was originally approved in 1990, including those under the California Environmental Quality Act (CEQA). AB 1991 would reinstate these approvals despite the lengthy delay due to litigation.

A Coastal Development Permit (CDP) could have been issued without a problem at the time of the original City approvals because no wetlands existed on the property. In fact, a U.S. District Court found: "The development history of this Property has been marked by a long series of approvals by the City, the California Coastal Commission and the California Department of Fish & Game. None of the agencies ever raised any issue regarding wetlands on Beachwood in the pre-TAAD years, and this lack of concern continued well after the construction of TAAD."

All of them. If it didn’t, we wouldn’t need a bill.

6. Are there wetlands on Beachwood?

Yes. The southeast comer of the Beachwood property contains wetlands, which were protected by the 1990 subdivision approvals and will continue to be protected under the settlement agreement.

Other portions of Beachwood and Glencree are subject to wetland conditions as a result of City construction activities. However, federal law does not consider these areas wetlands because they fall into an exemption for wetlands created by construction activities.

No federal agency has ruled on the source of the wetlands on Glencree. However, we hope that by telling the feds that we created the wetlands we can avoid paying the developer $18 million.

7. Are the wetlands on Beachwood federally protected?

No. In addition, we have no reason to believe that a federal permitting process is required before development. In 1989 and 1999, the U.S. Army Corps of Engineers said no permitting was required, and we have no reason to believe this time will be any different. Meanwhile, the previously-identified wetlands in the southeast comer of Beachwood will continue to be protected under the settlement agreement.

We hope not, but we have no idea whether there are federally-protected wetlands on Glencree.

8. Will endangered species be harmed?

No. No endangered species have been observed on the property during intensive review over many years, and the property does not contain habitat suitable for such species. A CEQA review of the property prior to approval of the subdivision plan concluded that no protected species would be affected by the development.

We have no idea. No one’s looked in 20 years.

9. Does AB 1991 "sell out" coastal wetland protection for all of California in order to protect Half Moon Bay from bankruptcy?

Absolutely not. AB 1991 is narrowly drafted so that it will only apply to Beachwood and Glencree, which have always been part of the City’s residential development plan, and no other properties. The bill is also carefully predicated on three facts unique to Half Moon Bay’s situation only that combined into the perfect storm the City now faces: (1) the wetland conditions on Beachwood are man-made, accidentally resulting from a City drainage project; (2) development was approved in 1990 after a review found no environmental impact; and (3) the City faced a court-imposed liability that would have bankrupted the City.

The bill explicitly states in its preamble that, without these three facts, it cannot be used as precedent.

California’s coastal wetlands, both natural and man-made, will continue to be protected by the Coastal Act and the California Coastal Commission on a state level, and the U.S. Army Corps of Engineers on a federal level. This bill has zero impact on these protections.


10. Won’t developers in the future ask for special bills like AB 1991 that give them an exemption from the Coastal Act?

No. As we have said, the circumstances that led to AB 1991 are unique and will not be repeated. Specifically: (1) the wetland conditions on Beachwood are man-made, accidentally resulting from a City drainage project; (2) development was approved in 1990 after a review found no environmental impact; and (3) the City faced a court-imposed liability that would have bankrupted the City. Because this unique combination of facts will not occur again, AB 1991 is not a precedent for permitting development on wetlands, whether naturally-occurring or manmade.


11. Does AB 1991 have any effect on how Coastal Development Permits will be issued in the future?

No. AB 1991 is a narrowly drafted bill affecting only Beachwood and Glencree. AB 1991 is based on the unique facts of the Beachwood litigation: (1) the wetland conditions are the result of half-completed grading and drainage improvements undertaken by the City of Half Moon Bay; (2) development was always part of the City’s growth plan and was approved in 1990; and (3) the City faced a $41.1 million judgment that could have bankrupted it.

Natural and man-made wetlands will continue to be protected by the California Coastal Commission and the City through its Local Coastal Program.


12. Beachwood was originally zoned for 83 houses, and the settlement agreement allows construction of 129 houses. Why is the City allowing more houses on Beachwood than was authorized in 1990?

The 129 lots refers to the combined number of lots on Beachwood and an adjacent strip of land known as Glencree. AB 1991 authorizes development of 83 houses on Beachwood and 46 lots on Glencree, as originally planned by the City.

Good question.

13. Why is Glencree included in the settlement? I thought the litigation was over Beachwood.

The 12-acre Glencree parcel is adjacent to Beachwood. The City is facing pending litigation regarding Glencree that could subject the City to similar claims. AB 1991 would eliminate that threat to the City. Glencree had also been previously approved for development at approximately the same time as Beachwood with no adverse environmental impact. From current observations, there appear to be wetland conditions on Glencree that one can reasonably assume developed after the City’s construction activities in the 1980s.

We included Glencree because the developer told us to. It has nothing to do with the lawsuit that we settled other than the fact that the developer saw a chance to get it on the express track.

14. Does AB 1991 override the entire Coastal Act?

No. AB 1991 is narrowly drafted so that it will only apply to the properties of Beachwood and Glencree, both of which have always been part of Half Moon Bay’s residential development plan. AB 1991 does not apply to any property other than Beachwood and Glencree. The Coastal Act will continue to protect coastal wetlands through the Coastal Commission and Local Coastal Programs.
AB 1991 is limited to the unique circumstances of the Beachwood litigation and will not serve as precedent for any future legislation: (1) the wetland conditions are the result of half-completed grading and drainage improvements undertaken by the City of Half Moon Bay; (2) development was always part of the City’s growth plan and was approved in 1990; and (3) the City faced a $41.1 million judgment that would have bankrupted the City.
Because this perfect storm of unique facts will not occur again, AB 1991 is not a precedent for permitting development on wetlands, whether naturally-occurring or manmade.

If AB1991 didn’t override the Coastal Act, it wouldn’t be necessary. Any future damage to Coastal Act enforcement is strictly collateral damage, but it wouldn’t break our hearts, either.

15. How do you react to the fact that the California Coastal Commission voted unanimously to oppose AB 1991?

The Coastal Commission announced its opposition to the settlement agreement before reading the final bill or permitting the City to explain why it entered the settlement agreement, which would allow the City to avoid paying $18 million to settle a $41.1 million court-imposed liability.

It is ironic that the Coastal Commission, on whose advice the City originally relied when it denied a development permit for Beachwood, resulting in the $41.1 million liability, has now decided to oppose the settlement agreement that would allow the City to avoid this liability. The Coastal Commission did so with a predisposed set of opinions uninformed by the facts and without consulting the City, and thus resulting in misleading and false statements, as shown by the Commission’s inaccurate letter to the California Legislature.

The Coastal Commission didn’t get a look at the bill until the last possible second, but they knew exactly what was coming when they saw the settlement. We didn’t disappoint them. We’re dealing with this by disparaging their good will and legal competence.

16. Why did Senator Yee drop his name from the bill so quickly? What does that mean for the legislation?

We were disappointed Sen. Yee did not co-author the legislation. We hope he will support it when he learns all the facts - that the bill is narrowly tailored to Beachwood’s specific circumstances, that it does nothing to weaken environmental protections, and that it sets no precedent for the future. We commend Assemblyman Mullin for introducing the bill, and all parties intend to do whatever we can to help pass it.

Senator Yee agreed to be a co-author without looking at the bill. As soon as he saw the bill, he took his name off it.  Why do you think he did it?

17. Environmental groups have already come out against AB 1991. What is your reaction?

It’s unfortunate that they took this position before hearing all the facts before even seeing the legislation. We believe the bill’s text is explicit in creating no precedent for weakening protections for the environment, including wetlands of any kind. We have met with some of these groups and are reaching out to others to ask for their ideas and, if they are inclined, their help. We look forward to continuing to educate them on the facts.

We’re pretending to listen to them, but we’re also disparaging them in our testimony and in documents like this.

18. Is AD 1991 constitutional/legal?


Has anybody seriously asked that question?

19. Can environmentalists prevent passage of AB 1991?

We can’t speculate. However, we are confident that AB 1991 will become law and are working hard to make that happen. We look forward to working closely with those in the environmental community who are concerned about AB 1991 to share the facts and to assure them that this bill will do nothing to weaken environmental protections. We hope they will appreciate the importance of this narrowly tailored, one-of-a-kind bill, which will help the City of Half Moon Bay avoid paying an $18 million settlement that would otherwise severely diminish city services, including public safety.

We ignored the environmentalists in the run-up to the settlement, and now we’re trying to convince them that night is day. It turns out that they’re not that stupid, but we’re betting the legislature is.

Fantastic piece here… covers quite a bit amidst the 2,322 words (thanks to Mozilla Firefox for the word count, 11,738 characters for those interested in more breakdown).

As always, I appreciate a more “palatable” serving on the spin, as it’s always good to revisit context. However, I do see some of this “swung” back to anti-1991 side of this pendulous matter, vs plain and simple clarity. It’s opinionated clarity, which is fine, but noted for what it pretends. For instance… the rhetoric of “all permits”... does that include building permits, secondary infrastructure permits, fire/safety et. al. ... sounds frighteningly all-inclusive when it’s put that way. I know what was meant, but color can provide as much as, sometimes more, than content… ask the ‘mainstream media’ espousing as “un-biased”.

I understand (at last I think I do) the passion about holding fast to what has been so often fought hard for (as an on/again off/again 38 year resident in these parts). But does everyone just want the city to take it on the chin, and prove what??? I’ll repeat my blather, in that I look at this as pretty much farm land, with converted farm land on each side, on the east side of a major arterial, nee state highway. Bite the bullet, save the millions, take the lesson learned. Good to see this unrelenting 100% sticking to thine’s ideals, but I just see so many folks whom would rather have a lose-lose vs a consolatory lose-win in this situation… all in the name of already overzealous protectionism.

The passing of the bill will not be a slippery slope that will end up turning the midcoast into the San Clemente hillsides, or Oakland (gotta like that reference… whomever threw that out in another thread, love the conspiracy that a city council would some how band together, meet in the catacombs under Main St, and have a secret ideal to turn a sleepy coastal town vehemently locked in by POST and no-growthers into a major MSA… the Half Moon Bay A’s… I like it).

Besides, I have complete confidence in the deft and unrelenting no-growthers here on the Coast coming in on the next project and sealing a development’s fate for failure.

It just seems some unintended evil came out of good intentions from the get-go. Good intentions backed by ideals that I somewhat already disagree with, but for this sake can console with (a la lose-win vs lose-lose). I see no difference, nor harm in what Beachwood will/could/should become vs the subdivisions that are next to it.

Even Judge Walker would say that the development proposed by the city is illegal. That’s why the city is trying to change the law.  I’m hardly a no-growther and have always been prepared to support reasonable, legal development of Beachwood.

The rule of law is a meaningless concept if you can get yourself released from it in exchange for money.

Beachwood is part of the ongoing urban sprawl process set into motion in the City of HMB many decades ago. As such, it and all future sprawl activities will make the city less sustainable and less liveable. Nothing about sprawl improves liveability.

It is probably too late for HMB and its classic leapfrog sprawl to redesign itself into anything better. Who is going to tear down those outlying subdivisions? But the same is not true for the several unincorporated communities if they can figure out how to block such bad plans for damaging development as those embodied in the proposed LCP revision prepared by the county and involve the principles of liveability well known to community architects.

18. Is AD 1991 constitutional/legal?


Has anybody seriously asked that question?

If a settlement is similar to contract and HMB lacks the capacity to pay $18 million, then the “contract” isn’t enforceable.

I don’t know if that’s the case, but it would be interesting to know if the settlement could be challenged on that basis.

There’s also the constitutional question of legislating in a such a way as to effectively change legislation resulting from a voter initiative.

That’d be another dandy precedent this lousy bill would establish. Don’t like Prop. 13? Then use the Subdivision Map Act to re-define residential property in a way that allows the state to disqualify most Californians from the mortgage interest deduction.

Barry wrote: “The rule of law is a meaningless concept if you can get yourself released from it in exchange for money.”

I agree with that as a core value, but an already overzealous law doesn’t warrant it as unquestionable law or doctrine. Slavery was legal (perhaps far too reaching analogy I know, sorry), or legal precedent to not allow to women to vote… required landmark contrarian actions (whether local thru federal civics).

The money, the actual land itself, the acts and environmentalist precedent thereof… there’s many factors going on…  this is just silly. It is also a great time to swing this proverbial pendulum back towards the “reasonability” side. There should be dismissal and review of these type of very debatable laws, acts, commissions on a case-by-case basis, anyways. This isn’t a developer with $25 million additional for legal fees to fight everyone on a Fitzgerald Marine Reserve landfill with 50 condo units, and leveraging some “in”. Sure, the city tripped up here, but granted ... tripped by the very “wires” they helped to set and support into place over the past decades. Of course, the “pitchforks” and “torches” of their enviro-extremist constituenc loomed on the streets, so they HAD to espouse and practice to gain the support from their “witch hunt” constituency). Too much digression, opinion… moving on.

Half of me would love to see this fail. If you grew up here in the late 70’s/early 80’s, you’ll remember the removal of so many services via “Prop 13”. I can see it now circa 2015 as social and public services decay in HMB, and “Beachwood” is blamed for it… although I can see the remnants of the AB1991 will have already moved to Del Norte County or Montana by then to escape what they couldn’t overcome.  Many blame the city 100%, I also blame McCarthy-like environmental strongholds and witch hunts that got the city into this mess. What could of been a developer coming back to the city and saying clean up this mess, and eat the $25K bill, it’s at a legal/moral impasse.

How serendipitous it would be to cast a “deserves you right”, yet realize the innocent (youth, poor, etc) take the brunt. Thanks folks, this was bound to happen, and will continue to happen.

Also, good to see so many non-HMB residents (a-hem) lashing out at 1991 here on ol’ Coastsidah, easy to fight for “undebatable” precedent vs. personal impact. Maybe we can get AB1991 amended to require all Beachwood residents to drive Hybrids and use clean nuclear energy to power their homes, in case it does pass… too late ;-)

I’ve decided I really don’t care what sanctity of life, including the necessary life support systems provided by nature, means to other people. Who are they to decide what is vital to them, to have their representatives vote protections for those things into law (or to vote the laws into being directly in initiatives), and then to impose that law on me? Their self-serving laws are just their opinion of what they want. In other words, debatable.

What brings on this outburst is my decision to investigate the position of hit man. Short hours and good pay, I hear. We even had a famous hit man living in Moss Beach at one time, and people can remember how good it was then. None of the endless namby-pamby concern about civil and ethical rights we have now. No pretending you were going to live forever if someone did not kill you. No trying to take away a person’s chosen profession just because life-extremists managed to gang up and force through a bunch of capricious, over-the-top laws about murder.

We need to go step-by-step through our law enforcement system, rescind laws against killing others, and begin to dismantle the portion of the overzealous law enforcement community working on homicides. Put them to work defending “property rights” or something else that does some good for the wealthy few to whom this country owes everything. That will free me to do what I might want to do, and I have a right to freedom as much as anyone else. Admit it; that part of the Declaration of Independence that said everyone has a right to life never said how long that life had to be, now did it?

You have your silly values and I have my superior ones. Stop dreaming the kind of life you want counts for something and get out of my way.

Carl May

If AB 1991 restores everything as it was in 1990, Half Moon Bay misses out on all impact fees that have been established or revised since then, Cabrillo Unified School District (CUSD) loses any school mitigation fees, etc., etc.

Someone on TalkAbout was complaining about there not being enough money for schools - see “School Funding - Property taxes fall short”,;=

Under Proposition 13 limits, each of those 129 houses might produce $3,500 or so in property taxes for CUSD. That’s about enough to educate half a child. So the more school children that come from the Beachwood / Glencree developments, the further in the hole, financially, CUSD will go.

Residential development usually does not generate enough in property taxes to pay for the cost of services that it requires. On the other hand, if HMB or a special district doesn’t need to provide any incremental services, any new revenue would be a positive thing. For example, if the existing fire department has enough apparatus and staffing to cover these new homes, it would benefit from around $200,000 more a year to cover existing expenses and salaries.

“For example, if the existing fire department has enough apparatus and staffing to cover these new homes, it would benefit from around $200,000 more a year to cover existing expenses and salaries.”

Net result in such a case, current taxpayers in the now-combined fire district would subsidize the developer. Gee, thanks, former Point Montara directors for possibly consolidating us MMBers into yet another bad deal. But don’t worry about us citizens, we’re used to having our interests thrown away without having a chance to vote on it.

Carl May

My intent here isn’t to knock Carl May off his soap box.  I just don’t want anyone seriously involved with AB1991 issue to run off with misinformation.  CFD’s are complex, I don’t have all the information on CFPD’s actual regulation or the history of Beachwood and HMBFPD, but here is what I know:

Beachwood is in the HMBFPD service zone of CFPD.  Big commercial, multiple residential and probably large housing subdivisions are subject to a Mello-Roos Community Facilities District(CFD) in the HMBFPD service zone of CFPD. CFD is a structure to recapture the cost of the existing Fire infrastructure the development would benefit from over and above property taxes.  Given the Beachwood saga has dragged on so long, it’s hard to say whether Beachwood or Glencree were grandfathered as far as HMBFPD and CFPD.  Mello-Roos was enacted in 1982 and I don’t know when HMBFPD enacted their CFD regulations under Mello-Roos.  I don’t know whether HMBFPD accepted any prior subdivision plans form Keenan. I suspect, the 129 homes on Beachwood and Glencree as far as CFPD is concerned would be a new development, because that combination did not exist before the HMB/Keenan settlement. CFPD is a separate entity from the City of HMB.  I wouldn’t expect CFPD to be bound by any agreement between the City of HMB and Keenan.

PMFPD and now the PMFPD service zone in CFPD doesn’t have CFD’s.  Developments in PMFPD get a free ride on the existing Fire infrastructure.  At some point, CFPD needs to get the two service zones to have similar regulations.  Hopefully, that will mean CFD’s in the Point Montara service zone.

A call to Chief Cole or Chief Jolley at CFPD could clear this issue up.  I don’t know if they could answer off the top of their heads or would have to do some research.

As bad a mess as Beachwood is, and as bad a precedent for the state as AB 1991 is, in context this is just an example of destructive urban sprawl proceding in mindless fashion in only one of the many growth-addled cities in the state. We will see a lot more of this in the rest of HMB and on the unincorporated midcoast, especially if legislative chicanery like AB 1991 is successful in helping to clear the way around obstacles.

No one needs to punish the wrongdoers in places like HMB. In the not so long term, thoughtless growth is its own punishment. HMB, and probably the midcoast communities under the county’s misguidance, have already begun to suffer the effects of declining livability and the social and economic ill health that goes with that. Those with money will be able to deny it and insulate themselves from the worst effects for a few years longer than those living more from day to day. More and more scientists, demographers, economists, sociologists, and others looking at contemporary problems on a global scale are concluding it is too late to avoid dire global consequences due to population overshoot and multiple, interacting problems with misuse of natural resources and declining natural systems. Here is just one recent attempt to communicate what can be said about our state of affairs to a lay audience:

There is no answer to peak fossil fuels this century. Those who theorize nuclear energy is going to bail out the planet have not calculated how long it would take to get the energy supply flowing and how intractable the political problems are worldwide to even allow this approach to be tried.(U.S. position on Iran, anyone?) Cleanup of nuclear waste is actually sliding backward as our government tries to promote more of what it cannot handle:

Part II:

In spite of the increasing global misery to come, few experts on the factors involved envision a sudden die-off and environmental Armageddon. (None believe religious myth or cornucopian magic will rescue us, either.) Localities and governments with long-term views have a much better chance of providing livability through it all, no matter the details and timing.

Where there is local control, there is greater chance for survival and success, as people with their living situation in common can agree and adapt for success even as larger, more abstract regions and institutions become more desperately nonsensical. This means communities designed for energy and resource efficiency and with ensured supplies of those things and food.

In thinking about stable, livable communities, many anthropologists, sociologists, and urban designers are coming up with something a lot like older European towns centered on a commercial and employment core and ending abruptly at their outer boundaries. Walking and bicycling distances are short and doable for almost all, and vehicles, while present, are secondary and mostly out of sight. (In other words, the towns emphasize the activities of people and not cars.) Though such small cities have more people per unit area than urban areas built for the sake of vehicles, they usually seem less crowded and frantic.

For our local populations, HMB, with its haphazard checkerboard of subdivisions laid out in grids, some miles from city center and with car-serving shopping malls being the main form of commercial activity, is obviously farthest from hope. And that city is so determined to keep with the pattern (witness Beachwood/Glencree) that peak fossil fuel and other crunches will be upon it before it can change course and redesign.

But El Granada, with its arcing and radiating street pattern and room for walking and biking paths, offers a more hopeful challenge. And Montara and Moss Beach, with room for more people-serving commercial development in their small cores are not beyond the pale; their badly laid out grids involve short enough distances to be bearable with some people amenities.

Carl,  ... Jerry Bruckheimer needs a new doomsday script, and I think you’ve got a calling here. 3/4 of San Mateo County itself is uninhabited… much less the state.

Success, survival, peak fossil fuel and other crunches will be upon it before it can change course and redesign

The best thing we can do is continue to use fossil fuels at exorbitant rates. Then ingenuity (perhaps American) will kick in, and the almighty dollar will drive a viable solution.

Increasing global misery? Wow, the glass is half full, at least.

High Country News????

Wait, your whole past was sarcasm… got it. Back to AB1991 please.

Not to worry. With any attempts to deal with quality of life and environmental problems on the coastside, it is understood improvement will have to come in spite of the financially self-centered and ignorant.

It is in the larger context of what is going on on a larger scale, how we fit into it, and what might be done for a better future that AB 1991 becomes fully illuminated for the scumbaggy ploy it is.

Carl May

I’ve decided that any post by Carl is just too lengthy and ranty to warrant my 15-20 minutes to read. Also, it looks like this article is soooo long it must have taken Barry several days to compile. It would be interesting to see how this article would have been if the writer actually lived in Half Moon Bay.

Actually, mostly it was a cut & paste of HMB’s current line of justification for AB1991, which consists mostly of handwaving:  Pay no attention to our undermining of the Coastal Act.  Let’s imagine that Beachwood has no value whatsoever.

Also, please note that AB1991 is a state law.  I’ve got as much of an interest in the integrity of the Coastal Act as anyone and a lot less to gain than a resident of Half Moon Bay from its subversion.