Save Our Agricultural Land v. County of Santa Cruz CA6

I. FACTUAL AND PROCEDURAL BACKGROUND

A. First amended verified petition and complaint2 1. Alleged facts The Property consists of an approximately 6400-acre parcel of land, located inland of Highway 1 in Santa Cruz County within the Coastal Zone established by the California Coastal Act, and it contains “an imminent reversionary interest in a portion of the water supply for the Town of Davenport as well as important agricultural and timber lands, and highly sensitive environmental resources.” The Property has been owned by CDLC since 1902. On October 26, 1998, TPL purchased CDLC and subsequently developed a plan to

2 The first amended verified petition and complaint was filed after the County, TPL and Coast Dairies’ demurrers to the initial verified petition and complaint were sustained with leave to amend.

2 transfer the Property to the BLM. After BLM indicated it would not accept any portion of the Property used for agriculture, farm labor housing and/or disposal of industrial waste, cement dust or slurry, TPL and CDLC revised the plan to exclude such areas from the proposed transfer. On March 1, 2004, the Coastal Commission wrote to TPL advising that it would have…