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HomeMy WebLinkAboutMINUTES - 04161996 - D.12 D. 12 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Adopted this Order on April 16, 1996 by the following vote: AYES: Supervisors Rogers,Bishop, DeSaulnier, Torlakson and Smith NOES: None ABSENT: None ABSTAIN: None ---------------------------- SUBJECT: Hearing on Administrative Appeal of Charles M. Koss, et al, Regarding the Issuance of a Grading Permit for Subdivision 7462 , Black Oak Estates, Diablo Area. This is the time heretofore noticed by the Clerk of the Board of Supervisors for hearing on the administrative appeal of Charles M. Koss, et al, from the decision regarding the issuance of a grading permit for Subdivision 7462, Black Oak Estates, Diablo area. Dennis Barry, Community Development Department, presented the staff report on the administrative appeal, giving a brief history of the project approval, and of actions leading to the appeal . The following persons presented testimony before the Board of Supervisors : Leah Weinger, P.O. Box 792 , Diablo, spoke in support of the appeal . Richard Carlston, 1331 N. Broadway, Suite 700, Walnut Creek, representing Black Oak Estates, spoke in opposition to the appeal . James Adams, 2043 Calle Los Callados, Diablo, spoke in support of the appeal . Dean Kimball, Contra Costa County Sheriff' s Department, spoke on traffic issues . Hal Seibert, no address given, advised that it was premature to grant a grading permit . Charles Koss, 2480 Mt . Diablo Scenic Boulevard, Diablo, spoke in support of the appeal . John M. Compaglia, 5000 Executive Parkway #125, San Ramon, project developer, reserved the right of rebuttal . The Board discussed the issues including grading permit procedures and policy, and access . Supervisor Torlakson suggested a meeting of staff and the parties to facilitate resolution of concerns . Supervisor Bishop concurred with the suggestion that the property owners meet with the developer, staff, and board members but that in the interim the grading activity cease, and she moved to continue the matter for one to three weeks to provide an opportunity for the parties to meet . Rebuttal testimony was presented by the applicant' s representative . Supervisor Torlakson seconded the motion, but requested that the matter be continued for one week and he requested clarification on the issue of whether the grading would cease or continue for the week. Supervisor Rogers requested to add to the motion that staff return to the Board with a review of the policy rationale behind permitting grading. Victor Westman clarified that the motion did not include a stop work order. The Chairman concurred. A member of . the audience requested that since there was no stop work order, that the matter be continued for one week. Supervisor Bishop agreed that the matter would be continued for one week. IT IS BY THE BOARD ORDERED that the hearing on the administrative appeal of Charles M. Koss, et al, regarding the issuance of a grading permit for Subdivision 7462, Black Oak Estates, Diablo area, is CONTINUED to April 23 , 1996 , at 4 : 00 p.m. in the Board chambers; and staff is DIRECTED to meet with the parties involved to facilitate resolution of the issues; and staff is REQUESTED to provide for Board consideration in the near future a review of the policy permitting grading. I hereby certify that this Is a true and correct copy of an action taken and entered on the minutes of the Board of Supe ora on the date shown, ATTESTED: C(1 PHIL BA ELOR,Clerkof the Board .uperviso and County inistrator 0 By ,Dequty CC : Community Development Department County Counsel Charles A. Koss,, et al Black Oak Estates , Inc. Miller, Starr & REgalia, Richard Carlston ti............•O �' I�. Contra TO: BOARD OF SUPERVISORS 'S Costa County FROM: FRANKLIN LEW, DIRECTOR OF BUILDING INSPECTION �•• ' - Osr'� COUlyCt DATE: April 11, 1996 SUBJECT: Appeal by Charles A. Koss, et al, on an Administrative Decision to Issue a Grading Permit (#G206677) for the Black Oak Estates Project (SUB 7462 and FDP 3004-90) in the Diablo Area. SPECIFIC REQUEST(S) OR RECOMMENDATIONS) & BACKGROUND AND JUSTIFICATION RECOMMENDATIONS 1. Deny the Appeal of Charles A. Koss, et al, allowing grading for the Black Oak Estates project in accord with the grading permit as no violation of the County Ordinance (e.g. , Title 7 on grading permits)has been established by the Building Inspector. 2 . Direct the Public Works Department to notify Charles A. Koss of the review of any proposed final map for Subdivision 7462 when it is scheduled on the agenda of the Board of Supervisors. FISCAL IMPACT None. BACKGROUND/REASONS FOR RECOMMENDATIONS In 1992 , the Board of Supervisors approved the Black Oak Estates Planned Unit District Final Development Plan and Vesting Tentative Mapproject for 36 residential lots fronting on the east side of Mt. ' Diablo Scenic Boulevard. The project site is located between the community of Diablo and the Blackhawk residential project, north of \the Town of Danville and immediately north of the Athenian School. CONTINUED ON ATTACHMENT: X YES SIGNATURE RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER SIGNATURE(S) : ACTION OF BOARD ON APPROVED AS RECOMMENDED OTHER VOTE OF SUPE ORS I HEREBY RTIFY THAT THIS IS A UNANIMOUS (ABSEN TRUE D CORRECT COPY OF AN AYES: ON TAKEN AND ENTERED ON THE ABSENT: ABSTA MINUTES OF THE BOARD OF SUPERVISORS ON THE DATE SHOWN. Contact:Robert H. Drake (CDD) - 335 4 Orig: Building Inspection Depar ent ATTESTED cc: Black Oak Estates, PHIL BATCHELOR, CLERK OF Miller, Starr & R alia, Richard Carlston THE BOARD OF SUPERVISORS Charles A. Kos D COUNTY ADMINISTRATOR Public Wor Dept. Commun . Development Dept. BY , DEPUTY Co y Counsel 2 . Mt. Diablo Scenic Boulevard Mt. Diablo Scenic Boulevard (Scenic Boulevard) provides access to Mt. Diablo State park, several residences within the Diablo community (including appellants' residences) , and the Athenian School, a private school. Scenic Boulevard is a privately- maintained road, however, the State of California possesses an access easement to permit public access to the State park. Concerns Expressed at the Time of the 1992 Prosect Hearing Improvements - Prior to -the County approval, when the Black Oak Estates project was being considered by the County, staff had proposed that the segment of road extending from Diablo Road to the project entrance be upgraded to standards that would qualify for County maintenance. Such an upgrade would have meant providing a substantially wider road and right-of-way, curb and gutter improvements. The local community opposed such improvements because they felt that they would detract from the natural ambience of the area. Instead, the improvements required by the County in the approval of the project were more modest in scope; improvements that would be consistent with private road standards but not County road maintenance standards. Evidence of Legal Access - At the time of the project hearing, Diablo residents questioned whether the applicant possessed legal access to Scenic Boulevard. In response, the County conditioned the approval of the project to require that the applicant furnish legal proof to the satisfaction of County Counsel as well as the Public Works Department that legal access to the property is available from Diablo Road, the nearest publicly-maintained road (ref. C/A #36.L. ) . Moreover, the County required that there be evidence in the record that owners of all properties fronting on Scenic Boulevard be notified to provide an opportunity to submit comments or documentation on the question of legal access prior to a County determination. LEGAL ACCESS COMPLIANCE REVIEW Submittal of Evidence by the Applicant On January 13 , 1995 the title insurance company for the developer of the Black Oak Estates subdivision submitted copies of deeds and easements with a letter stating that the deeds and easements showed legal access to the subdivision from Diablo Road. Over the course of the next several months, the Public Works Department and County Counsel reviewed the deeds for adequacy and requested further information. On May 26, 1995 the applicant submitted a title insurance policy insuring access to the development from Diablo Road. On June 27, 1995 the title insurance company submitted a letter reaffirming that the title insurance policy was insuring access for the subdivision. Notice to Abutting Property Owners On January 10, 1995 notice was sent to all property owners fronting along Mount Diablo Scenic Boulevard. The mailing list was prepared by the developer and submitted to the Public Works Department along with a map showing which parcels were included on the mailing list. The map and list were checked by Public Works staff against the current addresses in the Assessor's Office data base. After verifying that the addresses were correct and the proper properties were included, the notifications were mailed. The notification included a copy of Condition of Approval #36 .L. and requested any information, comments, or evidence from the • i �. I Z 3 . neighboring property owners pertaining to the development's legal access rights on Mount Diablo Scenic Boulevard. The notification provided the neighboring property owners 30 days to respond. The only responses received concerning the development's legal access have been from Weingers, Kosses, and Hal Seibert. Public Works Department and County Counsel Review and Determination County Counsel reviewed the materials submitted by the applicant and other interested parties and concluded that sufficient proof of legal access to the property had been furnished and that Condition #36.L had been satisfied. This was stated in a memorandum from County Counsel dated June 27 , 1995 . On July 10, 1995, Public Works Department informed the developer of County Counsel's opinion and that the Public Works Department concurred that Condition #36.L had been satisfied. Copies of this letter were sent to the three neighbors who had raised the issue of legal access, the Weingers the Kosses, and Hal Seibert. Legal Challenge of County Determination by Abutting Property Owners Litigation was filed by the appellants contesting the determination by County Counsel and Public Works Department that sufficient proof of legal access had been furnished by the applicant. On December 9 , 1995 the court issued an order dismissing the appellants' lawsuit. According to the court, a lawsuit challenging the staff determination was not the proper way to challenge the applicant's legal access to Scenic Boulevard. Instead, appellants could raise the issue by filing a quiet title action against the applicant or by waiting until formal action is taken (e.g. , approval of the final map) and then filing a legal challenge. PROCESSING OF GRADING PERMIT APPLICATION The applicant filed grading plans with the Building Inspection Department. Staff determined that the plans were in accord with the 1992 Board of Supervisors approval of the Black Oak Estates project, the grading ordinance and other applicable laws. The Public Works and Community Development Departments reviewed the plans and advised the Building Inspection Department that they, did not have any objection to the issuance of a grading permit. Consequently, a grading permit was issued by the Building Inspection Department on February 27 , 1996. RECEIPT OF KOSS APPEAL On March 5, 1996, an appeal of the administrative decision to issue a grading permit for the Black Oak Estates project was filed by Charles A. Koss, et al. , with the Clerk of the Board. The appellants feel that issuance of a grading permit is pre-mature pending consideration of the final map for the project relative to compliance with the proof of legal access requirement. DEVELOPER'S RESPONSE TO KOSS APPEAL In a letter dated March 28, 1996 the applicant's engineer has responded to the appeal. The letter references a title policy endorsement from a title insurance company that had been provided to the County as evidence of legal access. The letter also indicates that the Koss appeal should be considered as an appeal under Title 8 (public hearing decisions) . 4 . DISCUSSION The 1992 approval of the Black Oak Estates project by the Board of Supervisors required that documentation of legal access to the site be provided to the County prior to the approval of the final map by the Board of Supervisors. That entitlement did not prevent the applicant from qualifying for a grading permit before the final map is approved by the Board of Supervisors. Where an applicant can demonstrate compliance with entitlements and applicable laws and ordinances, the County has traditionally allowed grading for subdivision projects to proceed in advance of the approval of the final map by the Board of Supervisors. Accordingly, not to allow the Black Oak Estates project to commence grading activity could be challenged as discretionary. Therefore, the appeal of the neighbors should not be granted. Notwithstanding the above, if the Board of Supervisors determines that there has been a code violation then the Board would have to authorize the Director of Building Inspection to place a stop-work order on the project. At the same time, staff is recommending that the Board direct the Public Works Department to notify the appellant of the consideration of any final map for Black Oak Estates when it is scheduled on the Board's agenda. Status of Final Map Application It is staff's understanding that the applicant must still post bonds for road and/or drainage improvements with the County before the Public Works Department is prepared to schedule the Black Oak Estates final map for approval by the Board of Supervisors. The Board of Supervisors decision to approve the final map will be ministerial in nature. That is, the Board must approve the final map if it is satisfied that the project complies with applicable conditions of approval of the tentative map approval, and applicable laws and ordinances. Processing of Appeal The decision to issue a grading permit was a ministerial action pursuant to the provision of Division 716 of Title 7 of the County Ordinance Code in relation to the 1992 zoning/subdivision approved entitlements. No violation of the County Ordinance Code (e.g. , Title 716) by the Building Inspector has occurred. As such, the appeal filed by Koss, et al. , is processed pursuant to Section 14 . 006 of the County Ordinance Code pertaining to appeals of administrative decisions. Such appeals are heard by the Board of Supervisors. Appeals filed pursuant to Title 8 pertain to planning agency decisions on discretionary projects. Therefore, the appeal is appropriately being processed under the administrative code and should be denied as no failure by the Building Inspector to comply with Title 7 (Division 716) can be established. RHD/aa BD1/Black.RHD sua C N-D tfl 0 AJ A" 36 . -T- 36 L. Furnish legal proof to the satisfaction of the County Counsel as well as Public Works Department, Engineering Services Division, that legal access to the property is available from Diablo Road. Said proof shall not consist of opinion letters from experts retained by the applicant. Prior to filing a final map, the applicant shall submit evidence that owners of all properties fronting on Mt. Diablo Scenic Boulevard have been mailed notices. The purpose of the notice shall be to provide an opportunity to potentially interested parties to submit documentation which pertains to the project's right ,to use and make improvements to mt. Diablo Scenic Boulevard as required by this approval. The notice shall invite the public to provide any evidence pertaining to the project's legal access rights (or lack thereof)to use Mt. Diablo Scenic Boulevard for submission to the Public Works Department within a minimum 30-day period. The Public Works Department shall review the responses and forward copies to County Counsel for review. 36 T. The applicant shall contribute a sum to the State of California for modification of the vertical curve on Mount Diablo Scenic Boulevard near the northerly line of this property. The contribution shall be placed in Public Works Trust Fund 819200-0800 and the State of California shall be adequately notified of the availability of the contribution and prerequisites to use of those funds. Accrued interest will remain in this account. This contribution shall be held for up to 24 months. If the State of California does not accept the money within the 24 month period the contribution shall revert back to the developer. The amount shall be based on a cost estimate prepared by the applicant's engineer subject to the review of the Public Works Department and review and approval of the -Zoning Administrator- The contribution shall be placed in the Trust Fund prior to the filing of the final map. A prerequisite to the State's use of the contribution is construction of the vertical curve improvements. BRYAN sus MURPHY BRYAN & MURPHY, GORMAN & ASSOCIATES, INC. 5000 Executive Parkway,Suite 125,San Ramon,CA 94583,(510)867-3380,FAX(510)867-3388 c� March 28, 1996 M. M,--, C-3 Mr. Harvey E. Bragdon, Dir. of Community Dev. Community Development Department rT1 Contra Costa County -a--� 651 Pine Street, 4th Flr.No. Wing v Martinez, CA 94553 —+ C3 u, RE: Subdivision 7462 Black Oak Estate Dear Mr. Bragdon: This letter is in response to the appeal dated March 5, 1996 by Charles A. Koss for the Grading Permit issued on February 27, 1996 to Top Grade Construction. A copy of said grading permit is enclosed for your reference. .The letter cites as the reason for appeal: the lack of a legal access to the parcel as required by Condition 36.L. of the Conditions of Approval for Subdivision 7462. The nature of the appeal would seem to come under Title 8 of the Contra Costa County Planning and Zoning Ordinance Article 26-2.24 appeals Section 26-2.2404 sub-paragraph C. Other Matters Item (2). not Section 14-4.002 Item(2) states: "Required standards identified by appellant, are not satisfied by the evidence presented at a hearing for rezoning conditional use,variance,plan or special permit." Condition 36.L. has been met by the applicant. It was evidenced by a title policy endorsement from Old Republic Title Company insuring access to the property. Further, supporting legal opinions were submitted by Miller, Starr& Regalia and McCutchen, Doyle, Brown and Enersen as to the right of access by the property owner. The endorsement has been reviewed and approved by County Council which cleared Condition 36.L.. The issue was also brought before the court and the ruling upheld the right of access to the property. The appellant is already aware of these facts. The condition has been complied with to the satisfaction of County Council. CJC55918.018 F. Mr. Harvey E. Bragdon March 28, 1996 Page 2 However, the Conditions of Approval for Subdivision 7462 do not require proof of access as a condition to issue the grading permit. Therefore, the appellant has no basis for the appeal because there is no violation of Article 26.2404. On behalf of the applicant we are requesting the appeal be denied. Sincerely, Bryan & Murphy, Gorman & Associates, Inc. M.M. 'Compaglia Senior Planner JMC:lg cc: David Schmidt, County Council Dennis Barry Bob Drake Richard Carlston Sanford M. Skaggs, Esq. Mike Bedker BRYAN MURPHY CJC55918018 ���& �� �,�__� �ERK80[ ��� �� ^ f �r--- n*oFORM BECOMES THE PERMIT WHEN APPROVED BUILDING INSPECTION DsPAnrwswT APPLICANT ' mvBUILDING DEPARTMENT AND NUMBER ASSIGNED CONTRA COSTA COUNTY rf"(40"Fl.. U51 PinoStn,dpmo, wo�xwinc # 203-14O-O�1-q Martinez, CA 94533-9991 206,677 PH. (s1o)s4s'23o /FAX (s/v)««s-oe DAlE 0?/27/96 (�RAWIN C/SUBOIVISION-SUPV APM'ICAN | TOP GRADE CUNSTRUCTION INC SEA'S MIC PK DED FLP Z DP | [ 1 SlREET 324 EARHART NAY SCH DIST SAN RAMOM UNI CJ ( Y iI\/ERMORE, CA DESC QRAOINO F8R SUD[/ 7462 Z[P 9455O PHONE 510'449 '5784 MBR BR NBR UN1 1: C(1) ^ -_----_'-----_ _ -- '--' ---' - �RFA DBLO ZONE A-2 CT 3551 ^O3 FEE CD DIMENSIUNS RAlE $ hi ||0 | TRACl LOT LUP t 3004-9025A 36�-)00 @ .00 S[REET CALLE LOS CAI-131100825C 38O0� @ ,O8 CRUSS ST ��C 20000 @ .00 tlX HGF 35 ' NR ST 2 1/2 MNSB 25^ MNSY 2O ' TIAT AL 92000 TOTAL 1680�' AC, TOTAL 401 REAR YD 15 ' ----- --�------------------ - -- - - ' - - --- ' --'----------- --�---------------- PLAN CHK PC940415 REVIENED BYI 0AlF OHN� R BLACK OAK ESTATES DAlE REGI) 08/19/94 EMC STREEF 111 DEERNnQD PL #200 BOX NO 057 ELEC C77Y sAm RAViON CA MECH 7VP 94583 D � ����������������������� FN� CONTR ToP GRADE CONSTRUCTION 1NC SlR�[V 324 EARHART WAY --- --------' ------- -- '-- '-' - ' ' — ' ' C [ lY LIVERMORE, CA RECEIPT # 811�40 7 [1:' 9q55O PH8111E 510-449-5764 G-RA,� PMT 681 1:",00 ( IC O.ASG A LIC # 592597 GRADPLNCHK 2O15^0O --- --- -------------------- ------- 0000316835 - 210� ,00 TOTAL PA}D** 5960 ^00 LICENSED CONTRACTORS DECLARATION lhnre,by affirm under penalty of perjury that I am licensed under provisions of Chapter 9(commencing vw;ttl Section 7000)of Division 3 of the Business and Professions Code.and my license is in full force uc I hereb.affirm under penalty of by Xollowlng� t from the Contractors r the - lonstruct,aller,improve,demolish,or repair any structure,prior to its issuance,also requiresp the Go'It,actots License Law(Chapter 9(commencing with Section 7000)of Division 3 of the Business �ld Proless�ons Code)or that he or she is exempt therefrom and the basis for the alleged exemption. Any violation of Section 7031.5 by any applicant for a permit subjects the appicant to a civil penalty of not M,ore than five hundred dollars($500).)� or my employees with wages as their sole CiDirnpensation,will do 1110 wolp"and thp structure � Intended- --safe(Sec.does not apply to an owner of property who bulds or improves thereon. 7044,Business-nd Professions-- 9nd vilro does such work himself or herself or through his or her own emploi—es,provided that such improvements are not intended or offered for sale.It,however,the building or iftprovement is sold within �.lne year of completion,the ownet-builder wilt have the burden of proviing that he or she did not build or improve for the purpose of sale.). D 1.as owner of the property,am exclusively contracting with licensed contractors to construct the'0j., ,-t(See;,7044,Business and Professions Code:The Contractors Licen"s Law does not apply to of properly who buiids or improves thereon,and who contracts Aor such projects with a lkensed pursuant to the Contractors License Law,). "w" m" __-_______-'oA,xfor this m°n" _-_______' ' �� WORKERS'COMPENSATION DECLARATION I hr.re!by affian urider penalty of perjury one of the following declarations I have and will maintain a certificate of consent to self-insure for Wcokers'compensation,as provided for by Section 3700 of the Labor Code,for the periomiance or the work for which this Pennit is issued, /.a,.,e and will maintain workers'compensation insurance,as required by 000/*° Lu� mw for the ��� mu ��m�issued. My=*� ' ['0[�rrCr-`�--R[p13'l�J (�9�9��^~~are: 1 �,J 491 ltI -.1 :us tasr J / t� 2 P Jar 1,s toe �ry rrtJ tis S o tJ� yyi° 'tT! 246 t�i5 Y155 lj1 IT 5 r i 4 rIp5 N /f '�U rrr Ylo\ t'i � ry !�¢otrti trrr i eI 2q4 9 1°v 3 2p2 4yt 8 YYtr t'Y'`` 490 tttt , i llryi ttil }/// OD � toy pR > W > d 'Q a 1 y2o 3t7° fl p'' 32 � /+489 Sa 2p7 V y 64 <JJ14�}. � t 1lld0 tli0 { 61 • dldo q 15 m_ '141 u pTNENi5CM001Go eo 61 }Ir r• a tt R c 4V 1 �H q rrae ARILLO nw r7iiiirr J o• rod> /."' 0 y gT J t o0 55 / i /set j1 574 ♦w w+ 84 g5 56 t r� t 1 lru 17p tr iBTw w 3 42 65 O�" 31=;30 + 46 w A5 5p 41. 3 34 y 24 ti 28 �R34f' 1 3 •.! M i 47+ ° w w e! 9 �y 33 274 26 t _ 26 ' •a 42 '4 �',` 1 dr F• 2 44 AA rd 38 36 ri ;- rr 'd rd O a' " A 1 q6 15 13 2012 y O ti {SUB /d. '� 1 o Q8 487 1 o ter Y p\t i tl V t0 to c 4 . +.$6 l 14� p- - -- - "4i tlpt ty ;� 23 i N tJFt 12' w ter 6101 lo6 5 tet 6 S ',7 %584 7 5 148 t583 15 900 too loo 1582 4Et EAS _. } 04 MEET7. a 1593 4�.�-..j�di'T 1581 too 940 �92�..158 �t I�,�,n►._.! 304 "••`....�--- � o _ 100 too 1580 soo rE7EA3 0 (t3T CC 300 304 0 300 RECEIVED LW7;W 6:vm - 5W a"6 o cr-suffjwr"s CONMA COSTA C March 5, 1996 HAND DELIVERED Clerk of the Board of Supervisors Contra Costa County County Administration Building 651 Pine Street Martinez, CA 94553 Re: Appeal of Grading Permit Subdivision Application No. 7462 Black Oak Estates Dear Sir or Madam: Pursuant to County Ordinance Code Section 14-4.002, and any other applicable provisions, the undersigned hereby submit this notice of appeal of staff's determination regarding the issuance of a grading permit for Subdivision 7462, Black Oak Estates. Section 14-4.002 authorizes any person aggrieved by an administrative action to file an appeal of that action to the County Board of Supervisors. The County Public Works' Department issued a grading permit to Black Oak Estates and/or Land Based Research and Development Corporation on February 27, 1996. The undersigned believe that the issuance of a grading permit, which permits the grading of a 45 acre parcel in preparation of a 36-unit development is premature in that the applicant has not established that it has legal access to the parcel as required by Condition 36.L. The undersigned further believe that other conditions of approval of the subdivision have not been satisfied and remain at issue. The undersigned and the public would be irreparably injured if the applicant is allowed to grade its property without having satisfied a critical condition of approval related to access,a condition that it will never be able to satisfy. Clerk of the Board of Supervisors Appeal of Grading Permit Subdivision Application No. 7462 Page Two Please notify us as soon as a hearing date is scheduled regarding this matter. Enclosed herewith please find a check in the amount of$125.00 to cover the costs of this appeal. Thank you very much for your consideration of this matter. V truly yours, Charles A. Koss for Robert D. Weinger Leah R. Weinger Amara L. Koss Charles A. Koss VERIFICATION 1, Charles A. Koss, declare: I am filing the within Notice of Appeal. I have read the foregoing Notice of Appeal. I certify that the same is true of my own knowledge, except as to those matters which are therein stated upon information and belief, and as to those matters I believe them to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on March 5, 1996 in Diablo, California. Charles A. Koss cc: David F. Schmidt, Esq. Sanford M. Skaggs, Esq. A Contra Public Works Department J.Michael Watford Public Works Director Costa 255 Glacier Drive Milton F.Kubicek County Martinez, California 94553-4897 Deputy.Engineering FAX: (510) 313-2333 Telephone: (510) 313-2000 Patricia R.McNamee July 10, 1995 Deputy-Operations Maurice M.SNu Deputy-Transportation Michael Bedker S. Clifford Hansen Land Based Research and Development Corporation Deputy•Administration 111 Deerwood PI., Suite 200 San Ramon, CA 94583 JUL 14 1995 Dear Mr. Bedker: ;Z CAIF,� RE:SUB 7462, COA 361 After reviewing the enclosed memorandum dated June 27, 1995, from Victor Westman of the County Council's office, the Public Works Department is of the opinion that the property being subdivided, Subdivision 7462, has physical and,legal access to Mt. Diablo Scenic Road. Moreover, we feel that the developer has successfully complied with condition of approval 361. This conclusion is based on our observation that Mt. Diablo Scenic Boulevard, for all practical purposes, acts as a public roadway and Mt Diablo Scenic Boulevard is the only access to and from the subject property. - If you have any questions or need clarification, please call me,,at 313-2348:- Very t , chier Asso ate C;il ngineer Engineeri g Services Division RL:a GJen9svGr11Bedker.t7 oc:cc: B.Faraone,Engineering Services $$ o Engineering Services rticR,'County Counsel S.Skaggs McCutchen,Doyle,Brown and Enersen 1331 No.California Blvd. P.O.Box V Walnut Creek,CA 94596 S.Magata Bryan,Murphy and Associates 5000 Executive Parkway,Ste.125 San Ramon,CA Leah H.R.Weinger 2033 No.Main Street,Ste.370 Walnut Creek,CA 94596 Hal F.Seibert P.O.Box 310 Diablo,CA 94528 Amera Koss P.O.Box 371 Diablo,CA 94528 COUNTY COUNSELS OFFICE CONTRA COSTA COUNTY MARTINE7,CALUZORNIA owe: June 27, 1995 To: J. Michael Walford, Director of Public Works T Attn: R; 11it. ez.3Malpp, Engineering services Division From: victor J. W tman,,-,County counsel By: David?' "Schmidt, Deputy County Counsel �-h��A`c* Oak Estates Re: Condition 36L', Having reviewed all materials submitted by the subdivider and other interested parties, we are satisfied, as provided in Condition 36L, that sufficient legal proof has been furnished that legal access to the property is available from Diablo Road. As also provided in Condition 36L, assuming that your department is similarly satisfied, you should inform the subdivider and other interested parties that Condition 36L has now been satisfied. DFS/ cc: Franklin Lew, Director of Building Inspection Harvey E. Bragdon, Director of Community Development D. Ir 1 CHARLES A. KOSS, SBN # P .O. Box 218 FILED 2 Danville, CA 94526 (510) 837-0585 3 :SSP 2 6 1995 Attorneys for Petitioners 4 STEPHEN L.WEIR,COUNTY CLERK CONTRA COSTA COUNTY 5 BY VV RAA DEPUTY 6 SUPERIOR COURT OF THE STATE OF CALIFORNIA V 7 FOR THE COUNTY OF CONTRA COSTA 8 9 LEAH R. WEINGER, ROBERT D. ) Case No. : WEINGER, CHARLES A. KOSS and 10 AMARA L. KOSS, ) DECLARATION OF ROBERT W. FEAD 11 Petitioners, ) 12 V. ) 13 COUNTY OF CONTRA COSTA, ) 14 Respondant . ) 15 I , Robert W. Fead, declare as follows : 16 17 1 . I am a private consultant for attorneys and title 18 insurance companies in the area of title insurance claims and 19 practices and in searching title to real property. I have 20 practiced as a private consultant for one year. Prior to that 21 time, I was employed by Commonwealth Land Title Insurance Company 22 for a period of four years during which time I worked as a title 23 insurance claims administrator and Regional Underwriter for 24 Northern California . Between the years of 1968 through 1990 , I was employed by Transamerica Title Insurance Company in the 25 positions of title searcher, examiner, Assistant Plant Manager, 26 27 Title Officer, Advisory Title Officer, Manager of Central 28 Services, Northern California . My last position was Title I Insurance Claims Administrator and Regional Underwriter for 2 Northern California. 3 2 . Over the course of the last 29 years, as a result of my 4 duties in the above positions, I have become experienced and 5 expert at searching title to real property including examination 6 of all recorded documents, knowledge of County Recorder' s Office 7 procedures, and maintenance of County real property records . 8 3 . I was retained by Petitioners to render an opinion as to 9 the rights, if any, of Black Oak Estates ( "BOE" ) in and to Mount 10 Diablo Scenic Boulevard ( "MDSB" ) in the unincorporated area of 11 Diablo in Contra Costa County. MDSB was previously entitled 12 Calle Crespi and Calle Los Callados on the Map of the Mount 13 Diablo Estate Park Subdivision, First Unit, recorded on May 16, 14 1916 in Book 15 of Maps at Page 301 . 15 4 . I searched for, reviewed and examined all of the deeds 16 purporting to transfer title to the road and adjoining property 17 on both sides of MDSB between the dates of 1912 and present . 18 Based upon my review of the public records, it is my considered 19 opinion that BOE holds no interest, fee nor easement, in MDSB . 20 S . In 1912 , title to both the BOE property (on the east 21 side of MDSB) and the property ultimately subdivided as Mount 22 Diablo Estate Park Subdivisions (on the west side of MDSB) were 23 vested in R.N. Burgess and Anne Fish Burgess, his wife . They 24 conveyed the property to Mount Diablo Park Company by deed 25 recorded July 17, 1912 in Book 182 of Deeds, Page 224 , Contra 26 Costa County Official Records . Subsequently, in 1916 , a portion 27 of that property was subdivided into Mount Diablo Estate Park 28 Subdivision, Unit Nos . 1 and 2 . The property on the easterly 2 D. I�- 1 side of MDSB was ultimately conveyed to W. P . Frick by Hibernia 2 Savings & Loan by deed recorded on November 3 , 1922 in Book 434 3 of Deeds, Page 5, Contra Costa County Official Records . 4 6 . By deed recorded on December 14 , 1928 in Book 160, Page 5 127, Contra Costa County Official Records, Frick, the owner of 6 the easterly parcel, and owners on the westerly side of MDSB 7 granted to Claire Simmons a "perpetual right of way" over a strip 8 of land 60 feet in width which meanders through portions of 9 Sections 14 , 22 , and 23 , Township 1 South, Range 1 West, M.D.B.M. 10 for the purpose of construction of a toll road over MDSB . 11 7 . By deed dated December 31, 1928 , and recorded on January 12 17, 1939 in Contra Costa County, Claire Simmons deeded her 13 interest in the 60 foot "perpetual right of way" to W. P. Frick. 14 Frick subsequently deeded any and all interest in and to the 60 15 foot area to Mount Diablo Co. , Ltd. by deed recorded on July 21, 16 1930 in Book 249 Official Records, Page 47, Contra Costa County 17 Official Records . As of 1930, Mt . Diablo Company, Ltd. owned all 18 interests, both fee and easement, in the 60 foot area which 19 encompassed MDSB . 20 8 . By deed recorded on April 3 , 1931 as Series No . 3866, 21 Official Records of Contra Costa County, Mount Diablo Company, 22 Ltd. deeded a 60 foot easement, which encompassed MDSB, to the 23 State of California for the sole purpose of access to Mount 24 Diablo State Park. 25 9 . By a series of deeds and decrees of distribution, 26 recorded in Contra Costa County between the dates of 1930 and 27 1955, title to the property on the easterly side of MDSB became 2$ vested in Mrs . Florence R. Force by reason of an Order for 3 D. lox_ 1 Distribution under Will of Raymond C. Force, Probate No. 17823 , 2 Contra Costa County Records . All deed and decrees in the record 3 up through this recorded Order described the BOE property as a 4 fee parcel, and excepted therefrom the 60 foot area which had 5 previously been granted to Claire Simmons, and subsequently to 6 Mount Diablo Company, Ltd. 7 10 . By deed recorded on May 1, 1956 in Book 2758, Page 73 , 7 Official Records of Contra Costa County, Florence R. Force 9 conveyed the BOE parcel and other property to Castle & Cooke, 10 Ltd. , a Hawaiian corporation as to a 1/2 interest, and Helemano 11 Company, Ltd. , a Hawaiian corporation as to an undivided 1/2 12 interest . The BOE property was once again described as a fee 13 Parcel excepting from it the 60 foot strip of land. 14 11 . By deed recorded on August 6 , 1964 , Castle & Cook, 15 Ltd. , et al . deeded the BOE property to Peterson Tractor Co. , a 16 Nevada corporation. Again, the BOE property was described as a 17 fee parcel, which excluded the 60 foot strip of land which 18 encompassed MDSB . 19 12 . On October 8 , 1964 , Peterson Tractor Co. quitclaimed to 20 Castle & Cook, Inc . all of the right, title and interest in the 21 BOE parcel . Said quitclaim deed, recorded on October 8 , 1964 in 22 Book 4719, Page 166, Contra Costa County Records, described the 23 BOE parcel using a new metes and bounds legal description which 24 did not except the 60 foot strip of land encompassing MDSB. 25 Based upon the record, the new legal description was erroneous, 26 as Peterson Tractor Co. had not been conveyed any portion of the 27 60 foot strip previously conveyed to Mount Diablo Company, Ltd. 23 4 1 13 . By deed recorded on November 22 , 1968 in Book 5756, 2 Page 433 , Contra Costa County Records, Castle & Cook, Inc . deeded 3 the BOE property to the Athenian School, a California 4 corporation. The legal description in said deed mimicked that 5 used in the prior quitclaim deed, and did not except the 60 foot 6 strip of land. or 7 14 . The Athenian School conveyed the BOE parcel to BOE by 8 deed recorded on August 16, 1989 in Book 15270, Page 314 , Contra 9 Costa County Records . In that deed, a completely different legal 10 description was employed. Said description purports to convey to 11 BOE the easterly portion of MDSB (formerly Calle Los Callados) . 12 Said description does not contain the exception of the 60 foot 13 strip previously referenced in the prior deeds . 14 15 . Based upon the foregoing brief synopsis of the chain of 15 title to the BOE parcel, it is apparent that BOE' s predecessors 16 owned no portion of the 60 foot strip containing MDSB . 17 Therefore, BOE has no fee title interest in the 60 foot strip. 18 Moreover, there are no recorded deeds of easement benefitting BOE 19 as to said 60 foot strip; thus BOE has no granted easement over 20 MDSB . 21 16 . In addition to reviewing the recorded documents which 22 affect title to the BOE parcel , I inspected MDSB and what 23 purports to be the westerly boundary of BOE' s parcel . 24 17 . MDSB, as it meanders by the BOE property, is an 25 improved roadway which appears to range in width from 26 approximately 16 feet to 21 feet . At the southwest corner of the 27 BOE parcel , approximately 20 feet easterly of the easterly edge 28 of the improved road, there exists an old barbed wire fence 5 1 running in a northerly direction parallel with the road and 2 approximately 20 feet easterly ofthe improved road. The fence 3 runs along the western boundary of the BOE parcel . Between the 4 easterly edge of the improved road and the existing fence 5 described above, there is a substantial drainage "moat . " In its 6 current condition, access to the BOE parcel from MDSB is. 7 virtually impossible by a non-four wheel drive vehicle . Attached 8 . hereto as Exhibit "A" , and incorporated herein by this reference, 9 are true and correct photographs of the improved roadway and the 10 general western boundary of the BOE property. 11 18 . I have reviewed a copy of the ALTA Owner' s Policy of 12 Title Insurance, No. AZ 911781, issued to Black Oak Estates, a 13 California General Partnership, by Title Insurance Company of 14 Minnesota on August 16, 1989 . Schedule A of said originally 15 issued policy describes only the fee parcel owned by Black Oak 16 Estates, and did not insure that Black Oak Estates holds any 17 easements over any other parcels . 18 19 . I have additionally reviewed a copy of the CLTA Form 10 110 . 1 Endorsement attached to Policy No. AZ 911781 by Old 20 Republic National Title Insurance Company, which is undated. 21 Said endorsement purports to replace the legal description of the 22 property originally described in Schedule A of the ALTA policy 23 issued to Black Oak Estates, by adding the following language at 24 the very end of the legal description described in Schedule A of 25 said ALTA policy as follows : "together with the right of access 26 over Mt . Diablo Scenic Boulevard as the same existed August 16, 27 1989 . 28 6 1 20 . It is my considered opinion that the endorsement issued 2 by Old Republic Title Insurance Company referenced above does 3 nothing to enhance the scope of title insurance coverage provided 4 to Black Oak Estates under its original policy of title 5 insurance . This is so because, according to the language 6 inserted in the endorsement itself, the scope of coverage would 7 be increased only if Black Oak Estates held "any right of access 8 over Mt . Diablo Scenic Boulevard" as of the date of its 9 acquisition of the property on August 16, 1989 . As set forth in 10 Paragraph 15 above, subsequent to the execution and recordation 11 of the deed from Frick to Mt . Diablo Company, Ltd. of his 12 interests in MDSB, neither Black Oak Estates nor its predecessors 13 in interest to the property owned any record right, title, estate 14 or interest in, under or through the sixty foot strip of land 15 which encompasses the MDSB . Additionally, there are no easements 16 recorded in favor of Black Oak Estates over MDSB as of August 19, 17 1968 . Because Black Oak Estates did not own any "right of 18 access over Mt . Diablo Scenic Boulevard" as of August 16, 1989, 19 the date it acquired the fee title to the property, the 20 endorsement issued by Old Republic Title Insurance Company does 21 not insure any access rights in favor of Black Oak Estates . In 22 essence, the endorsement operates to insure nothing. 23 24 25 26 27 28 / / / 1 I declare under penalty of perjury under the laws of the 2 State of California that the foregoing is true and correct, and 3 that this declaration is executed on September 8, 1995 at Walnut Creek, California. 4 5 6 Robert W. 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W 3��i f�y�.�..,..A+A'.�`�'Is'- �� i tRs - � �. ��A , :,.-Y�4�__,.•�V�J.a��'�.\M1��t� 14 4410 44, mom • L �i _ . .. aha :•.., t. t � -w ...� $-'',As.. �..,�- .'rte 'r..., ;,,,-•,.,,7 . �,.� ,� �;K`.�'�P,e:•'�',e n�r: �.f• J J�. ,gyp�.,t rr ri_ , •y o.° �•tt .. J .. 1jt�aR 4 i �T.��0.9h:�. � `�Z • r; I fl �` .pct r"a �' �Ct"'+' d '�' r'a+ -'•� .-a. •/✓ ' C �r�i -''.•fpr �� �t4� t ' �... x, a y*," ,iri F r{+r g . ro"�•1%.•� �g wl4�: �. ,..rl.•..«-. "C.'7``�1 " �`w^+t '�Yfx.e .(f'•s+ '.���,r ts, • i _ �' � ,�.��•;,r_gam® •,,,�•2•; - st�.��g��'' l• ? as e.�Y-' _- N..�+t.•.��.R -y �' r 'tt - r -DA- RECEIVED MAR 1 91996 PUBLIC WORKS DEPARTMENT CONTRA COSTA COUNTY CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. DATE: March 14, 1996 TO: Frank�Lew irector of Building Inspection FROM: Avalon, Assistant Public Works Director, Engineering Services SUBJECT: Black Oak Estates; SUB 7462 FILE: SUB 7462 We have received the attached memo from the Clerk of the,Board regarding an appeal to the Board of Supervisors on the above project. The appeal concerns the issuance of a grading permit. It is my understanding that you will be preparing a response to this appeal. RMA:mw g:\engsvc\rnitch\Iew-7462.t3 cc: Clerk of the Board 0 CONTRA COSTA COUNTY Clerk of the Board Inter-Office Memo TO: Mike Walford, Director, Public Works Department DATE : March 5, 1996 FROM: Ann Cervelli, Deputy Clerk Clerk of the Board of Supervisors SUBJECT: Appeal of Charles A. Koss from the issuance of a .grading permit by the Public Works Department for Subdivision 7462, Black Oak Estates We are in receipt of the attached appeal of Charles A. Koss from an Administrative Decision of the Public Works Department' relative to issuance of a grading permit for Subdivision 7462, Black Oak Estates . This appeal has tentatively been set for April 2, 1996, at 2 P.M. in the Board' s chambers . Please advise this office in writing by March 13 , 1996, as to whether or not this appeal is timely or if there is any. other reason it should not be heard by the Board of Supervisors . If this appeal is timely, and should be heard, please have material for the Board' s consideration to this office by March 27, 1996 . Thank you. attachment CC : County Administrator County Counsel • D. RECEIVED NSR - 5 W6 CLARKM OF SIIPERNiSORS RA March 5, 1996 HAND DELIVERED Clerk of the Board of Supervisors Contra Costa County County Administration Building 651 Pine Street Martinez, CA 94553 Re: Appeal of Grading Permit Subdivision Application No. 7462 Black Oak Estates Dear Sir or Madam: Pursuant to County Ordinance Code Section 14-4.002, and any other applicable provisions, the undersigned hereby submit this notice of appeal of staff's determination regarding the issuance of a grading permit for Subdivision 7462, Black Oak Estates. Section 14-4.002 authorizes any person aggrieved by an administrative action to file an appeal of that action to the County Board of Supervisors. The County Public Works' Department issued a grading permit to Black Oak Estates and/or Land Based Research and Development Corporation on February 27, 1996. The undersigned believe that the issuance of a grading permit, which permits the grading of a 45 acre parcel in preparation of a 36-unit development is premature in that the applicant has not established that it has legal access to the parcel as required by Condition 36.L. The undersigned further believe that other conditions of approval of the subdivision have not been satisfied and remain at issue. The undersigned and the public would be irreparably injured if the applicant is allowed to grade its property without having satisfied a critical condition of approval related to access, a condition that it will never be able to satisfy. Clerk of the Board of Supervisors Appeal of Grading Permit Subdivision Application No. 7462 Page Two Please notify us as soon as a hearing date is scheduled regarding this matter. Enclosed herewith please find a check in the amount of$125.00 to cover the costs of this appeal. Thank you very much for your consideration of this matter. V truly yours, Charles A. Koss for Robert D. Weinger Leah R. Weinger Amara L. Koss Charles A. Koss VERIFICATION I, Charles A. Koss, declare: I am filing the within Notice of Appeal. I have read the foregoing Notice of Appeal. I certify that the same is true of my own knowledge, except as to those matters which are therein stated upon information and belief, and as to those matters I believe them to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on March 5, 1996 in Diablo, California. Charles A. Koss cc: David F. Schmidt, Esq. Sanford M. Skaggs, Esq. The Board of Supervi�3rs r Phil Batchelor Contra Clerk of we Board Costa and CounryAdministration Building CountyAdministraror 651 Pine Street, Room 1.06 (510)646-2371 Martinez,California 94553-1293 County Jim Rogers,1st District �. Jeff Smith,2nd District Gayle Bishop,3rd District E: Mark DeSaulnier,4th District '•' i Tom Torlakson,5th District yaia 4T'4 COU:�� March 28, 1996 Mr. Charles A. Koss for Robert D. Weinger Leah R. Weinger Amara L. Koss Charles A. Koss 2480 Mt . Diablo Scenic Boulevard P.O. Box 371 Diablo, CA 94528-0371 Dear Mr. Koss: Pursuant to Section 14-4 . 006 of the County Ordinance Code, notice is given that April 16, 1996, at 2 : 00 p.m. at 651 Pine Street, Room 107, Martinez, California has been set as the time and place for hearing by the Board of Supervisors of your appeal regarding the issuance of a grading permit for Subdivision 7462, Black Oak Estates, Diablo area. If you challenge this matter in Court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered to the County, at or prior to, the public hearing. Very truly yours, PHIL BATCHELOR, Clerk of the Board of Supervisors and County Administrator By Ann ervel-li, Deputy Clerk CC: County Counsel County Administrator Community Development Department Public Works . J. Michael Watford Cant\'ra t J Public Warks Department Public Works Director Costa'-'( 255 Glacier Drive - /'� Martinez, Cal fornia 94553-4897 Milan, P. Kubicek-- � County i'1 Deputy • Engineering 3' FAX: (5101313-2333 Telephone: (510) 313-2000 Frtriria R. McNarnee Deputy C:)pr:r�,tign=, FAX TRANSNER TAL MEurice M.Sniu Deputy-Trans port atior. (510) 313-2333 S, Clifford Hansen l)erulY Adminis;r,+tion DATE: TIME: BY: TO: FIRM: ^ FAX NUMBER: FROM: TOTAL NUMBER OF PAGES INCLUDING COVER SHEET: _ MESSAGE: . ♦t�e����s��s��a;��aa����i��oos��+♦s�ss�♦#���������t�����������a�♦ If you have any problems with this transmittal, please contact: at (510) 313-_ — — c-faxtrans 5002 SHTIA 'Jil lid 31)") CCU tiTC 01S XYJ C�:` IF1 ' 96ItT-L0 PUBLIC WORKS DEPARTMENT CONTRA COSTA COUNTY DATE: March 14, 1996 TO: Frank Lew ator of.Building Inspection FROM: Avalon, Assistant Public Works Director, Engineering Services SUBJECT: Black Oak Estates; SUB 7462 FILE: SUB 7462 We have received the attached memo from the Clerk of the Board regarding an appeal to the Board of Supervisors on the above project. The appeal concerns the issuance of a grading permit. It is my understanding that you will be preparing a response to this appeal. RMA-mw g:�engsvelmitchllew-7462.0' ec: Clerk of the Board #x�d �xe� !F eU014 #9uoyd y !'T/��a� � 'idoo('o� +O if' wad �W � al�Q �L9L aloN 6 x3�>41-Isod TOUR SHHOSI :)Ilalld DD-1> CCCZ CIC OTS' XVd 02:9T 11HZ 96/TT/C4 -- CONTRA COSTA COUNTY Clerk of the Board Inter-Office Memo TO: Mike Walfard, Director, Public Works Department DATE : March 5 , 1996 FROM: Ann Cervelli, Deputy Clerk Q Clerk of the Board of Supervisors SUBJECT: Appeal of Charles A. Koss from the issuance of a grading permit by the Public works Department for Subdivision 7462 , Slack Oak Estates We are in receipt of the attached appeal of Charles A. Koss from an. Administrative Decision of the Public Works Department relative to issuance of a grading permit for Subdivision 7462, Black Oak Estates . This appeal has tentatively been set for April 2 , 1996, at 2 Q.M. in the Board' s chambers . Please advise this office in writing by March 13 , 1996 , as to whether or not this appeal is timely or if there is any other reason it should not be heard by the Board of Supervisors . If this appeal is timely, and should be heard, please have material for the Board' s consideration to this office by March 27 , 1996 . Thank you . attachment CC : County Administrator County Counsel Z00Q� SHHOht �CVZ CTC OTS 17 d T2:9T !IHI 96/fT/C0 -RECEivFD CLEM BOARD Of geNM COVA ae March 5, 1996 HAND,DELIVERED} Clerk of the Board of Supervisors Contra Costa County County Administration Building 651 Pine Street Martinez, CA 94553 Re- Appeal of Grading Permit Subdivision Application No, 7462 Black Oak, Estates Dear Sir or Madam: Pursuant to County Ordinance Code Section 14-4.002, and any other applicable provisions, the undersigned hereby submit this notice of appeal of staff's determination regarding the issuance of a grading permit for Subdivision 7462, Black Oak Estates, Section 14-4.0021 authorizes any person aggrieved by an administrative action to file an appeal of that action to the County Board of Supervisors, The County Public Works' Department issued a grading permit to Black Oak Estates and/or Land Based Research and Development Corporation on February 27, 1996, The undersigned believe that the issuance of a grading permit, which permits the grading of a 45 acre parcel in preparation of a 36-unit development is premature in that the applicant has not established that it has legal access to the parcel as required by Condition 361. The undersigned further believe that other conditions of approval of the subdivision have not been satisfied and remain at issue. The undersigned and the public would be irreparably injured if the applicant is allowed to grade its property without having satisfied a critical condition of approval related to access, a condition that it will never be able to satisfy. OTe IVI Zi*:9T !IHI 96,,tT/C0 Clerk of the Board of Supervisors Appeal of Grading Permit Subdivision Application No. 7462 Page Two Please notify us as soon as a hearing date is scheduled regarding this matter. Enclosed herewith please find a check in the amount of$I 25.00 to cover the costs of this appeal. Thank-you very much for your consideration of this matter. (v 'ytruly Yours, t 14�� Charles A. Koss for Robert D. Weinger Leah R. Weinger Amara L. Koss Charles A, Koss VERIFICATION 1, Charles A. Koss, declare: I axn filing the within Notice of Appeal. I have read the foregoing Notice of Appeal. I certify that the same is true of my own knowledge, except as to those matters which are therein stated upon information and belief, and as to those matters I believe them to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on March 5, 1996 in Diablo, California. Charles A. Koss cc: David F. Schmidt, Esq. Sanford M. Skaggs, Esq. SHHOA A10111d DY) CCU M OTS XV3 ZS:U M1 99-tT .r = D h CONTRA COSTA COUNTY Clerk of the Board Inter-Office Memo TO: Mike Walford, Director, Public Works Department DATE: March 5, 1996 FROM: Ann Cervelli, Deputy Clerk Clerk of the Board of Supervisors SUBJECT: Appeal of Charles A. Koss from the issuance of a grading permit .by the Public Works Department for Subdivision 7462, Black Oak Estates We are in receipt of the attached appeal of Charles A. Koss from an Administrative Decision of the Public Works Department relative to issuance of a grading permit for Subdivision 7462 , Black Oak Estates . This appeal has tentatively been set for April 2, 1996, at 2 P.M. in the Board' s chambers . Please advise this office in writing by March 13, 1996, as to whether or not this appeal is timely or if there is any other reason it should not be heard by the Board of Supervisors . If this appeal is timely, and should be heard, please have material for the Board' s consideration to this office by March 27, 1996 . Thank you. attachment cc: County Administrator county Counsel L41 J J,41 i RECEIVED MSR - 51N CLMM of SU SMS rte► March 5, 1996 HAND DELIVERED Clerk of the Board of Supervisors Contra Costa County County Administration Building 651 Pine Street Martinez, CA 94553 Re: Appeal of Grading Permit Subdivision Application No. 7462 Black Oak Estates Dear Sir or Madam: Pursuant to County Ordinance Code Section 14-4.002, and any other applicable provisions, the undersigned hereby submit this notice of appeal of staff's determination regarding the issuance of a grading permit for Subdivision 7462, Black Oak Estates. Section 14-4.002 authorizes any person aggrieved by an administrative action to file an appeal of that action to the County Board of Supervisors. The County Public Works' Department issued a grading permit to Black Oak Estates and/or Land Based Research and Development Corporation on February 27, 1996. The undersigned believe that the issuance of a grading permit, which permits the grading of a 45 acre parcel in preparation of a 36-unit development is premature in that the applicant has not established that it has legal access to the parcel as required by Condition 36.L. The undersigned further believe that other conditions of approval of the subdivision have not been satisfied and remain at issue. The undersigned and the public would be irreparably injured if the applicant is allowed to grade its property without having satisfied a critical condition of approval related to access, a condition that it will never be able to satisfy. D. Clerk of the Board of Supervisors Appeal of Grading Permit Subdivision Application No. 7462 Page Two Please notify us as soon as a hearing date is scheduled regarding this matter. Enclosed herewith please find a check in the amount of$125.00 to cover the costs of this appeal. Thank you very much for your consideration of this matter. V truly yours, Charles A. Koss for Robert D. Weinger Leah R. Weinger Amara L. Koss Charles A. Koss VERIFICATION I, Charles A. Koss, declare: I am filing the within Notice of Appeal. I have read the foregoing Notice of Appeal. I certify that the same is true of my own knowledge, except as to those matters which are therein stated upon information and belief, and as to those matters I believe them to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on March 5, 1996 in Diablo, California. Y Charles A. Koss cc: David F. Schmidt, Esq. Sanford M. Skaggs, Esq. 1 � titl bggbtir"qy 1 i r .r^ M r l 3 m .i s�� a• .B�` �� � r co l a i c s w U s& / to O ay V- N E p C0 � tl� 7 0 m AS m Q 6 u> NV o o V 2 m