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HomeMy WebLinkAboutMINUTES - 07172001 - D.5 TO: BOARD OF SUPERVISORS Contra FROM: DENNIS M. BARRY, AICP Costa COMMUNITY DEVELOPMENT DIRECTOR �;_ ---.`Te County DXU: July 17, 2001 SUBJECT: THIS IS AN APPEAL OF THE RECOMMENDATION OF THE COUNTY PLANNING COMMISSION'S DECISION TO APPROVE A LAND USE PERMIT FOR A TEMPORARY MOBILEHOME FOR INTERIM AGRICULTURAL USE LOCATED AT 4900 MORGAN TERRITORY IN THE CLAYTON AREA. COUNTY FILE#LP00-2111, E&B FARMS (APPLICANT AND OWNER). SAVE MOUNT DIABLO (APPELLANT) SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION RECOMMENDATIONS 1. UPHOLD the County Planning Commission decision to approve the land use permit, as contained in their Resolution No. 9-2001, with modifications to one condition as shown on Page 3, to address the issues raised in the appeal. 2. ADOPT the findings contained in the County Planning Commission Resolution No. 9-2001 as the basis for the Board's action. CONTINUED ON ATTACHMENT: X YES SIGNATURE RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER SIGNATURE(S): ACTION OF BOARD ON T f1 yam, 2001 APPROVED AS RECOMMENDED OTHER_,XX The Board continued this matter to August 14, 2001 at 1:00 p.m. VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE AND XX UNANIMOUS(ABSENT III ) CORRECT COPY OF AN ACTION TAKEN AND AYES: NOES: ENTERED ON THE MINUTES OF TILE BOARD OF ABSENT: ABSTAIN: SUPERVISORS ON THE DATE SHOWN Contact: Telma Moreira(925)335-1217 ATTESTED July 17, 2001 To'n S�-7ee.teh- CLERK OF THE BOARD OF ,. cc: Public Works SUPERVISORS AND COUNTY ADMINISTRATOR Applicant Building Inspection c�C� l�. BY ,DEPUTY July 17, 2001 Board of Supervisors File#LP00-2111 Page 2 3. ADOPT the Categorical Exemption, Section 15303, Class 3 and direct the Community Development Department Director to file the notice of Exemption with the County Clerk. FISCAL IMPACT: The applicant is responsible for cost of processing the application. BACKGROUND/PROPOSED PROJECT The applicant applied for a Land Use Permit on December 14, 2000 with the Community Development Department to allow a temporary 1,440 sq. ft. mobilehome for interim agricultural use. The subject site is located at 4900 Morgan Territory Road. The property is vacant, relatively steep and is 28.7 acres in size. The subject property is not currently used for agriculture; however, the applicant has indicated that part of the property would soon be used for agricultural use. The applicant is proposing to use the mobilehome as a temporary residence until the main residence is built and to build a second residence and replace the proposed 1,440 sq. ft. mobilehome with a caretaker mobilehome. The applicant has not submitted the plans for the proposed future residences, and is aware that a second residence and a caretaker mobilehome require review and approval of a Land Use Permit. The applicant's request was heard by the County Planning Commission on March 13, 2001. Seth Adams of Save Mount Diablo testified before the Commission expressing concerns that the application lacked sufficient environmental review and disregard to existing County policies. The County Planning Commission, after taking testimony, and evaluating this proposal, unanimously approved this land use permit. Prior to granting approval of the requested mobilehome, the Commission clearly stated that approval of the mobilehome does not guarantee approval of any future structures. Following the Planning Commission's decision, staff is recommending that Condition No. 3 be deleted and the following additional conditions be included for clarification: 1.. The proposed mobilehome shall be removed at the end of five years or upon the construction of a main residence on the property, whichever occurs first. 2. The applicant may apply for a new land use permit for a caretaker mobilehome as long as the mobilehome complies with the caretaker mobilehome criteria as stated in Section 84-68.1804. 3. The applicant shall install fencing on the southern part of the property to keep domestic animals from entering neighboring properties. Prior to granting the occupancy for the mobilehome, the applicant shall provide evidence to the Zoning Administrator that the fencing has been installed. July 17, 2001 Board of Supervisors File#LP00-2111 Page 3 APPEAL ISSUES On March 23, 2001, the Community Development Department received an appeal from Seth Adams of Save Mount Diablo. His appeal letter describes the grounds for the appeal as follows: 1) The approval is based on a lack of environmental analysis. The project was judged categorically exempt from CEQA but the record does not include analysis and support for this judgment, nor does it meet the standard for exemption. 2) The mobilehome Land Use Permit application is based on interim agricultural use, but the discussion at the public hearing was clear in that the purpose of the mobilehome is to house the applicant while other residences are applied for and constructed. 3) The comment request letter, the application description, the applicant's statement of purpose, and the applicant's site map all refer to a larger phased project including both the Land Use Permit for a temporary mobilehome, and two additional residences which might cumulatively include a much greater level of significance in impacts from grading, conflicts with landslides, impermeable surfaces and runoff, leach fields, tree removal, visibility, etc. The staff analysis, however, treats only the mobilehome. CEQA requires that all foreseeable impacts be considered, even in phased projects. 4) The application also fails to comply with the County's subdivision, Ranchette, or Morgan Territory area policies. 5) The parcel is within areas designated by the U.S. Fish & Wildlife Service as critical habitat for the California Red-legged Frog and the Alameda Whipsnake, two federally listed threatened species, both of which have been confirmed on the Wright property, 1/4 mile way from the subject site. 6) This application will encourage continued fragmentation of agricultural parcels in the Morgan Territory area. 7) Development of residences on this property could be very visible. In nearby projects, the county has placed scenic easements on upper elevations to decrease visual impacts. The commission did not place conditions on this application to decrease visual impacts. DISCUSSION OF APPEAL POINTS 1) CEQA Analysis: The appellant is correct in saying that the applicant has stated on the application that he intends to build a main residence and eventually a second residence, and replace the temporary mobilehome for interim agricultural use for a caretaker mobilehome. However, the timing, location, size, design and height of the future structures are uncertain at this time. July 17, 2001 Board of Supervisors File#LP00-2111 Page 4 The State CEQA Guidelines require that an agency must use its best effort to predict impacts but does not require the.agency to predict the unforeseeable. Section 15145 of the CEQA Guidelines states the following: If, after thorough investigation, a lead agency fends that a particular impact is too speculative for evaluation, the agency should note its conclusion and terminate discussion of the impact. The applicant has indicated on the site plan, the location of the subject mobilehome and 2 additional building sites on the property. It should be noted that the pads were placed on the site by the previous property owner. The applicant has not indicated what buildings are proposed for the padded areas (i.e., main residence, second residence, caretaker mobilehome). The applicant has not submitted as part of this application, floor plans, elevations, or exact location of any future structure besides the proposed temporary agricultural mobilehome. The applicant will be required to apply and obtain approval of a Land Use Permit before he decides to construct a second residence and a caretaker mobilehome. The impact of any future development on site is too speculative to evaluate at this time. Hence, staff recommends the Board adopt the CEQA Categorical Exemption, Section 15303, Class 3. In response to the appeal issue, staff recommends condition #3 to be deleted and the following conditions be added for clarification: • The proposed mobilehome shall be removed at the end of five years or upon the construction of a main residence on the property, whichever occurs first. • The applicant may apply for a new land use penn.it for a caretaker mobi.lehonae as long as the mobilehome complies with the caretaker mobilehome criteria as.stated in Section 84-68.1804. • The applicant shall in..stall fencing on the southern part of the property to keep domestic animals from entering neighboring properties. Prior to granting the occupancy for the mobilehome, the applicant shall provide evidence to the Zoning Administrator that the fencing has been installed. 2) Intent of the mobilehome: Section 84-68.2006 of the Zoning Code allows the establishment of a mobilehome as housing upon approval of a land use permit, on a parcel containing at least ten acres for a period not exceeding five years and where the Zoning Administrator has determined that the following criteria are satisfied. (1) No other adequate residential housing exists on the involved parcel. There is no available housing in the property. (2) There is a need for the on-site mobilehome to assist the agricultural use of the involved parcel during the interim (but not to exceed five-year)permit period. July 17, 2001 Board of Supervisors File#LP00-2111 Page 5 The subject property is not yet used for agricultural purpose but the applicant has stated that he intends soon to (1) plant olive trees which require 3 to 5. years before being productive (2) keep horses on the property and (3) other grazing animals to control grass and weeds to avoid fire hazard to the site and to Mount Diablo. The use of the mobilehome will not exceed five years. (3) The term of any approved permit shall not exceed five years and shall be set at the discretion of the zoning administrator. No permit extensions are allowed. Even though staff has mentioned that the mobilehome will not be used for a period exceeding five years, staff is adding a condition of approval that specifies that the mobilehome be removed at the end of five years or upon the construction of the main residence, whichever occurs first. (4) The square feet of the mobilehome's floor area shall not exceed two thousand square feet and shall be as set at the discretion of the zoning Administrator. The proposed mobilehome will not exceed 1,440 square feet. (5) The.mobilehome shall not be installed on a permanent foundation system. The mobilehome will not be installed on a permanent foundation. (6) Conditions of the health office are satisfied regarding water supply, sewage and refuse collection. The subject property is served by the Contra Costa County Water District and the applicant will be required to provide evidence that the above conditions have been met prior to the issuance of a building permit. (7) That upon expiration of the permit's term, the use of the mobilehome for human habitation, living or sleeping purposes shall immediately cease and it shall be removed from the parcel except for any storage allowed in Section 84-68.1404. The mobilehome must be removed at the end of five years or at the time the main house is established. (8) Other land use permit conditions determined appropriate by the Zoning Administrator will be complied with. The mobilehome will not be established prior to the approval of this land use and the applicant is aware of the required criteria and recommended conditions. July 17, 2001 Board of Supervisors File#LP00-2111 Page 6 3) Cumulative Impacts: The Rural Residential Policy of the Conservation Element of the County General Plan requires site plans to show the location of a proposed dwelling site, leach field site, anticipated well site, and driveway access. The Tree Protection and Preservation Ordinance, requires the location of trees within 40 feet from where the ground is proposed to be disturbed to be shown on the site plan. The submitted site plans shows additional buildings pads, which have already been graded. Those pads were graded by the previous property owner. There are no trees within 40 feet of the proposed temporary interim agricultural mobilehome nor within the additional building pads; however, it is speculative to analyze any of the impacts of these residences at this time since the design, size, and location of the houses are not available. 4) Compliance with County Policies: The County General Plan Conservation Element, Morgan Territory and Ranchettte Policy, which were designed especially for subdivision of land, have been applied to this land use proposal in the following manner: Drinking: The Rural Residential Development, policy 8-w (4), (page 8-42) of the County Conservation Element states that each parcel must have an "on site"producing water well. A memorandum dated January 18, 2001 was received from the Contra Costa Water District, which indicated that the project is within the existing Contra Costa Water District. Provision of septic system: Policy 8-w (7, page 8-34) of the County General Plan Conservation Element, states that a property must be suitable for septic tank use according to the County Ordinance Code criteria and Health Services Department Regulations. The applicant is proposing two optional sites for the future septic system. Contra Costa County Health Services Department- Environmental Health Division provided no comments on this application. Provision of fencing: Policy 8-al (page 8-45) of the County General Plan Conservation Element, requests that fencing be provided on properties in order to contain grazing animals and to keep domestic dogs out of grazing areas. The subject site is not used for grazing; however, according to the applicant, grazing activity is found along the west side of their property. Additionally, the subject property is already fenced with the exception of its southern side. The applicant is aware of the fencing requirement and is willing to work with the adjacent neighbor to provide fencing along the southern side of the property. Provision of access: Policy 8-w (6) (page 8-43) of the General Plan Conservation Element states that road, street and access requirements, including right-of-way acquision and/or dedications, will be subject to the Department of Public Works recommendations. This proposal was submitted to both Fire Protection District and to Public Works Department. The subject site already has three existing roads and no right-of-way acquisition was imposed by Public Works Department. The applicant has previously contacted both Departments to discuss this project and has submitted a written statement indicating that he feels confident he will be able to meet all the July 17, 2001 Board of Supervisors File #LP00-2111 Page 7 requirement of the Consolidated Fire District (see attached Public Works Department conditions of 2 and Fire Protection District conditions on page 4). Before scheduling this project for the public hearing, staff consulted all the interested agencies on this project and ensured that the applicant would be able to comply with the agency requirements and recommendations. Staff has included on "advisory notes" on page No. 4 (under the Findings and Conditions of Approval section) that the applicant should comply with the requirements of all of the agencies. The applicant will have to provide evidence before obtaining a building permit, that all of the above mentioned agencies recommendations are satisfied. 5) Federally listed Threatened Species: Staff has contacted LSA Associates to confirm the specific report on the Alameda Whipsnake on the Wright property '/a mile away from the subject property. Staff was informed by Malcolm Sproul of LSA Associates that the presence of the Alameda Whipsnake was not confirmed through an official report but rather through on site observation. A letter dated January 18, 2001 was received from the. Contra Costa Water District, which indicates that there are no occurrences recorded for listed species at the project site, or within its immediate vicinity. Based on review of the Contra Costa County Interim Service Area map for listing of federally endangered species, staff has concluded that both the Alameda whipsnake and the California red-legged occurrence are about 4 miles away from the subject site. 6) Fragmentation of Land: Policy for the Morgan Territory Area 3-108, page 3-57 of the County General Plan Land Use Element, states the following: The restriction on further fragrnentation of parcels is crucial to this plan.. A rezoning studv should be initiated on this planning area to apply new, more stringent zoning categories. The existing zoning is A-2, General Agricultural, which allows a minimum of 5 acres per property. The existing site is 28.7 acres. The issue of defragmentation is irrelevant to this application since the applicant is not proposing any subdivision of land. 7) Visual Impacts: Staff has determined that this issue is not relevant to the proposed temporary mobilehome. The site already has a horse-riding trail, which provides access to Mount Diablo State Park. When the applicant submits future plans for new construction on the site, staff will evaluate its impact on the surrounding neighborhood. It is speculative to evaluate the environmental impact on a large parcel such as the subject property without the exact size, height, and location of proposed structures. RESOLUTION NO. 9-2001 RESOLUTION OF THE COUNTY PLANNING COMMISSION OF THE COUNTY OF CONTRA COSTA, STATE OF CALIFORNIA, INCORPORATING FINDINGS AND RECOMMENDATIONS OF THE REQUESTED LAND USE PERMIT FOR A TEMPORARY MOBILEHOME FOR INTERIM AGRICULTURAL USE BY E & B FARMS (APPLICANT/OWNER) (LP00-2111) IN THE ORDINANCE CODE SECTION PERTAINING TO THE PRECISE ZONING FOR THE CLAYTON AREA OF SAID COUNTY. WHEREAS, a request by E&B Farms (Applicant/Owner) for a land use permit approval to allow a 1,440 sq. ft. temporary mobilehome for interim agricultural use in the Clayton area was received by the Community Development Department on December 14, 2000; and WHEREAS, for purposes of compliance with the provisions of the California Environmental Quality Act and the State and County CEQA Guidelines, the project was determined to be Categorically Exempt from the requirements of the California Environmental Quality Act (Class 3); and WHEREAS, after notice having been lawfully given, a public hearing was scheduled before the County Planning Commission on Tuesday March 13, 2001, whereat all persons interested therein might appear and be heard; and WHEREAS, on Tuesday, March 13, 2001, the County Planning Commission having fully reviewed, considered and evaluated all the testimony and evidence submitted in this matter; NOW, THEREFORE, BE IT RESOLVED, that the County Planning Commission: 1. FINDS that the proposed Categorical Exemption is adequate for the purposes of compliance with the California Environmental Quality Act and adopts the same; 2. RECOMMENDS to the Board of Supervisors the APPROVAL of the land use permit request of E&B Farms (Applicant/Owner), to allow a temporary mobilehome for interim agricultural use; BE IT FURTHER RESOLVED that the reasons for this recommendation are as follows: Land Use Findings: The use is in compliance with Section 84-68.2006 (Interim Agricultural Use). The following required findings have also been satisfied as provided by County Code Section 82-24.1002 (Land Use Permit). A. The proposed conditional land use shall not be detrimental to the health, safety and general welfare of the County. This is a land use permit approval to allow a temporarily mobilehome for interim agricultural use to be used as a residence while the owner provides agricultural care of the property. Additionally, the applicant will be required to provide evidence that requirements of the Consolidated Fire District, Contra Costa Water District, and Health Services Department are met prior to obtaining a building permit for the mobilehome. This land use shall not be in any way detrimental to the health, safety, and welfare of the County B. The proposed conditional land use shall not adversely affect the orderly development of the property within the County. The proposed mobilehome is conditionally allowed under the Zoning Code Section 84-68.2006 after the submittal and approval of a land use permit. The applicant will have to remove the mobilehome in the end of five years or when a main residence has been established, whichever occurs first. The project as conditioned should not adversely affect the orderly development of the property within the County. C. That it shall not adversely affect the preservation of the property values and protection of the tax base within the County. The proposed land use is a use conditionally allowed under A-2 General Agricultural. A land use for a mobilehome is a use enjoyed by other neighbors within the.vicinity. The proposed project is a temporary use and as conditioned will not adversely affect the preservation of the property values and protection of the tax base within the County. D. That it shall not adversely affect the policy and goals as set by the General Plan. 2 The subject site General Plan designation is Agricultural Lands (AL). The proposed project as conditioned will not affect any policy or goals as set by the General Plan. See Page No. 6 (Compliance with County Policies). E. That it shall not create a nuisance and/or enforcement problem within the neighborhood or community. This application was not originated through a code enforcement complaint. The applicant will be required to install fencing on the property prior to obtaining the final building inspection of the mobilehome (See Condition of Approval No. 5, on Page 2). Additionally, staff has added to the advisory notes that the applicant will have to comply with all of the requirements of the Contra Costa County Fire District, Contra Costa County Health Services Department, and Contra Costa County Water District prior to obtaining a final inspection for the proposed mobilehome. The proposed project as conditioned will not be a source of nuisance and/or enforcement problem within the community. F. That is shall not encourage marginal development within the neighborhood. This is a land use permit for a mobilehome. This is a conditionally allowed use within the A-2, General Agricultural Zoning District. The proposed mobilehome will be removed in the end of five years or when a main residence has been established. The proposed project as conditioned shall not encourage marginal development within the neighborhood. G. That special conditions or unique characteristics of the subject property and its location or surroundings are established. The subject property is a vacant site. The proposed land use for a temporary mobilehome for interim agricultural use has been proposed when no other residential unit is found in the property. 3 BE IT FURTHER RESOLVED that the Secretary of this Planning Commission will sign and attest the certified copy of this resolution and deliver the same to the Board of Supervisors, all in accordance with the Government Code of the State of California. The instructions to prepare this resolution was given by motion of the County Planning Commission on Tuesday, March 13, 2001, by the following vote: AYES: Clark, Wong, Battaglia, Hanecak, Kimber,Terrell NOES: None ABSENT: Gaddis ABSTAIN: None Richard Clark, Chair of the County Planning Commission County of Contra Costa, State of California ATTEST: Dennis M. Barry, Secretary County of Contra Costa State of California 4 FINDINGS AND CONDITIONS OF APPROVAL FOR COUNTY FILE#LP002111 AS APPROVED BY THE COUNTY PLANNING COMMISSION ON MARCH 13, 2001 WITH PROPOSED MODIFIED CONDITIONS (E & B Farms, Applicant & Owner) IN THE CLAYTON AREA. Land Use Findings: The use is in compliance with Section 84-68.2006 (Interim Agricultural Use). The following required findings have also been satisfied as provided by County Code Section 82-24.1002 (Land Use Permit). A. The proposed project will not be detrimental to the health, safety and general welfare of the County. B. The proposed project as conditioned will not adversely affect the orderly development of the property within the County. C. The proposed project as conditioned will not adversely affect the preservation of the property values and protection of the tax base within the County. D. The proposed project will not adversely affect the policy and goals as set by the General Plan. E. The proposed project will not create a nuisance and/or enforcement problem within the neighborhood or community. F. The proposed project as conditioned will not encourage marginal development within the neighborhood. G. That special conditions or unique characteristics of the subject property and its location or surroundings are established. Conditions of Approval: 1. Development is approved as shown on plans submitted with the application, received by the Community Development Department on December 14, 2000. 2. This permit is granted for an interim agricultural use mobilehome The mobilehome shall be located on a temporary foundation only. A concrete perimeter foundation or slab is not permitted. 3. This permit is granted-for five years owl, The applieant may apply for-a new land use pefmit wit Community Deyel .. Yent to allow the existing fnebilehofne to he eonyei4eil into ., retaker.neb-:leheffle, .,s long as the fnebilehofne liVl l Y�l LLil3 lllLV „lies with all the ear -fneh:lehofne e fife fi �ITIFII ILwJ W ILII , 3. The proposed mobilehome shall be removed in the end of five. years or when a main residence has been established in the property, whichever occurs first. 4. The applicant may apply for a new land use permit for a caretaker mobilehome as long as the mobilehome complies with the. caretaker mobilehome criteria as stated in Ordinance Code Section 84-68.1804. 5. Prior to obtaining the building final inspection for the mobilehome; the applicant shall install fencing on the southern part of the property to keep domestic animals from entering neighboring properties..; 6. The applicant shall apply for a building permit for the proposed mobilehome. 7. The existing trailer/cargo container located within the 60-foot road shall be removed from the property not later than 30 days after the granting of final building permit for the proposed mobilehome. The applicant shall submit evidence to the satisfaction of the County Zoning Administrator. 8. _ Prior to obtaining a building permit for the proposed mobilehome, the applicant shall provide evidence to the Zoning Adminsitror that the pile of used tires located on the site has been removed 9. Both the applicant and the property owner are fully responsible for County staff costs. Invoice(s) for additional costs beyond the initial application deposit of $2,033 will be mailed to the applicant and are due and payable 30-days following the date of the invoice. The unpaid balance shall be collected prior to issuance of a building permit or initiation of the use, whichever comes first. The applicant can obtain the current status of staff cost on this application from the project planner. 2 PUBLIC WORKS RECOMMENDED CONDITIONS OF APPROVAL FOR PERMIT LP 00-2111 Applicant shall comply with the requirements of Title 8, Title 9, and Title 10 of the County Ordinance Code. Any exceptions must be stipulated in these conditions of approval. Conditions of Approval are based on the plan submitted to Community Development on December 14, 2000. COMPLY WITH THE FOLLOWING CONDITIONS OF APPROVAL PRIOR TO ISSUANCE OF A BUILDING PERMIT AND PRIOR TO INITIATION OF THE USE PROPOSED UNDER THIS PERMIT. Area of Benefit Fee Ordinance: 10. Because caretaker mobile homes do not typically add to peak hour traffic, an exemption from the Bridge/Thoroughfare Fee Ordinance for the East County Area of Benefit, and Eastern Contra Costa Subregional Transportation Mitigation Fee Area of Benefit as adopted by the Board of Supervisors is allowed at this time. The Area of Benefit fees would become due in the future if the mobile home is placed on a permanent foundation, or if the use described under this permit extends beyond 5 years. ADVISORY NOTES THE FOLLOWING INFORMATION DOES NOT CONSTITUE CONDITIONS OF APPROVAL. IT IS PROVIDED TO ALERT THE APPLICANT TO LEGAL REQUIREMENTS OF THE COUNTY AND OTHER PUBLIC AGENCIES TO WHICH THIS PROJECT MAY BE SUBJECT. A. NOTIFY OF 90-DAY OPPORTUNITY TO PROTEST FEES, DEDICATIONS, RESERVATIONS, OR OTHER EXACTIONS PERTAINING TO THE APPROVAL OF THIS PERMIT. This notice is intended to advise the applicant that pursuant to Government Code Section 66000,et seq., the applicant has the opportunity to protest fees, dedications, reservations, and/or exactions required as part of this project approval. The opportunity to protest is limited to a 90-day period after the project is approved. The ninety (90) day period in which you may protest the amount of any fee or imposition of any dedication, reservation, or other exaction required by this approved permit, begins on the date this permit was approved. To be valid, a protest must be in writing pursuant to Government Code Section 66020 and delivered to the Community Development Department within the 90 days of the approval date of this permit. 3 B. Comply with the requirements of the County Building Inspection Department. C. Comply with the requirements of the Health Services Department-Environmental Health Division. D. Comply with the requirements of the CC Water District. E. Comply with the requirements of the Fish & Game, Region III. F. Comply with the requirements of the California Department of Forestry. G. Comply with the requirements of Save Mount Diablo. H. This project may be subject to the requirements of the Department of Fish and Game. It is the applicant's responsibility to notify the Department of Fish and Game, P.O. Box 47, Yountville, California 94599, of any proposed construction within this development that may affect any fish and wildlife resources, per the Fish and Game Code. I. This project may be subject to the requirements of the Army Corps of Engineers. It is the applicant's responsibility to notify the appropriate district of the Corps of Engineers to determine if a permit is required, and if it can be obtained. CONDITIONS OF APPROVAL ADMINISTRED BY CONTRA COSTA COUNTY FIRE PROTECTION DISTRICT J. Comply with the following requirements of the Contra Costa County Fire Protection District: 1. Provide access roadways with all-weather driving surfaces of not less than 16 feet unobstructed width, and not less than 13 feet six inches of vertical clearance, to within 150 feet of travel distance to all portions of the exterior walls of every building. Access roads shall not exceed 16% grade, shall have a minimum outside turning radius of 42 feet, and must be capable of supporting the imposed loads of fire apparatus i.e., 22 tons (902.2) UFC. The applicant shall submit two copies pf the roadway plans for review prior to obtaining a grading permit. 2. Dead end Fire District access roads in excess of 150 feet long shall be provided with approval provisions for the turning around Fire District apparatus. (902.2.2.4) UFC. 3. Access roads shall be installed and in-service prior to construction. (8704.1) UFC. 4 4. Approved premised identification shall be provided. Such numbers shall contrast with their background and be readily visible from the street. 5. The developer shall provide roof coverings with a minimum Class C rating. Untreated wood shake or shingles are not allowed. (1503)T-24, CCR. 6. The home as proposed shall be protected with an approved automatic fire sprinkler system. Submit two sets of plans to this office for review and approval prior to installation. (1003.1) UFC. 5 Walter& Margery Pease c/o Robert G. Olofson E.S. Bertagnolli Marilyn K. Kittrell 7979 Shay Drive P.O. Box 3 4940 Morgan Territory Rd Oakland, CA 94605 Clayton, CA 94517 Clayton, CA 94517 Robert G. &Linda J. Rodenburg Richard & Gayle Schwartz John & Jackie Ciapponi 488.5. Morgan Territory Road 4825 Morgan Territory Road P.O. Box 717 Clayton, CA 94517 Clayton, CA 94517 Clayton, CA 94517 Mary C. Smith Michael & Virginia M. Gotfried Seth Adams 4775 Morgan Territory Road 4895 Morgan Territory Road Save Mt. Diablo Clayton, CA 94517 Clayton, CA 94517 1196 Boulevard Way#10Walnut Creek, CA 94595 David Peterson McCutchen & Doyle ***INTEROFFICE*** ***INTEROFFICE*** 1333 North California Blvd Public Works Public Works Ste#210 Engineering Services Special Districts Walnut Creek, CA 94596 x;023/2001 14:19 9259473603 SAVE MT DIABLO PAGE 01 S 4a v M i i Post-it'Fax Note 7671 date 3, pa°ges► Attn.: Telma Moreira T° '"a (rOt From CoMept. Co. Community Development Dept. A-•-t pf=yS 1 Board of Dirrclors Contra Costa County Phone N Phone N �r�i 3s Malcoltn Sproul 651 Pirie Street Fax x - t Z Fsx tr t President Martinez, CA 94553 Arthur Bonweit J!•47 10 Vice President Amara Ko�c.J.D. re: Appeal of Plannin Commission Approval of LP002111 n� Secrera Karen Hunt,CFO E&B Farms c/o Ra ert Ennis T1easurer Mary L.Bowerman,Ph.D. March 23, 2001 Martin Breen Paul Choicer Dear Telma, Donald de Fminery.Ph.D, Stephen Joseph Save Mount Diablo Appeals the decision of the Contra Costa County Planning Robert Marx Steven Mthtnrart.J.D. Commission� Pprovapproving the E&B Farms Land Use Permit 1,1'002111, to the Board of Steg Robert Nunn, Supervisors. Allan Prager David 5argcm The grounds for the appeal are: Staff Brown • The approval is based on a lack of environmental analysis. The project was judged Ronald B (Jirerrr�r categorically-exempt from CEQA but the record does not include analysis and support Seth Adams for this judgment,nor does the project meet the standard for exemption. In addition, Director of Lurid some of the factors which invalidate categorical exemption are listed below. Progr arw Lucca Keller •The mobile home LP application is based on interim agricultural use,but the discussion ° ``'rifur,r7.(Nr at the public hearing was clear in that the purpose of the mobile home is to house the SMD Office applicant while other residences are applied for and constructed. 1196 13oulevard Way#10 Walnut Creek,GA 9459.5 `The comment request letter,the application description, the applicant's statement of purpose,and the applicant's site map all refer to a larger phased project including both SblO rtfrtiGn�Address this LP for a temporary mobile home,and two additional residences which might leo.Bux S:176 cumulatively include a much greater level of significance in impacts from grading, Wh Inut Creek,CA 94590 conflicts with landslides,impermeable surfaces and runoff,leach fields,tree removal, Telepheae: visibility,etc. The staff analysis,however,treats only the mobile home. CEQA requires (925)947.35.15 that all foreseeable impacts be considered,even in phased projects. Fax: (1425)947-3601 •The application also fails to comply with the County's subdivision,ranchette, or -matt: Morgan Territory area policies. scrvtmrdic4h @ctcrLerrrn iv°brie: *The parcel is within areas designated by the U.S. Fish& Wildlife Service as critical u tr w.,cnt r nr++trntrituhlrr.rrr�, habitat for the California red-legged frog and the Alameda whipsnake,two'federally listed threatened species,both of which have been confirmed nearby. In particular,the red-legged hog is confirmed in both Cunt creek and Marsh creek,and this parcel could serve as upland habitat for the frog. Marsh creek flows near the onr_� R1 2001 14:19 9259473603 SAVE MT DIABLO PAGE 02 2 _. bottom/road frontage of the parcel,and the frog has been professionally confirmed in the creek both upstream and downstream,as well as in neighboring watersheds. The Alameda whipsnalce has been professionally confirmed less than one half mile away,in addition to many sites at further distance,and it ranges widely. Although the whipsnake is generally thought to frequent chaparral areas on south facing slopes and in the vicinity of rock outcroppungs or streams,the snake ranges widely. The nearby confirmation was made by ISA Associates on 4-14-00 on the Wright property, APN 80-170-018 less than 1/4 mile from Morgan Territory Road,on north facing slopes, in oak-bay woodland,in the absence of both rock outcroppings and chaparral. With other applications being considered in the area(such as the Pacini subdivision approva),a ppropperty one half mile away and draining into Marsh creek,which also has confirmed red-legged frog but has not yet undergone wildlife regulatory review),impacts on endangered species could be cumulatively even greater. •This application will encourage continued fragmentation of agricultural parcels in the Morgan Territory area. • Development of residences on this property could be very visible. In nearby projects the county has placed scenic easements on upper elevations to decrease visual impacts. The Commission did not place conditions on this application to decrease visual impacts. The application description,staff analysis and the Conunission approval do not consider the full range ofpotential impacts based on the applicant's stated intent and does not comply with existing County policies for subdivision,ranehettes or within the Morgan Territory Area. The Commission's approval segments CEQA analysis and frustrates careful consideration of the full range of development impacts. Save Mount Diablo supported denial without prejudice of this permit until the pro)ect description was clarified and until further information was developed. The Commission also considered continuing the public hearing and offered that option to the applicant, who rejected the offer. The $125 Appeal fee is enclosed along with stamped envelopes addressed to property owners within a 300 ft. radius. Thank you for your consideration.. Seth Adams Director of Land Programs :j 'd eft-lo 1 co, re � 1r- save MOUNT DIAB L • Planning Commission Contra Costa County Board of Directors 651 Pike Street Malcolm Sproul Martinez, CA 94553 President Arthur Bonwell attn: Telma Moreira Vice President , Amara Koss,J.D. re: LP002111 r� Secvetu , Karen Hunt,CFO E&B Farms c/o Robert Ennis Treasurer Mary L. Bowerman, Ph.D. March 13, 2001 Martin Breen Paul Choisser Commissioners, Ikinald de Fremery, Ph.D. Stephen Joseph Sorry for the misunderstanding,but the staff report is inaccurate is suggesting that Save Rbedobcrt Marx i�ielilm:m,J.D. Mount Diablo doesn't have concerns related to this application; our discussion with staff h„hert Nunn. was that we needed to reserve comment until we had looked at the application in more Allah PraLer detail. We generally do not comment on single agricultural units, especially temporary D;tvid Sargent ones, and the notice for this item suggests that the application is for a land use permit for Staff temporary mobile home for interim agricultural use. Ronald Brovvn The comment request letter, however, includes the applicant's discussion of much more Elecutire Director Sett,Adams significant development, with the intent of a total of three units including this mobile Ifirector of Land home and two permanent residences to be applied for concurrently. The site map shows No."rr„,,., these other uses and includes a variety of references to them, representing significant I.ttiea Keller environmental impacts ofgradin5for building sites, drivewl�ays, leach fields, etc. Of.fie manager V.?(�,,.i� of �h l7 FAVI" AV•;"e. Y Sill/)office The application fails to include detailed information on these other applications, but they 1196 Boulevard way Irl(/ are clearly identified in the Proposal Statement and site map, and must be considered Walnut Creek,CA 94595 simultaneously. The application also fails to comply with CEQA or the County's subdivision,ranchette,or Morgan Territory area policies. .5;111)hlailingAddress P.O. Box 5376 This is a small parcel in a steep canyon with heavy oak woodland and part of a Walnut Creek,CA 94596 significant complex of landslides and slumps. The placement of a single house would be 72lephone: problematic in terms of slopes, landslides and tree cutting,let alone development of three (925)947.3535 units. There is also little justification for an agricultural dwelling on such a small parcel 1:,ff: and there are already significant numbers of rental units in the Curry Creek Trailer Park (925)947-3603 1/4 mile to the west. E-mail: cr,i „ttclirrl,c'uc lir„n, A previous subdivision attempt on this property was abandoned because of these very lii,b.`ite: difficult geologic conditions and landslides. rrwrr.s'ut'e'nuuu,Iclinhlo.or� In addition,under the federal Endangered Species Act this parcel is designated critical habitat for both the California red-legged frog and the Alameda whipsna.ke. In January Save Mount Diablo signed an acquisition deal for the Wright property less than 1/2 mile away, fronting Morgan Territory Road and has confirmed both.species on that property. Wright Canyon is similar to this parcel,but this parcel is even better whipsnake habitat and their presence is very likely. The county and this commission have repeatedly indicated an intention to discourage fragmentation of lands in Morgan Territory, and approval of this application will instead encourage continued fragmentation. In mid 1993 the Kittrells, owners of a property of similar size and adjacent to this one on the east, applied for a one unit subdivision. This Commission unanimously agreed to a condition for a scenic easement covering the upper two-thirds of that parcel and prohibiting grading within the easement area. In October 1993 the Board of Supervisors upheld that approval with the scenic easement condition. The two building sites at Kittrell are placed at the lowest point on the parcel, along Morgan Territory Road. Given the Scenic Easement and adopted mitigations,Save Mount Diablo did not oppose the unit. This parcel is more severely constrained than Kittrell and the resource values associated with its stream and steep canyon are even more important,especially given the high likelihood of significant protected species. The building sites shown on the application site map would be significantly higher than at Kittrell. In addition,Supervisor DeSaulnier has recently indicated an interest in tightening building permit standards around Mt. Diablo. Most importantly, the application description before you does not agree with the file and records of the landowner's intent and does not comply with existing County policies for subdivision,ranchettes or within the Morgan Territory Area. The applicant has clearly indicated an intent to build three units as a part of this application. Approval of this application would segment CEQA analysis and frustrate careful consideration of development impacts. Before proceeding with any approval, the applicant should clarify the project description and the County should require an initial study,biotic report and geologic studies. Save Mount Diablo supports denial.without prejudice of this permit until the project description is clarified and until further information is developed. Thank you for your consideration. Seth Adams Director of Land Programs Agenda Item # Community Development Department Contra Costa County CONTRA COSTA COUNTY PLANNING COMMISSION Tuesday, March 13, 2001 —7:00 P.M. I. INTRODUCTION E & B FARMS (Applicant & Owner), County File#LP0021.11: The applicant is requesting a land use permit approval to establish a temporary mobilehome for interim agricultural use. Subject property is a 28.7 acre parcel located 4900 Morgan Territory Road, in the Clayton area (A-2) (ZA:P20/Q20) (CT 3551.03) (Parcel #080-040-033). II. RECOMMENDATION Staff recommends that County Planning Commission approve the land use permit, subject to the attached conditions. III. GENERAL INFORMATION A. General Plan: General Plan designation is Agricultural Lands. B. Zoning: A-2, General Agricultural/ 5 acres per unit. C. CEQA Status: Categorical Exemption, Class 3, which allows the location and construction of small facilities or structures, including single family residences, where no more than three units are being established. D. Previous Applications: MS9-68: Minor Subdivision approved on February 7, 1968 to subdivide a 268.9 acre parcel into 4 parcels. The subject 28.7 acre parcel is known as parcel "C" of subdivision MS9-68. MS84-70: Minor Subdivision approved on September 29, 1970 to subdivide 28 acres into 4 lots. MS84-72: Minor Subdivision approved in 1972 to subdivide 28 acres into 4 lots. Subdivisions MS84-70 and MS84-72 were not recorded. MS6-92: Minor Subdivision to subdivide 28 acres into 4 parcels. This subdivision was withdrawn October 22, 1992. S-2 E. Regulatory Programs: 1. Active Fault Zone: Subject site is not within an active fault zone. 2. Redevelopment Area: The site is not in a redevelopment area. 3. Flood Hazard Area: Subject site is in Flood Zone C of minimum flooding, Panel # 0350B. 4. 60 dBA Noise Control: Subject site is not within a 60 dBA noise control area. IV. SITE/AREA DESCRIPTION The subject 28.7-acre parcel is a relatively steep site addressed 4900 Morgan Territory Road, in the Clayton area. The lot is currently vacant and there are three existing building pads. There are several trees throughout the property but no tree is within the existing building pads. The site is surrounded by several large properties of rural character, zoned A-2 and A-4. There are three unpaved roads in the site. A 60-foot wide road, which is an easement, shared with an adjacent property, is located along the.east side of the property. A 10-foot wide road located approximately in the middle of the site leads to the proposed mobilehome, and the third road, approximately 20-foot wide, curves towards the west side of the property. During the site visit, the applicant informed staff that the existing pile of used tires was left on the property by the previously owner, and he is intending to remove them from the site. Staff also noticed that a storage container exceeding 600 sq. ft. was located in the site. The applicant informed that the container was a temporary storage for their furniture and other domestic items,'.;Staff is recommending that the subject storage be removed from the site not later than 30 days after granting of the building final inspection for the proposed mobilehome. V. PROPOSED PROJECT The applicant is proposing to obtain a land use approval for the establishment of a temporary interim agricultural use mobilehome. Even though the subject property is not currently used as agricultural, the applicant mentioned that part of the property would eventually be used as agricultural. The applicant is proposing to use the mobilehome as temporary residence until the main residence is built. The applicant is also intending to build a second residence and convert the proposed interim agricultural mobilehome as a caretaker mobilehome. Section 84-68.2006 pertaining to interim agricultural use mobilehomes, states that a permit to allow an interim agricultural use mobilehome may be located for a period not to exceed five (5) years. The applicant is intending to build the main residence within the next two years. The applicant has not yet submitted the plans for the proposed future residences, and is aware that the second residence requires review and approval by the Community Development Department. S-3 VI. AGENCY A. Historical Resources Information System: An archeological report dated February 12,. 2001, prepared by Holman & Associates, was submitted to the Community Development and it states that no evidence of cultural resources was discovered either during the archival research or the field inspection. B. Save Mount Diablo: Staff was informed by Seth Adams of Save Mount Diablo, that he has no concerns regarding the subject project at this time. C. US Department of Interior, Fish and Wildlife Service: Memorandum dated January 29, 2001 does not indicate any list of endangered of threatened species within the subject site. D. Sheriff's Office, Administration & Community Services: Memorandum dated January 25, 2001 stated that they have no recommendations regarding this project. E. Contra Costa Water: Memorandum dated January 18, 20001 states that the project is within the existing Contra Costa Water District. Also, it indicates that according to the Interim Service Area Map (June 2000) there were no occurrences recorded for listed species at the project site or within its immediate vicinity. F. City of Cla on: Memorandum dated December 22, 2000 indicates that they have no comments on this application. G. Building Inspection, Property Conservation Division: Memorandum dated January 10, 2001, indicates that the applicant/owner should provide three copies of building plans, acquired permit form Community Development, electrical_permit in accordance with 1996 NEC, two copies of state approved engineering footing system, and sanitary approval from Health Department. H. Contra Costa County Fire Protection District: A revised memorandum dated February 23, 2001 was received which lists a number of conditions that are required prior to the installation of the proposed mobilehome. See attached conditions on page#4 of the advisory notes. The applicant has contacted the Fire Protection District and stated that he is confident that all required conditions can be acomplished. No comments were received from the following agencies: Health Services Department-Environmental Health Division Building Inspection California Department of Forestry Mount Diablo Unified School District S-4 VII. PUBLIC COMMENTS No public comments have been received to date regarding this project VIII. 'STAFF DISCUSSION/ANALYSES A. Appropriateness of Use: The approval of a temporary interim agricultural mobilehome is an appropriate land use for the A-2 zoning district. B. General Plan/Zoning Compliance: The proposed project is consistent with the Agricultural Lands (AL) and A-2, General Agricultural Zoning District. Staff has determined that this project meets the intent of Section 84-68.2006 of the County Zoning Ordinance (Interim Agricultural Use). The use of such mobilehomes are allowed use in the A-2 zoning provided that it is placed on a temporary foundation, and it does not exceed 2000 sq. ft., and no other residence exists in the property. C. Drainage/Road Improvements: Public Works Department submitted the following comments: "This permit request is to allow a temporary mobile home on this existing agricultural parcel. The applicant proposes to build two future homes on the parcel and use the temporary mobile home as a "caretaker mobile home". Because such residences do not typically create peak hour trips,this residence is not subject to AOB or ECC fees. This exemption from the fee will apply only as long as the use continues as approved. if the mobile home is ever placed on a permanent foundation or leased as a residence, full fees will be due at that time. One concern for a project of this nature is that the site drainage pattern be maintained. The location of the proposed mobile home appears to be located above a drainage course, and could altar the existing drainage pattern." The applicant has contacted Public Works and indicated that the he is intending to enhance the drainage pattern of the site. D. Environmental Issues: This project is exempt from California Environmental Quality Act- Class 3. IX. 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(v �: N - - __ yy — uH : : �Jy �•__=�:i :� ...�.��,..�.,:..::�:' 'i�,�••'� i i'ri'Y 1.r_ Si:i_ 7lD Id ei' 4 1 i I;w:'•fir'/.-r..II� ;i''�, -_ i Nov Am HIM Rig! � j S ebb n o w Wgc zba� p Bill a= �'^'-^ IN S im2 - . i 7 0 0 0 / b 0 0 j 0 , i'. r-- / 1 / Z LU X Z �e e flJ � Z r, H LU N FROM : M.Ennis PHONE NO. 9256865670 Feb. 27 2001 10:13AM E & B Farms • 4900 Morgan Territory Road • Clayton, CA 94517 February 26, 2001 Contra Costa County- Community Development Department Current Planning 651 Pine Street 2nd Floor North Wing Martinez, CA 94553-0095 Attention: Telma Moreira Subject: LP-002111 4900 Morgan Territory Road Clayton ; Telma: Please be advised that we have reviewed the codes and conditions of approval as required by the Contra Costa County Fire Protection District per the letter dated February 22, 2001 from Fire Inspector Richard S Ryan. I'm confident that we can fulfill these requirements. T o Rib s '� General Partner E&B Farms . Project Representation&Ivlonihn Boundary&Topographic Sun 0 0 a g � � Realtor Advisory Ser\ Aerial Control Sun n11 LAND SURVEYING Construction Sun Tentative M 411 Russell Avenue,Santa Rosa,California 95403 Parcel&Final N,: Tel(707)528-7649 Fax(707)571-5541 A.L.T.A.Sun Court Exhi CIS, C11 LAND USE PERMIT PROPOSAL STATEMENT FOR THE LANDS OF E& B FARMS 4900 Morgan Territory Road Clayton, California 94517 APN 080-040-033 Doc. # 2000-0183269 Official Records, Contra Costa County This application is being made to accommodate a phased agricultural/detached single-family dwellings improvement of the above referenced property as follows: The owners wish to place a mobile home on the site as a temporary residence while developing locations of two permanent residences in which case the mobile home will become a third unit for living accommodations for agricultural workers as temporary housing purposes. Several meetings with the Planning Department indicate a modification to the Land Use Permit will be required. The first phase of this project is to concurrently apply for the required building permits and Land Use Permit and place the mobile home after improvements have been made and begin development of the two permanent residences at the same time as one project. A modification to the Land Use Permit will be sought to make the first completed permanent residence the primary unit, the second permanent residence the second unit and the mobile home will become a third unit for living accommodations for agricultural workers as temporary housing purposes. 3 02/12/2001 14:44 4152826239 HOLMAN AND ASSOCIATE PA133E 01/02 �. '. r& JASSOCIATES AucbaeoLogicaL Consultants SINCE THE DEOINNINQ" 3c'a 1S FOLSOM 5T. SAN FRANCISCO, CALIFORNIA 94110 41S/5SO-2,2gd Dave Burnham E&B Farms 4900 Morgan Territory Road Clayton, CA 9451 i February 12; 2001 Dear Mr. Burnham, RE: ARCHAEOLOGICAL FIELD INSPECTION OF THE E&B 1RARNIS PROPERTY, (APN- 080-040-033),4900 MORGAN TERRITORY ROAD,CONTRA COSTA COUNTY, CALIF OR.NIA At your request I have completed ars archaeological field inspection of the above referenced project area located on Rlorgan Territory Road near its intersection with Levis Drive on the east slope of Mt. Diablo, Contra Costa County, California. No evidence of cultural o resources was discovered either during the archival research or the field inspection. This report contains a summary of my findings to date, PROJECT DESCRIPTION The proposed project area consists of an approximateiv triangular shapedparcel bf.land located on the west side of Morgan Territory Road near A5 intersection,"ith Leon Lane on.the eastern slope of Mt. Diablo. Located on the Antioch South and Tassajara li.S.G.S. maps of the area,the property is defined by open hillsides on its westem,northern and southeastern borders. Comprised of mostly steeply sloping hillsides,the property at present is covered by a dense layer of native and imported grasses and supports sparse stands of glue and white oar trees. access to the property is through a gate located along Morgan Territory Road which runs adjacent to a seasonal drainage which separates the property from an adjacent developed parcel at its northeastern corner. ARCHIVAL RESEARCH d a initial archival research for this project was done b-,-the Nortbwest lnforrriation Center (file no. 01-CC-01) located at Sonome State University. Based upon an inspection of their maps, a recommendation was made to conduct an archaeological fielc inspection of the property due to its potential for containing unrecorded archaeological sites. Additional archival research conducted by this author utilizing the -files of Holman& Associates reveals that there ary n o recorded sites inside the project parcel, but there is one site I 02/12/2001 14:44 41523826239 HOLMAN AND ASSOCIATE PAS 02/02 i r (Cco-591) recorded to the northeast of it oil the eastern side of Nforgar.Territory Road. A recommendation foz a;:field inspection was made in part upon the presence of a seasonal drainage on the project area,and partly upon its proxinuty to recorded archaeological sites; there are several additional prehistoric sites recorded within a mile of it along the drainage which parallels Morgan Territory Road:. DESCRIPTION OF FIELD INSPECTION A visual inspection of the project area was conducted by this author during the second week of February, 2001_ Utilizing a topographic map of the project area showing the location of temporary housing,the future access road, the ultimate building site and a leach field, a visual inspection was made of the general area where these improvements will occur_ Additionally the drainage found at the northeastern edge of the property was vixen additional inspection in an attempt to locate possible aboriginal use or tillage sites. The entire project area is covered with an at`drnes dense covering of grasses and contains sparse stands of oak trees with little exposed bedrock_ The ground surface inside and adjacent to those areas of planned improvements(.main house site,temporary mobile home site, leach field and access roads) was inspected.for any indications of aboriginal use and/or occupation. Given the slope of the property, aboriginal use would have been limited to temporary carup sites and areas utilized for the gathering or processing of grass seeds or acora.s.Visiblee signs of such use would include darker than surrounidiurg soils, concentrations of bone or stone, evidence of fue (ash, charcoal, fire altered rock), and artifacts of stare, bone or shellfish. PIN DIN GS/1ECOMMtNi DATIONTS In conclusion,no evidence of archaeological materai, Elither historic or prehistoric, wss seen anywhere inside the project parcel where improvements will occur, or M the general vicinity of these improvements. It is the opinion of this vv-niter that the proposed project can go forward with no effect to cultural resources.No additional reca r me.ndations regarding subsurface testing and/or monitoring of construction activities to search for such resources are included in this report. elv. Miley Paul Holman Holman& Associa:e.s 2