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HomeMy WebLinkAbout05_053 PC Resolution PC RESOLUTION NO. 2005-053 A RESOLUTION OF THE PLANNING DIRECTOR OF THE CITY OF TEMECULA APPROVING PLANNING APPLICATION NO. PA05-0066, A TENTATIVE PARCEL MAP NO. 33545, TO SUBDIVIDE 20.33 ACRES (4 EXISTING PARCELS) INTO SEVEN (7) COMMERCIAL PARCELS, LOCATED AT THE SOUTHEAST CORNER OF HIGHWAY 79 SOUTH AND BUTTERFIELD STAGE ROAD, KNOWN AS ASSESSOR PARCEL NUMBERS 952-200-002,011,012,013. WHEREAS, Michael Schweitzer, Masson and Associates, filed Planning Application No. PA05-0066, in a manner in accord with the City of Temecula General Plan and Subdivision Ordinance; WHEREAS, Planning Application No. PA05-0066 was processed including, but not limited to a public notice, in the time and manner prescribed by State and local law; WHEREAS, the Planning Commission. at a regular meeting, considered Planning Application No. PA05-0066 on July 20, 2005, at a duly noticed public hearing as prescribed by law, at which time the City staff and interested persons had an opportunity to and did testify either in support or in opposition to this matter; WHEREAS, at the conclusion of the Planning Commission Hearing and after due consideration of the testimony, the Commission approved Planning Application No. PA05-0066 subject to the conditions after finding that the project proposed in Planning Application No. PA05-0066 conformed to the City of Temecula General Plan; NOW, THEREFORE, THE PLANNING COMMISSION OF THE CITY OF TEMECULA DOES HEREBY RESOLVE, DETERMINE AND ORDER AS FOLLOWS: Section 1. That the above recitations are true and correct and are hereby incorporated by reference. Section 2. FindinQs. The Planning Commission, in approving Planning Application No. PA05-0066 (Tentative Parcel Map) hereby makes the following findings as required by Section 16.09.140 of the Temecula Municipal Code: A. The proposed subdivision and the design and improvements of the subdivision are consistent with the Subdivision Ordinance, Development Code, General Plan, and the City of Temecula Municipal Code. Staff has reviewed the proposal and finds that Tentative Parcel Map No. 33545 is consistent with the General Plan, the Subdivision Ordinance, and the Municipal Code in that the proposed project meets the design standards as required in the General Plan, Subdivision Ordinance, and the Municipal Code. B. The tentative map does not divide land which is subject to a contract entered into pursuant to the California Land Conservation Act of 1965, or the land is subject to a Land conservation Act contract but the resulting parcels following division of the land will not be too small to sustain their agricultural use. G:\Planning\2005\PA05~0066 Butterfield Ranch Shopping Centcr- :TM\P!anning\Reso and COA's for PC.doc 1 The proposed land division is not land designated for conservation or agricultural use. C. The site is physically suitable for the type and proposed density of development proposed by the tentative map. The project consists of a Parcel Map on property designated for commercial uses, which is consistent with the General Plan, as well as the development standards in the Development Code. D. The design of the subdivision and the proposed improvements, with conditions of approval, are not likely to cause significant environmental damage or substantially and avoidably injure fish or wildlife or their habitat. The project consists of a Parcel Map on property designated for commercial uses, which is consistent with the General Plan. In addition, staff has prepared an Initial Study for the Development Plan and found that there are no significant environmental impacts that will result with the development of this project. E. The design of the subdivision and the type of improvements are not likely to cause serious public health problems. The project has been reviewed and commented on by the Fire Safety Department, the Public Works Department and the Building and Safety Department. As a result, the project will be conditioned to address their concerns. Further, provisions are made in the General Plan and the Development Code to ensure that the public health, safety and welfare are safeguarded. The project is consistent with these documents. F. The design of the subdivision provides for future passive or natural heating or cooling opportunities in the subdivision to the extent feasible. The proposed Tentative Tract Map will not alter the approved design of the Development Plan (PA04-0621) or the future buildings. G. The design of the subdivision and the type of improvements will not conflict with easements acquired by the public at large for access through or use of property within the proposed subdivision, or the design of the alternate easements which are substantially equivalent to those previously acquired by the public will be provided. All required rights-of-way and easements have been provided on the Tentative Map. The City has reviewed these easements and has found no potential conflicts. H. (Quimby). The subdivision is consistent. with the City's parkland dedication requirements This is a map for non-residential use and will not be subject to Quimby fees. Section 3. Environmental Compliance. The proposed project has been determined to be consistent with the Negative Declaration related to PA04-0621 and is exempt from further Environmental Review (CEQA Section 15162 subsequent EIR's and Negative Declarations). G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TTM\Planning\Reso and COA's for PC.doc 2 Section 4. Conditions. That the City of Temecula Planning Commission hereby approves Planning Application No. PA05-0066 (Tentative Parcel Map 33545) a tentative tract map to subdivide 20.33 acres (4 existing parcels) into seven (7) commercial parcels located at on the south east corner of Highway 79 South and Butterfield Stage Road, with the conditions of approval set forth on Exhibit A, attached hereto, and incorporated herein by this reference together with any other conditions that may be deemed necessary. Section 5. PASSED, APPROVED AND ADOPTED by the City of Temecula of Planning Commission this 20th day of July 2005. ATTEST: 1)t/;/;t~. p-~U7)'~ Debbie Ubnoske, Secretary [SEAL] ~j , , , " - , " ../ , , f",' ...,\' '\ G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TTM\Planning\Reso and COA's for PC-doc 3 STATE OF CALIFORNIA ) COUNTY OF RIVERSIDE ) ss CITY OF TEMECULA ) I Debbie Ubnoske, Secretary of the Temecula Planning Commission, do hereby certify that PC Resolution No. 2005-053 was duly and regularly adopted by the Planning Commission of the City of Temecula at a regular meeting thereof held on the 20th day of July, 2005, by the following vote: AYES: 5 PLANNING COMMISSIONERS: Chiniaeff, Guerriero, Harter, Mathewson, Telesio NOES: o PLANNING COMMISSIONERS: None ABSENT: o PLANNING COMMISSIONERS: None ABSTAIN: o PLANNING COMMISSIONERS: None (/)fl fhA - t c. b ,...:J Yf.-..---- Debbie Ubnoske, Secretary G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TIM\Planning\Reso and COA's for PC.doc 4 EXHIBIT A FINAL CONDITIONS OF APPROVAL G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Ccnter-1TM\Planning\Reso and COA's for PC.doc 5 EXHIBIT A CITY OF TEMECULA FINAL CONDITIONS OF APPROVAL Planning Application No. PA05-0066 Project Description: A Tentative Parcel Map No. 33545, to subdivide 20.33 acres (4 existing parcels) into seven (7) commercial, located on the southeast corner of Highway 79 South and Butterfield Stage Road. Assessor's Parcel Nos.: 952-200-002,011,012,013 Approval Date: July 20, 2005 Expiration Date: July 20, 2007 WITHIN FORTY-EIGHT (48) HOURS OF THE APPROVAL OF THIS PROJECT Planning Department 1 . The applicant/developer shall deliver to the Planning Department a cashier's check or money order made payable to the County Clerk in the amount of Sixty-Four Dollars ($64.00) for the County administrative fee, to enable the City to file the Notice of Exemption as provided under Public Resources Code Section 21108(b) and California Code of Regulations Section 15062. If within said forty-eight (48) hour period the applicant/developer has not delivered to the Planning Department the check as required above, the approval for the project granted shall be void by reason of failure of condition (Fish and Game Code Section 711.4(c). G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TTM\Planning\Reso and COA's for PC.doc 6 GENERAL REQUIREMENTS G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TIM\Planning\Reso and COA's for PC.doc 7 Planning Department 2. The tentative subdivision shall comply with the State of California Subdivision Map Act and to all the requirements of Ordinance No. 460, unless modified by the conditions listed below. A time extension may be approved in accordance with the State Map Act and City Ordinance, upon written request, if made 60 days prior to the expiration date. 3. The applicant and owner of the real property subject to this condition shall hereby agree to indemnify, protect, hold harmless, and defend the City with Legal Counsel of the City's own selection from any and all claims, actions, awards, judgments, or proceedings against the City to attack, set aside, annul, or seek monetary damages resulting, directly or indirectly, from any action in furtherance 01 and the approval of the City, or any agency or instrumentality thereof, advisory agency, appeal board or legislative body including actions approved by the voters of the City, concerning the Planning Application. The City shall be deemed for purposes of this condition, to include any agency or instrumentality thereof, or any of its elected or appointed officials, officers, employees, consultants, contractors, legal counsel, and agents. City shall promptly notify both the applicant and landowner of any claim, action, or proceeding to which this condition is applicable and shall further cooperate fully in the defense of the action. The City reserves the right to take any and all action the City deems to be in the best interest of the City and its citizens in regards to such defense. 4. The applicant shall sign two copies of the final conditions of approval that will be provided by the Planning Department and return one signed copy to the Planning Department for their files. PUBLIC WORKS DEPARTMENT 5. It is understood that the Developer correctly shows on the tentative map all existing and proposed easements, traveled ways, improvement constraints and drainage courses, and their omission may require the project to be resubmitted for further review and revision. 6. A Grading Permit for either rough or precise grading shall be obtained from the Department 01 Public Works prior to commencement of any construction outside of the City-maintained road right-ol-way. 7. An Encroachment Permit shall be obtained lrom the Department 01 Public Works prior to commencement of any construction within an existing or proposed City right-of-way. 8. All improvement plans, grading plans, landscape and irrigation plans shall be coordinated for consistency with adjacent projects and existing improvements contiguous to the site and shall be submitted on standard 24" x 36" City of Temecula mylars. 9. The vehicular movement for the driveway on Highway 79 South shall be restricted to a right in/right out. 10. The vehicular movement for the northerly driveway on Butterfield Stage Road shall be restricted to a right in/right out. G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TIM\Planning\Reso and COA's for PC.doc 8 Fire Department 11. Any previous existing conditions for this project or any underlying map will remain in full force and effect unless superceded by more stringent requirements here. 12. Final fire and life safety conditions will be addressed when building plans are reviewed by the Fire Prevention Bureau. These conditions will be based on occupancy, use, the California Building Code (CBC), California Fire Code (CFC), and related codes which are in force at the time of building plan submittal. \ 13. The Fire Prevention Bureau is required to set a minimum fire flow for residential land division per CFC Appendix III.A, Table A-III-A-1. The developer shall provide for this project, a water system capable of delivering 1500 GPM at 20-PSI residual operating pressure with a 2-hour duration. The required fire flow may be adjusted during the approval process to reflect changes in design, construction type, or automatic fire protection measures as approved by the Fire Prevention Bureau. The Fire Flow as given above has taken into account all information as provided. (CFC 903.2, Appendix III-A) 14. The Fire Prevention Bureau is required to set minimum fire hydrant distances per CFC Appendix III.B, Table A-III-B-1. Standard fire hydrants (6" x 4" x 21/2" outlets) shall be located on Fire Department access roads and adjacent public streets. Hydrants shall be spaced at 500 feet apart, at each intersection and shall be located no more than 250 feet from any point on the street or Fire Department access road(s) frontage to a hydrant. The required fire flow shall be available from any adjacent hydrant(s) in the system. The upgrade of existing fire hydrants may be required. (CFC 903.2, 903.4.2, and Appendix III-B) 15. The Fire Prevention Bureau is required to set a minimum fire flow for commercial land division per CFC Appendix III-A, Table A-III-A-1. The developer shall provide for this project, a water system capable of delivering 4000 GPM at 20-PSI residual operating pressure with a 4 hour duration. The required fire flow may be adjusted during the approval process to reflect changes in design, construction type, or automatic fire protection measures as approved by the Fire Prevention Bureau. The Fire Flow as given above has taken into account all information as provided. (CFC 903.2, Appendix III-A) 16. The Fire Prevention Bureau is required to set minimum fire hydrant distances per CFC Appendix III-B, Table A-III-B-1. Super fire hydrants (6" x 4" x 2-2 1/2" outlets) shall be located on Fire Department access roads and adjacent public streets. Hydrants shall be spaced at 350 feet apart, at each intersection and shall be located no more than 210 feet from any point on the street or Fire Department access road(s) frontage to a hydrant. The required fire flow shall be available from any adjacent hydrant(s) in the system. The upgrade of existing fire hydrants may be required. (CFC 903.2, 903.4.2, and Appendix III-B) 17. Maximum cul-de-sac length shall not exceed 1320 feet. Minimum turning radius on any cul-de-sac shall be thirty-seven (37) feet for residential and forty-five (45) feet for commercial. (CFC 902.2.2.3, CFC 902.2.2.4) G:\Planning\2005\PAOS.0066 Butterfield Ranch Shopping Center-TIM\Planning\Reso and COA's for PC.doc 9 18. All traffic calming devices that could impede or slow emergency vehicle access are prohibited, except those expressly approved by the fire prevention bureau individually on a case by case basis when they maintain the required travel widths and radii. 19. Cul-de-sacs and/or intersections with planters must maintain 24 foot clear unobstructed travel width around the planters, not including parking. Hardscape areas are permissible provided that they meet the 80,000 lb. load requirements and are at road level. 20. Private entry driveways with divider medians must be a minimum of 16 feet wide on each side unless the median is held back 30 feet from face of curb of perpendicular road. 21. If construction is phased, each phase shall provide approved access and fire protection prior to any building construction. (CFC 8704.2 and 902.2.2) This will include all internal roads, connecting roads between phases, and construction gates. All required access must be in and available prior to and during ALL construction. Phasing is approved on a separate map, and is ultimately subject to final approval in the field. 22. Any existing water system in support of hydrants or fire sprinkler systems that was installed as a common system serving the property that will now be divided into more than one parcel will be the responsibility of ALL PARCELS and will be maintained and repaired by ALL PARCELS in perpetuity. 23. Any existing fire lanes, fire department access roads or gates, or any other apparatus, appliance or surface used to provide emergency fire department access SHALL BE LEFT UNALTERED in perpetuity. 24. This parcel when divided shall maintain reciprocal access to all parcels Community Services 25. The map shall identify the eight (8) foot wide Class I trail along Butterfield Stage Road and along the south side of Temecula Creek with a connection to a Riverside County regional trail. 26. The property owner shall provide a public access easement dedication over the both sections of the Class I trails on the Final Parcel Map. G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TTM\Planning\Reso and COA's for PCdoc 10 PRIOR TO RECORDATION OF THE FINAL MAP G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TTM\Planning\Reso and COA's for PC.doc 11 Planning Department 27. The following shall be submitted to and approved by the Planning Department: a. A copy of the Final Map. b. A copy of the Environmental Constraint Sheet (ECS) with the following notes: i. This property is located within thirty miles (30) of Mount Palomar Observatory. All proposed outdoor lighting systems shall comply with the California Institute of Technology, Palomar Observatory recommendations, Ordinance No. 655. c. A Reciprocal Use Agreement and maintenance agreement ensuring access to all parcels and joint maintenance of all roads, drives or parking areas shall be provided and shall be recorded concurrent with the map. Public Works Department 28. Prior to Approval of the Parcel Map, unless other timing is indicated, the Developer shall complete the following or have plans submitted and approved, subdivision improvement agreements executed and securities posted: 29. As deemed necessary by the Department of Public Works, the Developer shall receive written clearance from the following agencies: a. San Diego Regional Water Quality Control Board b. Rancho California Water District c. Eastern Municipal Water District d. Riverside County Flood Control and Water Conservation District e. City of Temecula Fire Prevention Bureau f. Planning Department g. Department of Public Works h. Riverside County Health Department i. Cable TV Franchise j. Community Services District k. General Telephone I. Southern California Edison Company m. Southern California Gas Company 30. The Developer shall design and guarantee construction of the following public improvements to City of Temecula General Plan standards unless otherwise noted. Plans shall be reviewed and approved by the Department of Public Works: a. Improve Highway 79 South from Butterfield Stage Road to the easterly property boundary (Urban Arterial Highway Standards - 134' R/W) to include installation of sidewalk, street lights, drainage facilities, signing and striping, utilities (including but not limited to water and sewer), and a raised landscaped rnedian. G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TIM\Planning\Reso and COA's for PC.doc 12 b. Improve Butterfield Stage Road from Highway 79 South to the southerly property boundary (Major Highway Standards - 100' R/W) to include installation of paving, curb and gutter, sidewalk, street lights, drainage facilities, signing and striping, utilities (including but not limited to water and sewer), and a raised landscaped median. c. The signal at the intersection of Highway 79 South and BlJttorfiolEl Stago RoaG Wolf Store Road shall be modified to accommodate full movement. (Amended at the 7/20/05 P.C. Hearing) 31. Unless otherwise approved the following minimum criteria shall be observed in the design of the street improvement plans: a. Street centerline grades shall be 0.5% minimum over P.C.C. and 1.00% minimum over A.C. paving. b. Driveways shall conform to the applicable City Standard Nos. 207A. c. Street lights shall be installed along the public streets shall be designed in accordance with City Standard No. 800, 801, 802 and 803. d. Concrete sidewalks shall be constructed in accordance with City Standard Nos. 400 and 401. e. All street and driveway centerline intersections shall be at 90 degrees. f. Landscaping shall be limited in the corner cut-off area of all intersections and adjacent to driveways to provide for minimum sight distance and visibility. g. All utility systems including gas, electric, telephone, water, sewer, and cable TV shall be provided underground. Easements shall be provided as required where adequate right-of-way does not exist for installation of the facilities. All utilities shall be designed and constructed in accordance with City Codes and the utility provider. h. All utilities, except electrical lines rated 34kv or greater, shall be installed underground. 32. A construction area Traffic Control Plan shall be designed by a registered Civil Engineer and reviewed by the Department of Public Works for any street closure and detour or other disruption to traffic circulation as required by the Department of Public Works. 33. Relinquish and waive right of access to and from Highway 79 South on the Parcel Map with the exception of one opening as delineated on the approved Tentative Parcel Map. 34. Relinquish and waive right of access to and from Butterfield Stage Road on the Parcel Map with the exception of two (2) openings as delineated on the approved Tentative Parcel Map. 35. An easement for reciprocal ingress/egress shall be provided prior to approval of the Parcel Map or issuance of building permits, whichever occurs first. 36. An easement for a joint use driveway shall be provided prior to approval of the Parcel Map or issuance of building permits, whichever occurs first. G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Centcr-ITM\Planning\Reso and COA's for PCdoc 13 37. Corner property line cut off for vehicular sight distance and installation of pedestrian facilities shall be provided at all street intersections in accordance with Riverside County Standard No. 805. 38. All easements and/or right-of-way dedications shall be offered for dedication to the public or other appropriate agency and shall continue in force until the City accepts or abandons such offers. All dedications shall be free from all encumbrances as approved by the Department of Public Works. 39. Pursuant to Section 66493 of the Subdivisio[1 Map Act, any subdivision which is part of an existing Assessment District must comply with the requirements of said section. Prior to City Council approval of the Parcel Map\Final Map, the Developer shall make an application for reapportionment of any assessments with appropriate regulatory agency. 40. Any delinquent property taxes shall be paid. 41. An Environmental Constraints Sheet (ECS) shall be prepared in conjunction with the Parcel Map to delineate identified environmental concerns and shall be recorded with the map. 42. The Developer shall comply with all constraints which may be shown upon an Environmental Constraint Sheet recorded with any underlying maps related to the subject property. ,43. The Developer shall make a good faith effort to acquire the required off-site property interests, and if he or she should fail to do so, the Developer shall, prior to submittal of the Parcel Map for recordation, enter into an agreement to complete the improvements pursuant to the Subdivision Map Act, Section 66462 and Section 66462.5. Such agreement shall provide for payment by the Developer of all costs incurred by the City to acquire the off-site property interests required in connection with the subdivision. Security of a portion of these costs shall be in the form of a cash deposit in the amount given in an appraisal report obtained by the Developer, at the Developer's cost. The appraiser shall have been approved by the City prior to commencement of the appraisal. 44. A copy of the grading and improvement plans, along with supporting hydrologic and hydraulic calculations shall be submitted to the Riverside County Flood Control and Water Conservation District for approval prior to recordation of the Parcel Map\Final Map or the issuance of any permit. A permit from Riverside County Flood Control and Water Conservation District is required for work within their right-of-way. 45. The Developer shall notify the City's cable TV Franchises of the Intent to Develop. Conduit shall be installed to cable TV Standards at time of street improvements. 46. Private drainage easements for cross-lot drainage shall be required and shall be delineated and noted on the final map. 47. ,Easements for sidewalks for public uses shall be dedicated to the City where sidewalks meander through private property. 48. Easements, when required for roadway slopes, landscape easements, drainage facilities, utilities, etc., shall be shown on the final map if they are located within the land G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Ccnter-TfM\Planning\Reso and COA's for PCdoc 14 division boundary. All offers of dedication and conveyances shall be submitted for review and recorded as directed by the Department of Public Works. On-site drainage facilities located outside of road right-ol-way shall be contained within drainage easements and shown on the final map. A note shall be added to the final map stating "drainage easements shall be kept free of buildings and obstructions. " G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Cenlcr-ITM\Planning\Reso and COA's for PC.doc 15 PRIOR TO ISSUANCE OF GRADING PERMITS G:\Planning\2005\PA05-0066 BuLtcrfield Ranch Shopping Center-TTM\Planning\Reso and COA's for PC.doc 16 Department of Public Works 49. As deemed necessary by the Department of Public Works, the Developer shall receive written clearance from the following agencies: a. San Diego Regional Water Quality Control Board b. Riverside County Flood Control and Water Conservation District c. Planning Department d. Department of Public Works 50. A Grading Plan shall be prepared by a registered Civil Engineer in accordance with City of Temecula standards and approved by the Department of Public Works prior to commencement of any grading. The plan shall incorporate adequate erosion control measures to protect the site and adjoining properties from damage due to erosion. 51. A Soils Report shall be prepared by a registered Civil or Soils Engineer and submitted to the Department of Public Works with the initial grading plan check. The report shall address all soils conditions of the site, and provide recommendations for the construction of engineered structures and preliminary pavement sections. 52. A Drainage Study shall be prepared by a registered Civil Engineer and submitted to the Department of Public Works with the initial grading plan check. The study shall identify storm water runoff quantities expected from the development of this site and upstream of the site. It shall identify all existing or proposed off-site or on-site, public or private, drainage facilities intended to discharge this runoff. Runoff shall be conveyed to an adequate outfall capable of receiving the storm water runoff without damage to public or private property. The study shall include a capacity analysis verifying the adequacy of all facilities. Any upgrading or upsizing of drainage facilities necessary to convey the storm water runoff shall be provided as part of development of this project. The basis for analysis and design shall be a storm with a recurrence interval of one hundred years. 53. NPDES - The project proponent shall implement construction-phase and post- construction pollution prevention measures consistent with the State Water Resources Control Board (SWRCB) and City of Temecula (City) NPDES programs. Construction- phase measures shall include Best Management Practices (BMPs) consistent with the City's Grading, Erosion & Sediment Control Ordinance, the City's standard notes for Erosion and Sediment Control, and the SWRCB General Permit for Construction Activities. Post-construction measures shall be required of all Priority Development Projects as listed in the City's NPDES permit. Priority Development Projects will include a combination of structural and non-structural onsite source and treatment control BMPs to prevent contaminants from commingling with stormwater and treat all unfiltered runoff year-round prior to entering a storm drain. Construction-phase and post-construction BMPs shall be designed and included into plans for submittal to, and subject to the approval of, the City Engineer prior to issuance of a Grading Permit. The project proponent shall also provide proof of a mechanism to ensure ongoing long-term maintenance of all structural post-construction BMPs. 54. The Developer shall post security and enter into an agreement guaranteeing the grading and erosion control improvements in conformance with applicable City Standards and subject to approval by the Department of Public Works. G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TTM\Planning\Reso and COA's for PC.doc 17 55. A flood mitigation charge shall be paid. The Area Drainage Plan fee is payable to the Riverside County Flood Control and Water Conservation District by either cashier's check or money order, prior to issuance of permits, based on the prevailing area drainage plan fee. If the full Area Drainage Plan fee or mitigation charge has already been credited to this property, no new charge needs to be paid. 56. The Developer shall obtain letters of approval or easements for any off-site work performed on adjoining properties. The letters or easements shall be in a format as directed by the Department of Public Works. 57. The site is in an area identified on the Flood Insurance Rate Maps as Flood Zone "A" and is subject to flooding of undetermined depths. Prior to the approval of any plans, the Developer shall demonstrate that the project complies with Chapter 15.12 of the Temecula Municipal Code for development within Flood Zone "A". A Flood Plain Development Permit is required prior to issuance of any permit. Residential subdivisions shall obtain a Letter of Map Revision (LOMR) from the Federal Emergency Management Agency (FEMA) prior to occupancy of any unit. Commercial subdivisions may obtain a LOMR at their discretion. 58. Prior to map recordation the applicant shall submit to the Fire Prevention Bureau a georectified (pursuant to Riverside County standards) digital version of the map including parcel and street centerline information. The electronic file will be provided in a ESRI Arclnfo/ArcView compatible format and projected in a State Plane NAD 83 (California Zone VI) coordinate system. The Bureau must accept the data as to completeness, accuracy and format prior to satisfaction of this condition. G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TIM\Planning\Reso and COA's for PC.doc 18 PRIOR TO ISSUANCE OF BUILDING PERMITS G:\PJanning\2005\PAOS-0066 Butterfield Ranch Shopping Center-TTM\Planning\Reso and COA's for PC.doc 19 Planning Department 59. The applicant shall comply with the recommendations set forth in the Rancho California Water District's letter dated March 15, 2005, a copy of which is attached. 60. The applicant shall comply with the recommendations set forth in the County of Riverside Flood Control District's letter dated May 17, 2005, a copy of which is attached. 61. The applicant shall comply with the recommendations set forth in the Pechanga Cultural Resources letter dated May 27,2005, a copy of which is attached. Department of Public Works 62. Parcel Map shall be approved and recorded. 63. A Precise Grading Plan shall be submitted to the Department of Public Works for review and approval. The building pad shall be certified by a registered Civil Engineer for location and elevation, and the Soils Engineer shall issue a Final Soils Report addressing compaction and site conditions. 64. Grading of the subject property shall be in accordance with the California Building Code, the approved grading plan, the conditions of the grading permit, City Grading Standards and accepted grading construction practices. The final grading plan shall be in substantial conformance with the approved rough grading plan. 65. The Developer shall pay to the City the Public Facilities Development Impact Fee as required by, and in accordance with, Chapter 15.06 of the Temecula Municipal Code and all Resolutions implementing Chapter 15.06. 66. The Developer shall pay to the City the Western Riverside County Transportation Uniform Mitigation Fee (TUMF) Program as required by, and in accordance with, Chapter 15.08 of the Temecula Municipal Code and all Resolutions implementing Chapter 15.08. Fire Department 67. Prior to building construction, all locations where structures are to be built shall have approved temporary Fire Department vehicle access roads for use until permanent roads are installed. Temporary Fire Department access roads shall be an all weather surface for 80,000 Ibs. GVW. (CFC 8704.2 and 902.2.2.2) 68. Prior to building final, all locations where structures are to be built shall have approved Fire Department vehicle access roads to within 150 feet to any portion of the facility or any portion of an exterior wall of the building(s). Fire Department access roads shall be an all weather surface designed for 80,000 Ibs. GVW with a minimum AC thickness of .25 feet. (CFC see 902) 69. Fire Department vehicle access roads shall have an unobstructed width of not less than twenty-four (24) feet and an unobstructed vertical clearance of not less than thirteen (13) feet six (6) inches. (CFC 902.2.2.1) G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-ITM\Planning\Reso and COA's for PC.doc 20 70. Prior to building construction, dead end road ways and streets in excess of one hundred and fifty (150) feet which have not been completed shall have a turnaround capable of accommodating fire apparatus. (CFC 902.2.2.4) 71. Prior to building construction, this development and any street within serving more than 35 homes or any commercial developments shall have two (2) points of access, via all- weather surface roads, as approved by the Fire Prevention Bureau. (CFC 902.2.1) 72. Prior to issuance of building permits, the developer shall furnish one copy of the water system plans to the Fire Prevention Bureau for approval prior to installation. Plans shall be: signed by a registered civil engineer; contain a Fire Prevention Bureau approval signature block; and conform to hydrant type, location, spacing and minimum fire flow standards. After the plans are signed by the local water company, the originals shall be presented to the Fire Prevention Bureau for signatures. The required water system including fire hydrants shall be installed and accepted by the appropriate water agency prior to any combustible building materials being placed on an individual lot. (CFC 8704.3, 901.2.2.2 and National Fire Protection Association 24 1-4.1) 73. Prior to issuance of building permits, plans for structural protection from vegetation fires shall be submitted to the Fire Prevention Bureau for review and approval. The measures shall include, but are not limited to, enclosing eaves, noncombustible barriers (cement or block walls), and fuel modification zones. (CFC Appendix II-A) G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TIM\Planning\Reso and COA's for PC.doc 2\ PRIOR TO ISSUANCE OF CERTIFICATES OF OCCUPANCY G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TIM\Planning\Reso and COA's for PC.doc 22 Department of Public Works 74. As deemed necessary by the Department of Public Works, the Developer shall receive written clearance from the following agencies: a. Rancho California Water District b. Eastern Municipal Water District c. Department of Public Works 75. All necessary certifications and clearances from engineers, utility companies and public agencies shall be submitted as required by the Department of Public Works. 76. All improvements shall be constructed and completed per the approved plans and City standards to the satisfaction of the Director of Public Works. 77. The existing improvements shall be reviewed. Any appurtenance damaged or broken due to the construction operations of this project shall be repaired or removed and replaced to the satisfaction of the Director of Public Works. Fire Department 78. Prior to issuance of a Certificate of Occupancy or building final, "Blue Reflective Markers" shall be installed to identify fire hydrant locations. (CFC 901.4.3) 79. All manual and electronic gates on required Fire Department access roads or gates obstructing Fire Department building access shall be provided with the Knox Rapid entry system for emergency access by firefighting personnel. (CFC 902.4) By placing my signature below, I confirm that I have read, understand and accept all of the above Conditions of Approval. I further understand that the property shall be maintained in conformance with these conditions of approval and that any changes I may wish to make to the project shall be subject to Community Development Department approval. Applicant's Signature Date Applicant's Printed Name G:\Planning\2005\PA05-0066 BuLterfield Ranch Shopping Center-1TM\Planning\Reso and COA's for PC.doc 23 Department of Public Works 74. As deemed necessary by the Department of Public Works, the Developer shall receive written clearance from the following agencies: a. Rancho California Water District b. Eastern Municipal Water District Department of Public Works J c. 75. All necessary certifications and clearances from engineers, utility companies and public agencies shall be submitted as required by the Department of Public Works. 76. All improvements shall be constructed and completed per the approved plans and City standards to the satisfaction of the Director of Public Works. 77. The existing improvements shall be reviewed. Any appurtenance damaged or broken due to the construction operations of this project shall be repaired or removed and replaced to the satisfaction of the Director of Public Works. Fire Department 78. Prior to issuance of a Certificate of Occupancy or building final, "Blue Reflective Markers" shall be installed to identify fire hydrant locations. (CFC 901.4.3) 79. All manual and electronic gates on required Fire Department access roads or gates obstructing Fire Department building access shall be provided with the Knox Rapid entry system for ernergency access by firefighting personnel. (CFC 902.4) By placing my signature below, I confirm that I have read, understand and accept all of the above Conditions of Approval. I further understand that the property shall be maintained in conformance with these conditions of approval and that any changes I may wish to make to the project shall be subject to Community Development Department approval. Applicant's Signature Date Applicant's Printed Name G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TfM\Planning\Reso and COA's fOf PC,doc 23 OUTSIDE AGENCIES G:\Planning\2005\PA05-0066 Butterfield Ranch Shopping Center-TTM\Planning\Reso and COA's for PC.doc 24 r@ ILanchD Water R"ardnfDirecIOT- Csaba F. Ko Pr...~idl'nl Ben R. nrake Sr. Vie-ePn'sidelll Stephen J. Corona Ralph II. Daily Lisa 1>. Herman .John E. HoaRhnd Michael R McMillan Omcers" Brian J. Brad)' \.1'1I"H1I/11anagt!f Phillip L. Forhes DirertorofFinance.TreflHlrer E.P. 'Bob~ Lemon.'; Uircctorof Enlfinl:'f:'ring Perry R. Louck DiredorofP1RIlninl1 Jeff D. ATmstronil' Controller Linda M. Fregoso Di~tTicl Secr<'t:lD'!Arlministl'Ati\'1' Ser"ircsMilnager C. Michael Cowett Best Best & Krieger LLP GencmlColln,.;cl March 15,2005 MAR 1 8 2005 Christine Damko, Project Planner City of Temecula Planning Department Post Office Box 9033 Temecula, CA 92589-9033 SUBJECT: WATER AVAILABILITY TENTATIVE PARCEL MAP NO. XXXXX BUTTERFIELD RANCH SHOPPING CENTER PARCEL 1 THROUGH PARCEL 4 OF PARCEL MAP NO. 17782; APN 952-200-002 THROUGH APN 952-200-013 P A05-0066 [MASSON & ASSOCIATES, INc.] Dear Ms. Damko: Please be advised that the above-referenced property is located within the boundaries of Rancho California Water District (RCWD). Water service, therefore, would be available upon construction of any required on-site and/or off-site water facilities and the completion of financial arrangements between RCWD and the property owner. If fire protection is required, the customer will need to contact RCWD for fees and requirements. Water availability would be contingent upon the property owner signing an Agency Agreement that assigns water management rights, if any, to RCWD. RCWD owns and operates a production well and a pumping station at the southeast comer of State Highway 79 South and Butterfield Stage Road. These facilities must remain in operation at all times. The developer should consult with RCWD regarding facility access and maintenance requirements. This project has the potential to become a commercial condominium development with individual building owners and an Owner's Association maintaining the common property and private water, fire protection and landscape irrigation facilities. RCWD requires that the City of Temecula include a Reciprocal Easement and Maintenance Agreement for these on-site private water facilities, as a condition of approval for the project. In addition to this agreement, RCWD would require individual water meters for each condominium unit. 4~ (Qih ~y I",!. UANCIIO ,l.~~ C^LIFOH.NI.~ " ''\,'ATt-:I~ ~ IJlSTH.ICT tI,..,,,._,.,.."..,.,.....,... .,,,,.,,>,., Rancho California Water District -42135 Winrhl'~lcr R,,;'Id . Po~1 OfficI' Box 9017 . Tf'm('culll. Calill>rnia 92.='''9-9UI7 . '95lJ 29(i.690Cl . F.~X (951) 296.61';60 1---- Christine DamkolCily of Temeenla Mareh 15, 2005 Page Two The project should be conditioned to use recycled water for landscape irrigation. for the use ofrecycled water are available from RCWD. Requirements If you should have any questions, please contact an Engineering Services Representative at this office at (951) 296-6900. Sincerely, RANCHO CALIFORNIA WATER DISTRICT -m;/ /J (f ~'h. Michael G. Meyerpeter, P . Development Engineering Manager OSIMM:ac063\FCE c: Laurie Williams, Engineering Services Supervisor Rancho California Watf'r [)i~tricl 421:r, Willrhc!'l(,l" n"ild . Po~! Onin' Box 901, . T,'mcclIla. ClIifurnia 9l589-~JOI7 . ,!l"I' :.!!!(j.fi!lOO . FAX (~~,II 'l9~.!;~()1) I I , @ 1"'\ e......e}.. vc.....; <->1 ,UI v...... 0.-'.............'. .-......... ..... . ......._............,..... ... --. .. .-- - MAY. 18.2005 9:31AM WARREND. WIllIAMS Gena-al Manager..chicfEngineer NO. 097 P.2/3 1995 MARKET STREET RIVERSIDE, CA 92501 951.955.1200 951.788.9965 FAX 93845.1 RlVERSIDE COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT May 17, 2005 ~ Ms. Christine Damico City of Temecula Planning Department Post Office Box 9033 Temecula, California 92589-9033 Dear Ms. Damko; Re: PA 05-0066 The District does not normally recommend conditions for land divisions or other land use cases in incorporated cities. The District also does not plan check city land use cases, or provide State Division' of Real Estate letters or other flood hazard reports for such cases. District conunentslreconunendations for such cases are normally limited to items of specific interest to the District including District Master Drainage Plan facilities, other regional flood control and drainage facilities which could be considered a logical component or extension of a master plan system, and District Area Drainage Plan fees (development mitigation fees), In addition, information ofa general nature is provided. The District has not reviewed the proposed project in detail and the following comment does not in any way constitute or imply District approval or endorsement of the proposed project with respect to flood hazard, public health and safety or any other such issue: This project proposes channels, storm drains 36 inches or larger in diameter, or other facilities that could be considered regional in nature and/or a logical extension of Temecu1a Creek Channel. The District would consider accepting ownership of such facilities on written request of the City. Facilities must be constructed to District standards, and District plan check and inspection will be required for District acceptance. Plan check, inspection and administrative fees will be required. In accordance with Assessment District 159, a drainage easement should be set aside (along the eastern boundary) to allow conveyance of flow from the north side of Highway 79 to Temecula Creek. GENERAL INFORMATION This project may require a National Pollutant Discharge Elimination System (NPDES) permit from the State Water Resources Control Board. Clearance for grading, recordation or other final approval should not be given until the City has determined that the project has been granted a permit or is shown to be exempt. If this project involves a Federal Emergency Management Agency (FEMA) mapped flood plain, then the City should require the applicant to provide all studies, calculations. plans and other infonnation required to meet FEMA requirements, and should further require that the applicant obtain a Conditional Letter of Map Revision (CLOMR) prior to grading, recordation or other final approval of the project, and a Letter of Map Revision (LOMR) prior to occupancy. t1c......c..J.vc.l...I~ QI 'OI\..lU ""..;0\..1........" --......... ...... ................;..............., ....--, . ,.-- - MAY.18.2005 9:31AM. NO. 1397 P.3/3 93845.1 Ms. Christine Damko Re: PA 05-0066 -2- May 17,2005 The applicant shall show written proof of compliance with the Multiple Species Habitat Conservation Plan (MSHCP) for any drainage facilities the applicant proposes to be maintained by the District. All applicable CEQA and MSHCP documents and permits shall address the construction, operation and maintenance of all onsite and off site drainage facilities. Draft CEQA documents shall be forwarded to the District during the public review period. If a natural watercourse or mapped floodplain is impacted by this project, the City should require the applicant to obtain all applicable Federal, State and local regulatory permits. These regulatory permits include, but are not limited to: a Section 404 Permit issued by the U.S. Army Corps of Engineers in compliance with Section 404 of the Clean Water Act, a Califomia State Department ofFish and Game Streambed Alteration Agreement in compliance with the Fish and Game Code Section 1600 et seq., and a 401 Water Quality Certification or a Report of Waste Discharge Requirements in compliance with Section 401 of the Clean Water Act or State Porter Cologne Water Quality Act, respectively, from the appropriate Regional Water Quality Control Board, The applicant shall also be responsible for complying with all mitigation measures as required under CEQA and all Federal, State, and local environmental rules and regulations. Very truly yours, ~ay ARTURO DIAZ Senior Civil Engineer c: Riverside County Planning Department Attn: David Mares AM:blj Chairperson: Germaine Arenas PECHANGA CULTURAL RESOURCES Temecula Band of Luiseiio Mission Indians Vice Chairperson: Mary Bear Magee .------------ .-.----- Committee Members: Raymond Basquez, Sr. Evie Gerber Darlene Azzarelli Bridgett Barcello Maxwell Frances Villalobos Post Office Box 2183 . Temecula, CA 92593 Telephone (909) 308-9295 . Fax (909) 506-9491 May 27, 2005 Monitor Supervisor: Aurelia MarrufTo JUL 0 Ii 2005 Director: Gary DuBois Ms. Christine Damko, Project Planner City ofTemecula Planning Department PO Box 9033 -----------.----- Temecula, CA 92589-9033 Re: Comments on Pre-DRC Notice for Tentative Tract Map for the Butterfield Ranch Shopping Center - P A 05-0066 Dear Ms. Damko, This comment letter is submitted by the Pechanga Band of Luiseiio Indians (hereinafter, "Pechanga Tribe"), ,a federally recognized Indian tribe and sovereign government. The Pechanga Tribe is formally requesting, pursuant to Public Resources Code 921092.2, to be notified and involved in the entire CEQA environmental review process for the duration of the above referenced project (the "Project"). I I We submit the following comments on the above listed document for the Project. Additional comments may be submitted directly by Pechanga or through their attorneys. We request that all such comments be part of the official record for the approval of this Project. We also request that the County provide us wiih copies of all archeological studieti, reports, site records, proposed testing plans, and proposed mitigation measures, and conditions as soon as they become available, for our comment. ' THE LEAD AGENCY MUST INCLUDE AND CONSULT WITH THE TRIBE IN ITS REVIEW PROCESS I I '---r----.---'---'---------n----'------ ! Sacred Is The Duty Trusted Unto Our Care And With Honor We Rise To The Need Pechanga comment letter to City of Temecula Planning Department RE: Comments on Butterfield Ranch Shopping Center Tract Map Page 2 It has been the intent of the Federal Governmentl and the State ofCalifornia2 that Indian tribes be consulted with regard to issues which impact cultural and spiritual resources, as well as other governmental concerns. The responsibility to consult with Indian tribes stems from the unique government-to-government relationship between the United States and Indian tribes. This arises when tribal interests are affected by the actions of governmental agencies and departments such as approval of Specific Plans and EIRs. In this case, it is undisputed that the project lies within the Luisefio tribe's traditional territory. Therefore, in order to comply with CEQA and other applicable Federal and California law, it is imperative that the Lead Agency and the Project applicant consult with the Tribe in order to guarantee an adequate basis of knowledge for an appropriate evaluation of the project effects, as well as generating adequate mitigation measures. PROJECT IMPACTS TO CULTURAL RESOURCES The Pechanga Tribe is not opposed to this development project. The Pechanga Tribe's primary concerns stem from the project's likely impacts on Native American cultural resources. The Pechanga Tribe is concerned about both the protection of unique and irreplaceable cultural resources, such as Luisefio village sites and archaeological items which would be displaced by ground-disturbing work on the project, and on the proper and lawful treatment of cultural items, Native American human remains and sacred items likely to be discovered in the course of the work. The Tribe would also like to point out that a preferred method of treatment for archeological sites according to the CEQA is avoidance (California Public Resources Code 921083.1), and that this is in agreement with the Tribe's practices and policies concerning cultural resources. The Pechanga Tribe asserts that the Project area is part of the Pechanga Tribe's aboriginal territory, as evidenced by the existence of Luisefio place names rock-art pictographs, petroglyphs, and an extensive artifact record in the vicinity of the Project. Given this threshold for scope ofPechanga traditional territory, the Pechanga Tribe is concerned about the potential impacts to Luisefio/Pechanga resources which may occur throughout the Project area. The Pechanga Tribe contends that the Project area is likely to contain cultural resources due to the fact that approximately eight (8) sites are recorded within a I-mile radius. Given all the information, there is a very strong likelihood oflocating sub-surface resources during ground disturbing activities. In addition, this Project is in close proximity to the Temecula Creek, which is a very well known and documented habitation area for the Luisefio/Pechanga people. The entire corridor of Hwy 79, with the width of that corridor extending from the Temecula Creek to Pauba Road to the north is a travel and trade route, as well as containing permanent habitation routes along the 1 See Executive Memorandum of April 29, 1994 on Government-to-Government Relations with Native American Tribal Governments and Executive Order of November 6,2000 on Consultation and Coordination with Indian Tribal Govenunents. 2 See California Public Resource Code ~5097.9 et seq. Pechanga comment letter to City ofTemecula Planning Department RE: Comments on Butterfield Ranch Shopping Center Tract Map Page 3 length of it. In addition to the habitation areas along this corridor, there are many burial and ceremonial areas. It is important to note that human remains have previously been found on an adjacent parcel to this tract, the exact nature of which will be disclosed to the City during consultation with the Tribe. This area which comprised the tract map is located in an' extremely culturally sensitive area to the Pechanga Tribe, and the cultural significance must be taken into account when evaluating project environmental impacts. The Pechanga Tribe's knowledge of the continuous occupation of the Luisefio people in this geographical area for thousands of years, through their stories and songs, are cultural evidence that subsurface sites may exist in this Project area. Therefore, the Pechanga Tribe requests that in the case of discovery of new or additional sites or resources, that the Lead Agency re-evaluate the Project impacts to cultural resources and adopt appropriate mitigation measures to address such. The Pechanga Tribe intends to assert its legal rights with respect to additional finds of significant sites or cultural resources which are of sacred and ceremonial significance to the Pechanga Tribe. Given that Luiseno cultural resources will likely be affected by the Project, the Pechanga Tribe must be allowed to be involved and participate with the Lead Agency and the Project Applicant in developing all monitoring and mitigation plans for the duration of the Project. Further, given the potential for archaeological resources within the Project area, it is the position of the Pechanga Tribe that Pechanga tribal monitors should be required to be present during all ground-disturbing activities conducted in connection with the project, including any archeological testing performed. It is further the position of the Pechanga Tribe that an Agreement regarding appropriate treatment of cultural resources be drafted and entered into. Further, the Pechanga Tribe believes that if human remains are discovered, State law would apply and the mitigation measures for the permit must account for this. According to the California Public Resources Code, S 5097.98, if Native American human remains are discovered, the Native American Heritage commission must name a "most likely descendant," who shall be consulted as to the appropriate disposition of the remains. Given the Project's location in Pechanga territory, the Pechanga Tribe intends to assert its right pursuant to California law with regard to any remains or items discovered in the course of this project. And, accordingly, the Pechanga Tribe further requests that the Lead Agency work with the Tribe to draft an agreement which would address any inadvertent discoveries of cultural resources, including human remains. Also, surveys and grading may reveal significant archaeological resources and sites which may be eligible for inclusion in the historic site register, and may contain human remains or sacred items. Therefore, we request that the Lead Agency commit to evaluating Project environmental impacts to any cultural sites that are discovered during archeological testing and grading, and to adopt appropriate mitigation for such sites, in consultation with the Pechanga Tribe. REOUESTED MITIGATION Pechanga comment letter to City of Temecula Planning Department RE: Comments on Butterfield Ranch Shopping Center Tract Map Page 4 The Tribe requests that appropriate assessment of the archeological and cultural resources on the Project property be evaluated to determine significant and appropriate treatment by a qualified archeologist in conjunction with the Pechanga Tribe. Any such testing should involve the Tribe, and all tests to determine impacts should be completed prior to Project approval. For the reasons above, the Pechanga Tribe requests the following mitigation measures be adopted at the present time. Upon completion of a thorough archeological assessment additional mitigation measures may be necessary. I. Prior to the issuance of grading permits, the Project ApplicantJDeveloper is required to enter into a Pre-Excavation Agreement with the Pechanga Band of Luiseiio Indians. This Agreement will address the treatment and disposition of cultural resources and human remains that may be uncovered during construction as well as provisions for tribal monitors. 2. Tribal monitors from the Pechanga Band of Luiseiio Indians shall be allowed to monitor all grading, excavation and ground-breaking activities within native soils in the Tribe's aboriginal territory, including further surveys, to be compensated by the Project ApplicantJDeveloper. The Pechanga Tribal monitors will have the authority to temporarily stop and redirect grading activities to evaluate the significance of any archaeological resources discovered on the property, in conjunction with the archeologist and the Lead Agency. 4. The landowner agrees to relinquish ownership of all cultural resources, including all Luiseiio sacred items, burial goods and all archeological artifacts that are found on the Project area to the Pechanga Band of Luiseiio Indians for proper treatment and disposition. 5. All sacred sites within the Project area are to be avoided and preserved. The Pechanga Tribe looks forward to working together with City of Temecula Planning Department, the Lead Agency and other interested agencies in protecting the invaluable Luiseiio cultural resources found in the Project area. If you have any questions, please do not hesitate to contact me at (951) 308-9295 or Laura Miranda at (951) 676-2768, Ext. 2137. Thank you for the opportunity to submit these comments. Sincerely, 1 it ~(jU{a E. 1JrufJ/;C' Stephanie Gordin Cultural Analyst