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Home My WebLink About1990-12-19; Planning Commission; Resolution 31500 e 1 2 3 4 5 6 i PLANNING COMMISSION RESOLUTION NO. 3150 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CAFWBAD, CALIFORNIA RECOMMENDING APPROVAL, OF A MITIGATED NEGATIVE DECLARATION FOR A MASTER PLAN I I AMENDMENT/LOCAL COASTAL PROGRAM i DEVELOPMENT PERMIT OVER PHASE I1 OF THE AVIARA AMENDMENT/MASTER TENTATIVE TRACT MAP/HILLSIDE MASTER PLAN. APPLICANT: AVIARA PHASE I1 I CASE NO.: MP-l77(B)/LCPA 90-5/CT 89-37/HDP 90-2 7 8 a duly noticed public hearing as prescribed by law to consider said request, and WHEREAS, the Planning Commission did on the 19th day of December, 1990, hold 9 WHEREAS, at said public hearing, upon hearing and considering all testimony and 10 I.2 considering any written comments received, the Planning Commission considered all factors 11 arguments, examining the initial study, analyzing the information submitted by staff, and relating to the Mitigated Negative Declaration, 13 I! NOW, THEREFORE, BE IT HEREBY RESOLVED by the Planning Commission as l4 11 follows: 15 16 A) That the foregoing recitations are true and correct. B) That based on the evidence presented at the public hearing, the Planning Commission 18 "ND", dated September 6, 1990, and "PII", dated August 27, 1990, attached hereto and made a part hereof, based on the following findings: 17 hereby recommends APPROVAL of the Mitigated Negative Declaration according to Exhibit I' /I Findings: I I 20 1. The initial study shows that there is no substantial evidence that the project may have a 21 significant impact on the environment provided that mitigating conditions of approval are complied with. 22 2. The streets are adequate in size to handle traffic generated by the proposed project. 23 3. The proposed project site has already been reviewed under Master Plan EIR 83-2(A) and 24 as designed, the project implements all recommended mitigation measures of said EIR 83- 25 26 27. 2(A). 4. The project will either preserve in open space or replace with comparable quality and acreage, the previously coastal deed restricted habitat areas. "." 28 0 0 Conditions: 1. Prior to the release of grading bonds for CI' 89-37, all geotechnical and soils corrective 1 2 m=ures identified in the Geotechnical Investigation of the property (KG, 1990) shall be required to be implemented. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 2. 3. 4. 5. All manufactured slopes (excluding revegetation slope area 10 within PA-28) as shown on Exhibits "1" - X, dated November 9,1990, shall be required to be landscaped consistent with the Habitat Enhancement Plan included within these same Exhibits. A detailed Habitat Enhancement Landscape and Irrigation Plan (which includes a timeline for implementation) shall be submitted and approved by the Planning Director prior to the issuance of grading permits. The Habitat F.nhancement Landscaping shall be required to be initiated immediately following rough grading of each of these graded areas. Prior to the issuance of a grading permit, a Habitat Enhancement Landscaping bond shall be required to be posted with the City. Prior to the revegetation of slope area 10 within Planning Area 28, this slope shall be required to be contoured and undulated through subsequent discretiow actions (tentative maps) subject to the approval of the Planning Director. Prior to the issuance of a grading permit, all "Give Back" areas (as shown on Attachment "A") and other project open space areas shall be requked to be placed under a deed restriction which prohibits any encroachment for development into those areas in Perpetuity. This project is approved subject to the condition that no project grading shall be permitted during the Black Tailed Gnatcatcher breeding season (March 1 - June 1). Any modifications to grading res~ctions shall be subject to approval of the City and be based on the prior approval of the California Coastal Commission in consultation with the Department of Fish and Game and U.S. Fish & Wildlife Service. All deed restricted habitat areas shall be required to be staked and flagged in the field by a certified biologist prior to the issuance of grading permits. All deed restricted areas shall be required to be clearly demarcated on all project grading plans. 19 i 6. All "Give Back" areas that are adjacent to Coastal Sage Scrub habitat shall be required to be fully landscaped with similar native species. Prior to the issuance of a grading permit, a landscape and irrigation plan for these areas shall be submitted for review by the Planning Director. 2o I 21 22 23 24 7. Prior to the recordation of the first final map, the applicant shall enter into a third party agreement with the City to contract with an environmental consultant, paid by the applicant, to provide a monitoring program for the mitigation measures required by the tentative map and environmental impact report. The program shall include specific monitoring activities, a reporting system, and criteria for evaluating the success of the mitigation measures. 25 26 ..... 27 28 PC RES0 NO. 3150 -2- 0 e 1 2 3 4 5 6 7 a 9 10 11 PASSED, APPROVED, AND ADOPTED at a regular meeting of the Planning ~O~ssion of the city Of Carlsbad, California, held on the 19th day of December, 1990, by the following vote, to wit: AYES: Chairperson Schramm, Commissioners: Schlehuber, Holmes, Erwin, Marcus & Hall. NOES: None. ABSENT: Commissioner McFadden. ABSTAIN: None. SHARON SCHRA", Chairperson CARLSBAD PLANNING COMMISSION ATTEST: l2 I1 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PLANNING DIRECTOR PC RES0 NO. 3150 -3- MITIGATED NEGATlVE DECLARATION PROJECT ADDRESS/LOCATION: The 247 acre project site is located north of Batiquitos Lagoon, south of Alga Road and immediately west of Aviara Phase I. PROEC'I' DESCRIPTION: (A) Master Plan Amendrnent/Local Coastal Program Amendment to; (1) mow Planning Area boundaries for Planning Area's 25, 26, 27 and 29, (2) change permitted product types from multi-family to single family within Planning Area 26 and Planning Area 30, (3) mow Master Plan development standards and design criteria within Planning Area's 25, 26, 27, 28, 29 and 30, and (4) reduce maximum dwelling unit potentials (from 569 DU's to 475 DU's) within Phase 11 of MP-177 while increasing acreage of natural open areas. (B.) A 247 acre/l 1 lot master tentative map for Phase It of Aviara Master Plan 177. (C.) Hillside Development Pennit. The City of Carlsbad has conducted an environmental review of the above described project pursuant to the Guidelines for Implementation of the California Environmental Quality Act and the Environmental Protection Ordinance of the City of Carlsbad. As a result of said review, a Mitigated Negative Declaration (declaration that the project will not have a significant impact on the environment) is hereby issued for the subject project. Justification for this action is on file in the Planning Department. A copy of the Mitigated Negative Declaration with supportive documents is on file in the Planning Department, 2075 Las Palmas Drive, Carlsbad, California 92009. Comments from the public are invited. Please submit comments in writing to the Planning Department within 30 days of date of issuance. \ Planning Director DATED: September 6,1990 CASE NO: MP-l77(A)/CT 89-37/HDP 90-2/LCPA 90-5 APPLICANT: AVIARA - PHASE I1 PUBLISH DATE: SEPTEMBER 6,1990 CDD:lh 2075 Las Palmas Orive - Carlsbad. California 920094859 - (61 9) 438-1 161 ENVIRONME I@ ..rL IMPACT ASSESSMENT FORM - & 11 (TO BE COMPLETED BY THE PLANNING DEPARTMENT) CASE NO. MP-177(B)/HDP 90-02/CT 89-37/LCPA 90-5 DATE: August 27, 1990 CKGROUND 1. CASE NAME: Aviara Phase I1 (MP-l77(B)/CT 89-37/HDP 90-02/LCPA 90-5 ?. APPLICANT: Aviara Land Associates Limited Partnership 3. ADDRESS AND PHONE NUMBER OF APPLICANT: 2011 Palomar Airport Road, Suite 206 Carlsbad, CA 92009 (619) 931-1190 . DATE EIA FORM PART I SUBMITTED: November 9, 1989 . PROJECT DESCRIPTION: A. Master Plan Amendment/Local Coastal Pronram Amendment to: (1 ) modify Planning Area boundaries for Planning Area's 25.26.27 and , (2) change permitted Droduct types from multi-family to single familv within Planning Area 26 and lnning Area 30, (3) modify Master Plan development standards and desim criteria within Planning Area's , 26, 27, 28. 29 and 30, and (4) reduce maximum dwelling unit potentials (from 569 DU's to 475 DU's) thin Phase 11 of MP-177 while increasinn acreages of natural oDen areas. A 247 acre/ll lot master tentative map for Phase I1 of Aviara Master Plan 177. Hillside Development Permit 'VIRONMENTAL IMPACTS ATE CEQA GUIDELINES, Chapter 3, Article 5, section 15063 requires that the City conduct an vironmental Impact Assessment to determine if a project may have a significant effect on the environment. e Environmental Impact Assessment appears in the following pages in the form of a checklist. This checklist :ntifies any physical, biological and human factors that might be impacted by the proposed project and )vides the City with information to use as the basis for deciding whether to prepare an Environmental pact Report or Negative Declaration. A Negative Declaration may be prepared if the City perceives no substantial evidence that the project or any of its aspects may cause a significant effect on the environment. On the checklist, "NO" will be checked to indicate this detennination. An EIR must be prepared if the City determines that there is substantial evidence that any aspect of the project may cause a sinnificant effect on the environment. The project may qualify for a Negative Declaration however, if adverse impacts are mitigated so that environmental effects can be deemed insianificant. - These findings are shown in the checklist under the headings 'YES-sig" and 'YES-insig" respectively. iiscussion of potential impacts and the proposed mitigation measures appears at the end of the form under SCUSSION OF ENVIRONMENTAL EVALUATION. Particular attention should be given to discussing tigation for impacts which would otherwise be determined sigmficant. 0 PHYSICAL ENVIRONMENT VILL THE PROPOSAL DIRECTLY OR INDIRECTLY: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. Result in unstable earth conditions or increase the exposure of people or property to geologic hazards? Appreciably change the topography or any unique physical features? Result in or be affected by erosion of soils either on or off the site? Result in changes in the deposition of beach river or stream or the bed of the ocean or any bay, inlet or lake? Result in substantial adverse effects on ambient air quality? Result in substantial changes in air movement? odor, moisture, or temperature? Substantially change the course or flow of water (marine, fresh or flood waters)? Affect the quantity or quality of surface water, ground water or public water supply? Substantially increase usage or cause depletion of any natural resources? Use substantial amounts of fuel or energy? Alter a significant archeological, paleontological or historical site, structure or object? sands, or modification of the channel of a -2- 1 YES (six) - - - - - - - - - YES (insig) X X - - X - - - - NO - - X X - - X X X X X X 9 e BIOLOGICAL, ENVIRONMENT THE PROPOSAL, DIRECTLY OR INDIRECTLY: ZS Affect the diversity of species, habitat or numbers of any species of plants (including trees, shrubs, grass, microflora and aquatic plants)? Introduce new species of plants into an area, or a barrier to the normal replenishment of existing species? Reduce the amount of acreage of any agricultural crop or affect prime, unique or other farmland of state or local importance? Affect the diversity of species, habitat or numbers of any species of animals (birds, land animals, all water dwelling organisms and insects? Introduce new species of animals into an area, or result in a barrier to the migration or movement of animals? HUMAN ENVIRONMENT L THE PROPOSAL DIRECTLY OR INDIRECTLY: Alter the present or planned land use of an area? Substantially affect public utilities, schools, police, fie, emergency or other public services? - - - - - E? - -3- %$I - - YES (msig) NO X X X X X NO X X HUMAN ENVlRONMENT WILL THE PROPOSAL DIRECTLY OR INDIRECTLY: 19. Result in the need for new or modified sewer systems, solid waste or hazardous waste control systems? 20. Increase existing noise levels? 21. Produce new light or glare? 22. Involve a significant risk of an explosion or the release of hazardous substances (including, but not limited to, oil, pesticides, chemicals or radiation)? 23. Substantially alter the density of the human population of an area? 24. Affect existing housing, or create a demand for additional housing? 25. Generate substantial additional traffic? 26. Affect existing parking facilities, or create a large demand for new parking? 27, Impact existing transportation systems or alter present patterns of circulation or movement of people and/or goods? 28. Alter waterborne, rail or air traffic? 29. Increase traffic hazards to motor vehicles, bicyclists or pedestrians? 30. Interfere with emergency response plans or emergency evacuation plans? 31. Obstruct any scenic vista or create an aesthetically offensive public view? 32. Affect the quality or quantity of existing recreational opportunities? -4- v as - - - - - - - E21 - - - - - - X NO X X X X X X X X X X X X x w 0 MANDATORY FINDINGS OF SIGNIFICANCE L THE PROPOSAL DIRECTLY OR INDIRECTLY: Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wild- life species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or en- dangered plant or animal, or eliminate important examples of the major periods of California history or prehistory. Does the project have the potential to achieve short-term, to the dis- advantage of long-term, environmental goals? (A short-term impact on the environment is one which occurs in a relatively brief, definitive period of time while long-term impacts will endure well into the future.) Does the project have the possible environmental effects which are in- dividually limited but cumulatively considerable? ("Cumulatively con- siderable" means that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? YES big) E$ NO X x X - - - x -5- w - >ISCUSSTON OF ENVIRONMENTAL EVALUATION :his project is a 247 acre Master Tentative Map (Aviara Phase 11) and Master Plan Amendment for Aviar; daster Plan 177. The project site is characterized by a north-south trending ridge and valley with maturc 2ucalyptus groves, coastal sage scrub and disturbed agricultural areas upon it. The project will entail th, xbdivision of the property into 11 parcels, and the grading of 158.9 acres of the site for the creation c naster residential pad areas and circulation corridors (ie. Batiquitos Drive, Kestrel Drive). Project specifi 2nvironmental impacts from future residential development upon the Phase 11 site will be evaluated 2 3pplications for development are processed. For this environmental analysis, staff conducted several field triF :o the subject property and reviewed the Pacific Rim Country Club and Resort Master Plan Environment: Lrnpact Report (EIR 83-2(A)) which already covered this property. In that: (1) the proposed project site ha already been reviewed under the Master Plan EIR 83-2(A), (2) as designed, the project implements 2 recommended mitigation measures of EIR 83-2(A), (3) the product type changes as proposed will t compatible with surrounding existing or future land uses, (4) the project will either preserve in open spa( or replace with comparable quality and acreage, the previously deed restricted coastal sage scrub habitat, ar (5) the project as proposed preserves an additional 16.7 acres of the project site in open space than original anticipated under MP-177, no environmental impacts are anticipated. There were no public cornmen received in response to the Notice for a Conditional Negative Declaration. Physical Environment 1. The existing site includes four ancient landslide areas located within the northern portion of tl property (Planning Area's 25 and 26). There are also alluvial and colluvial soils which are located ( site. Development of these areas shall require the implementation of corrective measures identified the Preliminary Geotechnical investigation (San Diego Soils, 1985) for the subject property. 2, Grading of the project site consistent with the proposed tentative map would require considerable ear movement 1,934,100 cubic yards cut/2,029,800 cubic yards fill. Potential visual effects associated wi this grading shall be mitigated through conformance with the design guidelines and developme standards of the City's Hillside Ordinance. Short term and long term visual impacts associated w project landform modification can be mitigated through full hydroseeding and landscaping manufactured slopes. 3. Drainage and erosion control facilities (desiltation basins, rip rap dissipators, and terrace drains) v be incorporated into the project to adequately reduce potential soil erosion impacts. The project sE also be conditioned to richly landscape all manufactured slopes. 4. Potential erosion impacts to Batiquitos Lagoon will be adequately mitigated as discussed in respo #3 above. 5. Construction emission and fugitive dust generation impacts associated with project grading considered short term and insignificant. Dust generation can be adequately controlled through water operations. As discussed in EIR 83-2(A), long term air quality impacts associated with fut development of housing upon this Phase I1 map area is considered significant. However, full mitigat of this regional impact shall require that dependence upon the automobile be reduced regionally ~ statewide. -6- 0 0 XJSSION OF ENVIRONMENTAL, EVALUATION (cont’d) In that no structural development is proposed at this time, impacts to air movement are not anticipated. Air quality impacts from dust generation can be adequately controlled through watering operations during project grading. This project will not change the course or flow of water as no streams are located in the immediate area and all drainage waters will ,be handled by proposed drainage facilities. Development of this project (tentative map grading and road construction) will create impervious surfaces which would reduce absorption rates and incrementally increase runoff velocities. However, to accommodate this increased runoff, drainage facilities will be incorporated into this project and future residential development upon the site, thereby mitigating this concern. Implementation of the proposed project will incrementally contribute to the depletion of fossil fuels during grading operations and other natural resources required for project roadways. This short term incremental impact is not regarded as significant. See #9 above. All identified archaeological, paleontological and historical sites identified in the Master Plan EIR (EIR 83-2(A)) have already been mitigated. The project site includes environmentally significant property which was placed under deed restriction by the California Coastal Commission upon approval of Master Plan 177. This proposal will encroach into 11.16 acres of the protected habitat including 3.98 acres of sage scrub (.45 acres dual criteria), 5.55 acres of Eucalyptus and 1.63 acres of disturbed land. However, as mitigation for this encroachment, the project applicant is proposing to give back as deed restricted open space 11.16 acres of habitat which is of higher quality including 5.75 acres of sage scrub, 3.54 acres of Eucalyptus and 1.87 acres of disturbed land. No significant impacts to the abovementioned coastal sage scrub habitat are anticipated in that project landscaping proposed adjacent to this habitat shall be required to be compatible and non-invasive. As stipulated in MP-177, conversion of agricultural lands shall be permitted upon payment of agricultural conversion fees. In accordance, the project applicant has already paid to the State Coastal Conservancy agricultural mitigation fees required for the development of the project site. As discussed in #12 above, the previously deed restricted coastal sage habitat (or comparable quality habitat) will be maintained in open space. Accordingly, no Significant impacts to habitat or species are anticipated. The project as proposed preserves in open space the majority of the previously deed restricted coastal sage scrub habitat. In addition, the project preserves in open space 16.7 additional acres than anticipated under MP-177. The addition of this open space in association with previously deed restricted open space will function to provide adequate corridors for the movement of animals throughout the project site. -7- w - DISCUSSION OF ENVIRONMENTAL EVALUATION (cont’d) 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. Development of this project will be consistent with the General Plan, Master Plan 177 (as amended and the Meilo I and East Batiquitos Lagoon LCP’s (as amended). The land use changes proposed wi be internally compatible as well as being compatible with adjacent uses. As discussed in the Zone 19 Local Facilities Management Plan, with the payment of all fees and tl- implementation of all improvement conditions (ie. upgrading of the Batiquitos sewer pump statio] construction of Alga Road and Batiquitos Drive), all public facilities and services will be available 1 meet the demands of all future developments proposed on the project site. Although the Master Tentative Map and Master Plan Amendment does not propose any actual site ( product development, any subsequent dwelling unit construction on site shall not be permitted unl the Batiquitos Sewer Pump Station is upgraded. Construction of the project (grading and road development) may result in short term insignifical construction noise impacts upon surrounding existing and proposed residences. Otherwise, the futul residential uses on the subject property will be acoustically compatible with surrounding existing ar future residential uses. At the time that future residences are constructed upon the subject propert traffic noise impacts from Alga Road shall be required to be mitigated. Since grading and road construction do not produce light and glare effects, no impacts are anticipate Mitigation of light and glare associated with street lighting can be mitigated through the use of lo sodium lighting. Grading of the project site and construction of associated roads is not anticipated to involve a1 significant risks of explosion or release of hazardous substances. Since no residential development is proposed at this time, no effect upon human population in the arc is anticipated. No residential development upon the project site is proposed at this time. Impacts of providing futu housing upon the site will be evaluated when development proposals are processed. Project construction traffic is not anticipated to be significant. No parking impacts associated with grading and road development upon the site are anticipated. No traffic impacts associated with grading and road development upon the site are anticipated. The project site is outside of the Airport Influence Area for Palomar Airport. No traffic hazard impacts to motor vehicles, bicyclists, or pedestrians are anticipated from grading a1 road development upon the project site. The project will not interfere with emergency response plans. -8- 0 0 XUSSION OF ENVIRONMENTAL EVALUATION (cont’d) . Grading of the subject property would result in a short-term significant but unavoidable visual impact. This impact can, however, be mitigated through the following mitigation measures: (1) all manufactured slopes shall be required to be fully hydroseeded and irrigated immediately following rough grading, and (2) all manufactured slopes shall be required to be undulated and contour graded consistent with the Hillside Development Ordinance. , As proposed, the project will have no impact on existing recreational opportunities. Implementation of this project will, however, ensure the preservation of 83.9 acres of natural open space areas. -9- m NALYSIS OF VIABLE ALTERNATIVES TO THE PROPOSED PROJECT SUCH AS: . a) Phased development of the project, b) alternate site designs, c) alternate scale of development, d) alternate uses for the site, e) development at sume future time rather than now, f) alternate sites for the proposed, and g) no project alternative. a) This project represents Phase I1 of Aviara Master Plan. In that there are major circulation corridor that need to be constructed to tie this phase together (ie. Batiquitos Drive, Kestrel Drive: processing as a single phase makes sense. It is important to note, however, that futur development of each of the six planning areas within this map will likely occur in six phases. b) The project as proposed is designed consistent with the Aviara Master Plan Planning Are conceptual site plans and the City‘s Hillside Development Ordinance. The project will also presen additional site acreage in natural open space than originally anticipated under the existing Mastc Plan. In summary, no alternate site designs would appear as environmentally superior. c) The potential scale (number of dwelling units) of this project will be reduced from 569 DU’s to 47 DU’s with the approval of this Master Plan Amendment, d) Any change of land use upon the subject property would necessitate a Master Plan Amendment ar! a General Plan Amendment. In that this project would result in the hture development of lo density residential (less than 2 DU/Acre), it is regarded as an environmentally preferab alternative. e) The project will result in the rough grading of Phase 11 (Planning Area’s 25-30) of Master Plan 17 Actual development within each of these neighborhoods will necessitate that separate applicatio: are processed and that public facilities are available concurrent with need. In accordance wi these requirements, this project will likely be developed in increments and over time. f) The project is proposed in a Master Plan area for which an EIR has already been certified (EIR 8 2 (A)). As discussed in this EIR, this site is regarded as the environmentally preferable one for r’ proposed project. g) The “no project” alternative is not in conformance with the General PlaWMaster Plan designatil for the property. Hence, it is not regarded as environmentally preferable. -1 0- -. 0 e :TERMINATION (To Be Completed By The Planning Department) On the basis of this initial evaluation: - I find the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. I - 1 find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because the mitigation measures described on an attached sheet have been added to the project. A Conditional Negative Declaration will be proposed. - I find the proposed project MAY have a signifkant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. 2”. . ‘‘7 :; . _’ ..? .> </ -. i ..) ;,/, J< -. 1 ,’ .,,’/ . - Y I Date Signature - ha, ’ /’ Planning Directo? ,J c:rvo IT MITIGATING MEASURES (IF APPLICABLE) Prior to the issuance of any building permits within any Planning Areas of CT 89-37, all geotechnical and soils corrective measures identified in the Geotechnical Investigation of the property (ICG, 1990) shall be required to be implemented. All manufactured slopes greater than 2’ in height shall be required to be fully hydroseeded and irrigated immediately following project rough grading. All manufactured slopes adjacent to coastal deed restricted habitat areas shall be required to be vegetated with similar native species. Prior to the issuance of a grading permit, a landscape and irrigation plan (which includes a time line for implementation) shall be submitted for review by the Planning Director. Prior to the issuance of a grading permit, all ”Give Back” areas shall be required to be placed under a deed restriction which prohibits any encroachment for development into those areas in perpetuity. This project is approved subject to the condition that no project grading shall be permitted during the Black Tailed Gnatcatcher breeding season (March 1 - June 1). All deed restricted habitat areas shall be required to be staked and flagged in the field by a certified biologist prior to the issuance of grading permits. All deed restricted areas shall be required to be clearly demarcated on all project grading plans. -11- a w APPLICANT CONCURRENCE WITH MITIGATING MEASURES THIS IS TO CERTIFY THAT I HAVE REVIEWED THE ABOVE MITIGATING MEASURES AND CONCUR WITH THE ADDITION OF THESE MEASURES TO THE PROJECT. 1 I?- Pptl~ jI HJ& Mature b(&$A LA.M/o 45JUCb DMrn 6 fwd* -1 2-