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HomeMy WebLinkAbout1980-02-19; City Council; 6177; Amend Planning Moratorium for General Planvc2 CITY OF CARLSBAD INITIAL AGENDA BILL NO. (j I 77 _ — DATE: FEBRUARY 19, 1980 _ _cty> Atty.V/^ DEPARTMENT: PLAN™ _ Cty. Mgr. SUBJECT: REQUEST TO AMEND PLANNING MORATORIUM FOR GENERAL PLAN ' AMENDMENTS STATEMENT OF THE MATTER ' ~~~~ Attached is a letter from Robert Ladwig of Rick Engineering requesting that the City Council direct staff to prepare an ordinance amendment to the Planning Moratorium to allow general plan amendments. Also attached is a brief history of the Planning Moratorium prepared by staff. EXHIBITS Letter from Mr. Ladwig, dated 12/14/79 / :4emo from James Hagaman, dated 2/19/80 Memo from James Hagaman, dated 4/11/78 „ City Council Minutes of 4/18/78 Letter from Roy Ward, dated 1/16/79 City Council Minutes of 1/16/79 Letter from Cordova Engineering Corp. dated January 24, 1980. RECOMMENDATION Receive and file. Council Action: 2-19-80 Council continued the matter to the meeting of February 20, 1980, 2-20-80 Council continued the matter to the meeting of February 26, 1980. RICK ENGINEERING COMPANY WttttSK RECEIVED 3088 PIO PICO DR. • SUITE 202 • CARLSBAD, CA 92008 P.O. BOX 1129 • PHONE • AREA CODE 714 • 729-4987 DEC 141979 December 14, 1979 OJY OF CARLSBADPlanning Department Mayor Ron Packard CITY COUNCIL CITY OF CARLSBAD 1200 Elm Avenue Carlsbad, CA 92008 RE: GENERAL PLAN AMENDMENTS Dear Mayor Packard: We would like to request that the Council consider directing the Staff and the Planning Commission to prepare the necessary lan- guage to amend the current planning moratorium to allow for the processing of general plan amendments. You have recently amended Chapter 21.49 of your Municipal Code to allow for the processing of applications for revisions to approve Master Plans in the Planned Community Zone. We are currently working on several of these Master Plans at this time, and find that there is a possibility that the changes to the Master Plan could require minor amendments to the General Plan. In addition to potential changes to the General Plan in the Planned Community Zone, there are also needs to amend the General Plan in the non-residential reserve areas of the City. There are currently applications in process in these areas around the air- port. By allowing General Plan amendments to proceed, City Staff would have the ability to enlarge the planning areas they are current- ly working on. We have also had requests to consider General Plan Amendments, in other areas of the City that are not in the Planned Community Zone, or in the non-residential areas. Because a change in the General Plan does not in itself create the need for any sewer service or public facilities, we hereby request the Council direct the Staff to pre- pare the necessary reports to present to the Commission and to the Council for your consideration to amend the Planning Moratorium to al- low for General Plan Amendments. Thank you for your consideration of this request. Sincerely, Robert C. Ladwig RCL:re cc: Wayne Dernetz, Jim Hagaman MEMORANDUM February 19, 1980 Frank Aleshire, City Manager James C. Hagaman, Planning Director GENERAL PLAN AMENDMENT (GPA), PLANNING MORATORIUM Mr. Robert Ladwig has requested that the Planning Moratorium be amended to permit General Plan Amendments as an exception. The request is two-fold. First, he is concerned that a change in a Master Plan would require an amendment to the General Plan. Although there is a moratorium exception to permit Master Plan amendments, there is no exception for General Plan Amendments which may be required as a result of the master plan revision. The second request is simply to make all General Plan Amendments an exception to the planning moratorium. The Planning moratorium does contain exceptions presently, but they are limited to on-going projects, public projects, projects not requiring City sewer services, or revisions to existing projects when no additional sewer demand will be created. This request of Mr. Ladwig differs in that a General Plan Amendment could increase the demand for sewer service by increasing the integrity of development on property. This is especially true in the NRR where there is a great deal of interest in general planning. Staff indicated the reasons for a strict moratorium in a memo dated April 11, 1978, during the discussion on the planning moratorium. The City Council agreed then and at later amend- ments to the moratorium by only providing exceptions that would not create more sewer demand. Mr. Ladwig is correct that amending a master plan could affect the general plan. Generally existing master plans are consis- tent with the General Plan. However if a master plan was amended it could then become inconsistent with the General Plan, Current policy is that if additional applications are necessary to complete permitted applications, staff asks the City Council to permit such additional requests. This is the method used to initiate the Lake Calavera Hills General Plan Amendments, which was necessitated by the modifications to the Lake Calavera Hills Master Plan. The Master Plan was initiated before the moratorium, and the General Plan Amendment afterward. Staff has no recommendation or suggests opposition to allowing general plan amendments throughout the community provided after the City Council adopts a policy on the master plan satellite treatment plants and the Encina plant expansion. Once the City Council is satisfied with a process to provide future sewer service is adopted or approved, little reason not to permit advanced plans such as general plan amendments and some specific plans. Recommendation Staff recommends that the planning moratorium not be amended and the present policy of permitting additional application if they are necessary to complete an accepted application. BP:ar DATE: APRIL 11, 1978 TO: CITY MANAGER FROM: Planning Director SUBJECT: PLANNING MORATORIUM - SECOND PHASE SEWER ALLOCATION SYSTEM .* BACKGROUND The planning moratorium was originally established by the City Council along with a moratorium on the issuance of building permits last • April 26, 1977, and subsequently extended on August 25, 1977. The planning moratorium will expire on April 26, 1978 unless the City Council takes an action to partially or fully extend the moratorium. City Council, prior to adopting the moratorium, was presented with a report which indicated that the City was approaching its capacity limits in the Encina Sewer Treatment Plant. The Council adopted two moratoriums prohibiting both the issuance of building permits unless sewer was available and prohibiting the acceptance of applications for new planning approvals. The Council subsequently adopted a First Phase Sewer Allocation System to essentially take care of those persons, known or unknownj who were .affected by the sewer moratorium while the}' were in the process of obtaining approvals for developments at that time. The planning moratorium as it now stands, essentially prohibits all processing arid approvals of discretionary entitlements within the City with'the exception of those areas served by San Marcos and Leucadia County Water Districts with specified exceptions, i.e., previous legal commitment to Plaza Camino Real Shopping Center, annexation of Palomar Airport, approved alternate sewer system, approvals which are determined not to increase sewer demand, and rcore recently, zone change requests. A Council Committee was appointed, and after working with City staff, developed the First Phase Sewer Allocation System which allocated the City's first sewer in December, 1977. A subsequent revision to the First Phase Sewer Allocation System allocated sewer in April, 1978. During the deliberations on the First Phase Sewer Allocation System meetings and subsequent Council meetings, staff was directed to com- mence preparation of a Second Phase Allocation System. The staff in their research on .Second Phase Sewer Allocation System has evaluated the entire General Plan and Zoning Ordinance as well as the current development processes in light of the reality that there, in all probability, will not be sufficient sewer available in the foreseeable future to meet demands. Staff work is continuing on this Second Phase Sewer System but as yet is not completed. The planning moratorium, which is to expire on April 26, as previously stated, can under the State Planning Act be extended for one additional year. Staff has taken the steps necessary to notice this hearing to consider the matter for the City Council meeting of April 18, 1978. Page 2 April 11, 1978 Subject: Planning Moratorium - Second Phase Sewer Allocation System DISCUSSION As the staff views the planning moratorium, there are several possible directions available for the City at this time. The directions are a matter of policy and should be considered as such and weighted as a matter of possible effects on the future activities of the City. The following discussion will explore some of those effects to assist the Council in their deliberations on this matter, The concern of what effect the total lifting of the planning moratorium will have on the City operation sections responsible for processing planning matters is substantially reduced over the last month. New employees have been and are being hired to fill vacancies. So, although there may be a rush of applications, there is now available staff in the Planning Department. A substantial amount of activity in the Current Planning Section is involved in sewer allocation explanations to land owners, citizens and interested participants in future allocations, processing applications on regular basis for those projects in the Leucadia and San Marcos County Water Districts and working on some of the various projects which have been backlogged in the department over a period of time when staff was not available. Based on the lack of sev;age capacity and on research into this matter with other cities and their problems with planning and/or sewer moratoriums, we have concluded that it would not be reasonable to recommend that the planning process continue on an uninterrupted basis. These conclusions were developed in general by independent research of the City Attorney, Public Works Administrator, Planning Director, and the City Manager. In summary, it is our opinion that to allow the planning process to continue, knowing that due to a lack of sewer capacity the project might not be able to be built, would only expose the City to additional pressures and possible legal liability. This was a common finding in other cities in similar situations. Based on this, it is the staff's position that the planning moratorium, as it was originally adopted, be extended until the Second Phase Sewer Allocation System is fully developed and implemented. Some of the specific arguments for this position are as follows: 1. If the moratorium is terminated and new applications are accepted by the City, a false sense of optimism may be created for those people applying where it possibly should not exist, since there is little or no guarantee they will be able to obtain sewer for their particular project. 2. 'By opening the permit process, we essentially are encouraging the applicants to spend large sums of money on their applications without any established protection of a return on that expenditure if the project is approved. e 3 APril 11 r 1978 Subject: Planning Moratorium - Second Phase Sewer Allocation System 3, It is argued that valuable staff resources will be misused in handling new applications v.?ithout knowledge of any capacity being available. 4. It has been pointed out that there will be a tendency for all applications to be constantly amended or changed to meet future City policies in terms of new proposed sewer allocation programs or a growth management program. This will tend to again load the processing system on a regular bcisis as new allocation systems are developed. « Council discussion in the past has indicated that there i-s some senti.rnent for lifting the planning moratorium, or at least lifting some portions of it. Although we have not had an opportunity to discuss this at length with the City Council, our impression was that the primary Council concern, was that the inability of a person to receive discretionary planning approvals from the Cityf prevented them from becoming eligible for sewer capacity. The staff has concluded that the City should not continue to limit access to available sewer in allocation systems to those persons who already have planning approvals as was done in the First Phase Sever Allocation. System. While it was appropriate in. the First Phase Sewer /Allocation System to limit access since the Council efforts were to provide immediate relief to those persons that had been caught in the pipeline by the moratorium, that has essentially now been accomplishod. In the future however, it is apparent to the.staff there are simply too many individuals who are in a "Catch 22" situation. For instance, a person cannot obtain a final map without sewer and at the same time, the person cannot apply .for a sewer application without a final map approval. That situation now must be properly addressed in the Second Phase Sewer Allocation System in order to allow people to first apply for a sewer application and then once having received it, proceed through an orderly planning process. "* The First Phase Sewer Allocation System denied some individuals a chance to obtain a share of the City's available sewer capacity, and denied the City possible benefits of projects which might be desirable but which had not yet been approved. Staff, in order to resolve the above dilemma within the legal constrains, recommends that an individual be allowed to apply for sewer allocation prior to obtaining the required planning approvals. The successful applicant would then be given adequate time to complete any necessary planning approvals. The details of the process will be worked out in the Second Phase Sewer Allocation System. In order to accomplish this, it is important that the planning moratorium be maintained. This conclusion contains the most recent qe. 4 W ,pril -1-1* 1978 subject: Planning Moratorium - Second Phase Sewer Allocation System knowledge available on the subject as well as your staff's best judgment. We feel that the Second Phase Sewer Allocation System should consider these three elements of change in our land use processes. 1. A General Plan Amendment 2. A Zone Code Amendment 3. Adoption of a Second Phase Sewer Allocation System The General Plan Amendment An amendment to the General Plan would reflect the reality of a lack of sewer capacity and indicate that all land use approvals and develop- ments contemplated by the plan were conditioned by arid subject to pro- vision of sewer service, the availability of which would be determined in accordance with such an allocation plan and/or growth management plan as the Council might develop. The General Plan which details how our community will develop must reflect the lack, of capacity we are experiencing so our planning and the developers' expectations will reflect the reality of the situation. The Zone Code Amendment . The zone code amendment would carry forward the General Plan- qualifi- cation by amending into the zoning code, a qualification on all the City's zones. That qualification would essentially indicate that in addition to the development standards contained within the zone, it is not possible to build until a sewer permit is obtained pursuant to an adopted sewer allocation system. Second Phase Sewer Allocation System The Second Phase Sewer Allocation System would be substantially different from the First Phase Sewer Allocation System. The allocation system would be the first step in processing a City development. With- out a sewer allocation permit, it would not be possible to further process developmental approvals. The system would be much simpler to administer than the First Phase Allocation System that we have now experienced and would allow the Council to make specific judgments on sewer allocations at the time sewer became available. The Council would consider how to allocate available sewer into various land use categories and under what qualifications the sewer would be allocated. Such qualifications as no expenditure of public funds or limiting the number of permits for any one individual and/or project during a given year, providing sewer in only certain areas of town in order to accomplish certain community goals, would tend to limit those applying. Depending on availability of sewer, allocation could be made once or more times a year as Council considers appropriate. Once the individual qualifies in obtaining a sewer allocation, a reasonable time to secure all planning approvals would be allowed. If the approvals are not obtained within that time (under AB 884 not over one year), the sewer capacity could go back into the City's original reserve or go to the next individual in line, whichever the Council considers appropriate. The criteria 5 . -W ' ' • & 11, 1978 . Planning Moratorium - Second Phase Sewer Allocation System /contained in the First Phase Sewer Allocation System could be modified and used. The skeletal outline of the points above describing the process could take care of all owner - developer initiated projects, however, City initiated projects such as General Plan Amendments, Agua Hedionda Lagoon plans and certain annexation could be allowed to process once the Council determined that in doing so, the require-* inents of the Public Facilities Element of the General Plan are met. STAFF CONCLUSION The staff has concluded that in light of the current and foreseeable sewer situation, a new approach by City Council should be explored. Council cannot find that sewer will be available when, in fact, it is not. We have concluded that the following steps should be taken by the City Council: 1. Extend the planning moratorium. 2. Amend the City's General Plan, Zoning Ordinance to reflect the current sewer situation and develop a Second Phase Sewer Allocation System. If the City Council disagrees with these staff conclusions and wishes to make the determination not to extend the moratorium, it will be necessary to amend the Public Facilities Element of the General Plan in order to approve developmental projects. JCH:ldg 41] Mayor Packard ticked if anyone wished to speak on the matter and- declared the public hearic-q open. Since no one shed to speak, the publi earjfig was closed at ti:01 P.M. Staff suggested the matter of roofs be coj by Council on a policy basis for all coi rather than project by project. dered ruction Councilman Skotnicki questioned 8 in that they appeared to be rep City Attorney responded indicati conditions could be combined i 3 and t i o u s. The those two Council directed the City AU^-ney to prepare necessary documents approvals CT 77-14 as per Planning Commission Resolj^ion No. 1437 as modified in the Memorandan to the City Manager dated March 24, 1978 aj^Fthe City Attorney's Memorandum dated ApriJ^/, 1978. the staff toBy minute motion, JPunci1 instructed research and devjppp a report on the advisability of requiring fTJ(F retardant roofs for multiple- family dwel1in^runits in areas where brush is a factor. 22. AGEN NUISANCE WESELO! BILL #5390 - Supplement #2 - PUBLIC TO E~XIST AT 5335 PAS'EO DEL NORTE IEVROLET SIG.N. equested the matter be continued to the meet ing of June 6, 1978. fncil concurred with the request and continued matter to the June 6, 1978, regular meeting. 23. AGENDA BILL #5294 - Supplement #3 - PLANNING MORATORIUM - SECOND PHASE: SEWER ALLOCATION SYSTEM The Planning Director gave .a staff report on the matter outlining the recommendations of staff to extend the Planning Moratorium, amend the City's General Plan and amend the City's Zoning Ordi- nance. ">''"~ Mayor Packard on the matter open. asked if anyone wished to be heard and declared the public hearing Mr. Lyle Gabrielson of Rick Engineering, 5620 Friar Road, San Diego, addressed Council on behal of Carrillo Ranch Properties. He requested Carrillo Ranch Properties be allowed to process their Master Plan Amendment which would bring them in conformance with the General Plan. • Motion Ayes Motion Ayes M o t i o n Ayes C:- 4 _ 18, 1978 106] Mr. Robert Small, 545 Mission Valley West, San Diego, addressed Council on behalf of Pacific Point Development, He questioned when the Second Phase of the Sewer Allocation System would be presented to Council and questioned the possibili of using other methods of sewage disposal such as a water reclamation plant. Mr. Ron Roberts of SGPA Planning representing Hughes Investments, Carlsbad Plaza, addressed Counci the staff report which suggests for sewer prior to proceeding th processes. He expressed the fee ing sewer permits would be diffi changes occur to a project as it the planning procedures. and Architecture developers of 1 . He referenced a developer apply rough planning ling that allocat- cult in that many processes through Since no one else wished to speak, the Mayor closejd the public hearing at 8:30-P.M. • • Staff indicated developers have a basic concept or idea and plans for a proposed development prio to making application to the City. Therefore, it was determined that it would be feasible to issue sewer permits first. •Council questioned if any applications had been received for zone changes that would be caught in process in that, zone changes would no longer be allowed. Staff responded in the negative. The following Ordinance was adopted by title only ORDINANCE NO. 7053:EXTENDING INTERIM ORDINANCE 7048, AS" AMENDED BY INTERIM ORDINANCE NO. 7043 BY ORDINANCE NO. 7050, AS AMENDED BY . 7051 TO CONTINUE THE PLANNING MORA- THE UNAVAILABILITY OF SEWER SERVICE ORDINANCE NO. 7052. Attorney and staff were instruct necessary documents to amend NO AS EXTENDED ORDINANCE NO. TORIUM DUE TO AND REPEALING Further, the City ed to prepare the the City's General Plan and Zoning Ordinance to reflect the current sewer, situation. By minute motion* Council instructed the ad hoc sewer committee consisting of Mayor Packard and Councilwoman Casler to continue through Phase II Mayor Packard relinquished the Chair to Vice- Mayor Skotnicki for" the next item in that his office is located in the proposed district. 24. AGEND/lLL_#53J_4_=_Supj3lJeni,ent ^^ R POSED Motion ,Ayes Motion Ayes • X (X I January 16, 1979 Mayor Ron Packard City of Carlsbad 1200 Elm St. Carlsbad, CA. 92008 Re: PLANNING MORATORIUM Dear Mayor Packard: I would like to ask the City Council to reconsider the proposed Planning Moratorium (ZCA-103) on the following grounds: 1. The City Staff does not determine what precise uses of lands within the General Plan land use criteria until after a land owner or devel- oper provides preliminary planning information and/or proposals. 2. Without opportunity to submit proposals to Staff for their review and comment, NO forward planning is taking place through city channels for the City of Carlsbad. 3. With the normal time frames required for review of proposed projects, one can count on the maximum time lapse of 1 year to development proposal in the City of Carlsbad. process 4.In my opinion and that of other responsible developers, the right to submit proposals to the city for Staff review and comment should be going on in spite of the Sewer Moratorium. A tremendous gap is being created in the planning of specific uses and projects which will, in my view, cause an even more critical, costly and time consuming condition when sewer capacity is available, by forcing staff to handle great quantities of submissions which will have back-logged against the dam of the Sewer/Building Moratorium. The result could be inadequate staff to handle i Ai^irr>Ai AI7ETOA un i c 3088 Pio Pico Dr., Suite 201 • Carlsbad, Ca. 92008 LAKE CALAVERA HILLS 4321 Birch Street - Newport Beach, Ca. 92660 (714) 729-4912 (714) 549-2988 Mayor Ron Packard January 16, 1979 Page 2 Re: Planning Moratorium the thrust, inadequate review by Staff under pressures, lack of forward planning to accommodate the need for added public facilities, and incomplete, late knowledge of what public facilities should be anticipated. There is no need to grant entitlements at this time or any time during the extent of the moratorium. To restrict submission of proposed development which would give the city staff greater perception of anticipated demands of public facilities is short sighted. It's akin to trying to hide the problem under the bushel basket of the moratorium. Thank you for considering this matter. i'f;:"''''. Very tr^ly yours, $.i''' ->. VT*^«'i Roy J/WaTd General Partner RJW:paf CITY of CARLSBAD COUNCILMAN -3- January 16, 1979 11. AB #5010 - Supplement #3 - RESURFACING 0F_VAR~IOUS CITY STREETS FISCAL YEAR 1 976- 1 </l 1 CONTRACT NO. 1039. Council adopted the following Resoluti RESOLUTION NO. 5653 APPROVING AGREEMENT "BETWEEN THE CITY OF AND SOUTH COAST ASPHALT PRODUj INC. FOR A COMPROMISE SETTLE] MUTUAL RELEASE AND AUTHORIZ, TO EXECUTE SAID AGREEMENT. RLSBAD S CO. , NT AND THE MAYOR Council authorized Change Ord/r No. 1 deleting the chip seal portions of \.\\t contract, accepted the balance of the^/ork as completed .and, conditioned upon sati/Faction of the term of the settlement agreeme/t, directed the City Clerk to record the Notice of Completion and release bonds at approp/iate time 12. AB #5703 - Suppl/ient #1 - REVISED TRAVEL POLICY. Council approved tire Travel Policy as revised. ITEMS REMOVED FW THE CONSENT CALENDAR: 13. FOR AB #5725 /GIFT TO THE CITY OF CARLSBAD PARAMEDIC 'IT Council man JTnear stated he had requested this item removjfd from the Consent Calendar in order to s^tate that items of this nature shoul not be placed on the Consent Calendar so that proper Recognition could be given by the Council^ to the donor. Council directed staff to prepare an appropriate letter of appreciation to Joseph Tre/otola on behalf of the City Council and ad/pted the following Resolution: RESOLUTION NO. 5654 GIFT OF MONEY THE PARAMEDIC TO BE FUND. ACCEPTING A DEPOSITED \\ ORDINANCES FOR ADOPTION: 14. AB #5711 - PLANNING MORATORIUM- ZCA-103 CITY OF CARLSBAD. Mayor Packard stated that Roy Ward had requested the opportunity to address Council on this matter. Roy Ward, 3088 Pio Pico Drive, Carlsbad, CA read his letter of January 16, 1979 directed to Mayor Packard which expressed his feeling that adoption of the subject Ordinance would preclude any advanced planning by the City.' ' ' Motion Ayes CITY CARLSBAD » -4- Oanuary 16, 1979 Following brief discussion, Council adopted the following Ordinance: ORDINANCE NO. 9518 AMENDING TITLE * 20 AND TITLE 21 OF THE CARLSBAD MUNICIPAL CODE BY THE ADDITION OF CHAPTER 21.49 TO IMPOSE A MORATORIUM ON DEVELOPMENTAL APPROVALS .IN THE CITY OF CARLSBAD DUE TO THE UNAVAIL- ABILITY OF SEWER SERVICE SUBJECT TO CERTAIN EXCEPTIONS. 15. AB #5715 - REVISION OF MUNICIPAL CODE/- BICYCLE LICENSING. Council adopted the following Ordinance Motion Ayes ORDINANCE NO. 3111 10, CHAPTER 10.56 MUNICIPAL CODE BY SECTIONS 10.56.060 INCLUSIVE, TO REVISE THE REGU AMENDING TITL1 OF THE CARLSBAJ THE AMENDMENT, THROUGH 10.5f.100 TIONS Motion Ayes AND FEES FOR LICENSING BICYCI REDEVELOPMENT AGENCY: Council adjourned to at 6:29 P.M. the Redewlo'pment Agency Council reconvened at .6:34,^/ith all members present. HOUSING AUTHORITY: Council adjourned to at 6:35 P.M. Housing Authority Council reconvened a^6:43, with all members present. DEPARTMENTAL & CITjf MANAGER REPORTS: PLANNING: 16. AB #5726 -/PROPOSED CONDOMINIUM DEVELOPMENT OF^LA COSTA. Council recoJFnzed Dale Naegle, architect, of 2210 Avejfda de la Playa, La Oolla, CA who exprespld his feeling that the recent condominiiM ordinance should be modified to provide for fewer parking spaces and storage JFreas and utilities metered on a pro-ratJTd basis for condominiums designed for arm oriented toward the elderly, retired, .singlrs and vacationers Coujfcil discussion reflected their concern that any such modification would create adouble standard, but indicated their concern that some flexibility be allowed. ;.C> CO*J)OVA ENGINEERING oORP. Consulting • Civil Engineering • Planning • Surveying 8240 Parkway Drive, Suite 204 La Mesa, California 92041 Tel: (714) 464-8288 RECEIVED January 1980 ...,<• 9i980 P/TY or CARLSCAD Engineering Department City Council City of Carlsbad 1200 Elm Avenue Carlsbad, CA 92008 Regarding: Tootsie "K" Project Gentlemen: The owners of the Tootsie "K" Ranch property are proposing to develop the property by constructing sewer mains and utilizing the Lake Calavera sewage treatment plant. We have requested permission from the staff to file the Tentative Map and related exhibits but were informed that they would not accept Tentative Maps for filing until the plant has been completed and is in operation, which should be in July. (6 months) We respectfully request that your body allow us to file our Tentative Map and related exhibits for processing. It will take at least six months before the necessary approvals can be obtained for the Tentative Map and an additional six months to a year before the Final Map could be ready for recording. Your consideration in this matter is appreciated. rohn D. Goddard JDG:sh Owners: We approve this request Sunny Creek Associates