HomeMy WebLinkAbout2.0 BOCC Staff Report 08.04.2008TYPE OF REVIEW
APPLICANT
LOCATION
BOCC 08/04/08
DD
PROJECT INFORMATION AND STAFF COMMENTS
Special Use Permit for "Processing and
Material Handling of Natural Resources" for
installation of a Service Pad/ Compressor
Booster Station
Chevron USA, Inc
The subject property is located approximately
2 miles from the end of CR 211, northwest of
Debeque
SITE INFORMATION 4.1 acres of approximately 54,000 acres
EXISTING ZONING / ADJACENT ZONING Resource Lands (Gentle Slopes and Lower
Valley Floor)
I. DESCRIPTION OF THE PROPOSAL
The Building & Planning Department received a Special Use Permit (SUP) application for
"Processing and Material Handling of Natural Resource" for the installation of two booster
compressors and related communication system on an existing well pad located atop a 54,000 -acre
property owned by Chevron USA, Inc. The site is located beyond the end of County Road 211, north
of Debeque. The location of the approximate 4 -acre facility is 1.4 miles beyond the private gate at
the end of CR 211.
The Applicant requests approval from the Board for installation of a Service Pad / Booster
Compressor Station and an associated communications system. The proposed facility will make
use of an existing well pad (Skinner Ridge 598-25-4) and an additional 1.4 acres of previously
undisturbed ground for the
project. Available space on the
existing pad will also be used
for `frac' equipment and
supplies.
By adding two Caterpillar G3516
LE combination compressor /
generators, two adjacent well
pads under construction can
transfer natural gas to the
Central Production Facility.
Construction Air Permits for the
two compressors were
approved by the CDPHE on
January 29, 2008. Approval of
a renewed storm water permit
took place in August, 2007.
Chevron USA Booster Compressor Station
BOCC– 08/04/2008 Page 2
II. BACKGROUND
Referral to Planning Commission
Staff brought the application to the attention of the BOCC to determine if a referral to the Planning
Commission was necessary. The BOCC did not refer the application to the Planning Commission.
III. SITE DESCRIPTION
The proposed site where the Compressor is located is situated on flat stream basin land bordering
Tom Creek, northeast of the confluence of Tom Creek and Clear Creek. The Compressor is located
on approximately 4 acres of a 54,000 -acre parcel owned by Chevron USA. The area where the
Compressors are to be located is surrounded by steep slopes and canyon terrain. Dense, mature
riparian vegetation exists along the creeks as they pass through the area.
1111111►4i 0:0111l17PAiwtomivi "
Muni! 11.111 1Ifidainre A` ' r�
pan" WI IrditWIP.11."11•41111171FilkirsiZr.FIVAfgaMMVOCIFAMprin
Iftitamalik av!vIl�,. IMI
tit
Tom Creek, looking NM;,;,�A �' 1;�,`i r-.—
l il III
A. b� V INRs r ,
,,I,ii.' �` '� 'fig' 4
1
(below) 'Hex Rig',
(right) Aerial
oblique looking S,
arrow indicates
location of 'Flex
Rig', compressor
booster station on
Tom Creek
wren - Control Production foo lity
Chevron USA Booster Compressor Station
BOCC— 08/04/2008 Page 3
WELL 5RE WELL SITE
09840YATN E -2,
I BOOSTER 1 AREA OP
• ,% iCOMPREssoR ECOSTER
L _.-I PARCEL CQMPRfiSSOR
I POS. 3 mammy. , WELL SITE
L , .._.....1 CLEAR tl98 2S 5V
_ CROCK RD.
:wax ant ~, , iCR•211j WELL R
s% -as WITH
BOOSTER .1..,--1
POS. 2 TQM CREEK R0.
t p_NpkESSOk _ L CENTRO.
. • ,PRODUGTICW
E+Dt1NoARYWITT-I i FACILITY CCM')
COLORADO ",,_ _ I� �1 1 .e
NATURE
RANCH
snipe Pad
-----.fit.-b
iiwe1H CampewaSuobn
CU-CRAWu
1t,uRE • 1 L 9WE L SITE
RANCH &O4 ID RY .
APPROX.4.00tT
rROM OFF
8
St11NEk
RFJC>r -�
r11'!ER \ l
ROSE
HOU$EON r - ---
C1EvRON
PROPERTY 2 \ CLEAR
CREEK RD.
jCR•2I1 j
CLEAR
CREEK
ROUSE
CNEWTON
PROPERTY
Detail of well Pad site
and location for compressors
r7-1 - NON-RESIDENTIAL BUILDING
- HOUSE OR MOBILE HOME
NSA- NOISE SENSITIVE AREA
4� - MEASUREMENT POSITION
-.] - WELL SITE
APPROXIMATE SCALE IN FEET
0 2700 5400 10800
D81ER
RIDGE
SHINER
RIDGE '-'so-
OLEAR
CREEK
CLEAR
ROAN) CREEK RD.
CREEK RD. r CCI.211J
CCR -2411
\.—
XWIi OY
OTHER p>r_
" . CHAPEL ~"',,.t'
HQMMs --Y-."
ROAN , ROM)
CREEK ! _ -CREEK RD
CCR -2411
C10 r
RESIDENCES
NOT ON
CHEYRCM
PROPERTY
CLEAR
K.
\ CREEK
TREES
Chevron USA Booster Compressor Station
BOCC— 08/04/2008 Page 4
IV. ZONING & ADJACENT USES
The subject property is zoned Resource Lands (Gentle Slopes and Lower Valley Floor). The type of
use requested falls under the definition of "Processing and Material Handling of Natural Resources"
which are contemplated as special uses in the Resource Lands (Gentle Slopes and Lower Valley
Floor) zone district.
The site totals approximately 4.1 acres in size, a portion of a 54,000 acre property owned by
Chevron USA. Adjacent lands under private and Federal ownership (BLM) demonstrate uses
including rangeland grazing, farming, and resource extraction (natural gas drilling).
V. AUTHORITY & APPLICABILITY
Pursuant to Section 9.03.04 of the Zoning Resolution, an application for a Special Use Permit shall
be approved or denied by the Board of County Commissioners after holding a public hearing
thereon in conformance with all provisions of the Zoning Resolution.
VI. REVIEW CRITERIA FOR SPECIAL USE PERMITS (SECTION 5:03)
Pursuant to Section 5.03, as listed under the Zone District Regulations, special uses shall conform
to all requirements listed there under and elsewhere in the Zoning Resolution, as well as the
following standards:
1. Utilities adequate to provide water and sanitation service based on accepted
engineering standards and approved by the Board of County Commissioners shall either be
in place or shall be constructed in conjunction with the proposed use.
Response
The compressor station is described as an unmanned facility. The traffic impact section of the
application, states that "no full-time employees are located on-site in relation to this operation.
The compressors are monitored remotely from Chevron USA's Grand Junction office." No water
or sanitation services are necessary for the proposed facility; any transient need can be met by
existing facilities already permitted nearby.
2. Street improvements adequate to accommodate traffic volume generated by the
proposed use and to provide safe, convenient access to the use shall either be in place or
shall be constructed in conjunction with the proposed use.
Response
The application states that during construction the Compressor is expected to generate an
average of 5 automobile trips and 1-2 tractor trailer trips per day into and out of the facility. All of
the truck travel will be traveling on private roads constructed by the industry or from Debeque on
CR 211. After construction there will be minimal traffic generated by the operation; its operation
will be managed for the most part through the revised communication system from the office in
Grand Junction.
Chevron USA Booster Compressor Station
BOCC— 08/04/2008 Page 5
The road to the Compressor site is an existing road that meets the County's standards and the
County does not foresee a major increase in traffic flow after the construction period and the
Compressor is online. No improvements to CR 211 are necessary as a result of this Compressor
expansion. Because this proposed facility is the re -use of an existing well pad, is on a road
vacated from the jurisdiction of Garfield County, and because the facility is proposed to be
unmanned it was not sent for review by the Garfield County Road & Bridge Department
3. Design of the proposed use is organized to minimize impact on and from adjacent
uses of land through installation of screen fences or landscape materials on the periphery of
the lot and by location of intensively utilized areas, access points, lighting and signs in such
a manner as to protect established neighborhood character.
Response
The property is located in a secluded portion of privately owned property. By its location and
topography, it is effectively screened by steep topography. The site is located approximately
one-half mile from the nearest residence, that being on Chevron USA property and leased to an
individual tending grazing cattle that are part of a lease.
The proposed use will have relatively limited visual impact to surrounding properties. It cannot
be seen from CR 211. It is situated beyond the end of a dead-end road vacated by the County,
which is used primarily for industrial traffic serving the existing industrial uses in the area with
very limited general population traffic. Further, the site itself is situated in an area already
characterized by intense industrial activity from the exploration / processing activities. No
screening is necessary as it is already screened by steep topography. While no lighting is
proposed, any future lighting shall be directed inward and downward.
Section 5.03.07 [Industrial Operationsl
Pursuant to Section 5.03.07 of the Zoning Resolution, a permit for Industrial Operations requires
the submittal of an impact statement on the proposed use describing its location, scope, design and
construction schedule, including an explanation of its operational characteristics. The impact
statement is required to address the following:
(A) Existing lawful use of water through depletion or pollution of surface run-off, stream
flow or ground water.
Response
The facility site has been designed to insure protection of ground water and nearby streams
through the development and implementation of a Storm Water Management Plan specific to
the area which is contained at the rear of the application. Staff notes that while this plan is
specific to the Compressor site, Chevron USA has also submitted a larger Storm Water
Management Plan for the general area. Further, containment facilities are designed into the
facility for any hazardous material stored or used during operations.
A Floodplain Permit was required as part of the previous Special Use Permit, and the related
information/requirements is valuable to the safety of personnel working the site.
(B) Impacts on adjacent land from the generation of vapor, dust, smoke, noise, glare or
vibration, or other emanations.
Chevron USA Booster Compressor Station
BOCC— 08/04/2008 Page 6
Response
Compressors produce considerable volumes of noise and vibration but whose acceptable levels
are regulated by the Colorado Revised Statutes. Noise generated will have very little impact on
adjacent properties since the compressor is located in a canyon area that will prevent any sound
from traveling as well as being located well within the boundaries of the subject property far from
adjacent properties. The former farmhouses that were purchased with the in -holdings are
occupied by hands managing herds of cattle on the site.
A preliminary acoustic analysis was performed by Hoover & Keith, Inc. that included the Central
Production Facility down the road. The sound analyses for that site which houses several
operating compressors, as well as an operating well site 598 -26 -AV, indicated that the
operations will perform within required residential Dbl levels on the Chevron -owned property
sound, and well within those residential thresholds at the nearest residential location.
Chevron USA shall adhere to the noise standards specified by the Colorado Revised Statutes
and the Colorado Oil and Gas Conservation Commission rules. Given the remote location of the
new facility, Staff agrees that noise will not be a nuisance to area residents. The nearest
resident is the occupants of the leased residence belonging to Chevron USA.
(C) Impacts on wildlife and domestic animals through the creation of hazardous
attractions, alteration of existing native vegetation, blockade of migration routes, use
patterns or other disruptions.
Response
The site is located within winter rangeland for mule deer, elk, and turkey as identified on the
Division of Wildlife's wildlife distribution maps. The 2.7 -acre site is currently disturbed; the open
flat area is taken up with the occupation of the facility, but the riparian zone remains intact. The
roadways have been located away from the drainages. Much of the cover and forage is being
utilized by a cattle lease. The Applicant has fenced the dumpsters to minimize conflicts with
wildlife, and dumpsters containing foodstuffs are emptied more often to prevent the attraction
and habituation of black bears.
(13) Affirmatively show the impacts of truck and automobile traffic to and from such uses
and their impacts to areas in the County.
Response
There will be several different phases of the operation, each with differing trip generation. All
traffic will travel up County Road 204 to County Road 211, to the point where it has been
vacated and becomes Chevron USA property. This existing road meets the County's standards,
and is presently under a program for surface maintenance performed by Hyland Enterprises to
treat fugitive dust, and to maintain surface through grading, sanding and snow -plowing.
The initial traffic is related to construction. This will involve the transport of earth -moving
equipment, construction materials and association personnel. The delivery of the compressor
Chevron USA Booster Compressor Station
BOCC— 08/04/2008 Page 7
equipment and related materials will follow. Vehicles range from pickup trucks to semi -trucks
with trailers to transport heavy loads, such as compressor and parts.
As noted earlier, the compressor facility, once fully operational, is expected to generate limited
vehicle trips per day into and out of the facility because most of the monitoring of the
Compressor's performance will be done remotely. Also as mentioned above, most of this truck
travel will be coming from Debeque on CR 211 which is capable of handling the additional trips.
There is no proposed increase of occupancy of the site.
Chevron USA does not foresee a major increase in traffic flow after the construction period and
the additional compressors are online. No improvements to CR 211 are necessary as a result of
this compressor station.
(E) That sufficient distances shall separate such use from abutting property which might
otherwise be damaged by operations of the proposed use(s).
Response
The operations at the facility will not involve any abutting property. The proposed facility will not
encroach upon existing setbacks or reduce current separation distances to abutting properties.
Staff agrees that the existing facility is located well within required setbacks and is sufficiently
separated from adjacent properties in all directions.
(F) Mitigation measures proposed for all of the foregoing impacts identified and for the
standards identified in Section 5.03.08 of this Resolution
Special Use Permits may be granted for those uses with provisions that provide adequate
mitigation for the following:
(A) A plan for site rehabilitation must be approved by the County Commissioners before a
permit for conditional or special use will be issued;
Response
The application does not include a reclamation plan for the additional 1.4 acres that will be
affected. There must be a demonstration that a plan would govern treatment of the site once the
useful life of the facility (20+ years) has expired which includes:
1) Removal of all surface equipment;
2) Restoration and re -contouring of grade to approximate original conditions;
3) Replacement of stockpiled topsoil; and
4) Compliance with all prevailing Colorado Oil and Gas Conservation Commission and Garfield
County regulations governing final reclamation.
The Applicant will need to provide Garfield County with an updated reclamation plan that
includes this additional affected acreage, as well as provide a permit bond at the rate of $4,000
per acre, as per the Garfield County Vegetation Manager.
Chevron USA Booster Compressor Station
BOCC— 08/04/2008 Page 8
(8) The County Commissioners may require security before a permit for special or
conditional use is issued, if required. The applicant shall furnish evidence of a bank
commitment of credit, bond, certified check or other security deemed acceptable by the
County Commissioners in the amount calculated by the County Commissioners to secure
the execution of the site rehabilitation plan in workmanlike manner and in accordance with
the specifications and construction schedule established or approved by the County
Commissioners. Such commitments, bonds or check shall be payable to and held by the
County Commissioners;
Response
In the past, the Board has required, as a condition of approval that "A sufficient monetary
security, determined by the Board of County Commissioners, to ensure rehabilitation of the site
once operation has ceased shall be provided by the Applicant."
The Applicant has provided the Garfield County Treasurers Office with permit bonds at the rate
of $4,000 per acre, an amount determined by the Garfield County vegetation manager for similar
projects. It is unclear at the time of this writing as to whether the former well pad currently exists
under a permit bond. It is anticipated that additional bond monies will be needed to ensure that
the additional 1.4 acres of previously undisturbed acreage that is to provide the site for the
compressors. If the former well pad is administered by an existing reclamation plan and secured
by an existing security it is felt that no additional action need be taken for that acreage, but a
bond and updated reclamation plan for the 1.4 acres must be secured. The security shall be
held by Garfield County until vegetation has been successfully reestablished according to the
Reclamation Standards in the Garfield County Weed Management Plan. It is the responsibility
of the Applicant to contact the County, upon successful revegetation establishment, to request
an inspection for bond release consideration.
Section 5.03.08 !Industrial Performance Standards)
Pursuant to section 5.03.08 of the Zoning Resolution, all Industrial Operations in the County shall
comply with applicable County, State, and Federal regulations regulating water, air and noise
pollution and shall not be conducted in a manner constituting a public nuisance or hazard.
Operations shall be conducted in such a manner as to minimize heat, dust, smoke, vibration, glare
and odor and all other undesirable environmental effects beyond the boundaries of the property in
which such uses are located, in accord with the following standards:
(1) Volume of sound generated shall comply with the standards set forth in the Colorado
Revised Statutes at the time any new application is made.
(2) Vibration generated: every use shall be so operated that the ground vibration
inherently and recurrently generated is not perceptible, without instruments, at any point of
any boundary line of the property on which the use is located.
(3) Emissions of smoke and particulate matter: every use shall be operated so as to
comply with all Federal, State and County air quality laws, regulations and standards.
(4) Emission of heat, glare, radiation and fumes: every use shall be so operated that it
does not emit heat, glare, radiation or fumes which substantially interfere with the existing
Chevron USA Booster Compressor Station
BOCC— 08/04/2008 Page 9
use of adjoining property or which constitutes a public nuisance or hazard. Flaring of gases,
aircraft warning signals, reflective painting of storage tanks, or other such operations which
may be required by law as safety or air pollution control measures shall be exempted from
this provision.
(5) Storage area, salvage yard, sanitary landfill and mineral waste disposal areas:
(A) Storage of flammable or explosive solids or gases shall be in accordance with
accepted standards and laws and shall comply with the national, state and local fire
codes and written recommendations/comments from the appropriate local protection
district regarding compliance with the appropriate codes;
(B) At the discretion of the County Commissioners, all outdoor storage facilities
may be required to be enclosed by fence, landscaping or wall adequate to conceal
such facilities from adjacent property;
(C) No materials or wastes shall be deposited upon a property in such form or
manner that they may be transferred off the property by any reasonably foreseeable
natural causes or forces;
(D) Storage of Heavy Equipment will only be allowed subject to (A) and (C) above
and the following standards:
1. The minimum lot size is five (5) acres and is not a platted subdivision.
2. The equipment storage area is not placed any closer than 300 ft. from
any existing residential dwelling.
3. All equipment storage will be enclosed in an area with screening at
least eight (8) feet in height and obscured from view at the same
elevation or lower. Screening may include berming, landscaping, sight
obscuring fencing or a combination of any of these methods.
4. Any repair and maintenance activity requiring the use of equipment that
will generate noise, odors or glare beyond the property boundaries will
be conducted within a building or outdoors during the hours of 8 a.m.
to 6 p.m., Mon. Fri.
5. Loading and unloading of vehicles shall be conducted on private
property and may not be conducted on any public right-of-way.
(E) Any storage area for uses not associated with natural resources shall not
exceed ten (10) acres in size.
(F) Any lighting of storage area shall be pointed downward and inward to the
property center and shaded to prevent direct reflection on adjacent property.
(6) Water pollution: in a case in which potential hazards exist, it shall be necessary to
install safeguards designed to comply with the Regulations of the Environmental Protection
Agency before operation of the facilities may begin. All percolation tests or ground water
resource tests as may be required by local or State Health Officers must be met before
operation of the facilities may begin.
Staff Response
Should the Board approve the request for the Compressor Station, Staff suggests the industrial
performance standards be considered conditions of approval as they are specifically intended to
ensure that any industrial use such as the proposed Compressor function in accordance with the
proper best management practices and within the parameters of the State statutes. The
Chevron USA Booster Compressor Station
BOCC— 08/04/2008 Page 10
requirement for screening should not be required as the site is remote and the topography
effectively shields the operation from applying an adverse visual impact on adjacent parcels.
Section 9.03.05 (Periodic Review of SUP1
Pursuant to section 9.03.05 of the Zoning Resolution:
Any Special Use Permits maybe made subject to a periodic review not less than every six (6)
months if required by the County Commissioners. The purpose of such review shall be to
determine compliance or noncompliance with any performance requirements associated with
the granting of the Special Use Permit The County Commissioners shall indicate that such a
review is required and shall establish the time periods at the time of issuance of a Special
Use Permit. Such review shall be conducted in such manner and by such persons as the
County Commissioners deem appropriate to make the review effective and meaningful.
Upon the completion of each review, the Commissioners may determine that the permit
operations are in compliance and continue the permit, or determine the operations are not in
compliance and either suspend the permit or require the permittee to bring the operation into
compliance by a certain specified date. Such periodic review shall be limited to those
performance requirements and conditions imposed at the time of the original issuance of the
Special Use Permit.
VII. RECOMMENDED FINDINGS
1. Proper posting and public notice was provided as required for the meeting before the Board of
County Commissioners.
2. The meeting before the Board of County Commissioners was extensive and complete, that all
pertinent facts, matters and issues were submitted and that all interested parties were heard at
that meeting.
3. The above stated and other reasons, the proposed special use permit has been determined to
be in the best interest of the health, safety, morals, convenience, order, prosperity and welfare of
the citizens of Garfield County.
4. The application has met the requirements of Special Use (Sections 5:03, 5:03:07, 5:03.08 and
9:03) the Garfield County Zoning Resolution of 1978, as amended.
VIII. STAFF RECOMMENDATION
Due to the following conditions:
• 1) the limited nature of potential impacts to surrounding properties,
• 2) the remote location of the property such that it is situated at the end of a dead-end
county road which is used primarily for industrial traffic serving the existing industrial uses in
the area with very limited general population traffic,
• 3) and the fact that the site itself will be situated in an industrial area already characterized
by intense industrial activity from processing activities,
• 4) the proposed expansion is to an existing facility,
Staff recommends the Board approve the request for a Special Use Permit for a Service Pad/
Booster Compressor Station with the following conditions:
Chevron USA Booster Compressor Station
BOCC— 08/04/2008 Page 11
1. That all representations of the Applicant, either within the application or stated at the
hearing before the Board of County Commissioners, shall be considered conditions of
approval unless explicitly altered by the Board.
2. That the operation of the facility be done in accordance with all applicable Federal, State,
and local regulations governing the operation of this type of facility.
3. That the Applicant shall comply with the fire protection provisions included in the rules and
regulations of the Colorado Oil and Gas Conservation Commission (COGCC) and the
International Fire Code as the Code pertains to the operation of this facility.
4. Volume of sound generated shall comply with the standards set forth in the Colorado
Revised Statutes.
5. Vibration generated: the Compressor shall be so operated that the ground vibration
inherently and recurrently generated is not perceptible, without instruments, at any point of
any boundary line of the property on which the use is located.
6. Emissions of smoke and particulate matter: the Compressor shall be so operated so as to
comply with all Federal, State and County air quality laws, regulations and standards.
7. Emission of heat, glare, radiation and fumes: the Compressor shall be so operated that it
does not emit heat, glare, radiation or fumes which substantially interfere with the existing
use of adjoining property or which constitutes a public nuisance or hazard. .
8. Any storage area for uses not associated with natural resources shall not exceed ten (10)
acres in size.
9. Any lighting of storage area shall be pointed downward and inward to the property center
and shaded to prevent direct reflection on adjacent property.
10. Water pollution: in a case in which potential hazards exist, it shall be necessary to install
safeguards designed to comply with the Regulations of the Environmental Protection
Agency before operation of the facilities may begin. All percolation tests or ground water
resource tests as may be required by local or State Health Officers must be met before
operation of the facilities may begin.
11. That all proper building permits are obtained for the structures associated with the
operation of the Compressor prior to the issuance of a Special Use Permit.
12. Additional permit bonding shall be put into place for the previously undisturbed 1.4 acres of
the compressor site, and an updated reclamation plan for this acreage shall be submitted
prior to the issuance of the permit.
IX. RECOMMENDED MOTION
"I move to approve a Special Use Permit for a Natural Gas Booster Compressor Station for
Chevron USA Inc with the conditions provided by Staff."
BOCC - 6/2/2008 DD
PROJECT INFORMATION AND STAFF COMMENTS
TYPE OF REVIEW: Referral of Special Use Permit ("SUP")
SUMMARY OF REQUEST: The Applicant requests a SUP for construction of a well pad
for the construction of two (2) booster compressors to
transport gas from two adjacent pads currently under
construction.
APPLICANT/PROPERTY OWNER: Sally Cuffin, PE, URS, Washington Division for Chevron USA
LOCATION: Approximately two and one-half (2.5) miles NNW of the end
of County Road 211 near the confluence of Clear Creek and
Tom Creek, northwest of Debeque, generally described as
portions of the NE Y, NW'/. and SE %, NW 1/4 of Section 36,
Township 5 South, Range 98 West of the 6th PM.
3.58 acres of a 54,000 -acre tract
County Road 211
RL (Resource Lands)
SITE INFORMATION:
ACCESS:
EXISTING & ADJACENT ZONING:
I. REQUEST
This proposal is permit construction
of an additional well pad (adjacent
to an existing well pad) to provide
for two (2) booster compressors
that will be used to transport gas
from two adjacent pads currently
under construction nearby. This
facility will support drilling and gas
production in the Tom Creek area
of Chevron's Skinner Ridge
Natural Gas Field.
II. AUTHORITY
Section 9.03.04 of the Zoning
Resolution of 1978, as amended,
requires that Special Use Permit applications be initial y
brought to the Board so that the Board may determine if
a recommendation from the Planning Commission
is necessary.
MINIM IIIINE1111111
�thieLlia11,te�
as anile, ®®�i0��
thettl
NSW
III. STAFF RECOMMENDATION
Staff finds that because this use type is unchanged, and the
project is limited in its complexity, it is appropriate to recommend
that the Board direct Staff to schedule a public hearing for the
Board, and not refer the matter to the Planning Commission.