Roy L. Wickland 15 Belvedere Avenue - Belvedere, CA 94920 June 19, Ms. Irene Borba Director of Planning and Building City of Belvedere ~1anning Department 450 San Rafael Avenue Belvedere, CA 94920 JUN. Z017 Subject: Response to Initial Study/Proposed MND 135 Belvedere Avenue APN Nos. 060-181-06 through 08 Project Sponsor: Amalfi 135 Belvedere, LLC State Clearing House No. 052058 Dear Ms. Borba: I reside at 15 Belvedere A venue in Belvedere, California. I have reviewed the Initial Study/Proposed Mitigated Negative Declaration (the "Initial Study") for 135 Belvedere Avenue, and am submitting these comments in accordance with the "Notice of Intent to Adopt a Mitigated Negative Declaration" issued for the project by the City of Belvedere Director of Planning and Building on May 20,. A photocopy of the Notice oflntent is attached. My wife and I do not have a problem or issue with the new residence and ancillary structures proposed for 135 Belvedere Avenue. However, we are extremely concerned and object to the fact that the Initial Study fails to acknowledge, let alone analyze or mitigate, the traffic and parking impacts that will occur during the construction phase of the project. The Initial Study indicates that the project will consist of a home and other structures aggregating almost 12,500 square feet, a 108 foot long, 875 square foot fixed pier, platform and boat lifts, and a hillavator. Other improvements will include an auto court, guest parking, a pool, terraces, retaining walls, stairway access to the shoreline, landscaping and bioretention/drainage management areas. From a square footage standpoint, the project appears equivalent to constructing a 16 unit apartment complex, a 10 unit entry level infill development or a mid-sized office building. The applicant is requesting a two year construction time limit, during which time a meaningful level of construction traffic to and from the project will undoubtedly take place. However, the only mention of construction generated traffic in the Initial Study is a statement that the project will necessitate a total of approximately 202 loads of off soil and demolition debris off-haul. This means that demolition/grading alone will generate a total of at least 404 dump truck trips (202 in and 202 out). Nowhere in the document is there any attempt to quantify the vehicle trips generated by project deliveries, equipment requirements or the work force engaging in project construction activities.
It is my understanding that the purpose of an initial study is to determine whether an environmental impact report or negative declaration should be prepared. The initial study should fully explain the basis for determining the scope and severity of project impacts. If a particular impact is deemed insignificant, the initial study should so state and set forth the standards of significance used to make the determination. Otherwise, a lead agency would be able to provide a superficial analysis (or no analysis at all) in the initial study and then defend its decision to adopt a negative declaration by pointing to the absence of any impacts. Traffic congestion, additional parking requirements and the increased wear and tear on Belvedere Avenue all constitute material aspects of the construction activities associated with the proposed project that are not, but should be, considered in the Initial Study. Belvedere Avenue is a winding, one lane road serving two- way traffic. On many p01iions of Belvedere Avenue, vehicles must utilize pull out areas to yield to passenger cars (let alone trucks) traveling in the opposite direction. In addition, street parking along Belvedere A venue is extremely limited. These facts, considered within the context of the apparent magnitude of the construction planed for 135 Belvedere Avenue, most definitely require analysis in the Initial Study, including the imposition of reasonable mitigation measures. I believe that the Initial Study should be revised as follows: 1. All construction traffic generated by the planned project, not just the truck trips associated with removal of soil off-haul and demolition debris, should be quantified. 2. The level of daily construction traffic should be estimated for the entire two year life of the project. 3. Parking requirements should be quantified for the duration of the project. 4. The wear and tear of construction traffic on the Belvedere Avenue should be described and estimated. 5. The construction traffic/parking impacts of this project should be considered cumulatively with other development proposed in the area. In this regard, I am aware that another large residence is apparently being planned for near term construction at 1 Belvedere A venue. 6. The standards of significance for determining construction traffic/parking impacts should be clearly stated. Based on the information resulting from this increased level of analysis, mitigation measures should be considered. These mitigation measures should, at a minimum, include the following: A. Limiting delivery of materials and equipment to and from the construction site to weekdays between 9:30 AM and 2:00 PM.
B. Prohibiting the parking of delivery trucks and construction equipment on Belvedere Avenue. C. Requiring off street and/or offsite parking for construction workers. D. Requiring an onsite staging and storage area for the delivery/storage of construction equipment and materials. E. Prohibiting or restricting the blockage of Belvedere A venue by construction equipment or delivery vehicles. If blockage is unavoidable, requiring advance review and approval of the date, time and duration of the blockage by the Department of Public Works, as well as advance notice to the neighborhood. F. Designating a specific, required street route for construction site ingress and egress. G. Performing pre-construction and post construction surveys of Belvedere Avenue, and requiring the project proponent to repair or fund the repair of any damage or increased wear and tear caused by construction traffic. Including a traffic/parking analysis with appropriate mitigations in the Initial Study will facilitate compliance with the California Environmental Quality Act and insure that the project is constructed with a minimum of disruption to what the Initial Study describes as a "park-like and semi-rural" neighborhood. Yours truly, Roy L. Wickland R~W-~~G cc: Jayni Allsep
NOTICE OF INTENT TO ADOPT A MITIGATED NEGATIVE DECLARATION for 135 Belvedere Avenue APN 060-181-06, 060-181-07 and 060-181-08 To: Owners of Property Contiguous to Project Site From: City of Belvedere Marin County Clerk 450 San Rafael Avenue State Clearinghouse Belvedere, CA 94920 Responsible Agencies and Trustee Agencies Interested Members of the Public The City of Belvedere is the Lead Agency and has prepared an Initial Study and Mitigated Negative Declaration for the project described below. Adoption of the Mitigated Negative Declaration and consideration of project applications are scheduled before the City of Belvedere Planning Commission on June 20, at 6:30 p.m. The public review period is from May 22 to June 20, Project: 135 Belvedere Avenue - Demolition Permit, Design Review, Conditional Use Permit, Exception to Floor Area, Variance, Second Unit Permit, Lot Merger, Construction Time Limit Extension and Revocable License applications for New Single-Family Horne, Accessory Dwelling Unit (Second Unit), Private Pier and other Site Improvements Project Applicant: Amalfi 135 Belvedere LLC Project Description: The project proposes demolition of existing structures on the property including an existing single family home, detached garage, water tank (currently empty and not connected to well) to make way for construction of a new two-story, 10,340 square-foot, single family residence with attached 1,250 square-foot, 5- car garage, a 750 square-foot accessory (second) dwelling unit; and other improvements including a hillavator, a 128-square-foot boat storage structure, and a fixed pier (875 square feet) that would extend approximately 108 feet from Mean High Water (MHW) seaward into Richardson Bay on a tide lot owned by County of Marin. Installation of a platform lift (96 square feet) and boat lift (12 square feet) is also proposed. The pier would be supported by 25 twelve-inch diameter piles. New retaining walls, auto court, guest parking, landscaping, terraces, pool, stairway to shoreline, bioretention and drainage management areas are also proposed as part of the project. Total lot size would be 53,978 square feet (1.24 acres) based on proposal to merge three lots into one single lot. Project approvals required by the City of Belvedere include: Demolition Permit pursuant to Chapter 16.28 of the Belvedere Municipal Code to remove existing single family home, water tank and garage/carport; Architectural and Environmental Design Review pursuant to Title 20 of the Belvedere Municipal Code for residence, accessory (second) dwelling unit, tree removal, landscaping and other proposed improvements; Exception to Floor Area; Second Unit Permit; Variances for the Second Unit for exceeding the required height limit and for the property exceeding the applicable floor area on which the Second Unit is located (Belvedere Municipal Code Sections 19.78.070 E and Section 19.78.070 C); Request for a 24-month Construction Time Limit; Use Permit pursuant to Title 19 of the Belvedere Municipal Code for private recreational use in R - Recreation Zone; and Revocable License for the construction of private improvements in public right-of-way pursuant to Chapter 272 of the Belvedere Administrative Policy Manual. A copy of the Mitigated Negative Declaration is available at the City Hall and Community Center at 450 San Rafael Avenue, Belvedere from 9 a.m. to 4:30 p.m., Monday to Thursday. City offices are closed from 12 p.m. to I p.m. Due to the time limits mandated by State law, our response must be sent at the earliest possible date but not later than June 20,. Please send your com1 en to t~e addre.~s shown above. I. / /2;-;_.J Date: May 20, Signature: 1Z,{_ Title: Telephone: (415) 435-3838 /(.AJ UcJZl/ Director of Planning and Building
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Gate Entry
Streetside-1
135 Belvedere Ave. Belvedere CA Streetside-2 STUDIO-
Great Room-Upper Level
Living Room
Aerial View-Rear Yard
Guest Studio sruo10
Fire Pit Area-View Toward House sruo100
Fire Pit Area-View Toward Bay
Cabana Area
Pool Terrace Area
I 1 / 135 Belvedere Ave, Belvedere CA Interior View -Lower Great Room
Aerial Night
Water Front