Summary of Committee Recommendations and Progress
1. Review of fees associated with grading, road-impact, and road closures o Increase the day-long encroachment permit fee to $260/day o Create a new category of encroachment permit for single deliveries with a fee $53 per delivery.
o Increase road closure fee to $490/half day and $990/day o Increase “impact” fee to 0.01% of project valuation
o Impose “grading” fee of $10/cubic yard.
Adopting new encroachment permit fees will require updating the City’s Master Schedule of Fees. Additionally, a rate study is required prior to adjusting the Road Impact Fee rate. Given the technical aspects of this endeavor, staff is recommending a third-party consultant be hired to oversee the work. Public Works is currently developing an RFP for consulting services and will consider partnering with other agencies to save costs. It may be necessary for staff to return to Council with a midyear budget amendment to fund this work.
2. Review of the City’s Design Review process
o The Planning Department should apply more scrutiny to enforce Section
20.04.110 by precluding site grading, terracing of sloped lots and other plans beyond “minimal” changes to site conditions.
o The Planning Department should require estimates by cubic yard for “cut and fill” and concrete, including for landscaping plans.
o The Building Department should require precise numbers by cubic yard for “cut and fill” and concrete, including for landscaping plans, before issuing a building permit.
Following the Committee recommendations, the Planning Commission, Building Department, and Planning Department are requiring more specific estimates of cut and fill volumes prior to project approval. At the Planning Commission level, greater attention is also being given to ensuring a project conforms with the intent of Belvedere Municipal Code 20.04.110.
3. Review of Parking
o Modify Staging and Parking Plan policy to include potential work stoppages and/or fines associated with policy requirements, including the three-vehicle parking limit, as well as material storage and equipment storage and utilization.
Establish manageable procedures for Building Department enforcement of contractor parking requirements. Broader site inspections and building department staffing would likely be required.
OTHER SCHEDULED ITEMS BELVEDERE CITY COUNCIL
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o Specifically, codify the current custom into actionable policy. Current custom is a verbal warning, written warning, and finally a stop work order, although this rarely, if ever happens. New policy would be a verbal warning, a written warning, and finally an administrative citation pursuant to Chapter 1.15 of the Belvedere Municipal Code.
o Additionally, a new or modified Ordinance may be necessary similar to the recently adopted Ordinance amending Title 9 of the Belvedere Municipal Code by adding chapter 9.80, “Parks and Community Center,” regulating the use of Belvedere parks and Community Center. This new ordinance would govern the enforcement of the modified Staging and Parking Plan
o City should consider adding people, possibly part-time employees or in conjunction with Tiburon, to enforce parking regulations.
Staff and the City Attorney will consider the necessary code amendments needed to Belvedere Municipal Code chapter 1.15 to formalize this current practice. Staff will return to Council with options for hiring additional personnel to oversee parking and other code enforcement; however, this hiring decision may need to be deferred until the next budget planning cycle.
4. Construction Time Limit (CTL)
o Migrate to a Permit Expiration model. Permits are valid for a fixed number of months (6, 12, 18); unusually complex project permits can still be issued for 24 months at the discretion of the Planning Commission. If the work is not complete within the initially-approved time period, reactivation fees would be required. The fees and penalties necessary to reactivate a permit increase with successive reactivations.
The Building Department is preparing a multi-year analysis of past construction projects in Belvedere. A comparison will be made between actual fees collected v. fees based on a permit expiration model similar to Tiburon. This information will be presented to Council along with a red-line model ordinance for consideration this winter.
5. Communications, information, and complaints
o Improve oversight: Provide adequate Building Department personnel to oversee safety, orange tags, parking issues, mess from workers, permitting issues o Improve Communication
Create and publicize a single contact point, including a phone number (unattended, with voicemail) and an email address, for all comments or complaints about construction impacts.
• This contact point should cover matters related to Building, Planning, Public Works, parking, traffic, and other construction-
OTHER SCHEDULED ITEMS BELVEDERE CITY COUNCIL
OCTOBER 10, 2022
related matters. Belvedere residents often do not know which department should handle their concerns.
• City staff should monitor all communication and distribute to the appropriate department or staff.
• Data on complaints should be collected and analyzed on a periodic basis.
For projects expected to have a duration of more than 30 days, and any long-duration encroachment or road closure permit (or other projects as determined by the Building Department), require on-site sign/poster, with a QR code that links to Planning Dept., at each worksite displaying:
• Project/site address;
• Permitted duration of project;
• Permitted hours of construction - Subsection 105.7.1 of Municipal Code 16.04.030
• Name, address, and phone number of contractor or lead agency; • Name, address, and phone number of the person responsible for the project or in case of emergency;
• The email of the Belvedere building official to contact for complaints regarding the project.
Improve community outreach, as a condition of use:
• For municipal projects, require an agency introductory letter to all affected neighbors with contact information for primary liaison. • For large residential projects, require a contractor introductory letter to all affected neighbors with contact information for primary liaison.
Improve the Building Department website
• Revise and update
• List current and upcoming road encroachments and closures Fortunately, a majority of these recommendations are simple changes to forms or project conditions of approval. The recommendation for additional staffing to improve oversight must also be considered in broader annual budget discussions that will begin in March of 2023. On an interim basis, Staff will consider assigning a single point of contact for construction-related complaints. Short-term website improvements will also be considered to capture complaint data and improve ease of access to information. It is worth noting that the City intends to renovate its web platform in 2023. Capital Budget funds will be requested for this undertaking.
6. Review of Historic Properties
o The Historical Preservation Committee should review the gaps between the HRI list, the Landmark Society lists, and the City of Belvedere list. o The City of Belvedere list should be adjusted as the HPC believes is appropriate.
OTHER SCHEDULED ITEMS BELVEDERE CITY COUNCIL
OCTOBER 10, 2022
The Historical Preservation Committee (HPC) appointed a subcommittee in July to begin this work. Following the conclusion of the Housing Element Update, the Planning Department will convene the HPC to generate a report to City Council on its findings.
The Construction Impacts Committee Draft Report contains a summary of the Committee’s work, findings, and recommendations for consideration by City Council (Attachment 1).
ATTACHMENTS
1. Construction Impact Committee July 7th Draft Report.
CITY OF BELVEDERE
CONSTRUCTION IMPACT COMMITTEE
Draft report, August 3, 2022
I. Summary
A. Key data
1. Data supports observations that construction has increased in recent years. a) Construction increased in 2020 and 2021 over levels seen in preceding 10 years.
b) Road closures and encroachments also were among the highest in the preceding 10 years.
2. Large projects (project valuations excess of $500K) are responsible for most road closures and encroachments.
3. Length and scope are primary drivers of construction impact on a neighboring community.
B. Summary of recommendations
1. Increasing certain fees may enhance efficient use of public resources, recover for roadway damage, and bring Belvedere in line with fees charged in other Marin municipalities.
2. Enhanced enforcement of existing Design Review standards to preserve site conditions should reduce project scope and duration, and limit truck trips that add to traffic and parking congestion, and unduly impact our roadways.
3. Greater enforcement of existing rules regarding construction parking permits and limits on vehicles per project can reduce impacts.
4. We should consider revisions to the Construction Time Limit ordinance that may encourage more consistent compliance with CTL deadlines.
5. We can improve communications about building projects to enhance neighborhood awareness and expectations, and encourage reporting of complaints to help us better understand construction impacts.
6. A proposed12-month trial period of modestly increased permitted hours for quiet work should shorten project duration without adding meaningful impacts.
7. We should examine our list of historical properties to ensure that construction projects do not unduly impact our objective of preserving historic properties.
II. Committee Background, Approach and Data Review
A. Construction Impact Committee (“CIC”) Background
1. Formation
a) Formed by City Council Resolution 2022-11 approved on February 14, 2022.
b) Charter is set forth in Exhibit A to that resolution.
2. Members
a) Public Members
Attachment 1
CIC DRAFT REPORT - For revision with Committee and public input 1 (1) Andy Allen
(2) Jane Cooper
(3) Sandy Donnell
(4) Jeff Hadley
(5) Peter Mark (City Council Liaison beginning June 2022) (6) Steve Stroub
(7) John Tantum (Chair)
b) City Council Liaisons
(1) Steve Block
(a) Upon Steve Block’s resignation from Council, James
Campbell was appointed Liaison.
(b) Upon Peter Mark’s appointment to Council, he replaced James Campbell as Liaison in June 2022.
(2) Jim Lynch
c) Ex-Officio (at invitation of Committee Chair):
(1) City Manager
(2) Building Official
(3) Planning Official
(4) Chief of Police
3. Scope per Resolution 2022-11, Exhibit A:
a) Gather and analyze data pertaining to construction projects (e.g., number and types of building permits, number of road closures) and citizen complaints related thereto;
b) Evaluate whether residents are currently experiencing greater impacts from projects than in the past because of the complexity of projects, more stringent building code requirements, or topography challenges, etc; c) Evaluate whether the concentration of construction projects is contributing to negative impacts on residents;
d) Consider options for reducing construction impacts on Belvedere residents consistent with the City’s desire to continuously improve its environment; and
e) Report the findings of its analysis to Council and, if applicable, make recommendations to Council on strategies that could mitigate the impacts of construction projects on residents.
4. Traffic & Safety Committee
a) The CIC was mindful of the extensive work by the Traffic Safety Committee, and endeavored not to replicate or revisit the analysis and recommendations in that committee’s 2021 report to Council.
5. Timing
a) This is a temporary committee (approximately 6 months) scheduled to “disband after its report to Council,” unless Council directs otherwise.
B. Approach
1. The CIC began by considering all ideas about reducing construction impacts. a) We then divided into groups focused on developing ideas to address distinct impacts.
CIC DRAFT REPORT - For revision with Committee and public input 2 b) We then discussed those ideas in public hearings, and refined ideas for further research and analysis in sub-groups.
2. Public meetings
a) Monthly, beginning in March, 2022
b) Draft report presented to Council in August.
c) August 2022 is the last planned meeting, with the final report to Council in August.
C. Data Review
1. A primary question we confronted was whether construction actually was increasing in Belvedere, or whether residents were experiencing more impacts because COVID caused residents to spend more time at home. Or both? a) We cannot discount the effect of COVID on residents’ experience of construction impacts.
b) But the data confirms that 2020 and 2021 were among the busiest construction periods in a decade.
2. Building permits
a) Data supports the conclusion that construction activity was higher in 2021 than in years past.
(1) 2021 had the highest number of opened building permits -- 289 -- since 2013. 2021 had 9% more open permits than 2020, and 21% more than 2019.
b) An increase in “large projects” (over $500k in value) may be causing greater community impact.
(1) In 2020 14 projects opened with valuations of more than $500K (including 1 valued at more than $2 million and 1 at more than $7 million).
(2)
(3) In 2021 10 projects opened with valuations of more than $500K (including 5 valued at more than; $1 million and 1 valued at more than $2 million).
(4) For comparison, in 2019, 7 projects opened with valuations of more than $500, (including 1 valued at more than $1 million).
3. Road encroachments and closures are higher, with large projects responsible for most of them.
a) Large projects account for most road encroachments and closures b) In 2019 - 2022, 11 projects accounted for:
(1) 470 of 605 road encroachments; and
(2) 48 of 61 road closures.
c) Large projects at “choke points” in roadways are particularly challenging.
III. Discussion and Recommendations
A. Topic 1: Fees for road encroachments, closures, “impacts,” and “grading” CIC DRAFT REPORT - For revision with Committee and public input 3 1. The Committee compared Belvedere’s fees to other community fees, and while “apples to apples” comparisons were not always possible, we did make the following observations.
2. Road encroachment and closure fees.
a) Compared with other Marin municipalities, Belvedere’s fees do not appear to encourage efficient use of encroachment and closure permits. b) Many Marin towns charge encroachment fees that are three to nine times higher than Belvedere.
(1) Belvedere’s encroachment fee is $53/day and $105/week (2) Some surrounding towns charge from $180 to $463 per day, and some charge a percentage of the project value, which would be much higher than $463/day, in most instances.
c) Belvedere’s road closure fee is $245/half-day and $489/day. (1) Mill Valley is $292/day
(2) Ross charges $1,796/day minimum
(3) Most Marin towns do not allow road closures
3. “Impact” fees
a) Belvedere charges a “road impact fee” of 0.075% of project valuation. b) Except for Sausalito which has no specific “road impact fee,” every other municipality in Marin charges at least 0.1% road impact fee.
4. “Grading” fees
a) Unlike most municipalities in Marin, Belvedere does not charge for truck trips related to “grading” of a property.
(1) Ross charges $3/cubic yard hauled in/out of town
(2) Mill Valley charges $1,052 for 51-100 cubic yards, then increases the cost above 100 cubic yards ($20/cubic yard for 51 cubic yards).
b) Cement trucks contain approximately 8-10 cubic yards; dump trucks approximately 10-16 cubic yards.
5. Recommendations:
a) To encourage more efficient use of public resources, revise fees for road encroachment and closures, impact fees, and grading. These recommendations will also , protect roads and bring fees in line with fees in surrounding municipalities.
(1) Increase the day-long encroachment permit fee to $260/day (about five times higher than present, and in the middle of fees many surrounding municipalities charge).
(2) Create a new category of encroachment permit for single deliveries with a fee $53 per delivery. This is equal to the current encroachment permit fee.
(3) Increase road closure fee to $490/half day and $990/day (about double existing fees).
(4) Increase “impact” fee to 0.01% of project valuation (in line with all other towns charging impact fees).
CIC DRAFT REPORT - For revision with Committee and public input 4 (5) Impose “grading” fee of $10/cubic yard. This is roughly a midpoint between the Ross and Mill Valley fees, and is about $100 per truck trip.
(6) Implement an inflation-based annual escalator for all fixed fees.
B. Topic 2: Design Review requirement that projects “preserve existing site conditions.”
1. The Planning Code requires that projects minimize the removal of rock and soil, “cut and fill areas,” and grade changes. BMC, section 20.04.110:
To preserve the landscape in its natural state, the removal of trees, vegetation, rock, and soil should be kept to a minimum. Projects should be designed to minimize cut and fill areas, and grade changes should be minimized and kept in harmony with the general appearance of the neighboring landscape. All disturbed areas should be finished to a natural appearing configuration and planted or seeded to prevent erosion. (Ord. 90-5 § 2, 1990; Ord. 80-1 § 48, 1980.)
2. This Planning Code requirement has many benefits, including reducing the number of truck trips to haul dirt, debris, and concrete. a) Fully loaded cement trucks and dump trucks can weigh up to 33 tons - roughly 16 times more than a typical passenger vehicle. b) They are responsible for many road encroachments and some road closures.
c) They significantly add to traffic and parking congestion. d) They substantially add to wear and damages to our roadways.
3. The CIC recognizes that current construction standards often require more substantial concrete foundations for structures, engineered walls, fences, etc., than in the past. Simply replacing a fence or decking can require much more steel and concrete than existing. But we can and should preclude site changes that require anything beyond minimal revisions to existing conditions.
4. Recommendations:
a) The Planning Department should apply more scrutiny to enforce Section
20.04.110 by precluding site grading, terracing of sloped lots and other plans beyond “minimal” changes to site conditions.
b) The Planning Department should require estimates by cubic yard for “cut and fill” and concrete, including for landscaping plans. c) The Building Department should require precise numbers by cubic yard for “cut and fill” and concrete, including for landscaping plans, before issuing a building permit.
(1) Any requests to increase such amounts should be strongly disfavored.
C. Topic 3: Parking
1. Construction-related parking beyond the allowable limit has an adverse impact on neighborhoods by the loss of on-street parking, street congestion, and impairment of emergency access.
CIC DRAFT REPORT - For revision with Committee and public input 5 2. Belvedere Police can and do respond to complaints regarding traffic and parking related to construction, however, if no statute or ordinance is being violated their primary concern is health and safety, and possible traffic violations.
3. Belvedere Building Department officials attempt to remind and enforce the requirements of a Permittee’s Staging and Parking Plan, but the Building Department does not currently have the personnel adequately to enforce the requirements nor, as importantly, the policy guidelines for this enforcement.
4. Recommendations:
a) Modify Staging and Parking Plan policy to include potential work stoppages and/or fines associated with policy requirements, including the three vehicle parking limit, as well as material storage and equipment storage and utilization. Establish manageable procedure for Building Department enforcement of contractor parking requirements. Broader site inspections and building department staffing would likely be required. b) Specifically, codify the current custom into actionable policy. Current custom is a verbal warning, written warning, and finally a stop work order, although this rarely, if ever happens. New policy would be a verbal warning, a written warning, and finally an administrative citation pursuant to Chapter 1.15 of the Belvedere Municipal Code.
c) Additionally, a new or modified Ordinance may be necessary similar to the recently adopted Ordinance amending Title 9 of the Belvedere Municipal Code by adding chapter 9.80, “Parks and Community Center,” regulating the use of Belvedere parks and Community Center. This new ordinance would govern the enforcement of the modified Staging and Parking Plan
d) City should consider adding people, possibly part-time employees or in conjunction with Tiburon, to enforce parking regulations.
5. The CIC also discussed the possibility of establishing two-hour parking regulations for all cars other than residents’ throughout the City. While this option seems to be beyond the scope of the CIC, we feel it could have a positive impact on construction-related parking. The Traffic & Safety Committee recently reviewed parking regulations and we defer to their recommendations.
D. Topic 4: Construction Time Limit
1. Belvedere’s Construction Time Limit Ordinance (20.04.035) and related Administrative Policy (14.4) provides for a maximum amount of time for completion of a project without incurring a penalty. Time is based on valuation from 6 months to 18 months. A 24 month CTL can be approved by the Planning Commission prior to the issuance of a building permit. This ordinance is intended to motivate the timely completion of construction projects.
2. We may consider revisions to the CTL to more effectively encourage project owners to complete projects within the CTL.
3. Recommendations:
CIC DRAFT REPORT - For revision with Committee and public input 6 a) Migrate to a Permit Expiration model. Permits are valid for a fixed number of months (6, 12, 18); unusually complex project permits can still be issued for 24 months at the discretion of the Planning Commission. If the work is not complete within the initially-approved time period, reactivation fees would be required. The fees and penalties necessary to reactivate a permit increase with successive reactivations. b) Example attached.
(1) The goal is to improve upon the project shortening financial motivation of Construction Time Limits. A reactivation/extension charge is primarily a penalty for failure to complete the project within the allotted time, and secondarily a fee to recover the cost of providing additional building inspection services.
4. Actions
a) Belvedere would need to modify section 16.03.020, which amends the California Building Code uniquely for Belvedere. Section 105.5 Expiration of the California Building Code would need to be modified in the BMC (16.03.020).
5. Supporting Documents
a) Relevant City Ordinances & Policies
(1) 20.04.035 Time limits for construction
(2) Policy 14.4 Violation of the Construction Time Limit Ordinance b) Model Ordinance from Tiburon
(1) https://library.municode.com/ca/tiburon/codes/code_of_ordinances ?nodeId=TITIVLAIMUS_CH13BURE
(2) Example
(a) Grace Period. In instances where the permittee has
proceeded with due diligence and made substantial
progress but is unable to complete the project because of unforeseen circumstances beyond the control of the
permittee, one extension of up to three (3) months may be granted, without payment of additional charges or
penalties.
(b) Extension #1 (6 Months). If the project is not completed within the extension allowed under section 1 above, a Stop Work Order may be issued on the date of expiration and
work shall not recommence until the permit is reactivated and extended. A six (6) month extension may be issued by the Building Official once a reactivation/extension Charge equal to one (1) times the original project construction permit fee is paid.
(c) Extension #2 (6 Months). If the project is not completed within the six (6) month extension allowed under section 2 above, a Stop Work Order may be issued on the date of
expiration and work shall not recommence until the permit is reactivated and extended. Reactivation and extension of CIC DRAFT REPORT - For revision with Committee and public input 7 the permit for another six (6) month period shall be allowed only if a Reactivation/Extension Charge equal to three (3) times the original project construction permit fees is paid. (d) Extension #3 (tbd) with City Council Approval. If the project is not completed within the six (6) month extension allowed under section 3 above, a Stop Work Order shall be issued and the matter referred to the City Council for resolution.
The City Council may reactivate and extend the permit for additional time based upon submission and acceptance of a completion schedule for the project and payment of five (5) times the original project construction permit fees as a Reactivation/Extension Charge. The City Council may
reduce the reactivation/extension charge based on such
reasons as the project's nearness to completion and/or the cause of the delay. The City Council may impose
additional requirements, such as the retention of a
qualified contractor for owner/builder projects or retention of a qualified construction manager for a contracted
project, in order to promote swift completion.
E. Topic 5: Communications, information, and complaints
1. Improving communications regarding construction projects, and implementing a system for tracking complaints, will help us continue to monitor construction impacts going forward.
2. Recommendations:
a) Improve oversight: Provide adequate Building Department personnel to oversee safety, orange tags, parking issues, mess from workers, permitting issues
b) Improve Communication
(1) Create and publicize a single contact point, including a phone number (unattended, with voicemail) and an email address, for all comments or complaints about construction impacts.
(a) This contact point should cover matters related to Building, Planning, Public Works, parking, traffic, and other
construction-related matters. Belvedere residents often do not know which department should handle their concerns. (b) City staff should monitor all communication and distribute to the appropriate department or staff.
(c) Data on complaints should be collected and analyzed on a periodic basis.
(2) For projects expected to have a duration of more than 30 days, and any long-duration encroachment or road closure permit (or other projects as determined by the Building Department), require on-site sign/poster, with a QR code that links to Planning Dept., at each worksite displaying:
CIC DRAFT REPORT - For revision with Committee and public input 8 (a) Project/site address;
(b) Permitted duration of project;
(c) Permitted hours of construction - Subsection 105.7.1 of Municipal Code 16.04.030
(d) Name, address, and phone number of contractor or lead agency;
(e) Name, address, and phone number of the person
responsible for the project or in case of emergency;
(f) The email of the Belvedere building official to contact for complaints regarding the project.
(3) Improve community outreach, as a condition of use:
(a) For municipal projects, require an agency introductory letter to all affected neighbors with contact information for primary liaison.
(b) For large residential projects, require a contractor introductory letter to all affected neighbors with contact information for primary liaison.
(4) Improve the Building Department website
(a) Revise and update
(b) List current and upcoming road encroachments and
closures
F. Topic 6: Permitted work hours
1. The CIC’s objective is to explore how modifying permitted work hours, for quiet work only, could reduce the duration of projects without meaningfully increasing disruptions. To illustrate, a 5% increase in productivity due to expanded quiet work hours could result in a large project being completed 4-5 weeks sooner.
2. Based on discussions with two of Belvedere’s leading contractors, who participated on the CIC, there are several ways expanding permitted work hours will reduce project duration and construction impact:
a) Expanded hours will result in greater scheduling flexibility and increased productivity, reducing overall duration of projects.
b) Construction crews could be on-site before school traffic fills the streets, reducing congestion. RUSD schools start at 8:00, 8:20, and 8:30 am; Redwood and Tam start at 8:30 am.
c) Expanded hours would permit a construction team to optionally work four 10-hour days instead of five 8-hour days, reducing traffic congestion and preparation/disassembly time (shortening projects).
d) Expanded hours would enable >40-hour work weeks if the homeowner is willing to pay overtime (as they may in a CTL fine situation). e) These changes closely align with other Marin cities and towns, where quiet work is generally permitted before 8:00 am and after 5:00 pm.
3. Recommendations:
a) For a pilot period of 12 months, extend the time when construction work is permitted to the hours of 7 am and 6 pm Monday through Friday, CIC DRAFT REPORT - For revision with Committee and public input 9 provided that from 7 am to 8 am, and from 5 pm to 6 pm, only light noise associated with preparing or disassembling the job site is permitted; for example, no heavy equipment or power tools are permitted. Delivery of construction material such as lumber and cement would be unchanged, and may be made to the work site only between the hours of 8 am to 5 pm Monday through Friday.
b) Clarify the language in Belvedere Municipal Code section 16.04.030 (subsection 105.7.1) to accommodate these changes and to clean up ambiguities.
c) After the 12-month pilot period, assess the response of the community to the extended quiet hours based on complaint data.
4. To address concerns about construction-related noise between 7 and 8 am and 5 and 6 pm, the CIC recommends improved communication and complaint processes, as described under Topic 5.
G. Topic 7: Historic properties
1. The Belvedere General Plan recognizes “that the conservation of historic properties stabilizes and increases property values and strengthens the overall community.” The CIC recognizes that the preservation of historical structures, avoiding their tear-down and replacement, will significantly reduce negative construction impacts.
2. As defined by Belvedere’s Historical Preservation Committee, list of historic properties is maintained by Belvedere Planning pursuant to Title 21 of the Belvedere City Code.The list currently enumerates 21 buildings.
3. However, a more comprehensive list is the Historic Properties Data File for Marin County that is maintained by the California Office of Historic Preservation (OHP), referred to as the Historic Resources Inventory (HRI). There are 49 properties listed on the HRI that are located in Belvedere. Additionally, reports made by the Landmark Society name other structures.
4. Recommendations:
a) The Historical Preservation Committee should review the gaps between the HRI list, the Landmark Society lists, and the City of Belvedere list. b) The City of Belvedere list should be adjusted as the HPC believes is appropriate.