Cities Index.
Public Comment

Fort Bragg City Council
July 14, 2025

Document
Public Comment
Meeting
July 14, 2025
Body
Fort Bragg City Council
Pages
37
Original file
56.2 MB
Text extracted from the city's file for reading and search. Open the original on legistar1.granicus.com. That file is the official record.

7B
Paoli, Diana
From: Teresa Skarr <[email protected]>
Sent: Monday, July 14, 2025 9:11 AM
To: City Clerk
Subject: Coastal Development Permit Amendment (8-24/A)
Attachments: Review of Fort Bragg City Council Staff Report for July 14.pdf Dear Ms. Paoli,
Attached are comments regarding the above-named Coastal Development Permit that will be discussed at this evening's City Council meeting.

Thank you,
Teresa Skarr
1 Review of Fort Bragg City Council Staff Report for July 14, 2025, City Council Meeting By Teresa Skarr
The Fort Bragg City Council Staff Report for the July 14, 2025 City Council meeting has numerous errors and misleading statements. Some of these errors involve aspects of the project that could be a basis for denial and/or appeal of the requested coastal development permit. I urge the City Councilmembers to review the staff report along with the table below before making their determinations about this project and to postpone the vote if there is insufficient time to consider the staff report and errors below.

Reference Description/ Quote Comments

Page 4 ends

Para 5 professional input regarding various potential 4-way stop at Ocean View Drive and traffic calming measures to address Harbor Ave. Input regarding various calming existing traffic safety concerns along measures was not provided.

Ocean View Ave (Attachment 18)"
The proposed project will have significant
impact on traffic and pedestrian safety.

Page 9 ends

Para 3 40+ on-street parking spaces... These be approximately 200 people residing in or 40 new public parking spaces would occupying the new development. Even if only be available for public access to the 75% of them have cars, and not counting any nearby Fort Bragg Coastal Trial and visitors to the development, the residents would Pomo Headlands Park." require 150 total parking spots. Considering that the development is adjacent to the new
parking spaces and about 1000 feet away from
Pomo Bluffs Park, it is very unlikely that any on-
street parking will be available to Pomo Bluffs
Park and Trail visitors.

In previous hearings, the Planner specified that
the on-street parking spaces would be added
only on the east side of Harbor Ave and the west
side of Unnamed Rd, and would only extend to
the north and south boundaries of the proposed
development. Considering that 1 parking space
takes a minimum of 22 feet, and allowing for
driveways, there would only be enough room for
about 20 parking spaces. However, even if there
were 40 additional on-street spaces, there still
wouldn't be enough parking for the residents of
the development, let alone their visitors.

Because it will be so difficult to for residents
and visitors to find parking after the
development is built, this is another way in
which the project will have significant impact on
traffic and pedestrian safety.

Page 1 of 6 ends

Reference Description/ Quote Comments

Page 10 ends

Para 2 pathway through the project site to where the new public access trail ends is allow improved access to Pomo approximately 1000 feet from the park onto a Bluffs Park." narrow, 1 lane dirt and potholed road with no pedestrian path or sidewalk, and from which
Pomo Bluffs Park isn't even visible.

Special Condition 44 includes a requirement for
a misleading sign for this path that reads,
"Public access trail. Public access is available
through this property to Pomo Bluffs Park. Part
of this route is NOT ADA accessible." This sign is
misleading because the path does not lead to
the park, but approximately 1000 feet south of
the park onto a dirt road that is unsafe for
pedestrians.

This proposed path is another way in which the
proposed project will have significant impact on
traffic and pedestrian safety.

Page 13 ends

Para 9 compatibility between the residential in 2 of the buildings. None of the parking spaces and nonresidential uses on the site." are designated for hotel guests, and parking And "The non-residential uses are would be far from Building 5. located in only one building"
The location of the parking lot and inadequacy
of parking spaces renders the residential and
visitor serving uses incompatible.

Page 13 ends

Para 10 consideration existing and potential neighboring residences. future uses on adjacent properties
Special Condition 5 requires a 5 foot
and shall include specific design
soundwall" without any design requirements or
features to minimize potential
proof of effectiveness.
impacts." And "The project includes
special conditions to reduce impacts Special Condition 22a allows the west side of on neighboring residential uses such Harbor Ave. to be left unfinished, which will not as installation of a sound wall, discourage parking. In addition, the unfinished extensive landscaping, street west side of the road will allow for contaminants improvements and discouraging from the roadway and parked cars to wash into parking on the west side of Harbor the yards of residences on the west side of Ave." Harbor Ave. and risk contaminating wells.

By including driveways onto Harbor Ave, the
proposed development exacerbates rather than
mitigates impact onto neighboring residences to
the west.

There are no mitigations for the significant traffic
and pedestrian safety impacts in the
neighborhood. The proposed project will have
significant noise and safety impact on the
neighborhood and adjacent properties.

Page 2 of 6 ends

Reference Description/ Quote Comments

Page 14 ends

Para 4 shall be compatible with and with, and does not enhance, the adjacent and enhance the adjacent and surrounding residential neighborhood. surrounding residential The least desirable aspects of the project- neighborhood." And "...this mixed use
specifically, the garbage dumpsters and parking
project is located as far east on the
lot - are directly adjacent to the residential
parcel as feasible and thereby
neighborhood. This maximizes noise and odor
increases the distance between the
impact on the adjacent residential properties
approved project and the residential
and is also visually incompatible.
areas to the west." Also, "Design
Review has already been approved This development's design was amended and for this project by the City Council." has not been approved yet by City Council.

Page 17 ends

Para 2 operating characteristics of the businesses to the north, east and south of the proposed activity are compatible with proposed development, not the houses to the the existing and future land uses in west. These homes were not included in the the vicinity." And a table is provided design analysis despite being closer to the that lists design features of 7 proposed development than most of the businesses. businesses listed.

The design, location, size and operating
characteristics of the proposed activity of the
development are not compatible with the
adjacent properties to the west.

Page 18 ends

Para 4 clientele may be permitted where the not oriented to and does not serve visitor, primary use of a site is oriented to or regional or transient traffic. Less than 5% of the serves visitor, regional or transient proposed development is intended to serve traffic." visitors, regional or transient traffic.

The proposed development does not comply
with zoning requirements for the Highway
Commercial zone in which it is located.

Page 26 ends

Para 5 shows 0 residents per unit in the the overall expected population of the hotel rooms, while acknowledging development. The development will add about that the hotel room water use would 200 people on this small parcel, tripling the be equivalent to a 4 bedroom population of Todd's Point. residence.

Because the only egress for evacuation of
Todd's Point is via Ocean View Drive, and
because the large bulk of population added by
this development will be closest to the point of
egress, the development will severely impact
evacuation safety for the existing residents.

Page 27 ends

Para 2 Caltrans, which determined that a determine the safety or adequacy of traffic traffic study was not warranted." studies on roads outside of their jurisdiction.

The proposed development would significantly
impact traffic and pedestrian safety and
emergency evacuation safety for Todd's Point.

Page 3 of 6 ends

Reference Description/ Quote Comments

Page 27 ends

Para 3 that a traffic study was not warranted pedestrian safety of OceanView Drive and for this project as it would not impact Harbor Ave, which were not considered in the levels of service on highway 1 and a statement from Public Works Staff. Number of prior traffic study for the Autozone peak trips is not an appropriate metric to project identified the required public determine safety impacts. safety changes that should be made
The AutoZone project did not have any
to the roadway system for a project
driveways onto Harbor Ave.; therefore, the
with substantially the same level of
previous traffic study is not adequate to address
daily trips." or mitigate the impact to traffic and pedestrian safety along Harbor Ave and Ocean View Drives.

AutoZone only had 26 parking spaces for
customers and employees, who would only be
present during business hours. The 200
residents of the proposed development would
significantly impact emergency evacuation
egress for all residents of Todd's Point.

The proposed development would significantly
impact traffic and pedestrian safety and
emergency evacuation safety for Todd's Point.

Page 28 ends

11 intersection is not included. Ave and adds 200 people and their vehicles using the Harbor Ave and Oceanview Drive
And intersection. The intersection is already unsafe

Page 29 ends

Table 13 issues and speeding along OceanView Drive. Yet this intersection wasn't included in this
analysis.

The proposed development would significantly
impact traffic and pedestrian safety and
emergency evacuation safety.

Page 30 ends

Para 4 traffic engineer for this project trips and the previous AutoZone traffic study. (Attachment 17) which confirmed the Peak hour vehicle trips is not an appropriate City's analysis that traffic impacts of metric to address traffic and pedestrian safety, the project would be minimal and a or emergency evacuation safety. The AutoZone new traffic count is not required for project did not have any driveways onto Harbor the project because the project Ave. and did not include the intersection of would not impact levels of service at Harbor Ave. and OceanView Dr. AutoZone was a any intersection." dramatically different project than the proposed development, including only 26 parking spaces
compared with the 200 residents plus visitors
including children that would be added by the
proposed development.

The proposed development would significantly
impact traffic and pedestrian safety and
emergency evacuation safety.

Page 4 of 6 ends

Reference Description/ Quote Comments

Page 31 ends

Para 1 issuance of the building permit, the intersection of Harbor Ave., and differences in applicant shall insure that the 'traffic elevation, speed at which cars travel along visibility area' on their property at the Ocean View Drive and the absence of sidewalks intersection of Ocean View Drive and west of the intersection, trimming bushes to 42 Harbor Ave complies with the city's inches is not sufficient to ensure visibility for zoning code and is less than 42 traffic or pedestrian safety at the intersection of inches in height." Ocean View Drive and Harbor Ave.

Page 31 ends

Para 4 an urban infill project." is does not meet the conditions required for in- fill development specified under Title 14,
Section 15332. For example, the project is not
consistent with zoning requirements and its
impact such as noise and traffic and pedestrian
safety is not benign.

Page 34 ends

Para 6 consist of typical residential noises significantly increase the number of vehicle such as intermittent noise from door slams, garbage dumping and other noises vehicle use and outdoor socializing, that are much more acute than the constant which are typical for residential low-level highway noise experienced by current neighborhoods and which will blend residents of Harbor Ave. into the background noise of 60 dB
In addition, because the garbage dumpsters are
from the highway for the nearby
located on the west side of the proposed
residents."
development, garbage pickup and truck backup
beeping, will represent a significant increase in
the quantity of nuisance noises experienced by
current residents of Harbor Ave.

Page 35 ends

Para 4 special condition to further protect "soundwall" without any other design the nearby residences from noise requirements nor any other proof of through the construction of a sound effectiveness for mitigating noise impacts. wall on the western edge of the
The proposed development would significantly
project parking lot."
impact both noise quantity and quality for
current nearby residents.

Page 37 ends

Para 3 commercial uses will be located as dumpsters located as far west as possible in the far as possible residential units." parking lot, which is on the west side of the development. This puts the dumpsters as close
as possible to the existing residents of the
adjacent homes to the west of the proposed
development.

Locating the garbage dumpsters on the far west
side of the development causes significant
noise and air quality impact to the neighboring
residences.

Page 5 of 6 ends

Reference Description/ Quote Comments
Pages 37-42 Threshold Requirements for The proposed development does not qualify for Exemptions for Residential Infill a CEQA exemption because it does not meet the projects and In-Fill Housing conditions required for in-fill development. For Development Exemption Analysis do example, the project is not consistent with the not include an analysis of how the applicable general plan designation and all project meets the conditions required applicable zoning designation and regulations, for in-fill projects specified in as required under Title 14, Section 15332 (a). As California Code Regulations Title 14, another example, approval of the project would Section 15332 - In-Fill Development result in significant effects relating to traffic, projects noise, air quality or water quality, and the
project therefore would not meet the definition
for in-fill development under Title 14, Section
15332(d).

Page 6 of 6 ends

Paoli, Diana
From: Melissa Hays <[email protected]>
Sent: Monday, July 14, 2025 10:51 AM
To: City Clerk
Subject: Development at 1151 South Main St.

I am writing about the development that is being considered at 1151 South Main St. My overall comment is too much development, sensitive area, not enough environmental oversight.

If development is not carefully thought through on our coast, we will have traffic congestion from 128 to Fort Bragg.

Deep respect needs to be given to our fragile location, otherwise we will end up a too congested, overbuilt area just like the 101 corridor. Remember the beautiful plum trees and huge oaks between Santa Rosa and Cloverdale? We live in a unique location unlike anywhere else on the planet. Our job is to protect it from the overdevelopment that we see everywhere else. Our job is NOT to "Pave Paradise, put up a parking lot!" Thank you,
Melissa Hays
Paoli, Diana
From: Paul Clark <[email protected]>
Sent: Thursday, July 10, 2025 8:13 AM
To: City Clerk
Cc: CMAR ([email protected]); Paul Clark
Subject: City Council 07/14/2025 Item 7B
Attachments: 1151SMainHousingStudy.pdf
1151 S Main and City goals for 200 units
Think all the Council should see this.

This is the response I got from the city on my formal request for any studies done for the city council to have declared the need for 200 residential units by 2026.

I was surprised to see any study, but as you will see this is not Fort Bragg specific.

I wanted this in the record and would ask the city to rethink this strategy.

Being the owner of a property management company here in Fort Bragg, I would think that any study would include reaching out to rental providers in the area, also as it is called for in the City's Economic Development Strategy, another grant funded plan that is not often followed.

Thank you
Paul Clark
1 Paoli, Diana
From: Paul Clark < [email protected]>
Sent: Saturday, July 12, 2025 8:58 AM
To: City Clerk
Cc: Paul Clark; CMAR ([email protected])
Subject: July 14 City Council Item 7B 1151 S Main
Attachments: FortBraggPopStats.pdf
No charge for this brief population study for Fort Bragg. Some links below as some are hard to read, but the basic idea is clear. There is no housing shortage in Fort Bragg, and with the aging baby boomers and the disgusting results of Prop 19 many home buying opportunities in the near future, unless of course people can be held in non-equity building housing situations.

Again I would suggest a serious discussion with local housing providers, private and public. I do believe you will be a bit shocked at the true picture.

Affordable housing is not inexpensive, someone is paying the bill.

Included as it is important that the City is working with a false policy that there is a housing "crisis" in Fort Bragg. Please share the city economic development strategy with all the council members, it was adopted by the city, and I recall paid for by yet another grant. Wasted money? I hope not https://www.biggestuscities.com/city/fort-bragg-california https://www.census.gov/quickfacts/fact/table/fortbraggcitycalifornia/PST045224 Paul Clark
Fort Bragg, California Population History | 1990 - 2022 https://www.biggestuscities.com/city/fort-bragg-california Fort Bragg Population History 1990 - 2023
Fort Bragg Population By Year
7200
7000
6800
6600
6400
6200
1990 1995 2000 2005 2010 2015 2020 2025
Year Population Rank in US Growth Rate
2023 6,919 4,030 -1.3%
2022 7,010 3,985 0.6%
2021 6,970 3,983 -0.0%
2020 6,972 3,973 -0.4%
2010 7,273 3,694 0.6%
2000 6,828 3,605 1.0%
1990 6,155 3,535 -
Fort Bragg Population Facts
What is the current population of Fort Bragg?
Based on the latest 2024 data from the US census, the current population of Fort Bragg is 6,919. Fort Bragg, California is the 4,030th largest city in the US.

What county is Fort Bragg, California in?
Fort Bragg is located entirely in Mendocino County.
1 ofs 7/12/2025, 8:39 AM
Fort Bragg, California Population History | 1990 - 2022 https://www.biggestuscities.com/city/fort-bragg-california What is the size of Fort Bragg, California in square miles? Fort Bragg has an area of 2.8 square miles.

What was the peak population of Fort Bragg?
The peak population of Fort Bragg was in 2010, when its population was 7,273. In 2010, Fort Bragg was the 3,694th largest city in the US; now its fallen to the 4,030th largest city in the US. Fort Bragg is currently 4.9% smaller than it was in 2010.

How quickly is Fort Bragg growing?
Fort Bragg has grown 1.3% since the 2000. Fort Bragg, California's growth is about average. 60% of similarly sized cities are growing faster since 2000.

What is the population density of Fort Bragg, California? Fort Bragg has a population density of 2,645.7 people per square mile.

Fort Bragg Demographics
What is the voting age population of Fort Bragg, California? The total voting age population of Fort Bragg, California, meaning US citizens 18 or older, is 4,509. The voting age population is 44.5% male and 55.5% female.

What percentage of Fort Bragg, California residents are senior citizens? According to the latest census statistics, 18.9% of the residents of Fort Bragg are 65 or older.

What are the racial demographics of Fort Bragg, California? The racial demographics of Fort Bragg are 80.7% White, 10.7% Other, 5.2% Two or more races, 1.4% American Indian, 1.0% Black and 1.0% Asian. Additionally, 34.1% of the population identifies as Hispanic.

What percentage of Fort Bragg, California residents are below the poverty line? In Fort Bragg, 19.4% of residents have an income below the poverty line, and the child poverty rate is 24.9%.

On a per-household basis, 16.3% of families are below the poverty line in Fort Bragg.

What percentage of Fort Bragg, California residents are in the labor force? Among those aged 16 and older, 59.9% of Fort Bragg residents are in the labor force. 2 of 5 7/12/2025, 8:39 AM
Fort Bragg, California Population History | 1990 - 2022 https://www.biggestuscities.com/city/fort-bragg-california What are the education levels among Fort Bragg, California residents? Among the adult population 25 years old and over, 82.2% of Fort Bragg residents have at least a high school degree or equivalent, 19.5% have a bachelor's degree and 7.5% have a graduate or professional degree.

What percentage of Fort Bragg, California residents speak a non-English language at home?
Among Fort Bragg residents aged 5 and older, 33.0% of them speak a non-English language at home. Broken down by language: 28.8% of residents speak Spanish at home, 2.7% speak an Indo-European language, and

1.1% speak an Asian language.

Fort Bragg Income & Labor Statistics
What is the unemployment rate in Fort Bragg, California? The unemployment rate in Fort Bragg is 7.8%, which is calculated among residents aged 16 or older who are in the labor force.

What percentage of Fort Bragg, California residents work for the government? In Fort Bragg, 9.7% of the residents in the non-military labor force are employed by the local, state and federal government.

What is the median income in Fort Bragg, California?
The median household income in Fort Bragg is $44,276.

Fort Bragg Housing & Rent Statistics
What percentage of housing units are owner-occupied in Fort Bragg, California? In Fort Bragg, 37.2% of housing units are occupied by their owners.

What percentage of housing units are rented in Fort Bragg, California? Renters occupy 62.8% of housing units in Fort Bragg.

What percentage of Fort Bragg, California housing units were built before 1940? Of all the housing units in Fort Bragg, 23.0% of them were build before 1940.

What percentage of Fort Bragg, California housing units were built after 2000? In Fort Bragg, 8.1% of the total housing units were built after the year 2000, which is approximately 250 units.

What is the median monthly rent in Fort Bragg, California? The median gross monthly rent payment for renters in Fort Bragg is $1,082. 3 of 5 7/12/2025, 8:39 AM
Fort Bragg, California Population History | 1990 - 2022 https://www.biggestuscities.com/city/fort-bragg-california What percentage of households in Fort Bragg, California have broadband internet? In Fort Bragg, 86.8% of households have an active broadband internet connection.

Similarly Sized Cities In California
US Rank Name Population Growth
2000-2023
3889 Escalon (/city/escalon-california) 7,355 20.4%
3916 Fowler (/city/fowler-california) 7,274 80.9%
3918 Gridley (/city/gridley-california) 7,269 30.4%
3949 Mammoth Lakes (/city/mammoth-lakes-california) 7,187 0.8% 3989 Sausalito (/city/sausalito-california) 7,021 -4.2% 4014 Taft (city/taft-california) 6,961 -21.0%
4030 Fort Bragg 6,919 1.3%
4062 Atherton (/city/atherton-california) 6,823 -5.1%
4080 Loomis (/city/loomis-california) 6,779 8.4%
4175 Colusa (Icity/colusa-california) 6,527 20.1%
4232 Huron (/city/huron-california) 6,377 0.6%
4293 Calipatria (/city/calipatria-california) 6,188 - 15.7% 4307 Willows (Icity/willows-california) 6,160 -0.8%
Similarly Sized Cities In US
US Rank Name Population Growth
2000-2023
4024 Fircrest, Washington (/city/fircrest-washington) 6,932 17.8% 4025 Mendota, Illinois (/city/mendota illinois) 6,929 4.8% 4026 Pacific, Washington (/city/pacific-washington) 6,927 29.5% 4027 Mountainside, New Jersey (/city/mountainside-new-jersey) 6,924 4.8% 4028 Lindale, Texas (Icity/lindale-texas) 6,923 119.7%
4029 Philadelphia, Mississippi (/city/philadelphia-mississippi) 6,921 -6.2% 4030 Fort Bragg, California 6,919 1.3%
4031 Youngtown, Arizona (/city/youngtown-arizona) 6,919 129.1% 4032 Tamaqua, Pennsylvania (/city/tamaqua-pennsylvania) 6,917 -3.2% 4 of 5 7/12/2025, 8:39 AM
Fort Bragg, California Population History | 1990 - 2022 https://www.biggestuscities.com/city/fort-bragg-california 4033 Ocean City, Maryland (/city/ocean-city-maryland) 6,915 -3.7% 4034 Walden, New York (/city/walden-new-york) 6,915 9.4% 4035 Vine Grove, Kentucky (/city/vine-grove-kentucky) 6,907 65.8% 4036 Stewartville, Minnesota (/city/stewartville-minnesota) 6,904 26.5% © 2025 www.biggestuscities.com, All Rights Reserved • Privacy Policy (/privacy) • Last updated: Jan 2, 2025 5 of 5 7/12/2025, 8:39 AM
U.S. Census Bureau QuickFacts: Fort Bragg city, California https://www.census.gov/quickfacts/fact/table/fortbraggeitycalifornia..

An official website of the United States government Here's how.you.know census
QuickFaets What's New & FAO, >
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Quick Facts provides statistics for all states and countie. Also fer cities and towns with a populution of 5,000 or more 9 Llid <
tuie sar oorar con lowg t2. - Select a fact -
CLEAR TABL.E MAP CHART MORI
Table
Fort Bragg cits.

All Topics
California
O Population estimates, July 1. 2024, (Y2024) A 7,117
1 PEOPLE
Population
© Population estimates, Juls 1, 2024, (V202+)
O Population estinales basc, April 1, 2020, (V2024) A i,9SG © Population, percent clunge - April 1, 2020 (estimates basc) to July 1, 2024. (V2024) A 15% © Population. Census. April 1. 2020 6,383
© Population. Census. April 1, 2010 7,273
Age and Sex
i Panors under 5 vcars. peicita
© Parsons under I8 years. percent
O Persons 65 years and ovcr. percent
© Female persons, percent
Race and Hispanic Origin
O White alonc. percent
• Black alonc. percent (a) {a) PAPARA RA r R2
f American Indian and Alaska Vatie alane nerat (a)a
© Asian alonc. percent (a) (a)
d Natie Hawaiian ard Other Pacifie Islander along, porcent (a) (al O Two or More Races. parcert
O Hispanic or Latino, percent (b) (b)
• White alonc, not Hispanic cr Latino, percen
Population Characteristics
• Veterans, 2019-2021
O Forcin-bom persons, nerceat, 2019-2023
Housing
© Hosing Units, Juls 1, 2024, (V2024)
© Owner-occupied housing unit ratc, 2019-2023
di Median salue of outer-ocenied house umts, 2019.3023
• Median selected monthle owner costs - with a mongagc, 2019-2023 • Median selected monthly owner costs -without a mortage, 2019-2023 579 Median gross rent, 2019-2023
© Building Permits. 2024
Families & Living Arrangements
fotonceholde 9010.3033
© Persons per bouschold. 2019-2023
© Living in thie same house 1 year ago. percent of persons age1 ycar*. 2019-2027 O Langue other tlan English spoken at bomc. percent of persons age 5 years•, 2019-2023 Computer and Internet Use
© Houscholds with a computer. percent. 2019-2023
© Houscholds with a broadband Internet subscription. percent. 2019-2029 Education
O High school graduate or hügher, percent of persors age 25 ycars-. 2019-2023 • Hachclor's degree or higher, percent ef persons age 25 years-, 2019-2023 Health
• With a disability, under age 65 years. percent. 2019-2023 O Persons without health insurance, under age 65 years, percent Economy
© In civilian labor force, total, percent of population age 16 cars-, 2019-2023 50.6% O In civilian labor force. femalc, percent of population ag: 16 years*. 2019-2027 17 tr% O Total accommodation and food services sales, 2022 (S1.000) (c) 58,553 © Total Icalth care and social assistance reccipts/revemc. 2022 (S1.000) (61 141,230 Is this page helpful? X O Total transportation and warchousing reccipts/revenue, 2022 (S1.000) (c1 20.01+ EB ros © Total retail sales, 2022 (S1.000) (c) 207.493
1 of 2 7/12/2025, 8:39 AM
Paoli, Diana
From: Annemarie <[email protected]>
Sent: Monday, July 14, 2025 6:43 AM
To: City Clerk; Peters, Sarah; cad; Whippy, Isaac
Subject: public comment 1151 S Main City Council meeting 7-14-25 item 7B Dear Diana,
Sorry for having mailed my comments to the wrong e-mail. I am therefore sending my comments again.

Thanks, Annemarie Weibel
Thank you Sarah Peters for following up on my request. I asked whether "it is possible that all these environmental studies can be downloaded for the agenda for the City Council meeting as at least the City Council members could see it, and also the general public? Unfortunately the Planning Commissioners were not able to see these studies. Thanks, Annemarie"
You responded:
"Hello Annemarie,
I apologize for the delay in getting back to you. I have consulted with the team and the City does not post studies on-line. Council members can easily access the applicable studies as desired through City Hall." The point is that not only planning commissioners and city council members should be able to easily access the applicable studies, but the general public as well. In the past with many projects all these studies were online (either listed on the agenda for a planning commission, or city council meeting, or listed here:
https://www.city.fortbragg.com/departments/community-development/city-projects If planning commissioners and city council members need to request these studies and will not have them at their fingertips they might not request them and therefore will not have read them.

At first a community member who wanted to see these studies was told he would need to wait 10 days for these studies, but as he insisted to see them sooner (since Marie Jones mentioned that they are available at City Hall) he generously shared the flash drive with a few other interested community members.

That leaves out the people who did not attend that planning commission meeting, do not know that this individual has a flash drive with these studies, or that they can also get these at City Hall before the City Council meeting.

This project as you Sarah, or Diana might know is exempt from CEQA. No story poles alerted the public to this precedent setting monstrosity (7, three story high buildings) at the gateway to Fort Bragg in front of the ocean. No visual analysis was performed, no serious traffic study was done even though the applicant was willing to hire an expert to do this study. The planning commissioners did not request for this to happen.

I am disappointed to realize that in my opinion neither City staff, planning commissioners, or city council members are being trained about the California Environmental Quality Act, and the Coastal Act. It would not cost much money to hire Marie Jones to give a training, or tell the above mentioned entities the title of a book for laypeople so they would be better informed as to the rights and responsibilities of the public and the above mentioned entities. When a controversial project is exempt from CEQA it is even more important that everyone is educated about it.

Sincerely, Annemarie Weibel
------ Forwarded Message ------
Subject:Automatic reply: personal comment 1151 S Main City Council meeting 7-14-25 item 7B Date:Fri, 11 Jul 2025 23:06:54 +0000
From:Paoli, Diana <[email protected]>
To:Annemarie <[email protected]>
Thank you for your email. I am out of the office this afternoon and will reply to emails on Monday, July 14, 2025. If you have public comment please email to [email protected].

Thank you,
Diana Paoli
City Clerk
Paoli, Diana
From: Paul Clark < [email protected]>
Sent: Monday, July 14, 2025 7:25 AM
To: City Clerk
CC: Paul Clark; MAR (MAR@MCNORG)
Subject: City Council 07142025 Item 7B Don't talk to strangers AB 130 represents California's latest drive to improve affordable housing development by streamlining affordable housing infill development and reducing delays associated with local oversight. AB 130 adds a statutory exemption for infill housing projects that meet the requirements listed below. Permitting for projects that meet these requirements are fully exempt from CEQA, notwithstanding any other laws. AB 130 includes requirements related to prevailing wage, air filtration, hazardous site review, and consultation with California Native American Tribes for certain exempt projects.

Exemption Requirements for infill housing projects:

1. The site is up to 20 acres, or 5 acres for "builder's remedy" projects. The existing Class 32 categorical exemption limited the site area to no more than 5 acres.

2. The site is within an incorporated city or a census-defined urban area.

3. The site was previously developed with urban use, or at least 75% of the perimeter area is developed urban.

4. The development is consistent with the general plan, zoning, and the local coastal program.

5. The project must be built at a density of at least half the minimum number of homes per acre that the law says is appropriate for lower income housing, specified in Cal. Gov. Code S 65583.2(c)(3)(B).

6. The development cannot include transient lodging (e.g., hotels and short-term rentals) or demolition of designated historic structures.

Note item 6. This project as proposed still does not meet the intent of the CH zoning per the City's adopted plan. And we now have a sad example of why the item is addressed in #6 above, (in my opinion).

This is a substantial (non-mitigatable or even discussed) health and safety risk to the potential tenants in this project, particularly minor children.

The management will of course screen tenants for credit and criminal backgrounds to avoid bad people living in the units, but the motel portion can not do that. So, the proposal is to put a steady stream of total strangers among the tenants? Undoubtedly the motel folks will wander toward the Pomo Bluff Park, and the restaurant, and the ocean. The risk that this puts the tenants in is not understated. I doubt that HUD would issue housing certs for this project, which should have been part of the review by staff, both local and coastal, and 1 the planning commission. I don't recall any serious questions on this important issue.

You cannot approve this project. It does not meet the CH requirements and has this serious flaw that you cannot mitigate. Megan's Law was created around this issue.

You can't screen motel guests for pedophiles. Don't put the City in this liability risk. Should something happen, the city will (and should) most likely be brought in any legal action, as well as the coastal commission ( that staff person often referred to in particular)
Paul Clark
2 DEFINITION OF A CULTURAL DISTRICT
"State-designated cultural district" is defined as a geographical area with a concentration of cultural facilities, creative enterprises, or arts venues that accomplishes one or more of the following outcomes:

1. Attracts artists, creative entrepreneurs, and cultural enterprises.

2. Encourages economic development and supports entrepreneurship in the creative community.

3. Encourages the preservation and reuse of historic buildings and other artistic and culturally significant structures.

4. Fosters local cultural development.

5. Provides a focal point for celebrating and strengthening the unique cultural identity of the community.

6. Promotes opportunity without generating displacement or expanding inequality.

Paoli, Diana
From: Paul Clark <[email protected]>
Sent: Monday, July 14, 2025 7:44 AM
To: City Clerk
Cc: Paul Clark
Subject: 7B 1151
HUD issued Notice 2018-10 providing best practices regarding situations in which guest suites are permissible in Multifamily rental projects with mortgages insured or held by HUD under the National Housing Act. Section 513 of that act prohibits renting for "transient or hotel purposes." Leases and occupancy agreements for fewer than 30 days are prohibited.

The guidance applies to Section 221(d)(3), Section 236, Rent Supplement (Rent Supp), and Rental Assistance Program (RAP) projects, along with Project-based Section 8 properties that have Federal Housing Administration (FHA) mortgage insurance.

Notice 2018-10 states that in certain circumstances one or more units may be set aside as an amenity for residents. However, such guest suites are typically available for reservation by residents as an overnight accommodation for residents' relatives or guests.

The Notice provides "best practices" that include:
• Rent is not charged
• Guest suites are not available to the public and are limited to residents' family and friends • Residents are limited to two reservations per year with up to seven days per resident Notice 2018-10 is at: https://bit.ly/2zduA1z
More about HUD's Multifamily programs is on page 4-23 of NLIHC's 2018 Advocates' Guide.

A brief search on HUD and "motel units"
Paul Clark
Century 21 Fort Bragg Realty
809 North Main Street
Fort Bragg, CA 95437
707-964-0811
DRE 00640014
[email protected]
Paoli, Diana
From: CARIN BEROLZHEIMER <[email protected]>
Sent: Monday, July 14, 2025 8:10 AM
To: City Clerk
Subject: Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main St...

We live on Todd Point. We oppose the size of this project! The city and the county must work together regarding traffic study, impact of humans and pets to blufftop and wildlife at Todd Point, and the environmental impact to groundwater and runoff into ocean.

Opposed!
Carin Berolzheimer
(518) 526-4534
Paoli, Diana
From: Judy Mashhour Azad <[email protected]>
Sent: Sunday, July 13, 2025 2:07 PN
To: ity Clerk
Cc: Judy Mashhour-Azad; [email protected]; Kathy Zarrabi Subject: APPEAL: 1151 SOUTH MAIN STREET
Saturday, July 12, 2025
APPEAL: 1151 South Main Street
NEEDS TO BE ADDRESSED ONE BY ONE AND NOT ISSUES SKIRTED PLEASE. • Where are the story poles required?
• Most of the citizens of Fort Bragg have no idea what you are planning to do to the Gateway to Fort Bragg.
• Yes, I agree more housing is needed but why not build it with the rest of the 3 story structures that your planning commission has pushed through?
• Traffic study needs to be done by someone outside of relative and friend relationships • Stop sign will only cause more congestion on Ocean View • Traffic entering from frontage road and Harbor View will cause not only traffic congestion but also accidents which the city can be held accountable for • Only ADA requirements are through proposed complex, Ocean View has no sidewalks nor does Harbor Avenue which is a pitted un maintained road with no sidewalks, so is the city then responsible to make sure their streets are safe and ADA compliant? • How can anyone who is ADA be able to fairly rent a space other than on the very bottom floor? • Chemicals from automobiles can still sink below the well encasement into our well water supply for all of Pomo Bluffs Subdivision
Judy Mashhour Azad
Paoli, Diana
From: Horstman, Lisi
Sent: Monday, July 14, 2025 8:30 AM
To: Paoli, Diana
Subject: Fw: City council meeting 7/14/2025
Lisi Horstman
Administrative Assistant
Community Development Department
City of Fort Bragg
707-961-2823×119
From: Hamid Zarrabi <[email protected]>
Sent: Sunday, July 13, 2025 4:09 PM
To: cdd <[email protected]>
Cc: HAMID ZARRABI < [email protected]>
Subject: City council meeting 7/14/2025
Comments for up coming City Council meeting 7/14/2025
Council members;
By reading the new modified proposal regarding the apartment project at 1151 South Main St. there are still several problematic health and safety issues.

Traffic and parking being on top of the list. We are being told that this project has adequate on site and street parking and will not cause any major traffic problems. In order for the average local residence to be able to afford living in these units most of them would have to share the rent. According to the California Department of Fair Employment and Housing Two Plus One formula standards, a one bed room apartment could be occupied by three people and two bedrooms could be occupied by five people. This could bring up to 339 occupant and over 300 vehicles to the area. If these numbers do not raise a safety and health issue for the surrounding neighborhood I don't know what will.

I must remind you that this project is located between two Dead End streets which are "No Name Street" and "Harbor Ave." We know, due to inadequate parking at this project, these roads will become a permanent 24/7 parking lot. According to the proposal, Harbor Avenue will only be partially paved and only along and between this project boundaries. The west side and the remaining part of this road will still be a gravel road. The unimproved portion of Harbor Ave. will be totally exposed to contamination by hazardous material leakage from the parked vehicles. This will eventually contaminant and effect the wells at Todd's point, especially, the four residents on Harbor Ave. I have, previously, complained to the city regarding the condition of this road but I was told due to the fact that there are only four residents on this road there will not be any improvements done. Well, now there will be over 300 or so residents using this road. We are now demanding that this road be brought up to the city's road standards by paving and installing proper gutter and drainage system in its entirely. I might add that by doing so you will also provide a proper ADA access to the Pomo blutt park.

Hamid Zarrabi
2 Paoli, Diana
From: Horstman, Lisi
Sent: Monday, July 14, 2025 8:30 AM
To: Paoli, Diana
Subject: Fw: proposed development at 1151 S. Main
From: City of Fort Bragg <[email protected]>
Sent: Sunday, July 13, 2025 3:34 PM
To: cdd <[email protected]>
Subject: proposed development at 1151 S. Main
Message submitted from the < Fort Bragg, CA> website.

Site Visitor Name: Diane Swingle
Site Visitor Email: [email protected]
As a long time local, I oppose any 3 story constuction on the west side of hwy 1. Our visual connection with the Pacific has already been obscured more than enough.

Paoli, Diana
From: Paul Clark <[email protected]>
Sent: Friday, July 11, 2025 10:12 AM
To: City Clerk
Cc: Paul Clark
Subject: FW: 1151 S Main City Council 07/14/2025 Item 7B Attachments: 1151SMain.pdf
Attached some information on Coastal act and views and other protections.

Being promoted as a rural small-town city, one would think it would be of some importance for all of us.

The lack of "story poles" on this or any project that will impact views to the ocean should be a primary concern, not using some lame excuse that it is not important, or exempt, or not on some map that some staff person came up with years ago.

The recent meeting on the MOU with the railroad was very interesting it was stressed that one of the main points of the coastal act was to protect views.

Too bad that is not true. The City Council should demand story poles on any project, no matter what it is, like all the previous applications in this area have been made to do.

No excuses at all on this. Had the story poles been put up you would not be able to find a seat in town hall. But sadly, that is why it was decided by staff that the poles not be used.

There is no good reason at all to have not required this, only bad reasons. The residents of the area will be furious with you if this project goes ahead, and the 2026 election may well be like the one in 2000, when three councilmembers were voted out. That is how we ended up with this current general plan. It did not turn out well for us. We ask you to represent the voters that put you on the council.

I already think of this each time I go by the intersection of Main and Ocean View Drive, and yes, I do look at the ocean as I drive by. It cannot be missed but will be if you allow it to disappear.
1 California Coastal Commission - Wikipedia https://cn.wikipedia.org/wiki/California_Coastal_Commission

WIKIPEDIA
The Free Encyclopedia
California Coastal Commission
The California Coastal Commission (CCC) is a
California Coastal Commission
state agency within the California Natural Resources
Agency with quasi-judicial control of land and public
access along the state's 1,100 miles (1,800 km) of
coastline. Its mission as defined in the California
Coastal Act is "to protect, conserve, restore, and
enhance the environment of the California
coastline".

Protection of coastal resources includes shoreline
public access and recreation, lower cost visitor California Coastal Commission Logo accommodations, terrestrial and marine habitat
Agency overview
protection, visual resources, and regulation of
Formed 1972
agricultural lands, commercial fisheries, and
industrial infrastructure. By regulating land use Jurisdiction California within a defined coastal zone extending inland from Headquarters San Francisco 3,000 ft (910 m) up to 5 mi (8.0 km), it has the
Employees 205(2024-2025)
authority to control construction of any type,
including buildings, housing, roads, as well as fire Annual budget $48 million (2024-2025) and erosion abatement structures, and can issue Agency Kate Huckelbridge, fines for unapproved construction. It has been called executive Executive Director(2] the single most powerful land-use authority in the Parent agency California Natural Resources United States due to its purview over vast Agency
environmental assets and extremely valuable real
Website coastal.ca.gov (https://coasta
estate.
l.ca.gov/)
Critics say that the CCC has exceeded its mission, as Footnotes well as exacerbated California's housing shortage by 11] limiting housing supply in some of the state's most
affluent areas, and harmed the environment by defending parking infrastructure, blocking public transit and scuttling dense housing development, while proponents say that the Commission has protected open space, views, habitats, endangered species, and public coastal access.

Composition
The commission is composed of 12 voting members, 6 chosen from the general public, and 6 appointed elected officials, 3] Being on the commission can carry responsibilities which are highly politicized.14] The 12 appointed commissioners control zoning, compel property alterations, 1 of 19 7/9/2025, 8:54 AM
California Coastal Commission - Wikipedia https://en.wikipedia.org/wiki/California_Coastal_Commission impose fines, bestow construction approvals or vetoes, and require public thoroughfares on private property. 5116]
Separate from the appointed Commissioners are the commission's employed staff, numbering some 164 people during 2021-22.7
Jonathan Zasloff, a law professor at the University of California, Los Angeles stated that "The commission is the single most powerful land use authority in the United States given the high values of its jurisdiction and its high environmental assets." and that, because its members are appointed by the governor and the State Senate and Assembly leaders (which have generally been Democrats), The commission reflects a constituency that is important to Democrats. "5] Authority
Development activities are broadly defined by the Coastal Act to include (among others) construction of buildings, divisions of land, and activities that change the intensity of use of land or public access to coastal waters. Development usually requires a Coastal Development Permit from either the Coastal Commission or the local government if such development would occur within the Coastal Zone. 8! The Coastal Zone is specifically defined by law as an area that extends from the State's seaward boundary of jurisdiction, and inland for a distance from the Mean High Tide Line of between a couple of hundred feet in urban areas, to up to five miles in rural areas.!6l The state authority controls construction along the state's 1,100 miles (1,800 km) of shoreline.l4] One of the provisions passed under the 1976 California Coastal Act specifically prohibits State Route 1 from being widened beyond one lane in each direction within rural areas inside the Coastal Zone.!9l The Coastal Commission also had the power to block a proposed southern extension of State Route 241 to Interstate 5 at San Onofre State Beach in San Diego County. 10] The Coastal Commission has the ability to overrule local elected representatives and has also gained the ability to fine private citizens. [1][12) The agency has sought enforcement through the courts as it originally did not have the power to issue fines on its own to alleged violators. A bill in the California legislature to grant the commission a broad power to issue fines was defeated in September 2013. 13] However legislation attached to the state budget in the summer of 2014|141 finally granted the authority to impose fines on violators of public-access which could apply to about a third of the backlog of over 2,000 unresolved enforcement cases. 15/|16] The first notable fines were issued in December 2016 against Malibu property owners Dr. Warren M. Lent and his wife, for $4.2 million, and Simon and Daniel Mani, owners of the Malibu Beach Inn, who settled amicably for $925,000. The difference in severity of the fines were attributed to the "egregious" nature of the Lent case. [17]
Local agency administration
A "local coastal program" is the official name for a zoning plan controlled by the commission but administered by a local agency. The commission can retake granular control of any project if it is 2 of 19 7/9/2025, 8:54 AM
California Coastal Commission - Wikipedia https://en.wikipedia.org/wiki/California_Coastal_Commission appealed. 8! An appeal will take approximately 6-8 months on average to reach a final decision and may take longer to resolve more complicated appeals. 18] The commission is the primary agency which issues Coastal Development Permits. However, once a local agency (a County, City, or Port) has a Local Coastal Program (LCP) which has been certified by the commission, that agency takes over the responsibility for issuing Coastal Development Permits. For areas with Certified LP's, the Commission does not issue Coastal Development permits (except in certain areas where the Commission retains jurisdiction, i.e. public trust lands), and is instead responsible for reviewing amendments to a local agency's LCP, or reviewing Coastal Development Permits issued by local agencies which have been appealed to the commission. 18] A Local Coastal Program is composed of a Land Use Plan (LUP) and an Implementation Plan (IP).

A Land Use Plan details the Land Uses which are permissible in each part of the local government's area, and specifies the general policies which apply to each land use. The LUP can be a part of a local government's general plan. The Implementation Plan is responsible for implementing the policies contained in the LUP. The IP is generally a part of the city's zoning code. 19] One example
The Local Coastal Program (LP) for a run-down gateway to Channel Islands Harbor in Oxnard is designated for visitor-serving commercial uses and harbor-related uses that support recreational boating and fishing. The county owns and manages the harbor and wanted to amend the LCP to allow a mixed-use development with up to 400 apartments as their selected developer said the project was only feasible with the housing. In 2020, the commission refused to override the denial by the city of Oxnard of land-use changes as that is only intended to be used in rare instances when a local government is standing in the way of the development of a public works project that would meet regional public needs. 20]
Managed retreat
The Commission recommended cities implement managed retreat philosophies allowing oceans to naturally erode developments thereby nourishing beaches with reclaimed sand made of disintegrated former properties. [21||22||23]
In 2019, after the Commission allowed a new seawall to be constructed to protect apartments built in 1972, but denied a permit for townhomes built in 1984, the owners of the 1984 townhomes sued. [24] The Commission reasoned that the Coastal Act states that the Commission "shall" issue permits for coastal armoring designed to protect "existing structures," which the Commission interpreted as existing at the time of the passage of the Coastal Act, 1977.24. In 2023, the judge ruled for the plaintiffs, stating that the Commission's position was an "erroneous and unreasonable" interpretation of the law, [24]
The Commission appealed the ruling, and observers have stated that the final result of this litigation will have far-reaching consequences on the future of California's coast. 24) Currently, 14% of the whole of the California coastline, and 38% of Southern California beaches are protected with seawalls. [24] One proposal to remedy this situation and allow managed retreat was a bill which 3 of 19 7/9/2025, 8:54 AM
About Caltrans ContactUs ADA Certification RequestADA Compliant Documents • Settings @ Translate Et Caltrans
Home Programs Environmental Analysis Coastal Program
Coastal Act Policy Resource Information
Coastal Scenic and Visual Resources
Coastal Scenic and Visual Resources
Coastal Scenic and Visual Resources Basics
The Coastal Act requires scenic and visual qualities of coastal areas to be considered and protected as a resource of public importance. Development is also required to be sited and designed to protect public views to and along the ocean and other scenic areas. Depending on the characteristics of the site and surrounding area, scenic resources can include sandy beaches and blue water ocean views, rocky headlands and shorelines, coastal bluffs, coastal lagoons and marshlands, rural farmlands and pasturelands, and open or forested slopes, hillsides, ridgelines and mountain tops, as well as more urbanized harbors and waterfront areas. Cultural features set in scenic areas and other historic or natural points of interest visible from public viewing areas or scenic corridors may also be considered scenic resources.

Despite Coastal Act protections, incremental approval of individual developments and variances that include minor additions and maintenance activities have resulted, over time, in the cumulative degradation of public views and coastal scenic resources.

Coastal issues that may need to be addressed during project development could include:
• Blocking or altering bluewater views
• Loss or alteration of views to open space, rural areas, or inland hillsides and mountains
• Landform alteration through grading and earthwork
• Compatibility with, and subordination to, surrounding areas and change in character
• Night lighting and glare
• Design considerations such as guardrail type and height, down drain color, retaining wall or viaduct concrete color, and aesthetic treatments (rock or earth textured concrete)
• Landscaping and planting plans
Coastal Act Policies Related to Coastal Scenic
and Visual Resources
• Coastal Act Section 30251 states the scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance. Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the character of surrounding areas, and, where feasible, to restore and enhance visual quality in visually degraded areas. New development in highly scenic areas such as those designated in the California Coastline Preservation and Recreation Plan prepared by the Department of Parks and Recreation and by local government shall be subordinate to the character of its setting.

Coastal Scenic and Visual Resources
considerations when developing your project
and preparing to submit a coastal
development permit
When applying for a CDP from the California Coastal Commission (Commission) or a local agency where project development may result in impacts to visual resources due to project location, size, or scale, it is critical to provide a thorough assessment of coastal view impacts and to address potential view impacts as early as possible in project planning. In addition to Coastal Act policy requirements, a local government's certified Local Coastal Program (LCP) may also have more specific special provisions that must be considered for siting and design, such as particular height limitations, protecting particular view corridors and vantage points, or protecting the community character of certain areas.

Key considerations to help determine your project's consistency with applicable visual and scenic resource protection policies and its potential for permit approval include:
• Baseline: Consider the context of the existing scenery and coastal visual resources. In addition to project plans, it may be necessary to provide demonstrate the change from existing to proposed conditions.

Information may be required to show how the size and scale of the proposed development compares with the existing visual baseline and site-specific visual context. For example, consider whether the landscape is rural or urban, whether there will be a visual change to an identified scenic resource such as a historic bridge, whether there are isting unobstructed ocean views that may be affected, or wheth oposed new lighting in locations with outdated or no lighting u affect dark skies.
• Alternatives Analysis: Strict Coastal Act protections of scenic coastal resources require a thorough alternatives analysis to determine if a more appropriate alignment or design alternative would be feasible to reduce the potential for impacts on visual and scenic resources. The Commission is required to identify the least environmentally damaging alternative when making findings pertaining to scenic and visual • Avoidance and Minimization: The analysis of project impacts on visual resources should take into account avoidance and minimization efforts such as siting and design measures to reduce effects and mitigate to the greatest extent feasible. The use of mitigation measures alone will not ensure that the Commission can approve a project. However, where impacts are unavoidable, the Commission has approved mitigation measures (usually as special conditions of an approved CDP) such as restrictions on the type, amount, and location of new lighting or signage; requirements for an earth-toned color scheme; modifications in the height, scale, or style of the project; limitations on guard rail height or type; utility undergrounding; and other design strategies.

To help streamline the process of rail selection and coastal development permitting, Caltrans and the Commission have developed a guidance document for designing bridge rails and barriers in the coastal zone. Bridge Rails and Barriers: A Reference Guide for Transportation Projects in the Coastal Zone includes fundamental design standards, aesthetic designs and treatments, and design features to ensure safety, versatility, and ease of maintenance.

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STATE OF CALIFORNIA -- THE RESOURCES AGENCY ARNOLD SCHWARZENEGGER, Governor

CALIFORNIA COASTAL COMMISSION
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105-2219
VOICE AND TDD 415) 904-5200
W 3
MEMO
May 3, 2004
TO: Commissioners and Interested Persons
FROM: Peter Douglas, Executive Director
RE: Protecting Views from the Ocean Under the Coastal Act INTRODUCTION: The Commission has asked for a summary review and discussion of actions protective of scenic coastal resources and specifically the protection of views from the ocean to the land. The protection of scenic values along the California coast, together with public access, is a principal driver underlying continuing strong public support for effective coastal management.' The premiere objective of the California Coastal Plan called for in the California Coastal Zone Conservation Act of 1972 (Proposition 20 - a citizen's initiative) was: The maintenance, restoration, and enhancement of the overall quality of the coastal zone environment, including, but not limited to, its amenities and aesthetic values. " The "coastal zone" was defined in the initiative as extended from three miles at sea inland to a specifically delineated boundary.

The California Coastal Act of 1976 made permanent the Coastal Commission and established the conservation and use policies guiding planning and regulation of land and water areas in the new coastal zone established by that law. Specifically, relative to the protection of scenic values, the Act provides that:

The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance. Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas. [emphasis added] to minimize the alteration of natural land forms, to be visually See Public Policy Institute of California Statewide Survey: Special Survey of Californians and the Environment, November 2003 (this survey focused on public attitudes toward and support for coastal P'cion 7302 (a) Public Resources Code (repealed January 1, 1977 and replaced by the Coastal Act).

Protecting Views
Memo to CCC

Page 2 ends

compatible with the character of surrounding areas, and, where feasible, to restore and enhance visual quality in visually degraded areas....

Section 30009 PRC requires that "[The Coastal Act] shall be liberally construed to accomplish its purposes and objectives."
The Coastal Commission has implemented scenic resource protection policies primarily by focusing on land-based scenic views from public parks, trails, roads and vista points.

Over the years however, and in recognition of changing recreational use patterns and input from the boating community, the Commission began calling for protection of landscape views from state ocean waters (3 miles) in rural areas of the coast that are essentially devoid of development as well as other areas having unique landforms even in built environments. This position takes into account the fact that boating is and will continue to be an increasingly important form of coastal recreation that is also called out for protection in the Coastal Act. (See section 30224 PRC.) The conceptual basis for this position is quite simple: Like scenic vistas from upland public places, the enjoyment of uncluttered views from the ocean to and along California's magnificent coastline is a public resource and aesthetic value of importance to substantial numbers of current and future coastal users. It is an important public interest - a coastal resource worthy of protection.

Protecting views from the ocean: While the primary focus of the Commission's application of the scenic resource protection policies of the Coastal Act has been from the edge of the sea along the coast and inland, as well as other vistas in the coastal zone, views from the ocean to the land have also been taken into account. Viewsheds include views from a particular place on land to and along the ocean and scenic coastal areas as well as from the ocean toward the land and along scenic coastal areas. Generally, viewsheds from the ocean toward land that have been considered important enough to warrant protection through siting, design, landscaping and other measures have most often included geographic reaches of coast that are rural in character and relatively unaltered by human activity. However, in some unique situations scenic values as enjoyed from coastal waters have also been taken into consideration and protected in urban areas such as Marina Del Rey and Point Loma in San Diego.

The protection of scenic values in unique geographic places on the planet is receiving increased attention from government as population grows and tourism becomes a greater part of national and local economies. Because increasing numbers of people enjoy scenic vistas from places on or in the water (i.e., coastal ocean waters, seas, lakes, rivers, great ponds, estuaries, etc.), protecting such public values and resources has become a recognized and legitimate land and water use planning and regulation objective. A recent court decision upholding rules designed to protect views from the waters of lake Tahoe 3 Section 30251 PRC.

Paoli, Diana
From: Paul Clark < [email protected]>
Sent: Friday, July 11, 2025 10:25 AM
To:

Cc: Paul Clark; CMAR ([email protected])
Subject: City Council 07/14/2025 Item 7B
Attachments:

Some reminders from the railroad MOU meeting about what the coastal act says, and from the city website stating goals and what Fort Bragg is, a rural small town.

Please make sure it stays that way. This is as has been said the gateway to our town. All of us look to the ocean when we drive by, or are stopped at the light, or in McDonalds,
Or just driving either direction. It's a big part of why we live here. We don't want it to look like every big city in California, and I suspect you don't either, but feel pressured to approve this project that obviously does not meet the intent of the zoning, regardless of what you have been told. Our appeal should have been the first clue, please listen to all of us, not just those that want housing at any cost.

I also refer you to the unproven need for 200 units by 2026. There is not local study.

Thank you
Paul Clark
FromMEetiNg
MoU
Coastal Policy Alignment
Coastal Act Priorities
• Coastal Access
• Open Space and Recreation
• Coastal Dependent Uses
• Resource Protection
Protection of views
From MoU
meeting

PROTECTION OF PUBLIC
VIEWS to and along the ocean.

The Coastal Act protects public views
from street corridors and public parks.

The site will be analyzed for impacts to
ocean views as part of the LCP amendment
process.

Potential views could be blocked with future
development from Alder, Madrone, and
Maple Streets and between Walnut and
South Street.

The LCP amendment will establish view
corridors from public vantage points.

C6:4.2025

CITY COUNCIL WORKSHOP
Thursday, 26, 2025 - 5:30 pm
Cotton Auditorium
500 N. Harold Street
Fort Bragg, CA 95437
Engaging the community in shaping the direction and content of the Mill Site Memorandum of Understanding (MOU) through a collaborative, transparent process focused on land use planning.

WORKSHOP PURPOSE
This community workshop is the first in a series designed to shape the Memorandum of Understanding (MOU) between the City of Fort Bragg and Mendocino Railway. Your input will help guide long-term planning and development on the Mill Site.

AGENDA

1. Welcome & Opening Remarks
- Introduction by Mayor & City Manager
- Importance of Community Participation

2. Overview of MOU Process
• What is the MOU?
• How it fits into the Mill Site Master Development Program • What is the purpose of this workshop?
• What is the Public Process in Shaping the MOU?
• Goals of the MOU Process
• Schedule and decision-making milestones

3. MOU TOPICS FOR COMMUNITY INPUT
MOU Topic #1: Land Use Planning Context
What types of uses do you want to see prioritized on the Mill Site? MOU Topic #2: Key Factors Influencing Land Use and Development What challenges or opportunities should shape the land use strategy? MOU Topic #3: Infrastructure Needs & Financing Strategy How can infrastructure serve both the site and the broader community, and Costs? MOU Topic 4: Identifying Special Real Estate Land Transactions What principles should guide land ownership and transfers? MOU Topic 5: Articulating the Functions and Terms of the Master Development Agreement
What guarantees or public benefits should be included in the agreement?

4. Entitlement Strategy & Coastal Policy Alignment
Overview of how land use entitlements will be structured:
- Local Coastal Program Amendment
- Zoning and CEQA (Programmatic EIR)
- Coastal Act Policy Alignment
• Community & City Council Feedback on how the plan can support priority uses such as open space, access, and visitor services

5. Illustrative Plan Update - Mendocino Railway
Presentation of the revised draft plan based on community and Council feedback, with focus on:
- Rail-related uses on the North Mill Site
- Updates to proposed land use areas
• Community & City Council feedback on the updated plan

6. Rail-Related Zoning Proposal
New zoning district approach for rail-related land use:
- Objective standards and permitted uses
- Framework for mixed-use or future transitions
• Community & City Council feedback on clarity, appropriateness, and community safeguards

7. Summary & Next Steps
- Recap of community feedback received
- Direction & Feedback from the City Council
- Upcoming Council Study Session
- Opportunities for ongoing participation
Thank You for Attending.

City Mission, Vision, and Core Values | Fort Bragg, CA https://www.city.fortbragg.com/departments/city-manager-s-office/c….

SERVICE FINDER

CITY MISSION, VISION, AND CORE VALUES
T fe 1S843
e.

OUR MISSION
Fort Bragg is a small town nestled between the coast and the redwoods with a strong sense of community that seeks to preserve its environment while providing resilient public facilities and infrastructure and supporting a safe and vibrant economic, multi-cultural, and recreational experience for both locals and visitors alike. 1 of2 7/2/2025, 10:58 AM
City Mission, Vision, and Core Values | Fort Bragg, CA https://www.city.fortbragg.com/departments/city-manager-s-office/c...

OUR VISION
Fort Bragg, a California coastal destination with rich natural resources and rugged beauty, is transforming our future by weaving together our people, ecosystems, and economy to create community prosperity. We are making our mark in the 21st Century by creating climate-ready water and energy independence, housing and economic opportunities, accessible health care, community public safety, and education for all

OUR CORE VALUES
Innovation and Sustainability drive our city forward, encouraging creative solutions and continuous improvement by embracing new ideas and technologies to enhance quality of life.

Honesty and Integrity emanate throughout our community to engender the trust, transparency, responsibility, and accountability that our citizens deserve.

We are Service-Oriented and Responsive to the public and to each other to demonstrate our genuine commitment to create a Fort Bragg that serves us today and readies us for a successful tomorrow.

Leading with Fair and Ethical principles and practices, Fort Bragg promotes an inclusive community culture of unity and equality that openly invites everyone to enjoy our unique coastal enclave.

We champion Conservation, Preservation, and Protection of our natural environment that is the unifying foundation of Fort Bragg stewardship.

Consistent Communication and Collaboration nourish civic pride and celebrates the diversity of our city and the meaningful municipal services that our residents and businesses rely on. 2 of2 7/2/2025, 10:58 AM

MUSSION, VISION, AND VALUES
he City of Fort Bragg co-created the foundational elements of the SP28+ through an inclusive Council, Staff, and Community process that developed the City's Mission, Vision, and Values. The process began with surveys of the entire City staff, followed by interviews with City Council and internal City staff workshops to assess priorities, opportunities, and anticipated challenges for the coming years. The efforts of this preparation culminated in a public workshop where residents, businesses, and other interested parties were invited to attend, review the draft Strategic Plan framework, and provide input. This final document is a collaboration of diverse voices that provide a thoughtful, strategic direction to move the City forward for the next five years and beyond.

While Fort Bragg is small town in terms of numbers of people - no more than 7,000 residents have remained steady over the past several decades - our City reflects an in-depth diversity and vibrancy that is unparalleled for a community tucked quietly within a forested coastline.

Our community has resounding alignment in our City's Mission of what our purpose is; our Vision of where we are headed; and our principled Core Values that underlie what unites us.

Our multi-generational voices and passion for where we live and thrive, and our commitment to create and embrace Fort Bragg's future is why we remain steady and committed to preserving our unique character while embracing deliberate change.

OUR MISSION OUR VISION
Fort Bragg is a small town nestled Fort Bragg, a California coastal destination between the coast and the with rich natural resources and rugged beauty, redwoods with a strong sense of is transforming our future by weaving together community that seeks to preserve our people, ecosystems, and economy to its environment while providing create community prosperity. resilient public facilities and We are making our mark in the 21st Century infrastructure and supporting a safe by creating climate-ready water and energy and vibrant economic, multi-cultural, independence, housing and economic and recreational experience for both opportunities, accessible health care, locals and visitors alike. community public safety, and education for all. 4 City of Fort Bragg

OUR VALUES
Innovation and Sustainability drive our city forward, encouraging creative solutions and continuous improvement by embracing new ideas and technologies to enhance quality of life.

Honesty and Integrity emanate throughout our community to engender the trust, transparency, responsibility, and accountability that our citizens deserve.

We are Service-Oriented and Responsive to the public and to each other to demonstrate our genuine commitment to create a Fort Bragg that serves us today and readies us for a successful tomorrow.

Leading with Fair and Ethical principles and practices, Fort Bragg promotes an inclusive community culture of unity and equality that openly invites everyone to enjoy our unique coastal enclave.

We champion Conservation, Preservation, and Protection of our natural environment that is the unifying foundation of Fort Bragg stewardship.

Consistent Communication and Collaboration nourish civic pride and celebrates the diversity of our city and the meaningful municipal services that our residents and businesses rely on.

Strategic Plan 2024-2028+ 5
1E. Develop affordable and market-rate housing that Leading with fair and is accessible for every arc of residents' lifetime
experiences including Fort Bragg's permanent ethical principles and and temporary workforce, students, retirees,
and newcomers who want to share our rich practices, Fort Bragg cultural and natural home.
promotes an inclusive
• Dedicate staff to support and promote
affordable and accessible housing community culture
development that complements Fort of unity and equality Bragg's small town by the sea:
that openly invites
• Support Housing Mendocino Coast in
providing home ownership opportunities everyone to enjoy our to workforce using the Community Land
Trust model that preserves land for housing unique coastal enclave. in perpetuity.
• Update zoning regulations to accommodate
mixed-use developments, create innovation zones
for climate-resilient housing, promote walkability,
and preserve the character of our diverse
neighborhoods.
• Streamline, educate, and expedite the
permitting process, including:
» Crime Prevention Through
Environmental Design (CPTED)
and a fee structure to foster
ease of application, quick
turnaround, and status
tracking that supports fair
and equitable permitting
practices.
» Pre-application meetings,
software upgrades, in-house
plan checks and inspections.

Develop multi-residential opportunities
for shareable spaces that support students,
temporary employees, and other interested
residents for independent living.
• Consider City-owned or employee subsidized housing to attract a high-quality workforce while addressing barriers to living in Fort Bragg.
• Promote inclusive and transitional housing and integration planning for the underserved and unhoused populations to improve quality of life and support all of Fort Bragg's • Develop housing incentives to encourage conversions and additional housing. • Begin the long-term planning process to address a demographic influx and the associated economic, housing, and social disruptions triggered by the escalating climate crisis. • Conduct an analysis to better understand climate-driven demographic influx and associated economic and social disruptions to plan for future needs and contingencies. 10 City of Fort Bragg
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Housing Element Law +
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Request 25-109 - NextRequest - Modern FOIA & Public Records R... https://cityoffortbraggca.nextrequest.com/requests/25-109 City of Fort Bragg, California
CP NextRequest
Request Visibility: & Unpublished
Request 25-109 E Open
Dates Request
Hi there, how do I make formal request
Received
for copies of any studies the city has
June 19, 2025 via email relied upon to declare the housing "crisis" that lead to the city's goal of 200
residential units by 2026? I have asked at
several PC and CC meetings but have not
Requester received any response. My guess is there
is none but am making this formal
8 Paul Clark request.
[email protected] Please advise.
• 809 North Main Street, Fort Bragg, CA, Thank you
95437
Paul Clark
2 707-964-0811
Century 21 Fort Bragg Realty
Щ Century 21 Fort Bragg Realty
809 North Main Street
Fort Bragg, CA 95437
Invoices
707-964-0811
No invoices due DRE 00640014
[email protected]
Staff assigned
Timeline Documents
1 of3 6/30/2025, 2:35 PM
CityMtg 20250714b Request for Information
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEOA Exempt per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development *** ***
We are requesting the location of each bore hole / exploratory well (Bh/Ew) bored on the property at 1151 South Main Street, Fort Bragg CA 95437.

This information request should include:

City of Fort Bragg
Received
Date of boring
JUL 1 0 2025
Location of boring, plotted on this project's site plan Diameter of boring
Geologic log, with all strata encountered
Total depth of boring
Depth when water was encountered
If a completed well report is NOT available, then include these:

Thickness of silty soil
Thickness of terrace deposit
Thickness of Franciscan bedrock
Copies of invoices, and description of sealing material for each Bh/Ew Labor invoice for sealing each Bh/Ew
Name and signature of person confirming each Bh/Ew has been sealed according to California Department of Water Resources, Part III. Destruction of Monitoring Wells Sections 18 & 19.

Respectfully submitted by Guy Burnett & Truthful Kindness on 10July2025 Guy Burnett Guy RBurt
Trihal Findress
Truthful Kindness

Page 1 of 1 ends

on 201u/2025 O
City Council Mtg 14July2025c BOIL Water Notice
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Ex9tyRm6508499 l5332 - Class 32 Infill Development Projects and 15195 Infill Housing Development Received ***
The City Council has been presented with documentation that calls into question the legitimacy of proceeding with this project on site of 1151 South Main Street.

Here is MORE documentation of the misuse of this property for the project, which calls for a "NO" vote is needed on this project:

On 29Apr2025, Mendocino County Public Health issued a public advisory Water Quality Alert - Mendocino, CA; "The State Water Resources Control Board, Division of Drinking Water, has issued citations and compliance orders to three businesses west of Highway 1 in the town of Mendocino. These actions have resulted in boil water notices being issued for those businesses." ((see attached)).

One of the three wells had a finished depth of over 150', a properly installed sanitary seal, and still was "under the influence of surface water" contamination.

The contaminated stormwater from this project will inundate and overwhelm specific confined areas of a filtration/percolation basin. The soil bedrock constitution is not capable of adequately allowing a slow percolation process. In all likelihood wells along Harbor Avenue and further west will be destroyed because of this project.

City council does not have the right or jurisdiction to take and/or allow the destruction of personal property without imminent domain. *** ***
Respectfully submitted by Guy Burnett & Truthful Kindness on 10July2025 Guy Burnett Sy R.Burnett Jely 10,2025
TithfulL Kindness 10 duly 2085
Truthful Kindness
J 2

Page 1 of 1 ends

Fort Bragg City Council Mtg 14July2025a Nolan
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Exempt per Section 1533ZHg/as$ BarthBragg Development Projects and 15195 Infill Housing Development Received *** ***
JUL 10 2025
Excerpts from notes by Dick LaVen 27Aug2003 regarding the 23Aug1995 Nolan Report on Todds Point; area groundwater recharge & water balance report by Nolan Associates. These excerpts show that a "NO" vote is needed on this project.

Highest priority from Summary and Conclusions is page 3 excerpt:

6... BETTER THAN A CHOLERA EPIDEMIC." - Dick LaVen

Page 3 ends

There is no thought about potential health problems when the report proposes to recharge the aquifer from septic systems. The report says the terrace soils give "poor filtration for septic disposal" and that the SCS soils report recommends community sewage systems because of the potential for failure of septic tank absorption fields. But the report includes 150 gallons per day per household contributed to groundwater from each septic system as if it were a good thing. How about a dye study? It's better than a cholera epidemic.

So what should we do? My recommendation is a detailed inventory of surface topography, bedrock surfaces & fractures and wells & septic systems & interviews of residents & water use on the site. This will identify sub-basins. Then let some good groundwater modeler build a picture of what happens under 3 drought years in a row for each of the sub-basins, all the while separating septic leachfield contributions from rainfall contributions.
*** ***
Editorial comments:

At least septic systems have an inflow/outflow period of 7-15 days for its digestive process. Septic systems generally do not include runoff from parking lot consisting GRB.

Page 1 of 4 ends

IB
Fort Bragg City Council Mtg 14July2025a Nolan
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Exempt per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development *** ***
of petroleum products, antifreeze, pesticides, herbicides, and random "forever chemicals"
Please allow me to point out that this project intends to introduce polluted surface drainage containing petroleum products from parked vehicles, coolant drippings, pesticides, herbicides, animal waste, household waste drippings, etc, into the O'to 10' soil layer overlaying the fractured Franciscan bedrock. This slurry of chemical and biological soup will have 0 minutes of treatment time prior to its introduction to the chain of poor filtration leading to the water supply on Todd's Point. ((end editorial comment.))
*** ***

Page 1 ends

1. This level of analysis is no longer adequate. The information readily available will allow us to do a better job.

2. The information provided in the report does not support the report's conclusions about the adequacy of the Todd Point aquifer. ...

Adequacy of the Todd Point groundwater recharge and water balance evaluation:

The NOLAN Associates report references reporty by Scott (1982) and the USDA Soil Conservation Service (1987) describing the marine terrace fill material and underlying bedrock on Todd Point as:

1. An excessively drained sandy loam soil formed from and on marine terrace material. This soil has depths of 0 to 4 feet.

H

Page 2 of 4 ends

Fort Bragg City Council Mtg 14July2025a Nolan
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Exempt per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development

2. Marine terrace deposits, sand and gravel. The deposits range from 0 to 24 feet in thickness.

3. Very irregular surfaced Coastal Belt Franciscan sandstone. The sandstone bedrock itself is widely recognized as non-water bearing. *** ***

Page 2 ends

Pg 2, paragraph 2: The bedrock itself is does not produce groundwater. The bedrock is fractured and most of the fracture zones are readily observed on airphotos.. Wells have been successfully drilled into the bedrock, but if those producing wells are plotted on a map, they will be found to be located near bedrock fracture zones.
*** ***
Editorial comment: Unfortunately, the 20' of sanitary seal provides a very weak level of protection for a well drilled through fractured Franciscan bedrock. This presents poor filtration. ((end editorial comment)).
*** ***

Page 3 ends

There is no thought about potential health problems when the report proposes to recharge the aquifer from septic systems. The report says the terrace soils give "poor filtration for septic disposal" and that the SCS soils report recommends community sewage systems because of the potential for failure of

Page 3 of 4 ends

G
Fort Bragg City Council Mtg 14July2025a Nolan
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Exempt per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development *** ***
septic tank absorption fields. But the report includes 150 gallons per day per household contributed to groundwater from each septic system as if it were a good thing. How about a dye study? It's better than a cholera epidemic.

So what should we do? My recommendation is a detailed inventory of surface topography, bedrock surfaces & fractures and wells & septic systems & interviews of residents & water use on the site. This will identify sub-basins.

Then let some good groundwater modeler build a picture of what happens under 3 drought years in a row for each of the sub-basins, all the while separating septic leachfield contributions from rainfall contributions.

Respectfully submitted by Guy Burnett & Truthful Kindness on 10July2025 Guy Burnett Ley R Burnett July 10,2025
Truthful Kindness Total Kinder 1000d 2025
(RD

Page 4 of 4 ends

City, of Fort Bragg
Received
To: Dave Goble JUL 10 2025
From: Dick LaVen
Date: August 27, 2003
Subject: Notes on 1995 Todd Point area groundwater recharge & water balance report by Nolan Associates:

Summary and conclusions:

1. This level of analysis is no longer adequate. The information readily available will allow us to do a better job.

2. The information provided in the report does not support the report's conclusions about the adequacy of the Todd Point aquifer.

3. The information provided in the report supports the assumption that the area east of Hwy 1 does not contribute to the recharge of the Todd Point aquifer.

Contributions to the Todd Point aquifer from the area east of Hwy. 1:

The Nolan Associates report cites work by Krazan & Associates on the proposed K-Mart site. Krazan & Associates put down 24 borings in the winter of 1994-95 and came up with mostly dry holes. Krazan & Associates only hit water in one hole.

The author reports sandstone bedrock outcrops and shows the outcrops on the map. The outcrops are in the T intersection of Hwy 1 and Hwy 20. These outcrops are shown on the Nolan Associates Figure 1.

The geologic cross-section shown on the Nolan Associates Figure 2 shows a slice through a bedrock ridge trending in a northerly direction. The prism of Hwy 1 is built on this sandstone outcrop and on the shallow terrace soils to the north.

Construction of the highway prism and continued traffic has compacted the prism into a de-facto dam.

Based on these observations, it is reasonable to conclude that it is unlikely that groundwater moves from east to west across bedrock and Hwy. 1 prism barrier.

Adequacy of the Todd Point groundwater recharge and water balance evaluation:

The Nolan Associates report references reports by Scott (1982) and the USDA Soil Conservation Service (1987) describing the marine terrace fill material and underlying bedrock on Todd Point as:

1. An excessively drained sandy loam soil formed from and on marine terrace material. This soil has depths of 0 to 4 feet

2. Marine terrace deposits, sand and gravel. The deposits range from 0 to 24 feet in thickness.

3. Very irregular surfaced Coastal Belt Franciscan sandstone. The sandstone bedrock itself is widely recognized as non-water bearing.

The Nolan Associates report states that "south of the bedrock outcrop, the terrace surfaces (and presumably the underlying bedrock surfaces slope) LaVen : -ew of Todd Point area groundwater recharge Page 2 of 3 southward towards Hare Creek. North and west of the bedrock outcrop, slopes drain to the north and west. This divides the Todd Point "aquifer" into at least three separate units; east of the bedrock ridge (which may be ignored), south of the ridge, and north and west of the ridge. The Nolan Associates report started off on that idea, but conveniently forgot about it when the water balance was developed.

The bedrock itself is does not produce groundwater. The bedrock is fractured and most of the fracture zones are readily observed on airphotos.. Wells have been successfully drilled into the bedrock, but if those producing wells are plotted on a map, they will be found to be located near bedrock fracture zones.

It is wrong to imply that the sandstone is producing 8.7 gpm. The water produced by the wells is water draining from the marine terrace material and accumulating in the fracture zones, and the volume stored in the cracks is less than what Nolan Associates imply. The cracks simply accumulate what runs through the terrace soils. In addition, the bottom of some of the Todd Point wells might be below sea level and might be tapping fresh groundwater held in a lens on top of salt water. The study quotes Scott (1982), who drew the right conclusions. There is no water in the sandstone.

The Nolan Associates report indicates that there are 36 residences on Todd Point, plus the College of the Redwoods campus. The Nolan Associates report provided data from 12 well driller's reports. Presumably, since very few buildings are served with City of Fort Bragg water, there are many other wells drilled into the Todd Point aquifers.

In theory, there are well driller's reports for most of the wells drilled into the Todd Point aquifers. It is recognized that the well driller's reports are less than precise, and yes, we need to take the information provided with several grains of salt, but the reports will provide data that will be useful in further characterizing the aquifers.

It is rumored that peoples' wells run dry now and they have to import water.

Where are those wells? We need to see them, to identify their locations on a map and to have the well owners explain their problems. There will be a pattern.

Also Nolan Associates report does not tell us where wells were drilled & came up water, with dry holes. Nor does the report tell us about CR's water source and use City That was conveniently overlooked in the water balance.

The water balance itself is based on the assumption that all 174 acres delineated by Nolan Associates contribute water to a single Todd Point aquifer. But the eastern section covers about 51 acres and the southern section covers about 19 acres. That leaves 104 acres to supply water to the largest northern and western aquifer, not 174 acres as assumed in the water balance model.

There is no thought to cones of depression set up by wells and how they react when the cones intersect. The interference between wells is magnified when they are drawing from the same bedrock fracture zone. It's like two people slurping from straws in a single old-fashioned ice cream soda glass. 8 LaVen : ew of Todd Point area groundwater recharge rt Page 3 or 3 There is no thought about potential health problems when the report proposes to • recharge the aquifer from septic systems. The report says the terrace soils give "poor filtration for septic disposal" and that the SCS soils report recommends community sewage systems because of the potential tor failure or septic tank absorption fields. But the report includes 150 gallons per day per household contributed to groundwater from each septic system as if it were a good thing.

How about a dye study? It's better than a cholera epidemic.

So what should we do? My recommendation is a detailed inventory of surface tonnaraphv. bedrock surfaces & fractures and wells & septic systems & interviews of residents & water use on the site. This will identify sub-basins.

Then let some good groundwater modeler build a picture of what happens under 3 drouaht vears in a row for each of the sub-basins, all the while separating septic leachfield contributions from rainfall contributions.

Submitted by
Guy RBumett Jey 10, 2025
TribalL Kind wess 102uly 2027
9 City Council Mtg 14July2025d Historical Facts
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Exempt per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development *** ***
• On 16Dec2003, 24Mar2015, 12Nov2018, 11Jun2025, 18Jun2025 and 25Jun2025, the following excerpts notified the above entities of the soil characteristics on Todd Point; "The U.S. Soil Conservation Service (SCS, 1987) performed a soil survey that includes the Todd Point area....

Because of its rapid permeability, the Heezer sandy loam is considered to have poor filtration ability ..."
• The city has failed to confirm that bore holes have been properly sealed on this property. Multiple requests have been ignored, both oral and written presentations to these entities, which generates sustainable grounds for denial of this project. The harm that would be inflicted upon the aquifer would most likely be impossible to remedy/correct.

The City of Fort Bragg has not proceeded impartially in this project. Clearly, Fort Bragg's Community Development Department, Planning Commission, and City Council are (or should be) aware of the dangers presented by this current project.

They have historically turned a blind eye to the above issues until they had no choice but to finally disapprove prior development projects.

The damage done to this property by the bore holes and inappropriate backfill may have rendered it unable to be developed.

Respectfully submitted by Guy Burnett & Truthful Kindness on 10July2025 Guy Burnett Ley R Burnett Jelp 10,2025
Tail L Kind wers 10 daly 2025)
Truthful Kindness
A

Page 2 of 2 ends

City Council Mtg 14July2025d Historical Facts
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Exempt per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development City of Fort Bragg *** Received ***
JUL 1 0 2025
The City of Fort Bragg has not proceeded impartially in this project.

Fort Bragg's Community Development Department, Planning Commission, and City Council are (or should be) aware of the dangers presented by this current project since historical soil and water data submitted to these entities date back 30 years, leaving no room for lack of awareness of the issues or changing course and ignoring the information now. The ONLY justification for setting aside all of this previously embraced documentation would be new hydrological-geological- ecological study(s?) that refute past data. This information has been instrumental in denying four prior development projects on Todd's Point. All four of these projects share the same soil characteristics with the current project.

This shows that a "NO" vote on this project has merit (ie defensible).

The following information requests and documents supporting failure to properly process safeguards to water sources were submitted to the above entities in writing and/or verbally on dates indicated. • Identify locations of existing and abandoned bore holes and wells on Hare Creek project. Documentation was requested on 16Dec2003, 24Mar2015, 12Nov2018, 11Jun2025, 18Jun2025 and 25Jun2025. City of Fort Bragg has done nothing to comply with these requests.
• Excerpts from California Department of Water Resources, Part III.

Destruction of Monitoring Wells were submitted 16Dec2003, 24Mar2015, 12Nov2018, 11Jun2025, 18Jun2025 and 25Jun2025. These excerpts notified the above entities for actions that must be taken to insure bore holes are sealed properly, and proof that these safety actions have occurred.

City of Fort Bragg has done nothing to comply with these requests.

Page 1 of 2 ends

Paoli, Diana
From: Paul Clark < [email protected]>
Sent: Saturday, July 12, 2025 8:58 AM
To: City Clerk
Cc: Paul Clark; CMAR ([email protected])
Subject: July 14 City Council Item 7B 1151 S Main
Attachments: FortBraggPopStats.pdf
No charge for this brief population study for Fort Bragg. Some links below as some are hard to read, but the basic idea is clear. There is no housing shortage in Fort Bragg, and with the aging baby boomers and the disgusting results of Prop 19 many home buying opportunities in the near future, unless of course people can be held in non-equity building housing situations.

Again I would suggest a serious discussion with local housing providers, private and public. I do believe you will be a bit shocked at the true picture.

Affordable housing is not inexpensive, someone is paying the bill.

Included as it is important that the City is working with a false policy that there is a housing "crisis" in Fort Bragg. Please share the city economic development strategy with all the council members, it was adopted by the city, and I recall paid for by yet another grant. Wasted money? I hope not https://www.biggestuscities.com/city/fort-bragg-california https://www.census.gov/quickfacts/fact/table/fortbraggcitycalifornia/PST045224 Paul Clark
Fort Bragg, California Population History | 1990 - 2022 https://www.biggestuscities.com/city/fort-bragg-california Fort Bragg Population History 1990 - 2023
Fort Bragg Population By Year
7200
7000
6800
6600
6400
6200
1990 1995 2000 2005 2010 2015 2020 2025
Year Population Rank in US Growth Rate
2023 6,919 4,030 -1.3%
2022 7,010 3,985 0.6%
2021 6,970 3,983 -0.0%
2020 6,972 3,973 -0.4%
2010 7,273 3,694 0.6%
2000 6,828 3,605 1.0%
1990 6,155 3,535 -
Fort Bragg Population Facts
What is the current population of Fort Bragg?
Based on the latest 2024 data from the US census, the current population of Fort Bragg is 6,919. Fort Bragg, California is the 4,030th largest city in the US.

What county is Fort Bragg, California in?
Fort Bragg is located entirely in Mendocino County.
1 ofs 7/12/2025, 8:39 AM
Fort Bragg, California Population History | 1990 - 2022 https://www.biggestuscities.com/city/fort-bragg-california What is the size of Fort Bragg, California in square miles? Fort Bragg has an area of 2.8 square miles.

What was the peak population of Fort Bragg?
The peak population of Fort Bragg was in 2010, when its population was 7,273. In 2010, Fort Bragg was the 3,694th largest city in the US; now its fallen to the 4,030th largest city in the US. Fort Bragg is currently 4.9% smaller than it was in 2010.

How quickly is Fort Bragg growing?
Fort Bragg has grown 1.3% since the 2000. Fort Bragg, California's growth is about average. 60% of similarly sized cities are growing faster since 2000.

What is the population density of Fort Bragg, California? Fort Bragg has a population density of 2,645.7 people per square mile.

Fort Bragg Demographics
What is the voting age population of Fort Bragg, California? The total voting age population of Fort Bragg, California, meaning US citizens 18 or older, is 4,509. The voting age population is 44.5% male and 55.5% female.

What percentage of Fort Bragg, California residents are senior citizens? According to the latest census statistics, 18.9% of the residents of Fort Bragg are 65 or older.

What are the racial demographics of Fort Bragg, California? The racial demographics of Fort Bragg are 80.7% White, 10.7% Other, 5.2% Two or more races, 1.4% American Indian, 1.0% Black and 1.0% Asian. Additionally, 34.1% of the population identifies as Hispanic.

What percentage of Fort Bragg, California residents are below the poverty line? In Fort Bragg, 19.4% of residents have an income below the poverty line, and the child poverty rate is 24.9%.

On a per-household basis, 16.3% of families are below the poverty line in Fort Bragg.

What percentage of Fort Bragg, California residents are in the labor force? Among those aged 16 and older, 59.9% of Fort Bragg residents are in the labor force. 2 of 5 7/12/2025, 8:39 AM
Fort Bragg, California Population History | 1990 - 2022 https://www.biggestuscities.com/city/fort-bragg-california What are the education levels among Fort Bragg, California residents? Among the adult population 25 years old and over, 82.2% of Fort Bragg residents have at least a high school degree or equivalent, 19.5% have a bachelor's degree and 7.5% have a graduate or professional degree.

What percentage of Fort Bragg, California residents speak a non-English language at home?
Among Fort Bragg residents aged 5 and older, 33.0% of them speak a non-English language at home. Broken down by language: 28.8% of residents speak Spanish at home, 2.7% speak an Indo-European language, and

1.1% speak an Asian language.

Fort Bragg Income & Labor Statistics
What is the unemployment rate in Fort Bragg, California? The unemployment rate in Fort Bragg is 7.8%, which is calculated among residents aged 16 or older who are in the labor force.

What percentage of Fort Bragg, California residents work for the government? In Fort Bragg, 9.7% of the residents in the non-military labor force are employed by the local, state and federal government.

What is the median income in Fort Bragg, California?
The median household income in Fort Bragg is $44,276.

Fort Bragg Housing & Rent Statistics
What percentage of housing units are owner-occupied in Fort Bragg, California? In Fort Bragg, 37.2% of housing units are occupied by their owners.

What percentage of housing units are rented in Fort Bragg, California? Renters occupy 62.8% of housing units in Fort Bragg.

What percentage of Fort Bragg, California housing units were built before 1940? Of all the housing units in Fort Bragg, 23.0% of them were build before 1940.

What percentage of Fort Bragg, California housing units were built after 2000? In Fort Bragg, 8.1% of the total housing units were built after the year 2000, which is approximately 250 units.

What is the median monthly rent in Fort Bragg, California? The median gross monthly rent payment for renters in Fort Bragg is $1,082. 3 of 5 7/12/2025, 8:39 AM
Fort Bragg, California Population History | 1990 - 2022 https://www.biggestuscities.com/city/fort-bragg-california What percentage of households in Fort Bragg, California have broadband internet? In Fort Bragg, 86.8% of households have an active broadband internet connection.

Similarly Sized Cities In California
US Rank Name Population Growth
2000-2023
3889 Escalon (/city/escalon-california) 7,355 20.4%
3916 Fowler (/city/fowler-california) 7,274 80.9%
3918 Gridley (/city/gridley-california) 7,269 30.4%
3949 Mammoth Lakes (/city/mammoth-lakes-california) 7,187 0.8% 3989 Sausalito (/city/sausalito-california) 7,021 -4.2% 4014 Taft (city/taft-california) 6,961 -21.0%
4030 Fort Bragg 6,919 1.3%
4062 Atherton (/city/atherton-california) 6,823 -5.1%
4080 Loomis (/city/loomis-california) 6,779 8.4%
4175 Colusa (Icity/colusa-california) 6,527 20.1%
4232 Huron (/city/huron-california) 6,377 0.6%
4293 Calipatria (/city/calipatria-california) 6,188 - 15.7% 4307 Willows (Icity/willows-california) 6,160 -0.8%
Similarly Sized Cities In US
US Rank Name Population Growth
2000-2023
4024 Fircrest, Washington (/city/fircrest-washington) 6,932 17.8% 4025 Mendota, Illinois (/city/mendota illinois) 6,929 4.8% 4026 Pacific, Washington (/city/pacific-washington) 6,927 29.5% 4027 Mountainside, New Jersey (/city/mountainside-new-jersey) 6,924 4.8% 4028 Lindale, Texas (Icity/lindale-texas) 6,923 119.7%
4029 Philadelphia, Mississippi (/city/philadelphia-mississippi) 6,921 -6.2% 4030 Fort Bragg, California 6,919 1.3%
4031 Youngtown, Arizona (/city/youngtown-arizona) 6,919 129.1% 4032 Tamaqua, Pennsylvania (/city/tamaqua-pennsylvania) 6,917 -3.2% 4 of 5 7/12/2025, 8:39 AM
Fort Bragg, California Population History | 1990 - 2022 https://www.biggestuscities.com/city/fort-bragg-california 4033 Ocean City, Maryland (/city/ocean-city-maryland) 6,915 -3.7% 4034 Walden, New York (/city/walden-new-york) 6,915 9.4% 4035 Vine Grove, Kentucky (/city/vine-grove-kentucky) 6,907 65.8% 4036 Stewartville, Minnesota (/city/stewartville-minnesota) 6,904 26.5% © 2025 www.biggestuscities.com, All Rights Reserved • Privacy Policy (/privacy) • Last updated: Jan 2, 2025 5 of 5 7/12/2025, 8:39 AM
U.S. Census Bureau QuickFacts: Fort Bragg city, California https://www.census.gov/quickfacts/fact/table/fortbraggeitycalifornia..

An official website of the United States government Here's how.you.know census
QuickFaets What's New & FAO, >
Fort Bragg city, California
Quick Facts provides statistics for all states and countie. Also fer cities and towns with a populution of 5,000 or more 9 Llid <
tuie sar oorar con lowg t2. - Select a fact -
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All Topics
California
O Population estimates, July 1. 2024, (Y2024) A 7,117
1 PEOPLE
Population
© Population estimates, Juls 1, 2024, (V202+)
O Population estinales basc, April 1, 2020, (V2024) A i,9SG © Population, percent clunge - April 1, 2020 (estimates basc) to July 1, 2024. (V2024) A 15% © Population. Census. April 1. 2020 6,383
© Population. Census. April 1, 2010 7,273
Age and Sex
i Panors under 5 vcars. peicita
© Parsons under I8 years. percent
O Persons 65 years and ovcr. percent
© Female persons, percent
Race and Hispanic Origin
O White alonc. percent
• Black alonc. percent (a) {a) PAPARA RA r R2
f American Indian and Alaska Vatie alane nerat (a)a
© Asian alonc. percent (a) (a)
d Natie Hawaiian ard Other Pacifie Islander along, porcent (a) (al O Two or More Races. parcert
O Hispanic or Latino, percent (b) (b)
• White alonc, not Hispanic cr Latino, percen
Population Characteristics
• Veterans, 2019-2021
O Forcin-bom persons, nerceat, 2019-2023
Housing
© Hosing Units, Juls 1, 2024, (V2024)
© Owner-occupied housing unit ratc, 2019-2023
di Median salue of outer-ocenied house umts, 2019.3023
• Median selected monthle owner costs - with a mongagc, 2019-2023 • Median selected monthly owner costs -without a mortage, 2019-2023 579 Median gross rent, 2019-2023
© Building Permits. 2024
Families & Living Arrangements
fotonceholde 9010.3033
© Persons per bouschold. 2019-2023
© Living in thie same house 1 year ago. percent of persons age1 ycar*. 2019-2027 O Langue other tlan English spoken at bomc. percent of persons age 5 years•, 2019-2023 Computer and Internet Use
© Houscholds with a computer. percent. 2019-2023
© Houscholds with a broadband Internet subscription. percent. 2019-2029 Education
O High school graduate or hügher, percent of persors age 25 ycars-. 2019-2023 • Hachclor's degree or higher, percent ef persons age 25 years-, 2019-2023 Health
• With a disability, under age 65 years. percent. 2019-2023 O Persons without health insurance, under age 65 years, percent Economy
© In civilian labor force, total, percent of population age 16 cars-, 2019-2023 50.6% O In civilian labor force. femalc, percent of population ag: 16 years*. 2019-2027 17 tr% O Total accommodation and food services sales, 2022 (S1.000) (c) 58,553 © Total Icalth care and social assistance reccipts/revemc. 2022 (S1.000) (61 141,230 Is this page helpful? X O Total transportation and warchousing reccipts/revenue, 2022 (S1.000) (c1 20.01+ EB ros © Total retail sales, 2022 (S1.000) (c) 207.493
1 of 2 7/12/2025, 8:39 AM
Paoli, Diana
From: Annemarie <[email protected]>
Sent: Monday, July 14, 2025 6:43 AM
To: City Clerk; Peters, Sarah; cad; Whippy, Isaac
Subject: public comment 1151 S Main City Council meeting 7-14-25 item 7B Dear Diana,
Sorry for having mailed my comments to the wrong e-mail. I am therefore sending my comments again.

Thanks, Annemarie Weibel
Thank you Sarah Peters for following up on my request. I asked whether "it is possible that all these environmental studies can be downloaded for the agenda for the City Council meeting as at least the City Council members could see it, and also the general public? Unfortunately the Planning Commissioners were not able to see these studies. Thanks, Annemarie"
You responded:
"Hello Annemarie,
I apologize for the delay in getting back to you. I have consulted with the team and the City does not post studies on-line. Council members can easily access the applicable studies as desired through City Hall." The point is that not only planning commissioners and city council members should be able to easily access the applicable studies, but the general public as well. In the past with many projects all these studies were online (either listed on the agenda for a planning commission, or city council meeting, or listed here:
https://www.city.fortbragg.com/departments/community-development/city-projects If planning commissioners and city council members need to request these studies and will not have them at their fingertips they might not request them and therefore will not have read them.

At first a community member who wanted to see these studies was told he would need to wait 10 days for these studies, but as he insisted to see them sooner (since Marie Jones mentioned that they are available at City Hall) he generously shared the flash drive with a few other interested community members.

That leaves out the people who did not attend that planning commission meeting, do not know that this individual has a flash drive with these studies, or that they can also get these at City Hall before the City Council meeting.

This project as you Sarah, or Diana might know is exempt from CEQA. No story poles alerted the public to this precedent setting monstrosity (7, three story high buildings) at the gateway to Fort Bragg in front of the ocean. No visual analysis was performed, no serious traffic study was done even though the applicant was willing to hire an expert to do this study. The planning commissioners did not request for this to happen.

I am disappointed to realize that in my opinion neither City staff, planning commissioners, or city council members are being trained about the California Environmental Quality Act, and the Coastal Act. It would not cost much money to hire Marie Jones to give a training, or tell the above mentioned entities the title of a book for laypeople so they would be better informed as to the rights and responsibilities of the public and the above mentioned entities. When a controversial project is exempt from CEQA it is even more important that everyone is educated about it.

Sincerely, Annemarie Weibel
------ Forwarded Message ------
Subject:Automatic reply: personal comment 1151 S Main City Council meeting 7-14-25 item 7B Date:Fri, 11 Jul 2025 23:06:54 +0000
From:Paoli, Diana <[email protected]>
To:Annemarie <[email protected]>
Thank you for your email. I am out of the office this afternoon and will reply to emails on Monday, July 14, 2025. If you have public comment please email to [email protected].

Thank you,
Diana Paoli
City Clerk
Paoli, Diana
From: Paul Clark < [email protected]>
Sent: Monday, July 14, 2025 7:25 AM
To: City Clerk
CC: Paul Clark; MAR (MAR@MCNORG)
Subject: City Council 07142025 Item 7B Don't talk to strangers AB 130 represents California's latest drive to improve affordable housing development by streamlining affordable housing infill development and reducing delays associated with local oversight. AB 130 adds a statutory exemption for infill housing projects that meet the requirements listed below. Permitting for projects that meet these requirements are fully exempt from CEQA, notwithstanding any other laws. AB 130 includes requirements related to prevailing wage, air filtration, hazardous site review, and consultation with California Native American Tribes for certain exempt projects.

Exemption Requirements for infill housing projects:

1. The site is up to 20 acres, or 5 acres for "builder's remedy" projects. The existing Class 32 categorical exemption limited the site area to no more than 5 acres.

2. The site is within an incorporated city or a census-defined urban area.

3. The site was previously developed with urban use, or at least 75% of the perimeter area is developed urban.

4. The development is consistent with the general plan, zoning, and the local coastal program.

5. The project must be built at a density of at least half the minimum number of homes per acre that the law says is appropriate for lower income housing, specified in Cal. Gov. Code S 65583.2(c)(3)(B).

6. The development cannot include transient lodging (e.g., hotels and short-term rentals) or demolition of designated historic structures.

Note item 6. This project as proposed still does not meet the intent of the CH zoning per the City's adopted plan. And we now have a sad example of why the item is addressed in #6 above, (in my opinion).

This is a substantial (non-mitigatable or even discussed) health and safety risk to the potential tenants in this project, particularly minor children.

The management will of course screen tenants for credit and criminal backgrounds to avoid bad people living in the units, but the motel portion can not do that. So, the proposal is to put a steady stream of total strangers among the tenants? Undoubtedly the motel folks will wander toward the Pomo Bluff Park, and the restaurant, and the ocean. The risk that this puts the tenants in is not understated. I doubt that HUD would issue housing certs for this project, which should have been part of the review by staff, both local and coastal, and 1 the planning commission. I don't recall any serious questions on this important issue.

You cannot approve this project. It does not meet the CH requirements and has this serious flaw that you cannot mitigate. Megan's Law was created around this issue.

You can't screen motel guests for pedophiles. Don't put the City in this liability risk. Should something happen, the city will (and should) most likely be brought in any legal action, as well as the coastal commission ( that staff person often referred to in particular)
Paul Clark
2 DEFINITION OF A CULTURAL DISTRICT
"State-designated cultural district" is defined as a geographical area with a concentration of cultural facilities, creative enterprises, or arts venues that accomplishes one or more of the following outcomes:

1. Attracts artists, creative entrepreneurs, and cultural enterprises.

2. Encourages economic development and supports entrepreneurship in the creative community.

3. Encourages the preservation and reuse of historic buildings and other artistic and culturally significant structures.

4. Fosters local cultural development.

5. Provides a focal point for celebrating and strengthening the unique cultural identity of the community.

6. Promotes opportunity without generating displacement or expanding inequality.

Paoli, Diana
From: Paul Clark <[email protected]>
Sent: Monday, July 14, 2025 7:44 AM
To: City Clerk
Cc: Paul Clark
Subject: 7B 1151
HUD issued Notice 2018-10 providing best practices regarding situations in which guest suites are permissible in Multifamily rental projects with mortgages insured or held by HUD under the National Housing Act. Section 513 of that act prohibits renting for "transient or hotel purposes." Leases and occupancy agreements for fewer than 30 days are prohibited.

The guidance applies to Section 221(d)(3), Section 236, Rent Supplement (Rent Supp), and Rental Assistance Program (RAP) projects, along with Project-based Section 8 properties that have Federal Housing Administration (FHA) mortgage insurance.

Notice 2018-10 states that in certain circumstances one or more units may be set aside as an amenity for residents. However, such guest suites are typically available for reservation by residents as an overnight accommodation for residents' relatives or guests.

The Notice provides "best practices" that include:
• Rent is not charged
• Guest suites are not available to the public and are limited to residents' family and friends • Residents are limited to two reservations per year with up to seven days per resident Notice 2018-10 is at: https://bit.ly/2zduA1z
More about HUD's Multifamily programs is on page 4-23 of NLIHC's 2018 Advocates' Guide.

A brief search on HUD and "motel units"
Paul Clark
Century 21 Fort Bragg Realty
809 North Main Street
Fort Bragg, CA 95437
707-964-0811
DRE 00640014
[email protected]
Paoli, Diana
From: CARIN BEROLZHEIMER <[email protected]>
Sent: Monday, July 14, 2025 8:10 AM
To: City Clerk
Subject: Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main St...

We live on Todd Point. We oppose the size of this project! The city and the county must work together regarding traffic study, impact of humans and pets to blufftop and wildlife at Todd Point, and the environmental impact to groundwater and runoff into ocean.

Opposed!
Carin Berolzheimer
(518) 526-4534
Paoli, Diana
From: Judy Mashhour Azad <[email protected]>
Sent: Sunday, July 13, 2025 2:07 PN
To: ity Clerk
Cc: Judy Mashhour-Azad; [email protected]; Kathy Zarrabi Subject: APPEAL: 1151 SOUTH MAIN STREET
Saturday, July 12, 2025
APPEAL: 1151 South Main Street
NEEDS TO BE ADDRESSED ONE BY ONE AND NOT ISSUES SKIRTED PLEASE. • Where are the story poles required?
• Most of the citizens of Fort Bragg have no idea what you are planning to do to the Gateway to Fort Bragg.
• Yes, I agree more housing is needed but why not build it with the rest of the 3 story structures that your planning commission has pushed through?
• Traffic study needs to be done by someone outside of relative and friend relationships • Stop sign will only cause more congestion on Ocean View • Traffic entering from frontage road and Harbor View will cause not only traffic congestion but also accidents which the city can be held accountable for • Only ADA requirements are through proposed complex, Ocean View has no sidewalks nor does Harbor Avenue which is a pitted un maintained road with no sidewalks, so is the city then responsible to make sure their streets are safe and ADA compliant? • How can anyone who is ADA be able to fairly rent a space other than on the very bottom floor? • Chemicals from automobiles can still sink below the well encasement into our well water supply for all of Pomo Bluffs Subdivision
Judy Mashhour Azad
Paoli, Diana
From: Horstman, Lisi
Sent: Monday, July 14, 2025 8:30 AM
To: Paoli, Diana
Subject: Fw: City council meeting 7/14/2025
Lisi Horstman
Administrative Assistant
Community Development Department
City of Fort Bragg
707-961-2823×119
From: Hamid Zarrabi <[email protected]>
Sent: Sunday, July 13, 2025 4:09 PM
To: cdd <[email protected]>
Cc: HAMID ZARRABI < [email protected]>
Subject: City council meeting 7/14/2025
Comments for up coming City Council meeting 7/14/2025
Council members;
By reading the new modified proposal regarding the apartment project at 1151 South Main St. there are still several problematic health and safety issues.

Traffic and parking being on top of the list. We are being told that this project has adequate on site and street parking and will not cause any major traffic problems. In order for the average local residence to be able to afford living in these units most of them would have to share the rent. According to the California Department of Fair Employment and Housing Two Plus One formula standards, a one bed room apartment could be occupied by three people and two bedrooms could be occupied by five people. This could bring up to 339 occupant and over 300 vehicles to the area. If these numbers do not raise a safety and health issue for the surrounding neighborhood I don't know what will.

I must remind you that this project is located between two Dead End streets which are "No Name Street" and "Harbor Ave." We know, due to inadequate parking at this project, these roads will become a permanent 24/7 parking lot. According to the proposal, Harbor Avenue will only be partially paved and only along and between this project boundaries. The west side and the remaining part of this road will still be a gravel road. The unimproved portion of Harbor Ave. will be totally exposed to contamination by hazardous material leakage from the parked vehicles. This will eventually contaminant and effect the wells at Todd's point, especially, the four residents on Harbor Ave. I have, previously, complained to the city regarding the condition of this road but I was told due to the fact that there are only four residents on this road there will not be any improvements done. Well, now there will be over 300 or so residents using this road. We are now demanding that this road be brought up to the city's road standards by paving and installing proper gutter and drainage system in its entirely. I might add that by doing so you will also provide a proper ADA access to the Pomo blutt park.

Hamid Zarrabi
2 Paoli, Diana
From: Horstman, Lisi
Sent: Monday, July 14, 2025 8:30 AM
To: Paoli, Diana
Subject: Fw: proposed development at 1151 S. Main
From: City of Fort Bragg <[email protected]>
Sent: Sunday, July 13, 2025 3:34 PM
To: cdd <[email protected]>
Subject: proposed development at 1151 S. Main
Message submitted from the < Fort Bragg, CA> website.

Site Visitor Name: Diane Swingle
Site Visitor Email: [email protected]
As a long time local, I oppose any 3 story constuction on the west side of hwy 1. Our visual connection with the Pacific has already been obscured more than enough.

Paoli, Diana
From: Annemarie <[email protected]>
Sent: Monday, July 14, 2025 1:34 PM
To: City Clerk; Whippy, Isaac
Subject: public comment 7-14-25 CC meeting, item # 7B, 1151 S. Main Street Attachments: Comment City Council 7-14-2025 housing development.pdf; SCAN0120.PDF To City Manager and City Council,
Please accept my comments. Thanks, Annemarie Weibel
P.S.: See State CEQA Guideline section 15183.3. Streamlining for Infill Projects. See (2) (B) Negative Decaration, Mitigated Negative Decaration or Sustainable Communities Environmental Assessment. As this project entails significant effects it shall be subject to CEQA.

My name is Annemarie Weibel. I have lived on the Mendocino Coast for the last 47 years. I have followed the developments of the Emerald Dolphin Inn & Mini Golf, the Hare Creek mall, the Auto Zone, and now this development.

I urge you to vote against the 83-unit multifamily development, retail space, and 4 hotel units planned for 1151 S. Main Street for the following reasons:

There was an attempt to develop the area between the Emerald Dolphin Inn & Mini Gulf and the College of the Redwoods since at least 1991. Many community members recognized that the latest project, the Hare Creek mall, even with an Environmental Impact Report (EIR) would cause dangerous traffic conditions at the HWY20 - Main Street intersection; create light & noise pollution; destroy open space and views; and cause suburban blight at the Souther Gateway to the City to name just a few issues. All these issues and many more would be caused by the 1151 S. Main Street development.

Considering that the City considers this project exempt from the California Environmental Quality Act (CEQA) per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development is very interesting. It took so far 4 City Council, and 4 Planning Commission meetings, 16 "whereas" clauses, general findings, density bonus incentives, 48 special conditions, and 9 standard conditions to try to minimize the environmental effects to less than significant and that has still not happened. What was not mentioned is the negative impact on local property values, imperiling our tax base.

The reason neighbors filed an appeal with the Coastal Commission was due to the fact that there were many environmental issues that were not addressed, or not sufficiently addressed. Documentation for this project is inadequate, incomplete and fails to adequately consider potentially significant impacts to aesthetics, inconsistency with area plans and policies, traffic, noise, air quality, hydrology, water, and cumulatively considerable impacts. Considering the wealth of substantive comments received on the project from neighbors, community members, Appellants, and the Coastal Commission, there is a "fair argument" of potentially significant cumulative impacts such that the City should require an MND, or EIR. The city adopted a Climate Action Plan in 2012. Reduction goals were set at 30% for the municipality by 2020, and a 7% reduction goal for the community by 2020. CEQA prohibits piecemealing of environmental review and requires that all phases of a project must be considered together. The missing traffic information for this site makes it impossible to consider the project as a whole. This project has a growth inducing impact.

The City discussed with the Coastal Commission the project and the applicant chose to make certain changes.

This project is not consistent with the LCP, the Coastal General Plan (CGP), and the Coastal Act.

Section 30001.5 of the Coastal Act sets various goals which are not adhered to with this project. This development is not consistent with the Fort Bragg Land Use Plan Mission Statement. The mission of the Coastal General Plan is to preserve and enhance the small town character and natural beauty that make the City a place where people want to live and visit, .... .... Installing story poles would have made it clear to many people that this development does not preserve and enhance the small town character and natural beauty that make the City a place where people want to live and visit.

The public, nor the Planning Commissioners, or City Council members had access to the following studies that Marie Jones mentioned at the June 25 meeting: 2 biological studies, and a preliminary draft drainage report. The emissions "study" has a "summary report" title, but isn't a report. It doesn't have conclusions, or methods, or other normal report sections. The groundwater recharge study is very old, from 1995. The document with filename, "Trip Generation Data for Multifamily Projects" is a single page that seems to have no bearing on this project or even Fort Bragg. Interested members asked for these reports that at first were going to take 10 days to obtain and then were given to a community member. When asked to include them in the agenda we found out that this would not be an option.

Neither was posting them online on the city projects link.

The Density Bonus Law provides projects certain advantages for affordable housing projects.

Developments are allowed up to four (4) concessions depending on affordability levels and percentages and must be approved by City Council. In order to reject a concession, the City has to prove by substantial evidence that it would cause a public health or safety problem, and would cause an environmental problem, which I believe it does.

A Class 32 Urban Infill Exemption is allowed where:

1. The project is consistent with the applicable general plan designation, all applicable general plan policies, and applicable zoning designation and regulations.

2. The proposed development occurs within city limits on a project site of no more than five acres, substantially surrounded by urban uses.

3. The project site has no value as a habitat for endangered, rare, or threatened species.

4. Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality.

5.All required utilities and public services can adequately serve the site.

As mentioned earlier the project is not consistent with the applicable general plan designation, all applicable general plan policies, and applicable zoning designation and regulations, and also would result in any significant effects relating to traffic, noise, air quality, or water quality. As these issues are not benign and the City failed to study cumulative impacts it seems clear that a Mitigated Negative Declaration (MND), or an Environmental Impact Report (EIR) is needed to address these issues. It is interesting that 85% of CEQA lawsuits target infill development. According to the Public Resource Code 21080 (d) if there is substantial evidence, in light of the whole record before the lead agency, the project may have a significant effect on the environment, an environmental impact report shall be prepared.

For example to be consistent with the zoning each building in this mixed use development needs to have a commercial component (ground floor short term lodging component in each building, not just in two of them).

A thorough traffic and transportation study/analysis is absolutely necessary. The developer offered to pay for one. Past developments in the area all had traffic studies and even Caltrans in the past commented on issues in regards to developments located close by. As all these projects are very different using the traffic analysis for the Auto Zone, the Hare Creek mall, or the Emerald Dolphin Inn won't work. Most of these studies were not done while the local schools were in session, or during holidays. Caltrans this time around determined that a traffic study was not warranted, and Public Works agreed. The issue at hand is not Level of Service, but safety! There should have been a crosswalk connecting both Emerald Dolphin Inn buildings long ago and now there would be so much more additional traffic, as well as foot traffic along stretches with no sidewalks. The Snug Harbor development also increased traffic in this area. Unlike the Auto Zone project additional traffic would also be happening on Harbor Avenue. Having the odd shaped Frontage Road, and obstructions by bushes and plants between Frontage Road and Harbor Ave. makes it hard to see and will cause accidents even when plants are less than 42 in. (see Spec. Condition 45). Also during sunset people driving west on Ocean View Dr. will be blinded. A herd of 15 to 20 deer are grazing in the area. The Polliwog preschool licensed for 42 students also adds additional traffic. People tend to drive fast along Ocean View Dr. A traffic analysis should include the intersections of Hwy 1 and 20, Hwy 1 and Ocean View Dr., Hwy 1 and Boatyard Dr., Hwy 1 and driveways at Harbor RV Park, Frontage Rd. and Ocean View Dr., and Ocean View Dr. and Harbor Avenue. Unfortunately the public has not been informed where a school bus stop, and a MTA stop would be. The condition and width of Hare Creek Bridge is not conducive of any more traffic than already exists. It never got a seismic retrofit. Fort Bragg's South Main Street Access & Beautification Plan lists that high travel speeds, narrow travel lanes, no shoulders, commercial trucks, rough surface condition and high curbs all combine to create considerable safety concerns for bicyclists. The narrow sidewalks adjacent to high speed traffic create poor conditions for pedestrians as well. Caltrans removed this bridge from its to do list. Why? Fort Bragg's LG Traffic Element Goal C-3: Preserve the peace and quiet of residential areas is not possible with this project, neither is Policy C-3.1.1: Reduce through traffic on local streets. Policy C-2.6: traffic Studies for High trip Generating Uses: lists also under (b) other known and foreseeable projects and their effects on the street system. We need to consider additional traffic from the Grocery Outlet, the mill site, and the new development where the Hare Creek mall was planned to happen. Considering that several of the local rivers (Pudding Creek, Noyo River, and/or Hare Creek Bridges become unusable in a seismic event) everyone that lives south of East Oak St. would would want to evacuate across Noyo Bridge, Hwy20, and Hare Creek Bridge.

Parking will not be sufficient for all residents and their guests, guests of the 4 hotel units, and people wanting to access Pomo Bluff Park.

The so called Market Study & Feasibility Analysis is not a reliable study. Growth inducing impacts are not mentioned in this project.

The CP is clear that existing blue water ocean views through the site need to be protected, and need a visual analysis. The site offers direct views of the ocean and community members attested that ocean views are clearly visible from Hwy 1 at the project site. In order to be consistent with the LCP, the project must be designed and sited to protect views to and along the ocean and scenic coastal areas, be visually compatible with the character of the surrounding area and be sited and designed to protect views to and along the ocean and the scenic coastal areas. In 2019 a study was done for the Auto Zone planned for the same site and it was even mentioned that the trees to be planted need to be planted in such a way that they would not be in the way of the view corridor. Policy CD-1.1, Policy CD-1.3, Policy CD-1.4, Policy CD-1.5, and Policy CD-2.5, and LIP Section 17.50.070 (F) apply as well. Goal CD-4 of the FB LGP lists attractive entryways into the City. This project does not meet this goal.

A detailed water budget for the entire project must be performed and a detailed assessment documenting how water will be provided considering that we now have 4 hotel accommodations. We all know that tourists are not aware of our finite supply of water. As the groundwater recharge study is very old, from 1995 (Nolan Groundwater Recharge & Water Balance Evaluation) created for the proposed Kmart project). It also relies on studies conducted even earlier than that. We need new studies and well data as many of the neighbors in the County had to drill new wells as they run dry, share wells, and many of their wells are very shallow (about 35 ft.). They also experienced salt water intrusion. Why has the City not addressed the concerns of their own staff (Dick LaVen & Dave Goble, 2003) with regards to the water situation at Todd Point? Even the smallest amounts of hydrocarbons and other pollutants of these wells as neighbor Guy Burnett recently witnessed would be devastating to property owners and the environment. With the City not wanting to demand that the applicant carry the cost to deal also with the west side of Harbor Ave. these issues will become paramount. The City is committed to serve all known and foreseeable developments committed to serve pursuant to LCP Policies LU-5.2, PF-1.2, and PF-1.3. The extra water storage the City has does not get replenished once it runs out, and once we are in a drought.

Landscaping should be consistent with Policy CD-1.6, Policy CD-1.11, Policy CD-2.7, Policy OS-5.1, and Policy OS-5.2.

See included exterior noise limit standards. The noise study does not take into effect the proximity to the closest neighbors in regards to vehicles pulling in and out of the parking lot, revving their engines, slamming doors, garbage trucks making beeping sounds when backing up, and uploading garbage, etc.

The location of the playground is not a good location.

The staff report did not mention the City Council meeting that took place on Nov. 12, 2024.

Various neighbors were not notified of that meeting. They did not have a chance to be informed about the Density Bonus Planning Incentives. The video from the meeting is no longer available online. The notice of the hearing was posted on site for a different date. It was barely visible low to the ground surrounded by tall grass and the Spanish version was facing the tall grass.

Sincerely, Annemarie Weibel
TR:"
Map CD-1

SCENIC VIEWS IN THE

COASTAL ZONE
- - City Boundary
Potential scenic views toward the
ocean or the Noyo Rive
The protection and enhancement of
scenic views on the former Mill Site will
be addressed in a Specific Plan.

Source: Gily 2 For Brags
Scale 1=300 mate
Fer Schematic purposes only
Map LU-2

CITY BOUNDARY, SPHERE OF INFLUENCE,

AND COASTAL ZONE
City Boundary
Sphere of Influence
Coastal Zone Boandary
Source: City of Fort Bragg
July, 2008
Scale 1" = 2300' (approximate )
For Schematic purposes only
Map N-1
Sensitive Noise Receptors

SENSITIVE NOISE RECEPTORS
Mobile Home Park
Couny Putehert
Guest House Museum
Torn Hai
clly tacll
Sano coa rans on
nunions Hall

11. Eagles Hal:

12. Mobile Home Park

15. Convalss eo Here
ti dun Minh senaa
OCEAN 5. Redwocd Schock
i6. Dana Gray Schoo

17. Fort Bragg High Schcel

16. Courty Courtiousel

19. Mobie Home Park

20. Mendeciro Coesi Distict Hosptal Colege of the Reduoods Cny Limas
Sphare of Influence

PACIFIC
6 -2
3450811
11 12J
:14
15: 17
16 18.-™
21 20
;
Soure: Cus 2mga99
Seala 1° = 2300 (approximate)
For Schematic purposes only
Map OS - 2
Ocean
Pacific
OS -2
Rivers, Streams, Flood Corridors,
Riparian Habitats, and
areas for Water Recharge
City Boundary
Sphare of Influence
Coastal Zone Boundary
Open Space
Areas for Water Recharge

45. 20
LANE Source: City of Fort Bragg
July, 2012
cale 1" = 2300' (approximate
or Schematic purposes on
Map SF-1

GEOLOGIC HAZARDS
City Limits
Sphere of Influence
Fault
Slide
Inner Gorge
Gradational Contact
Slopes
OCEAN
All ocean bluffs contain potentially
unstable slopes

PACIFIC
Source: Department of Conservation Division
of Mines & Geology Geologic & Geomorphic
Features, Fort Bragg 7.5' Quadrangl
Mendocino Countv. California. 198.

Scale 1" = 2300' (approximate'
For Schematic purposes only
Map SF-2
Flood Hazards
Zone A "pt:"
= City Linits
= Sphere of Influence
= Waterway
ZONE A = No base flood elevatior
letenmine
Creek™ ZONE AE = Base flood elevations
OCEAN
2a11
determined
one A

PACIFIC
Pudding Zone A
Cre
River
Rone A
Zone V
Hare
Zone T7 Zone A
Creek Source: Fly or For Bragg catfonia Map
Mendocino County, Rev. June 16, 1992
Scale 1" = 2300' (approximate)
For Schematic purposes only
Mendocino County, CA Code of Ordinances about blank

APPENDIX C - EXTERIOR NOISE LIMIT STANDARDS
Exterior Noise Limit Standards
(Levels not to be exceeded more than thirty (30) minutes in any hour) Receiving Land Time Period Noise Level Standards (dBA) 1,2 Use Category 3,4
Rural/Suburban Urban/Highways
One and Two 10:00 p.m.- 7:00 a.m. 40 50
Family
Residential 7:00 a.m.- 10:00 p.m. 50 60
>Multifamily 10:00 p.m.-7:00 a.m. 45 55
Public Spaces 7:00 a.m.-7:00 p.m. 50 60
Limited 10:00 p.m.-7:00 a.m. 55
Commercial
Some Multifamily | 7:00 a.m.- 10:00 p.m. 60
Commercial 10:00 p.m.-7:00 a.m. 60
7:00 a.m.-10:00 p.m. 65
Light Industrial Any time 70
> Heavy Industrial Any time 75
Adjustments to Noise Level Standard
Duration
Attachment X
10f3 5/17/2021, 9:02 AM
Mendocino County, CA Code of Ordinances about:blank
L 50 30 minutes per hour Standard
L 25 15 minutes per hour Standard + 5 dB
Lo Maximum permissible level Standard + 20 dB
Character Tone, whine, screech, hum, Standard + 5 dB
or impulsive, hammering,
riveting, or music or
speech
Ambient Level' Existing ambient L 50, L 25 Standard + 5 dB Existing ambient Lo Existing maximum
Interpretive Footnotes

1. When an acoustical study demonstrates that ambient levels exceed the noise standard, then the ambient levels become the standard.

2. Higher noise levels may be permitted for temporary, short-term or intermittent activities when no sensitive or residential uses will be affected

3. County staff shall recommend which receiving land use category applies to a particular project, based on the mix of uses and community noise levels. Industrial noise limits intended to be applied at the boundary of industrial zones, rather than within industrial areas.

4. The "rural/suburban" standard should be applied adjacent to noise sensitive uses such as hospitals or convalescence homes.

5. "Highways" apply to roads and highways where average daily traffic (ADT) exceeds ten thousand (10,000).
(Ord. No. 4017 (part), adopted 1998)

MENDOCINO COUNTY

ZONING ORDINANCE
2 of3 5/17/2021, 9:02 AM
Figure 2. Example of useful light and light pollution from a typical pole-mounted outdoor luminaire
«Voward cecied light
MUseful light
_ Direct up vard lig
Glare zone
Sal Igh:

Direct glare Ligh: trespass
krea to be lt
Light pollution s often caused by the way felt s emitted from hghting equipmen: Choosing proper coupmert and careful y morting and a ming it car make a sign ficart difference Source: Adapted from Institution of Lighting Engineers
Light trespass is light being cast where it is not wanted or needed, such as light from a streetlight or a lloodlight that illuminates a neighbor's bedroom at night making it difficult to sleep.

Glare can be thought of as objectionable brightness. It can be disabling or discomforting. There are several kinds of glare, the worst of which is disabilips glare, because it causes a loss of visibility from stray light being scattered within the eye. Discomfortelare is the sensation of annoyance or even pain induced by overly bright sources. Think of driving along a dark road when an oncoming car with bright headlights suddenly appears. The sudden bright light can be uncomfortable and make it difficult to see. Discomfort and even disability glare can also be caused by streetlights, parking lot lights, floodlights, signs, sports field lighting, and decorative and landscape lights.

Dose, Jason
From: LaVen, Dick
Sent: Thursday, December 18, 2003 5:11 PM
To: Goble, Dave; Dose, Jason
Subject: Emerald miniature golf course
Dave & Jason,
There apparently was no boring work done on the Emerald Dolphin site. The ED file makes reference to a hydrologic study. What was that? Was it done or just wishful thinking? Also, perhaps there was work done on the CR site, and there was work done on the former K-Mart site. Lee Welty & Bonnie Lampley have a proposal to do a preliminary hydrogeology study for the next proposed development in the area. It seems to me that the min.golf course is one more patch of impermeability. I think Bonnie should be able to model incremental impacts with the work she proposes. Seems to me that this one can sit in limbo until Bonnie's study is done & can pay a smidge of the cost. I think we need to dredge out whatever work was done on the Boatyard shopping center and on CR and add that to the mix, as well as the well logs and interviews with residents.

The obvious answer is City water & sewers and let the developers pay for the installation & connections. Until that happens, no more development until the first & 2nd parts of the aquifer study has been completed and reviewed.

Another question about the golf course. Are these guys proposing Astroturf or real grass & plants? Dick
Dose, Jason
From: Goble, Dave
Sent: Monday, December 22, 2003 9:13 AM
To: Dose, Jason
Subject: RE: Emerald Dolphin Inn Miniature Golf
Jason: Attached is my memo regarding the miniature golf course. Also see comments below.

RECEIVED
2222003 Memo Jason
re Comment...

DEC 2 2 2003
-Original Message-..

CITY OF FORT BRAGG
Dose, Jasor
Thursday, December 18, 2003 12:01 P PLANNING DEPT.

Subject: Goble, Dave
Emerald Dolphin Inn Miniature Golf
Dave
I routed the proposed Emerald Dolphin Inn Miniature Golf project up to your area for comments a couple of weeks ago. Linda and I had some discussion about the project yesterday and we would like some input on a few things;
1) Linda indicated that there may be some drainage/erosional concerns at the end of Cliff Drive. Yes, this is a county road but, she says, it's a City drain pipe.

This is a County drain system. The City does add runoff to the system, and it will eventually have to be upsized and maintained as development occurs on Todd Point. As it now stands, the majority of the runoff to that pipe and outfall comes from County property, and I haven't seen any action to improve or upsize the system, even with the construction of the new homes on Todd Point. I wonder if the County is even looking at drainage issues when they issue the building permits for the new homes?
2) Relating to traffic at the intersection of Ocean/Hiway 1, do we need a traffic analysis? Linda also indicated that the Emerald Dolphin Inn was required to dedicate a portion of highway frontage for an increased The Emerald Dolphin was designed and built at a setback that allows room for additional right of way to be acquired by the City or future developer for the construction of a right turn lane on Ocean View Drive. I don't recall what the kicker was for requiring acquisition and construction of the right turn lane. I know it was discussed as part of the Kmart project, but I don't recall the traffic level that would kick in the requirement. I know Lee Welty was looking at this when he was the City Engineer. I wouldn't think the little bit of traffic created by this golf course would bring the level to a 3) I assume we would require an oil/grease separator for the paved area, no? Yes. They are going to have to address quality of the runoff water, especially now that the City has filed for our NPDES Phase Il Storm water permit.
4)Could you ask Dick for some direction as to what we need regarding the aquifer recharge thing at Todd Point regarding this project?
Dick sent comments.

Thanks.

Jason Dose
Associate Planner
City of Fort Bragg
Phone: (707) 961-2827
Voice Mail: Ext. 107
FAX: (707) 961-2802
1 CITY OF FORT BRAGG
416 N. FRANKLIN, FORT BRAGG, CA 95437
PHONE 707/961-2823 FAX 707/961-2802

MEMORANDUM
DATE: DECEMBER 22, 2003
TO: ASSOCIATE PLANNER
FROM: DIRECTOR OF PUBLIC WORKS
SUBJECT: BAXMAN'S MINIATURE GOLF
JASON:

After reviewing the site and plans, Engineering has the following questions & comments:

1. A grading and drainage plan will be required for this site. All runoff will must be captured on site, run through an oil/grease separator and directed to an existing drainage system, or develop system to retain or percolate runoff on site.

2. Need full set of improvement drawings for development of the project.

3. You might want to check previous environmental impact reports completed for this area that may include recommendations or requirements for improvements at time of new development.

Attachment 7
City Council Meeting 2015 March 23
Unanswered Questions since 2003:

August 23, 1995: Nolan Associates to Mr. Scott Mommer:
"out of 24 borings, 20 penetrated the entire thickness of the terrace deposits ... and extended down into the Franciscan bedrock. Only one boring (boring T-13, Krazan and Associates, 1995), located on the extreme Northwest edge of the property, encountered groundwater." August 27, 2003: memo from Dick LaVen to Dave Goble:
"of 24 borings in the area of the K-Mart site only one hit water in the winter of 1994-1995... These wells need to be mapped."
"It is rumored that people's wells run dry now (2003) and they need to import water. We need to identify them and their locations on a map and have the well owners explain their problems." "The Nolan Associates' report does not tell us where wells were drilled and came up with dry holes.

The dry holes should be identified and mapped."
"12) Is there a detailed inventory of surface topography:" This should include the following (per Guy Burnett_"d) wells; e) septic; f) have interviews of residents and water use on the site been compiled" December 12, 2003: I.L.. Welty & Associates to Dave Goble. "2. Review well log information collected by others as we discussed with Welty, they will conduct a well survey of the Todd Point area to identify all current wells" "6d: Documentation of on-site hydrological conditions, including geographic materials encountered during the drilling in the vicinity."
December 16, 2003: Dick LaVen to Dave Goble
"2. Please include the boring logs from Krazan Associates and the locations of those borings." There have been discussions of many bores, wells being placed around this property. Holes of this nature provide direct intrusion into pristine aquifers which we on Todd Point depend upon.

Many times a request for identifying the location of these holes has been presented, but apparently ignored. I have been unable to locate copies of: drillers' log, mapped hole locations, documentation of proper, legal abandonment (see attached) including receipts for fill material, evidentiary photos, confirmation or declaration by contractor performing the abandonment procedures.

These holes into our water supply represent a real threat to our aquifer. In addition, 20,000 CY of grading will remove critical aquifer protection. Once an aquifer is compromised additional wells are of no use; recovery is virtually impossible.

This glaring omission of ignoring a clear danger to the environment is self-sufficient evidence of a flawed document. Therefore Lask the City Council to approve the appeal of Negative Mitigated Declaration for this property, reicet the appeal for Coastal Development Permit (CDP 8-13), Design Review (DR 7-13), Use Permit (USP 5-13), and Lot Line Adjustment (LLA 3-14). http://www.water.co.00v/groundwater/wells/california-well standards/mws/mws_section19/ht Monitoring Well Standards
Section 19. Requirements for Destroying Monitoring Wells and Exploration Holes.

General requirements for destroying monitoring wells and exploration holes are contained in Sretion 2 ot the Water Well Sunderds. Special considerations for monitoring wells and exploration holes are as follows:

A. Monitoring Wells. Monitoring wells shall be destroyed in accordance with the following requirements and Sucion 23 of the Water Well Standards, irrespective of their original date of construction:

Preliminary Work. A monitoring well shall be investigated betore it is destroyed to determine its condition and details of its construction. The well shall be sounded inumediately before it is destroyed to make sure no obstructions exist that will interfere with filing and sealing.

The well shall be cleaned before destruction as needed so that all undesirable materials, including obstructions to filling and sealing, debris, oil from oil-lubricated pumps, or pollutants and contaminants that could interfere with well destruction, are removed for disposal.

The enforcing agency shall be notified as soon as possible if pollutants or contaminants are known or suspected to be present in a well to be destroyed. Well destruction operations may then proceed only at the approval of the enforcing agency. The enforcing agency should be contacted to determine requirements for proper disposal of all materials removed from a well to be destroyed.

2. Sealing Conditions. The following minimum requirements shall be followed when various conditions are encountered:

The monitoring well casing, and any other significant voids within the well. shall, at a minimum, be completely filled with saling material, if the following conditions exist:

The monitoring well is located in an area of known or potential pollution or contamination, and,
The well was constructed and maintained in accordance with these standards.

Sealing material may have to be placed under pressure to ensure that the monitoring well is properly filled and sealed.
b. A monitoring well shall be destroyed by removing all material within the original borehole, including the well casing, filter pack, and annular seal; and the created hole completely filled with appropriate sealing material, if the following conditions exist:

The well is located in an arca of known or potential pollution or contamination, and,
The well's annular seal, casing, screen, filter pack, or other components were not constructed or maintained according to these standards so thai well destruction be merely filling the well casing with sealing material, as in "a" above, would not prevent potential water-quality degradation from the movement of poor-quality water, pollutants, or contaminants through the destroyed well structure.

Material to be extracted from the original borehole shall be removed by means of drilling, including overdrilling, if' necessary. The enforcing agency should be contacted to determine requirements for proper disposal of removed materials.

Casing, filter pack, and annular scal materials may be left in place during sealing operations, if the enforeing agency agrees they cannot or should not be removed.

In such a case, appropriate sealing material shall be placed in the well casing; filter pack, and all other significant voids within the entire well boring. Casing left in place may require perforation or puncturing to allow proper placement of sealing materials. Sealing material may have to be applied under pressure to ensure its proper distribution.
c. Monitoring wells shall, at a minimum, be destroyed in accordance with the requirements of Section 23 of tbe Worer Well Sindards if located in an arca free of any known or potential contamination or pollution.

B. Exploratory Borings. Exploratory borings shall be completely filled with appropriate scaling matcrial from bottom to top, if located in areas of known or suspected contamination or pollution. Borings located outside such areas shall, at a minimum, be filled with sealing malerial from ground surface to the minimum depths specified in Section 22ottbe Mover Well standards. Additional sealing material shall be placed below the minimum surface seal where needed to prevent the interchange if poor-quality water, pollutants, or contaminants between strata penetraled by the boring.

Appropriate fill or scaling material shall be placed below and between intervals containing scaling material. Sealing matcrial is often economical to use as fill material.

The boring shall be inspected immediately prior to filling and sealing operations. All obstructions and pollutants and contaminants that could interfere with filling and sealing operations shall be removed prior to filling and sealing. The enforcing agency shall be notified as soon as possible if pollutants or contaminants are known or suspected to be in a boring to be Attachinent s
state of Calfornia - Natural Resources Agency EDMUND G. BROWN, Jr. Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Region 1 - Northern
601 Locust Street
Redding, CA 96001
www.vildlife.ca.gov
January 20, 2015
Ms. Marie Jones
Community Development Director
Cily of Fort Bragg
416 North Franklin Street
Fort Bragg, CA 95437
Subject: Notice of Public Hearing and Notice of Intent to Adopt Mitigated Negative Declaration (SCH #2014122062)
Mendocino County, California
Dear Ms. Jones:

On December 29, 2014, the California Department of Fish and Wildlife received from the State Clearinghouse a Mitigated Negative Declaration (MND) for the proposed Hare Creek Center Project (Project) in Fort Bragg, Mendocino County. The Department has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants and their habitat. As a responsible agency, the Department administers the California Endangered Species Act and other provisions of the Fish and Game Code (FGC) that conserve the State's fish and wildlife public trust resources. The Department's primary concerns involving the proposed Project include: (a) a substantial increase in water demand which may impact fish and wildlife and (b) ongoing diversion of water without notification pursuant to FGC section 1602.

The Department provides the following feasible and Project-specific recommendations in our role as a trustee and responsible agency pursuant to the California Environmental Quality Act (California Public Resources Code §21000 et seq.).

Project Description
The proposed Project would include construction and operation of a shopping center consisting of three separate buildings totaling 29,500 square feet of building space on Assessor's Parcels 018-450-40 and 018-450-41. The shopping center would contain a grocery store, three retail spaces, and a restaurant. Associated development would include a new access road, parking lot, pedestrian improvements, utility connections, low-impact development elements, and landscaping.

Conserving California's Wildlife Since 1870
properties consistent with present and future site uses.

Suitable scaling materials include neat cement, sand-cement, and bentonite, all of which are described in Section 9 eithese standards. Bentonite shall not be used as a sealing material opposite zones of fractured rock, unless otherwise approved by the enforcing agency. Drilling mud or drill cuttings are not acceptable as any part of sealing material for well destruction.

Concrete may be used as a sealing material at the approval of the enforcing agency.

Fill material, if any, shall meet the requirements of Section 23 otte Water Well Standards. Fill material shall be free of pollutants and contaminants and shall not be subject to decomposition or consolidation after placement. Drilling mud or cuttings are not acceptable as any part of fill material.

E. Additional Requirements for Monitoring Wells and Exploratory Borings in Urban Areas. The following additional requirements shall be met for destroying wells and exploratory borings in urban areas, unless otherwise approved by the enforcing agency:

1. The upper surface of the sealing material shall end at the depth of 5 feet below ground surface; and,

2. If the well casing was not extracted during destruction and scaling operations, a hole shall be excavated around the well casing to a depth of 5 leet below ground surface after sealing operations have been completed and the sealing material has adequately set and cured. The exposed well casing shall then be removed by cutting the casing at the bottom of the excavation. The excavation shall be backfilled with clean, native soil or other suitable material.

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Paoli, Diana
From: Colin Morrow <[email protected]>
Sent: Monday, July 14, 2025 1:48 PM
To: Paoli, Diana; City Clerk
Subject: Public Comment Concerning City Council Review of Agenda Item 7(B) on the July 14, 2025, Agenda, Concerning 1151 South Main Street in Fort Bragg, California Attachments: 250714_Ltr.pdf
Good afternoon:

Please find public comment attached.

Thank you,
Colin
Colin W. Morrow
Vannucci Momsen Morrow
An Association of Sole Practitioners
P.O. Box 1214
Mendocino, CA 95460
Phone: 707-380-1070
Email: [email protected]
Confidential: This email and any attachments should be presumed to be a privileged and confidential attorney-client communication, or subject to the attorney work product privilege. If you are not the intended recipient please stop reading immediately, delete any copies of this email, and advise the sender of any erroneous transmission.

VANNUCCI MOMSEN MORROW
Attorneys at Law
An Association of Sole Practitioners
Philip M. Vannucci
Brian S. Momsen Colin W. Morrow
The Hofman Building The Penny Farthing Building
308 S School St.

Ukiah, CA 95482 45060 Ukiah St.., Ste. A
P.O. Box 1214
Phone: 707.462.0900 Mendocino, CA 95460
Email: [email protected] Phone: 707.380.1070
Email: [email protected] Email: [email protected]
July 14, 2025

VIA EMAIL
City Clerk
City of Fort Bragg City Council
Fort Bragg City Hall
416 N. Franklin St.

Fort Bragg, CA 95437
([email protected])
Re:

Public Comment Concerning City Council Review of Agenda Item 7(B) on the July 14, 2025, Agenda, Concerning 1151 South Main Street in Fort Bragg, California Honorable City Councilors:
residential apartments between scenic Highway One and the Pacific Ocean at 1151 I represent Paul Clark. I write on his behalf in opposition to the proposed wall of fundamentally incompatible with the California Environmental Quality Act ("CEQA"), the South Main Street. Any approval of such a barrier of bedrooms-as proposed—s City of Fort Bragg's general plan, and the Coastal Act. recently, the City of Fort Bragg Planning Commission was divided as to the project, with This project comes to you after numerous hiccups and speedbumps. Most in their support of a recommendation. Planning Commissioners both outright voting against its recommendation and wavering previously came before the City, it was improperly approved with a blind eye toward The applicant and City have tacitly acknowledged that when this project the applicant seeing the writing on the wall that the Coastal Commission would significant Coastal Act considerations. This tacit acknowledgement came in the form of amended project rather than attempt to defend a woefully defective approval before the disapprove of this project. The applicant came back to the City for approval of an the Coastal Act issue, this Council must also revisit the EQA and general plan issues, Coastal Commission. Though the applicant has offered some inadequate remedies to which compel denial of the project.

Fort Bragg City Counsel
July 14, 2025

Page 2 of 7 ends

The Project Is Inconsistent with the General Plan
proposed project is consistent with the long-term planning for the City. Here, the First and foremost, the City Council must seriously consider whether the project-as detailed below-is inconsistent with the long-term planning for the City because it sacrifices what should be a marquee location for a commercial visitor-serving facility for cloistered bedrooms. Such a gateway parcel should be oriented toward commercial uses that will welcome the visitors whose tourist dollars support the local economy. This visitor serving commercial orientation is clearly articulated in the City's general plan.
depends upon consistency with the applicable general plan and its elements." (Orange "IT]he propriety of virtually any local decision affecting land use and development ordinance that conflicts with a general plan is invalid at the time it is passed." (Ibid.). Citizens for Parks & Recreation v. Superior Court (2016) 2 Cal.5th 141, 153.) "A zoning "An action, program, or project is consistent with the general plan if, considering all its aspects, it will further the objectives and policies of the general plan and not obstruct their attainment." (Ibid.) "Because of its broad scope, long-range perspective, and primacy over subsidiary land use decisions, the general plan has been aptly described as the constitution for all future developments within the city or county." (Id. at p. 152.) located at the central arterial in-route to Fort Bragg, directly where visitors from either General plan consistency at this site is key because the subject real property is San Francisco (traveling north via Highways 101 or 1) or the Central/Sacramento Valley (traveling west via Highway 20) enter Fort Bragg.
the small town character and natural beauty that make the City a place where people "The mission of [Fort Bragg's] Coastal General Plan is to preserve and enhance want to live and visit, and to improve the economic diversity of the City to ensure that it has a strong and resilient economy which supports its residents." (General Plan, Part that undermine the small-town character of Fort Bragg, perpetuates the City's drift 1(D).) This project does the opposite. It creates a homogenous monolith of apartments toward a bedroom community, and physically obstructs highway visitors' views of both the coastline and coastal access.
natural beauty and provide access to the scenic and recreational resources of its natural The mission and vision of Fort Bragg is of "[a] city which seeks to preserve its setting." (Ibid.) Nevertheless, the project obstructs nature with a wall of private residences. The mission and vision of Fort Bragg is as "[a] city that embraces its role as the primary commercial and service center on the Mendocino coast." (Ibid.) Nevertheless, this project sacrifices real property that was expressly allocated for visitor serving commercial facilities to insular bedroom units. The mission and vision of Fort Bragg is "[a] city which promotes itself as a tourist destination and which provides the necessary
Fort Bragg City Counsel
July 14, 2025

Page 3 of 7 ends

infrastructure and services to support a growing population of transient visitors." (Ibid.) Nevertheless, this project rebuffs transient visitors in favor of cloistered bedrooms.

Turning from broad considerations to brass tacks, "Highway Visitor Bragg's Coastal General Plan as follows: Commercial"-as the subject property is zoned-is specifically designated by Fort This land use designation applies to land uses serving residents and visitors on sites which are located along Highway One and arterials at the entry points to the community. Typical uses allowed in this designation include motels and other lodging enterprises, restaurants, and retail outlets. Residential uses are permitted above the ground floor or on the units per acre with a conditional use permit. ground floor at the rear of buildings' at a maximum density of up to 24 (General Plan, Part 2(G); see also Fort Bragg Municipal Code 17.22.030, subd. (C)(5)(a) ['Secondary uses oriented to local clientele may be permitted where the (emphasis added)].) primary use of a site is oriented to or serves visitor, regional, or transient traffic," recreational opportunities in the Coastal Zone consistent with sound resource Paired with this, it is a goal of the local coastal plan to "[m]maximize public conservation principles and the constitutionally protected rights of property owners." (General Plan, Goal LU-5.0) Local Coastal Plan policies include that the City of Fort Bragg should "[c]ontinue to provide for and encourage additional visitor-serving commercial facilities," (General Plan, Policy LU-5.1,) and "le]nsure that there are for Highway-Visitor Commercial uses; b) Maintaining the Highway Visitor Commercial adequate sites for visitor-serving land uses by: a) Maintaining existing areas designated land use designation as one allowing primarily recreational and visitor-serving uses; and c) Reserving adequate infrastructure capacity to accommodate existing, authorized, and probable visitor serving uses, " (General Plan, Policy LU-5.2). It is a policy of the local coastal plan to "[e]ncourage the development of residential uses in conjunction with commercial enterprises in commercial zones, where the viability of the commercial activities and visitor-serving uses would not be adversely affected." (General Plan, Policy H-2.2 (emphasis added).)
11 The choice to use-and approval of—ground floor spaces as residential facilities is a fundamental defect in the project. Moreover, the use of the ground floor for commercial use would not make the project unfeasible because the City's planner explained at hearing that the applicant had initially been "perfectly happy" with a 56 residential unit project. (Hearing Video, available at https://www.city.fortbragg.com/government/city- council/council-meeting-live-stream.) The applicant could still have 56 units with the ground floors committed to visitor serving commercial uses.

Fort Bragg City Counsel
July 14, 2025

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This project, however, sacrifices all these general plan priorities for dense, urban, and privately held residential units wholly contrary to these general plan priorities. The proper use of the space as a welcoming area for visitor serving facilities-rather than a of the highway. This project is the opposite.

The Project Is Not Exempt From CEQA
The applicant and City rely upon two CEQA exemptions, neither of which apply.

The first of these is the so-called "in-fill development projects" exception. (Cal. Code "consistent with the applicable general plan designation and all applicable general plan Regs. Tit. 14, § 15332.) This exception does not apply because the project is not policies as well as with applicable zoning designation and regulations" insofar as the subject real property was zoned in conformity with the City of Fort Bragg's General Plan to only have "[r]esidential uses ... above the ground floor or on the ground floor at the rear of buildings, (General Plan, Part 2(G)). This requirement was ignored. Moreover, approval of that many residential units is likely to add major traffic issues-including vehicle miles driven-additional greenhouse gas emissions from idiling in congested traffic, and added noise in proximity to sensitive noise receptors-which would also render the exception inapplicable. Two sensitive noise receptor locations are identified in the map attached hereto as Exhibit A, which is excerpted from the City of Fort Bragg's general plan. Fundamentally, this CEQA exemption is-and should only be- permitted where the project is truly consistent with all general plan policies because the general plan will have already been subject to CEQA review. When one deviates from a previously reviewed general plan, there is no longer an applicable prior CEQA review upon which to piggyback.

The second of these is the so-called "in-fill housing development" exemption. (Cal. Code Regs. Tit. 14, § 15195.) This exception does not apply becauseat a minimum—the project is not within one-half mile of a major transit stop. A "major transit stop" is defined as "a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods." Yet here, the cited transit stop in the staff report is qualify as a major transit stop. The relevant local transit authority website materials on only served by one bus route, and the frequency of that bus route is insufficient to point are attached hereto as Exhibit B. The staff report does nothing to explain that the project is near a "major transit stop," it merely states as much in a wholly conclusory off- hand remark. More shockingly, this inaccurate statement was pointed out at the Planning Commission, yet remains in the current staff report to the city council.

Regardless, "a finding of categorical exemption cannot be sustained if there is a Fort Bragg City Counsel
July 14, 2025

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"fair argument' based on substantial evidence that the project will have significant environmental impacts, even where the agency is presented with substantial evidence to the contrary." (Banker's Hill, Hillcrest, Park West Community Preservation Group v.

City of San Diego (2006) 139 Cal.App.4th 249, 262, fn. 12) "This unusual 'fair argument' standard of review over a public agency's decision has been characterized as setting a low threshold requirement for initial preparation of an EIR and reflects a preference for resolving doubts in favor of environmental review when the question is whether any such review is warranted.'" (Georgetown Preservation Society v. County of El Dorado (2018) 30 Cal.App.5th 358, 370 quoting Sierra Club v. County of Sonoma (1992) 6 Cal.App.4th 1307, 1316-1317.)
At a minimum, a fair argument can be made that the project is likely to have significant and important effects including vehicle miles driven, additional greenhouse gas emissions from idling in congested traffic, and added noise in proximity to noise sensitive locations.

The Project Is Inconsistent With the Coastal Act
The policies of the Coastal Act prioritize that "maximum access,.. and recreational opportunities shall be provided for all the people consistent with public safety needs ....
" (Pub. Res. Code § 30210.) "Development shall not interfere with the public's right of access to the sea...." (Id. at § 30211.) "Lower cost visitor and recreational facilities shall be protected, encouraged, and, where feasible, provided.

Developments providing public recreational opportunities are preferred." (Id. at § 30213.) "Oceanfront land suitable for recreational use shall be protected for recreational use and development unless present and foreseeable future demand for public or commercial recreational activities that could be accommodated on the property is already adequately provided for in the area." (Id. at § 30221) "The use of private lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, coastal-dependent industry." (Id. at § 30222.) general industrial, or general commercial development, but not over agriculture or These policies embraceand specifically articulate-the paramount value of coastal access and visitor serving facilities. "[A] core principle of the Act is to maximize public access to and along the coast as well as recreational opportunities in the coastal zone." (San Diego Unified Port Dist. v. California Coastal Com. (2018) 27 Cal.App.5th 1111, 1129.)
The Density Bonus Law "does not supersede or in any way alter or lessen the effect or application of the California Coastal Act of 1976." (Gov. Code § 65915.) Here, however, this project will defeat these aims. It will hijack a substantial 2.6 acre tract of land that is particularly situated to serve-and designated by prior conscious zoning for-visitor serving commercial facilities. Having a three story wall of Fort Bragg City Counsel
July 14, 2025

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private bedrooms also creates a visual barrier to coastal access contrary to Public Resources Code section 30251. Although the area is not labeled as a highly scenic viewshed, the ocean is clearly visible from Highway 1 through the lot, and this view (and notice to the public) of coastal access would be destroyed.

The applicant's very minor changes in relation to coastal access do little to change the project's flaws. As to the pedestrian path and signage, this is not a pedestrian focused area—it is a vehicle focused area-there is nothing to suggest signs will be visible to cars or that cars will have anywhere to park to use the pedestrian path.

A major issue that is not addressed by any of the very minor concessions is that visual notice of public coastal facilities will be walled off from drivers by this project.

A Required Traffic Study Has Not Been Performed and Would Compel Denial The project is situated upon an arterial roadway that brings Fort Bragg most of its visitors.

Fort Bragg is built along Highway One which is also called Main Street within the City. Highway One is the only continuous north-south road serving the north coast of Mendocino County, providing a local transportation corridor for many communities and the primary access route for visitors. Traffic volumes on this roadway have increased steadily over the years.
(General Plan, 5-C.)
The primary intersection serving the project is Ocean View Drive and Highway 1.

The City's own prior analysis has concluded that even prior to this project, the level of service at this intersection was in decline. (General Plan, Table C-3.) The local coastal plan is clear that "t]raffic studies shall be required for all major development proposals, including but not limited to, drive-through facilities, fast food outlets, convenience markets, major tourist accommodations, shopping centers, commercial development, residential subdivisions, and other generators of high traffic volumes that would affect a Level of Service. Traffic studies shall identify, at a minimum: (a) the amount of traffic to be added to the street system by the proposed development; (b) other known and foreseeable projects and their effects on the street system; (c) the direct, indirect, and cumulative adverse impacts of project traffic on street system operations, safety, and public access to the coast; (d) mitigation measures necessary to provide for project traffic while maintaining City Level of Service standards; (e) the responsibility of the developer to provide improvements; and (f) the timing of all improvements." (General Plan, Policy C-2.6.) These requirements are further in accord with-and parallelthe policy objectives of the Coastal Act.

Fort Bragg City Counsel
July 14, 2025

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Nevertheless, no traffic study has been required, and the City wholly-and improperly-delegated what scant mention of traffic there is to CalTrans, who declined to do a traffic study. This is despite that an apartment complex creates not just different volumes of traffic than a commercial project, but different kinds of traffic (e.g., distribution across different times of day).

Numerous local coastal plan policies focus on the importance of traffic considerations. It is a policy to "le]nsure that the amount and phasing of development can be adequately served by transportation facilities." (General Plan, Policy C-21.) To service this policy, the City Council is to "Irleview development proposals for their direct and cumulative effects on roadway Level of Service standards. During the development review process, City staff will determine whether traffic studies need to be carried out and the scope of such studies. (General Plan. Program C-1.2.1.) The City is to "provide consistent standards for the City's street system." (General Plan, Policy C-

2.4.)
Conclusion
For the foregoing reasons, we respectfully pray that this honorable City Council deny the submitted project as woefully defective.

Respectfully submitted,
Colin W. Morrow
Paoli, Diana
From: Annemarie <[email protected]>
Sent: Monday, July 14, 2025 2:01 PM
To: City Clerk; Whippy, Isaac
Subject: public comment 7-14-25 CC meeting, item # 7B, 1151 S. Main Street Attachments: Fort Bragg View Corridor_04.14.17.2.pdf; 1151 S. Main Site Plan_ Retail A + B

06.01.17.pdf; veg map.pdf
To City Manager and City Council,
Please accept my comments. Thanks, Annemarie Weibel
These include comments by Alison Gardner, local botanist. Previous botanist studies only include 2 dates on which site visits were made, and 3 are generally required for botanical surveys.

The trees include several bishop pines, a shore pine, a doug fir, and some monterey pines. Several of these trees, including the shore pine and the doug fir, have the sea fog lichen in them (Niebla cephalota), which has been declared rare in Oregon, and will likely be added to the rare list in California in the near future, but is not on it yet. There are several large areas of broom. At the very least, the shore pine should not be cut, as that's where Alison saw the sea fog lichen (Niebla cephelota).

The meadow is mostly introduced grasses: sweet vernal grass and velvet grass, with a number of other non-native grasses, also, but does have a significant percentage of native grasses incorporated. There is California brome (Bromus carinatus, AKA Bromus sitchensis var. carinatus) through out much of it, l'd estimate at about 5 to 10% of the total cover. There are many patches of blue wild rye (Elymus glaucus, and Elymus glaucus ssp. virescens) which is also a native grass. I'd say that as a component of the whole, maybe 3%? There is also a number of areas with bracken fern. The bracken is not over the whole field, but in patches. There are a lot under the doug fir and shore pine, and in the southwestern portion of the parcel. There is a vegetation classification California Brome-Blue Wild Rye Prairie (https://vegetation.cnps.org/alliance/499) which this is close to fitting into. I don't think that the percentage of the native grasses is quite high enough, though. Membership rules include "Bromus carinatus characteristically present with native plants > 10% relative cover in the herbaceous layer (Buck-Diaz et al. 2013)." and "Bromus carinatus, Elymus glaucus, and/or Pteridium aquilinum > 30% relative cover in the herbaceous layer (Sikes et al. 2025)." It's close, but I'm not sure it qualifies. The state and global rarity ranks are S3,G3.

An S3 ranking is considered "vulnerable" and it doesn't prohibit construction, but it would require more hoops to be hopped through, and likely some mitigation.

Table 1. Global and state ranking system for natural communities per NatureServe (2009) and Sawyer et al. (2009).

Rank-Title Definition Abundance
G1 or S1- Fewer than six viable
At very high risk of extinction due to
Critically occurrences
extreme
Imperiled and/or 2000 acres
1 rarity, very steep declines, or other (worldwide or
factors statewide)
At high risk of extinction or elimination due 6-20 viable occurrences and/or 2000-
G2 or S2-
very restricted range, very few 10,000 acres (worldwide Imperiled
populations, steep or
declines, or other factors statewide)
At moderate risk of extinction or
21-100 viable occurrences
elimination due to
and/or
G3 or S3— a restricted range, relatively few
10,000-50,000 acres
Vulnerable populations,
(worldwide or
recent and widespread declines, or other statewide)
factors
Greater than 100 viable
G4 or S4- Uncommon but not rare; some cause occurrences Apparently for long-term and/or greater than
Secure concern due to declines or other factors 50,000 acres (worldwide or statewide)
G5 or S5—
Secure
Community demonstrably secure due to common
and widespread abundance
Widespread and abundant (worldwide
and statewide
There are also some areas with California oat grass (Danthonia californica), which can be a component of the California brome/blue wildrye/bracken meadows. If the California oatgrass were added in, it should take the native grasses above the level where it would classify as that habitat. However, it's not listed in the "membership rules".

I would be curious as to whether these native grasses are on the botanical survey, and if they gave an argument as to why they shouldn't be considered.

There are a few, but not many, remnant coastal wildflowers--gum plant (Grindelia stricta var. platyphylla), lupine (Lupinus littoralis), yarrow (Achillea millefolium). There is the native wild blackberry.

There is red elderberry and pink flowering currant.

The visible plants can change with the seasons. Native grasses count for something. If they aren't addressed in the botanical survey, a new one might need to be done.

To not overload your system I am not including any more photos. See photos online already.

Sincerely, Annemarie Weibel
2 Alison found a whole lot more of the Danthonia than were reported in a previous study.

Danthonia (California oatgrass, not the non-native wild oats) is not classified as rare. However, there is a bit of a tradition locally to try and save native grassland, as there are so many invasive grasses. This parcel has more non-native grasses than it does native. Now, so far as habitats, in the Manual of California Vegetation, they don't have a separate category for Danthonia, they lump it into other habitats.

This parcel could fit into one of two vegetation types: https://vegetation.cnps.org/alliance/499 California brome-blue wildrye prairie (both are on this parcel, as well as the Danthonia) which is classified S3, which is considered a sensitive habitat. Or it could classify as Common sweet vernal grass-velvet grass meadows, which has no protection.

Here are the "membership rules" for the brome-wildrye prairie: (I put the likely arguments in bold) • Bromus carinatus, Bromus maritimus, or Pteridium aquilinum characteristically present with native plants > 25% relative cover in the herbaceous layer (Rodriguez et al. 2017). • Elymus glaucus > 30% relative cover in the herbaceous layer (Buck-Diaz et al. 2012). • Bromus carinatus, Thermopsis californica, and/or Pteridium aquilinum > 30% relative cover in the herbaceous layer (Evens and Kentner 2006).
• Bromus carinatus, Elymus glaucus, or Pteridium aquilinum > 30% relative cover in the herbaceous layer (Klein et al. 2015).
• Bromus carinatus characteristically present with native plants > 10% relative cover in the herbaceous layer (Buck-Diaz et al. 2013).
• Bromus carinatus, Bromus maritimus, Elymus glaucus, Pteridium aquilinum and/or Thermopsis californica > 30% relative cover in the herbaceous layer (Buck-Diaz et al. 2021, Sikes et al. 2021, Sikes et al. 2023).
• Bromus carinatus, Elymus glaucus, and/or Pteridium aquilinum > 30% relative cover in the herbaceous layer (Sikes et al. 2025).

I would estimate that Bromus carinatus is greater than 10% relative cover, and there are other native plants on the parcel, including the Danthonia. With the last two options, I think that combined with the other native grasses (I think one could argue that the Danthonia should count in that) there may be 30% or greater of the native grasses and bracken. Not sure, I'd have to go out there and sample plots, which would take a long time, which we don't have.

As this is a sensitive habitat, a current study should should be done including a mitigation.

Also, the bracken fern is a slightly sensitive habitat. It's listed as a 3. 1000 ft 9.2016 Google-
•S Main St
cearth Legeast
Boatyar dO,
Harbor Ave
Leonard Holmes St-
Del Mar Dr.

Ave
Lerey Ave
Noyo Bay

SITE DATA
APN: 018-440-58-00
SITE AREA: 113,124 S.F. (2.6 AC.)

ZONING CH (HIGHWAY VISITOR COMMERCIAL)
S MAIN STREET (STATE HIGHWAY 1) (D

21.000 ADT

SIDE STREET
Y(E)

RETAIL A
7,424 SF

BOATYARD DRIVE
(E) HOTEL
AMERICAN.

RETAIL DEVELOPMENT FORT BRAGG. CA 95437
REPAIR CO. 1151 S MAIN STREET
RETAIL
9,100 S
Detention Pond
DATE
REV. NO. REV. DATE
Detention Pond

HARBOR AVENUE

SITE PLAN

SITE PLAN
SCALE: 1° - 30-0
JOB NO.:

Map of Some of the Native Vegetation at 1151 S. Main St., Ft. Bragg, Calif. arbor Ave Doug fir
Coyote bush
Calif.

Oat grass
Bracken
Shore
Harbor Ave pine
Bishop
Shoreline Hwy pine
Calif.

Brome,
and
patches of
Harbor Ave Blue wild
rye found
Google throughout
Airbus, Maxar Technologies, Map data G2025 Google United States 3D Earth view is not available Terma Send Product Feedback 50 ft L the grassy areas of
Vegetation map by Alison Gardner, 7/9/25 the parcel.

Paoli, Diana
From: Annemarie < [email protected]>
Sent: Monday, July 14, 2025 2:17 PM
To: City Clerk; Whippy, Isaac
Subject: public comment 7-14-25 CC meeting, item # 7B, 1151 S. Main Street Attachments: IMG950921.jpg; IMG950935.jpg; IMG950912.jpg; IMG950909.jpg; IMG950905.jpg To City Manager and City Council,
Please accept these photos taken today by Guy Burnett. They show the ocean view. Some of it is hidden by tall bushes and trees.

Sincerely, Annemarie Weibel

Paoli, Diana
From: Paul Clark <[email protected]>
Sent: Monday, July 14, 2025 2:26 PM
To: City Clerk
Subject: City council agenda item 7B 1151 S. Main
Photo taken 2:25 PM this date tell me there's not a nice ocean view City Mtg 20250714b Request for Information
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Exempt per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development ***
We are requesting the location of each bore hole / exploratory well (Bh/Ew) bored on the property at 1151 South Main Street, Fort Bragg CA 95437.

This information request should include: City of Fort Bragg Received
Date of boring
JUL 1 n 2025
Location of boring, plotted on this project's site plan Diameter of boring
City of Fort Bragg
Geologic log, with all strata encountered Received
JUL 14 2025
Total depth of boring
Depth when water was encountered
If a completed well report is NOT available, then include these:

Thickness of silty soil
Thickness of terrace deposit
Thickness of Franciscan bedrock
Copies of invoices, and description of sealing material for each Bh/Ew Labor invoice for sealing each Bh/Ew
Name and signature of person confirming each Bh/Ew has been sealed according to California Department of Water Resources, Part III. Destruction of Monitoring Wells Sections 18 & 19.

Respectfully submitted by Guy Burnett & Truthful Kindness on 10July2025 Guy Burnett Guy RBuret
Truthful Kindness TithalL-Kindress

Page 1 of 1 ends

City Council Mtg 14July2025c BOIL Water Notice
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Exempt per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development *** ***
The City Council has been presented with documentation that calls into question the legitimacy of proceeding with this project on site of 1151 South Main Street.

Here is MORE documentation of the misuse of this property for the project, which calls for a "NO" vote is needed on this project:

On 29Apr2025, Mendocino County Public Health issued a public advisory Water Quality Alert - Mendocino, CA; "The State Water Resources Control Board, Division of Drinking Water, has issued citations and compliance orders to three businesses west of Highway 1 in the town of Mendocino. These actions have resulted in boil water notices being issued for those businesses." ((see attached).

One of the three wells had a finished depth of over 150', a properly installed sanitary seal, and still was "under the influence of surface water" contamination.

The contaminated stormwater from this project will inundate and overwhelm specific confined areas of a filtration/percolation basin. The soil bedrock constitution is not capable of adequately allowing a slow percolation process. In all likelihood wells along Harbor Avenue and further west will be destroyed because of this project.

City council does not have the right or jurisdiction to take and/or allow the destruction of personal property without imminent domain. *** ***
Respectfully submitted by Guy Burnett & Truthful Kindness on 10July2025 City of Fort Bragg Received
Guy Burnett JUL 14 2025
Truthful Kindness TrithbulL Kindness

Page 1 of 1 ends

publc
health Dr. Charles Evans, Deputy Public Health Officer
COUNT

MENDOCINO COUNTY
Our mission is to safeguard and promote the health and wellness of the people of Mendocino County Press Release
Not for op-ed
Date: APRIL 29, 2025
TO: MENDOCINO COUNTY NEWS MEDIA
FROM: MENDOCINO COUNTY PUBLIC HEALTH

CHARLES EVANS, MD, DEPUTY PUBLIC HEALTH OFFICER

PUBLIC ADVISORY
Water Quality Alert - Mendocino, CA
The State Water Resources Control Board, Division of Drinking Water, has issued citations and compliance orders to three businesses west of Highway 1 in the town of Mendocino. These actions have resulted in boil water notices being issued for those businesses.

Affected Area:
• The specific locations impacted are within the town of Mendocino west of Highway 1.

Guidance for Businesses and Residents:
• The Deputy Public Health Officer recommends all residents and businesses west of Highway 1 proactively test their water for safety.
• Mendocino County Environmental Health is working with affected businesses and offering support to others that may be impacted.
• Collaboration with the California State Water Resources Control Board is ongoing.

Public Information Opportunity:

Mendocino County Public Health staff will be available at: Harvest Market at Mendosa's P 10501 Lansing Street, Mendocino, CA 95460
Bil Wednesday, April 30, 2025, & Thursday, May 1, 2025
• 10:00 AM - 3:30 PM
Residents may visit during these hours to ask questions or get more information. City of Fort Bragg Received
#
JUL 1.4 2025

Page 1 of 1 ends

City of Fort Bragg Received
JUL 14 2025
Livestock Grazing & Vehicle Stains in parking area July 14, 2025 @ 1151 South Main Fort Bragg Ca City Council Mtg 14July2025j 18 & 19ez
Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Exempt per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development *** ***
https://water.ca.gov/Programs/Groundwater-Management/Wells/Well-Standards/Combined- Well-Standards/Monitoring-Destruction
Monitoring Well Standards
Section 18. General Requirements
All permanently inactive or "abandoned" monitoring wells and exploration holes subject to these requirements shall be properly destroyed. The purposes of destruction are to eliminate the well structure and borehole as a possible means for the preferential migration of poor-quality water, pollutants, and contaminants; and, to prevent a possible hazard to humans and animals.

Section 19. Requirements for Destroying Monitoring Wells and Exploration Holes.

B. Exploratory Borings. Exploratory borings shall be completely filled with appropriate sealing material from bottom to top, if located in areas of known or suspected contamination or pollution....

D. Sealing and Fill Materials. ... Fill material shall be free of pollutants and contaminants and shall not be subject to decomposition or consolidation after placement. Drilling mud or cuttings are not acceptable as any part of fill material.

Submitted by by Guy Burnett and Truthful Kindness on 14 July 2025.

Guy Burnett Guy RBinett
Truthful Kindness huttal L Kindness
Voice at 707-961-1614, 19200 Harbor Avenue, Fort Bragg CA 95437 City of Fort Bragg
Received
JUL 14 2025

Page 1 of 1 ends

City Council Mtg 14July2025h CA Well Standards Sections 18 & 19 Coastal Development Permit Amendment (8-24/A), Use Permit Amendment (UP 9-24/A), Design Review Amendment (DR 11-24/A), for an 83-Unit Multifamily Project with 1,000 SF of Retail Space and 2,450 SF of Visitor Serving Accommodations at 1151 South Main Street (APN 018-440-58) CEQA Exempt per Section 15332 - Class 32 Infill Development Projects and 15195 Infill Housing Development ***
***
https://water.ca.gov/Programs/Groundwater-Management/Wells/Well- City of Fort Bragg Received I 14 2025 Standards/Combined-Well-Standards/Monitoring-Destruction Monitoring Well Standards
Section 18. General Requirement
Section 18. General Requirements
All permanently inactive or "abandoned" monitoring wells and exploration holes subject to these requirements shall be properly destroyed. The purposes of destruction are to eliminate the well structure and borehole as a possible means for the preferential migration of poor-quality water, pollutants, and contaminants; and, to prevent a possible hazard to humans and animals.

Section 19. Requirements for Destroying Monitoring Wells and Exploration Holes. General requirements for destroying monitoring wells and exploration holes are contained in Section 23 of the Water Well Standards. Special considerations for monitoring wells and exploration holes are as follows:

A. Monitoring Wells. Monitoring wells shall be destroyed in accordance with the following requirements and Section 23 of the Water Well Standards, irrespective of their original date of construction:
• 1. Preliminary Work. A monitoring well shall be investigated before it is destroyed to determine its condition and details of its construction. The well shall be sounded immediately before it is destroyed to make sure no obstructions exist that will interfere with filing and sealing. The well shall be cleaned before destruction as needed so that all undesirable materials, including obstructions to filling and sealing, debris, oil from oil-lubricated pumps, or pollutants and contaminants that could interfere with well destruction, are removed for disposal. The enforcing agency shall be notified as soon as possible if pollutants or contaminants are known or suspected to be present in a well to be destroyed. Well

Page 1 of 5 ends

destruction operations may then proceed only at the approval of the enforcing agency. The enforcing agency should be contacted to determine requirements for proper disposal of all materials removed from a well to be destroyed
• 2. Sealing Conditions. The following minimum requirements shall be followed when various conditions are encountered:
• a. The monitoring well casing, and any other significant voids within the well, shall, at a minimum, be completely filled with sealing material, if the following conditions exist:
• The monitoring well is located in an area of known or potential pollution or contamination, and,
• The well was constructed and maintained in accordance with these standards.
• Sealing material may have to be placed under pressure to ensure that the monitoring well is properly filled and sealed. • b. A monitoring well shall be destroyed by removing all material within the original borehole, including the well casing, filter pack, and annular seal; and the created hole completely filled with appropriate sealing material, if the following conditions exist:
• The well is located in an area of known or potential pollution or contamination, and,
• The well's annular seal, casing, screen, filter pack, or other City of Fort Bragg Received JUL 14 2025 components were not constructed or maintained according to these standards so that well destruction be merely filling the well casing with sealing material, as in "a" above, would not prevent potential water-quality degradation from the
movement of poor-quality water, pollutants, or contaminants through the destroyed well structure.

Material to be extracted from the original borehole shall be removed by means of drilling, including overdrilling, if necessary.

The enforcing agency should be contacted to determine
requirements for proper disposal of removed materials. Casing, filter pack, and annular seal materials may be left in place during sealing operations, if the enforcing agency agrees they cannot or should not be removed. In such a case, appropriate sealing material

Page 2 of 5 ends

shall be placed in the well casing, filter pack, and all other significant voids within the entire well boring. Casing left in place may require perforation or puncturing to allow proper placement of sealing materials. Sealing material may have to be applied under • Fort Bragg
2025 pressure to ensure its proper distribution.

Received
Cicy of c. Monitoring wells shall, at a minimum, be destroyed in JUL accordance with the requirements of Section 23 of the Water Well Standards if located in an area free of any known or potential contamination or pollution.

B. Exploratory Borings. Exploratory borings shall be completely filled with appropriate sealing material from bottom to top, if located in areas of known or suspected contamination or pollution. Borings located outside such areas shall, at a minimum, be filled with sealing material from ground surface to the minimum depths specified in Section 23 of the Water Well standards.

Additional sealing material shall be placed below the minimum surface seal where needed to prevent the interchange if poor-quality water, pollutants, or contaminants between strata penetrated by the boring.

Appropriate fill or sealing material shall be placed below and between intervals containing sealing material. Sealing material is often economical to use as fill material. The boring shall be inspected immediately prior to filling and sealing operations. All obstructions and pollutants and contaminants that could interfere with filling and sealing operations shall be removed prior to filling and sealing. The enforcing agency shall be notified as soon as possible if pollutants or contaminants are known or suspected to be in a boring to be destroyed. Well destruction operations may then proceed only at the approval of the enforcing agency. The enforcing agency should be contacted to determine requirements for proper disposal of removed materials.

C. Placement of Material. The placement of sealing material for monitoring wells and exploratory borings is generally described in Section 23 of the Water Well Standards and Appendix B. The following additional requirements shall be observed when placing sealing material for monitoring well or exploratory boring destruction.
• 1. Placement Method. The well or exploratory boring shall be filled with appropriate sealing, and fill material where allowed, using a tremie pipe or equivalent, proceeding upward from the bottom of the well or boring.

Page 3 of 5 ends

Sealing material shall be placed by methods (such as the use of a tremie pipe or equivalent) that prevent freefall, bridging, and dilution of sealing materials, and/or prevent separation of aggregate from sealants. Sealing material may be placed by freefall only where the interval to be sealed is dry and no more than 30 feet in depth. Fill material shall be placed by methods that prevent bridging and voids.
• 2. Timing and Placement. Sealing material shall be placed in one continuous operation (or "pour") from the bottom to the top of the well 2025 or boring, unless conditions in the well or boring dictate that sealing City of Fort Bragg Received operations be conducted in a staged manner, and prior approval is 14 obtained from the enforcing agency.

JUL 3. Groundwater Flow. Special care shall be used to restrict the flow of groundwater into a well or boring while placing sealing and fill material, if subsurface pressure producing the flow is significant. • 4. Sealing Pressure. Pressure required for the placement of cement- based sealing materials shall be maintained long enough for cement- based sealing materials to properly set.
• 5. Verification. It shall be verified that the volume of sealing and fill material placed during destruction operations equals or exceeds the volume to be filled and sealed. This is to help determine whether the well or boring has been properly destroyed and that no jamming or bridging of the fill or sealing material has occurred.

D. Sealing and Fill Materials. Materials used for sealing exploratory borings and monitoring wells shall have low permeabilities so that the volume of water and possible pollutants and contaminants passing through them will be of minimal consequence. Sealing material shall be compatible with the chemical environment into which it is placed, and shall have mechanical properties consistent with present and future site uses. Suitable sealing materials include neat cement, sand-cement, and bentonite, all of which are described in Section 9 of these standards. Bentonite shall not be used as a sealing material opposite zones of fractured rock, unless otherwise approved by the enforcing agency. Drilling mud or drill cuttings are not acceptable as any part of sealing material for well destruction. Concrete may be used as a sealing material at the approval of the enforcing agency. Fill material, if any, shall meet the requirements of Section 23 of the Water Well Standards. Fill material shall be free of pollutants and contaminants and shall not be subject

Page 4 of 5 ends

to decomposition or consolidation after placement. Drilling mud or cuttings are not acceptable as any part of fill material.

E. Additional Requirements for Monitoring Wells and Exploratory Borings in Urban Areas. The following additional requirements shall be met for destroying wells and exploratory borings in urban areas, unless otherwise approved by the enforcing agency:
• 1. The upper surface of the sealing material shall end at the depth of 5 feet below ground surface; and,
• 2. If the well casing was not extracted during destruction and sealing operations, a hole shall be excavated around the well casing to a depth of 5 feet below ground surface after sealing operations have been completed and the sealing material has adequately set and cured. The exposed well casing shall then be removed by cutting the casing at the bottom of the excavation. The excavation shall be backfilled with clean, native soil or other suitable material.

F. Temporary Cover. The well or borehole opening and any associated excavations shall be covered at the surface to ensure public safety and to prevent the entry of foreign material, water, pollutants, and contaminants; whenever work is interrupted by such events as overnight shutdown, poor weather, and required waiting periods to allow setting of sealing materials and the performance of tests. The cover shall be held in place or weighted down in such a manner that it cannot be removed, except by equipment or tools.

Submitted by by Guy Burnett and Truthful Kindness on 14 July 2025.

City of Fort Bragg Received
Guy Burnett _ Guy RBunet 14 2025
jul
Truthful Kindness Trith L Kindness
Voice at 707-961-1614, 19200 Harbor Avenue, Fort Bragg CA 95437

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