Despite the County SEIR review rejecting the developers proposal for filling of the canyon, (see County of San Mateo Bayside Design Review Recommendation), there are still additional unresolved problems with the proposed filling and development in Edgewood Canyon and the PPO submitted a Letter to County Planning Commission outlining them to the Planning Commission on May 2, 2011. The Palomar Property Owners (PPO) provided this letter as input to the draft SEIR for the proposed revised grading permit for Edgewood Canyon Estates. The SEIR review is a recommendation to the Planning Commission, and not a final binding decision on the project.
The PPO believes that the proposed grading is excessive for the site, and in relation to the number of houses. The grading, tree removal, and the houses themselves clearly violate the tenets for the Bayside Design Review guidelines, and the project should be rejected based on that fact alone. In addition, the rejection of this grading permit will not cause undue harm to the developers, since they can still build the two houses on the current site under their existing grading permit. The enormous amount of grading proposed for these two houses is clearly in excess of what could be needed to build them.
We have read the draft SEIR, and we believe that the analysis focuses on the wrong issues associated with this revised grading permit. The analysis provides many comparisons between the current approved permit (6 houses, 19,200 cubic yards of grading) and the new proposal (2 houses, 88,484 cubic yards of grading). Although the comparisons may be correct in isolation, they ignore the key issue – the amount of grading being requested is not in proportion to the number of houses to be built. The amount of grading, cut and imported fill will dramatically change the topography of the canyon and cause increased risk of drainage and erosion in the area.
The grading guidelines for our area say “Grading and vegetation removal should be minimized and allow for only the construction of the structure and paved area such as driveways and paths. Should grading be required, such work should blend into adjacent land forms through the utilization of contour grading rather than cutting, filling, padding or terracing the site.” Everything about the grading in this new proposal violates these rules.
As best we can tell, the SEIR seems to be saying that the new proposal is good because it is “better” on some items of comparison with the 1992 project. We do not agree with this, and the line by line comparison is misleading because it attempts to compare two different projects rather than judging whether those projects are themselves inherently reasonable.
To illustrate this, we have summarized some of the points made in the SEIR, and provided our own comments in the Letter to County Planning Commission.
In April 2011, after meeting and public comment, the Planning & Building Department of San Mateo County declined to accept the developer's proposal to fill in Edgewood Canyon, citing reasons along the lines of those which were raised in the July 2010 PPO letter to the County. [Open in NEW WINDOW]
The letter from San Mateo County is reproduced below:
Recently PPO sent a letter to San Mateo County Planning regarding a proposed development in Edgewood Canyon (also called Hermosa Canyon) in Palomar Park. The terrain map below shows the region in Palomar Park in question. The pond in the canyon has already been filled in, and there is a proposal to the County to do additional filling of the canyon (88,485 cubic yards of additional fill) to level much of the canyon floor in preparation for unspecified future development.
The problems potentially caused and precedents possibly set by this proposed project will impact ALL residents of ALL of Palomar Park whether they live directly adjacent to the development site or not. All residents of Palomar Park should be alert to how this development project might impact development around their homes and on the parcels near or adjacent to their homes.
You may also download the formatted letter which includes full resolution graphics:
Palomar Park Edgewood Canyon Letter PDF
======= July 27 PPO Letter =======
July 27, 2010
Attention: Angela Chavez
San Mateo County Planning
455 County Center, 2nd Floor
Redwood City, CA 94063
RE: Edgewood Canyon Estates – Supplemental EIR PLN2009-00117
Dear Ms. Chavez,
The Palomar Property Owners (PPO) is a neighborhood association formed to enhance the quality and safety of the physical surroundings in Palomar Park. The PPO is providing the following input on the new development plans for Edgewood Canyon Estates and the Supplemental EIR (SEIR). Although the PPO is in support of the reduction of proposed homes in Edgewood Canyon from six to two, we do object to the increase in proposed grading from 19,000 cubic yards to 88,485 cubic yards for the following reasons:
1) Safety Issues
a) Drainage and Erosion
b) Landslide mitigation
2) Design Review and Building Code
a) Preservation of natural topology
b) Impact on building code rules
a) Precedents for multi-home developments
Drainage and erosion
Currently the Canyon handles the drainage from a large section of Palomar Park – outlined in red below.
Storm drains on Palomar Drive and Hermosa Road and natural drainage channels funnel water to the Canyon floor.
We understand that:
a) The holding pond that has been at the head of the Canyon was filled in last year by the developers
b) The plans in the SEIR call for filling the existing drainage channel and building the new road on top of the fill
Drainage & Erosion
There are many issues that need to be addressed as part of the SEIR:
With the holding pond removed and the existing drainage channel filled, has adequate drainage been design into the new plans?
The holding pond limited erosion and deposit of sediment into the runoff from the Canyon. Does the grading and development plan propose an alternative mechanism to reduce erosion and sediment?
How does the proposal comply with the San Mateo Community Design Manual – Page 37 1.C - which states “streams and other natural drainage systems are not altered so as to affect their character and thereby causing problems of drainage, erosion or flooding”?
Over the years there have been landslides both into and above the Canyon with the latest one being just above Hermosa Road. From the slide activity we know that there is underground water coursing down the Canyon walls. Given the extensive increase in grading that is proposed in this SEIR, we are concerned that the developers have not taken into account the geology of the Canyon walls above the property in order to ensure that neither new slides are caused nor old slides are reactivated.
What investigation has been done and prevention proposed to ensure that properties on the rim of the Canyon are not put at risk?
Design Review and Building Code
Preservation of Natural Topology
Palomar Park is designated a special Design Review district in order to more effectively preserve and enhance the visual character of especially fragile communities, the natural environmental resources, and the public health, safety, comfort, convenience, happiness, and welfare of the citizens of the County. One of the key goals of the Design Review guidelines is to make sure that development “minimizes alteration of the natural topography,” and “minimizes alteration of streams and natural drainage channels”.
We are concerned that the amount of proposed grading has gone from 19,000 cubic yards to 88,485 cubic yards of earthwork. This is a 4.5 times increase in grading when the number of proposed houses has been reduced to one third the original number. This increase in grading should not be granted without the grading permit going through the standard Design Review process so that the grading can be approved with reference to the actual houses being built in Edgewood Canyon. Without taking into account the specific location and design of the houses, there is no way to determine whether this massive increase in grading is necessary or appropriate to maintain the character of the natural topology in Palomar Park.
To illustrate our concerns, we have attached Exhibit A [see bottom of web page] which is the proposed site plan with:
a) Lot lines shown in the dashed line
b) The limits of grading in red
c) The grading (cut and fill) which creates two approximately 1.5 acre level pads
As shown on this map, the new grading proposed would level approximately 3 full acres on the site, including cutting off the toe of one hillside. This grading may or may not be appropriate for the site – but this should only be determined in the context of the houses being built on the site. This is the purpose of Design Review. We request that any grading approval beyond the minimum amount necessary for the ingress/egress road, utility access and minimal house pads be withheld until each lot goes through the Design Review process for the proposed houses.
The previous six house design was approved with 19,000 cubic yards of grading, so there is no reason that more should be necessary at this time.
a) Height restriction in Palomar Park.
Our height restrictions limit height to 28’ above natural grade or lowest finished floor. In looking at the plans, the house on the 280’ elevation shows about half the house on fill with the lower left corner filled from 258’ to 280’ or 22 additional feet above current natural grade. Under the height restriction this would mean that this corner of the house can only be 6 feet tall. The house on the 290’ elevation shows similar issues - the entire house is on fill with about half the house requiring 10+ feet of fill, limiting the house to 12’ of height.
Based on our current understanding, by doing the grading now without going through Design Review for each house, the developers would be able to define a new grade at the height of their fill level which means the houses will be 38’-50’ above current natural grade. We do not believe that simply approving a grading plan for a development should define a “new natural” grade for further development of the site. This would not be allowed for an individual developing their property – the rules should not be different for a developer. Instead, the developers should be required to follow the standard practice of surveying the site prior to grading and using the natural grade benchmark and elevation marker for house construction. If the increased grading were included as part of the individual house Design Review, as it should be, this would be the case.
We do not want this development to create an unintentional exception to the Palomar height restrictions.
b) Future lot subdivision.
If the proposed grading plan is approved to generate the two large level lots, is there any deed restriction on future subdivision of these lots? We do not see this included in the SEIR proposal. If not, we are concerned about how to ensure Palomar Park Design Standards are applied to the development.
Standards and Precedents
The approval of this SEIR with the new grading permit would set a dangerous precedent for multi-house developments in Palomar Park, and should be denied based on the issue alone. Previous multi-house developments in Palomar Park, such as Belle Roche and Palomar Oaks, were approved with basic grading as required for ingress/egress, utility access and minimal house pads. In these cases the developer put in the road, drainage, and utilities as part of the grading plan, but left the grading for the individual homes to be granted as part of Design Review. The currently approved Edgewood Canyon project was approved based on 19,000 cubic yards of grading for ingress/egress, utility access and minimal house pads, so this was consistent with standard practice.
The new plan, which increases grading to 88,485 cubic yards, subverts this practice, and allows the developers to do an end run around the both the Design Review process and the standard process for new development in Palomar Park. We ask that the Planning Department not allow this to happen.
The PPO asks that the Planning department deny the SEIR and the new larger grading permit. We have no objection to two houses being built in Edgewood Canyon – we simply ask that the proper process be followed by the developers and that extensive additional grading be addressed within the standard Design Review process. The developers today are able to build two houses instead of six without further review by the Planning department and without this SEIR process. If their only goal is to build fewer houses, they can and should do so.
Kate FitzGerald Vice President, Palomar Property Owners Palomar Property Owners Board Kurt Oppenheimer – President Carol Mondino – Secretary Joe Marshall – Director Kate FitzGerald – Vice-President Kathryn Bedbury – Director Chris Myers – Director John Claude – Treasurer Jeff Garratt – Director Joann Landi – Director
CC: San Mateo County Board of Supervisors Palomar Property Owners membership Zoning Officer