COtTNTY OF SAN MATEO PLANNING AND BUILDING

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					                             COtTNTY OF SAN MATEO 

                       PLANNING AND BUILDING DEPARTMENT 



                                                                          DATE: August 10,2011


TO: 	          Planning Commission

FROM: 	        Planning Staff

SUBJECT: 	 EXECUTIVE SUMMARY: Consideration of a Master Use Permit (20-year
           term), Resource Management Permit, and Grading Permit and certification of a
           Mitigated Negative Declaration for the continued operation and expansion of
           Skylawn Memorial Park, located at 100 Lifemark Road near the intersection of
           San Mateo Road (Highway 92) and Skyline Boulevard (Highway 35) in an
           unincorporated area of San Mateo County.


PROPOSAL

The project sponsor has applied for a Master Use Permit (and associated Resource Management
and Grading Permits) to allow for the continued use and expansion of the Skylawn Memorial
Park property over the next 20 years. The Master Use Permit will succeed and supplant all
previollsly issued use permits for the Skylawn facility, including the most recent iteration (PLN
2000-00166), which was recently renewed by the Zoning Hearing Officer on May 6, 2010 (the
use permit renewal was approved and no new development was proposed at the time). The new
Master Use Permit would allow the continued operation of the existing cemetery, mortuary, and
interment facilities on-site and would regulate the proposed addition of similar facilities over the
permit's 20-year term. The application would also result in the formal recordation a 20 I-acre
Environmental Protection Zone within which no disturbance will occur (except for necessary
stomlwater drainage features).

RECOMMENDATION

Approve the Master Use Permit, Resource Management Permit, and Grading Permit, and certify
the Mitigated Negative Declaration, County File Number PLN 20 I 0-00026, by making the
required findings and adopting the conditions of approval as listed in Attachment A.

SUMMARY

Skylawn Memorial Park is a full-service cemetery facility that has operated with a County-issued
use permit at this hillside location since 1955. The property is located just north of the junction
of State Highways 92 (San Mateo Road) and 35 (Skyline Boulevard) and extends northerly along
the ridgeline of the adjacent mountain range. The 23,000-acre San Francisco State Fish and
Game Refuge and Watershed area isjust east of the subject property. Immediately surrounding
land uses generally include open space and sparse agricultural development.

The Skylawn property is comprised of two parcels totaling approximately 521 acres, of which
94 acres are currently developed with cemetery-associated uses, i.e., traditional and tiered
interment burial, a mortuary, a mausoleum, an administration building, and a reservoir. Three
existing wireless telecommunications facilities (all operating with separate County-issued use
permits) are located along the eastern ridgeline and the County operates an emergency com­
munications facility in the same area.

Proposed development in the 35-acre Phase 1 area (the area where development is proposed
over the permit's 20-year term) includes traditional lawn burial areas along with a series of
high-density interment structures such as mausoleums and columbariums. Natural or "green"
burial areas are also proposed in the outer portions of the Phase 1 area. Phase 1 development
will be split into individual projects that will be undertaken sequentially over the permit's
20-year term. Each new project will incur some level of grading depending on project-specific
details. Lawn burial areas will generally be terraced and will attempt to follow the existing
contours as much as practicable. The high-density garden mausoleum and columbarium
structures will be set into the hillsides so as not to protrude above the ridgelines. Total earthwork
for all Phase 1 projects is not expected to exceed 50,000 cubic yards over the permit's 20-term.

Staff recommends that the project, as proposed and conditioned, is consistent with the goals and
objectives of the San Mateo County General Plan and the policies contained therein. The project
also conforms to the Zoning Regulations (including the Resource Management regulations,
Grading Ordinance, and Use Permit findings) and the Mitigated Negative Declaration was
prepared in accordance with California Environmental Quality Act (CEQA) guidelines and
regulations. For these reasons, staff recommends that the Planning Commission approve the
Master ese Permit subject to the recommended conditions of approval listed in Attachment A.

JC:pac - JXCV0508_ WPU.DOC




                                                -2­
                             COUNTY OF SAN MATEO           "

                       PLANNING AND BUILDING DEPARTMENT


                                                                          DATE: August 10, 20 II


TO: 	          Planning Commission

FROM: 	        Planning Staff

SUBJECT: 	 Considera,tion of a Master Use Permit (20-year term), Resource Management
           Permit, and Grading Permit, pursuant to Zoning Regulations Sections 6500, 6313,
           and 8602.1, respectively, and certification of a Mitigated Negative Declaration,
           pursuant to the California Environmental Quality Act. for the continued operation
           and expansion of Skylawn Memorial Park, located at 100 Lifemark Road near
           the intersection of San Mateo Road (Highway 92) and Skyline Boulevard
           (Highway 35) in an unincorporated area of San Mateo County.

               County File Number: PLN 2010-00026 (Lifemark Group)


PROPOSAL

The project sponsor has applied for a Master Use Permit (and associated Resource Management
and Grading Permits) to allow for the continued use and expansion of the Skylawn Memorial
Park property over the next 20 years. The Master Use Permit will succeed and supplant all
previously issued use permits for the Skylawn facility, including the most recent iteration (PLN
2000-00166), which was recently renewed by the Zoning Hearing Officer on May 6, 2010 (the
use permit renewal was approved and no new development was proposed at the time). The new
Master Use Permit would allow the continued operation of the existing cemetery, mortuary, and
interment facilities on-site and would regulate the proposed addition of similar facilities over the
permit's 20-year term. The application would also result in the formal recordation a 201-acre
Environmental Protection Zone within which no disturbance will occur (except for necessary
storm water drainage features).

Proposed development in the 35-acre Phase 1 area (the area where development is proposed
over the permit's 20-year term) includes traditional lawn burial areas along with a series of high­
density interment structures such as mausoleums and columbariums. Natural or "green" burial
areas are also proposed in the outer portions of the Phase 1 area.

Phase I development will be split into individual projects that will be undertaken sequentially
over the permit's 20-year term. Each new project will incur some level of grading depending
on project-specific details. Lawn burial areas will generally be terraced and will attempt to
follow the existing contours as much as practicable, The high-density garden mausoleum and
columbarium structures will be set into the hillsides so as not to protrude above the ridgelines.
Total earthwork for all Phase 1 projects is not expected to exceed 50,000 cubic yards over the
permit's 20-year term.

There are a series of communications facilities located on the eastern portion of the Skylawn
property near the Phase 1 development area. Existing wireless antenna facilities include those
owned and operated by AT&T, Verizon, and SprintlNextel. A County-operated communications
facility is also located adjacent to the SprintlNextel facility. These existing facilities are not part
ofthis project and will continue to be regulated by their respective use permits.

RECOMMENDATION

Approve the Master Use Permit, Resource Management Permit, and Grading Permit, and certify
the Mitigated Negative Declaration, County File Number PLN 2010-00026, by making the
required findings and adopting the conditions of approval as listed in Attachment A.

BACKGROUND

Report Prepared By: Joe Camicia, Project Planner 


Applicant/Owner: Skylawn Memorial Park/Lifemark Group 


Location: 100 Lifemark Road 


APNs: 056-550-020, -030 


Total Parcel Area: 521 acres 


Existing Zoning: RM (Resource Management) and RM-CZ (Resource Management-Coastal 

Zone) 


General Plan Designation: Open Space 


Existing Land Use: Primary uses include cemetery, mortuary, and other interment facilities; 

accessory uses include wireless telecommunications facilities. 


Water Supply: Potable water provided by private domestic wells on-site, non-potable water for 

irrigationllandscape management provided by Coastside County Water District (CCWD). 


Sewage Disposal: Private septic system on-site. 


Flood Zone: Zone C (Areas of Minimal Flooding), FEMA Pane) No. 060311-0120 B; effective 

date August 5, 1986. 


Environmental Evaluation: Staff conducted an Initial Study and determined that the project, 

as proposed and conditioned, would not have a significant impact on the environment. A 

Mitigated Negative Declaration was published on October 30, 2010 and the review period 




                                                 -2­
ended November 30, 2010. Two sets of comments were received during the review period
and are discussed in detail below in Section E (Environmental Review) of this report.

Setting: Sky lawn Memorial Park is a full-service cemetery facility that has operated with a
County-issued use permit at this hillside location since 1955. The property is located just north
of the junction of State Highways 92 (San Mateo Road) and 35 (Skyline Boulevard) and extends
northerly along the ridgeline of the adjacent mountain range. The 23,000-acre San Francisco
State Fish and Game Refuge and Watershed area is just east ofthe subject property. Immedi­
ately surrounding land uses generally include open space and sparse agricultural development.

The Skylawn property is comprised of two parcels totaling approximately 521 acres, of which
94 acres are cun'ently developed with cemetery-associated uses, i.e., traditional and tiered
interment burial, a mortuary, a mausoleum, an administration building, and a reservoir. Three
existing wireless telecommunications facilities (all operating with separate County-issued use
permits) are located along the eastern ridgeline, and the County operates an emergency
communications facility in the same area.

The majority of the project site consists of rolling landscape with hills and canyons. The
southern portion slopes southward toward Albert Canyon Creek (a tributary to Pilarcitos
Creek), which crosses the southern portion of the site. The topography of the northern portion
of the project site slopes westward toward a second, unnamed tributary of Pilarcitos Creek,
which traverses the western portion of the project site. The slope on the project site ranges from
0% to over 30%. The site contains areas characterized as coastal scrub, annual grassland, with
small areas of purple needlegrass grassland, wetlands, willow riparian woodland, and Douglas
fir woodland. The primary soils in the project vicinity consist of gently sloping to very steep
upland soils that are well drained to somewhat excessively drained. There is lack of shallow
groundwater given that the project site is located on a high ridge.

While the Phase 1 project area is not located within any scenic corridors, it is located within
close proximity to Junipero Serra (1-280 Freeway) and Skyline State Scenic Corridors and the
Highway 92 County Scenic Corridor. Portions of the Skylawn property (primarily the eastern
ridgeline) are visible from several locations within the above-mentioned scenic areas.

Since 1999, for clarification, major improvements approved at Skylawn have included:

•	    Retaining wall construction to protect PG&E gas line from minor landslide Planning
      approval (PLN 2008-00358) received on April 9, 2009; associated Building Permit
      (BLD 2008-00939) final inspection on March 25,2009.

•	    Retaining wall and grading to restore major landslide - Planning approval (PLN 2006­
      00418) received on November 1, 2007; associated Building Permit (BLD 2006-00808)
      final inspection on February 5, 2008.

•	    Mortuary/funeral home/chapel/administrative office facility Planning approval (PLN 

      2000-00166 Permit under which Skylawn's Use permit is being currently renewed) 





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       received on July 9,2002; associated Building Permit (BLD 2003-01336) finaJ inspection
       on March 17,2008.

•      Eternity Gardens 9-acre interment facility Planning approval (PLN 2003-00636) received
       on February 14, 2006; associated Building Permit (BLD 2005-00714) final inspection on
       November 18, 2008.

•      Bai Ling interment facility Planning approval (PLN 1999-00463) received on September
       7,2000; associated Building Permit (BLD 2000-01767) final inspection on October 7,
       2002.

       Master Use Permit Renewal- Planning approval (PLN 2000-00166) received on
       May 6, 2010.

All of the above-referenced Planning approvals and authorizations will be consolidated into this
Master Use Permit application (PLN 2010-00026), which will regulate both the day-to-day
operations of the Sky lawn property and all Phase 1 development described in this report.

KEY ISSUES

A. 	   CONFORMANCE WITH PREVIOUS USE PERMIT CONDITIONS OF APPROVAL

       As previously discussed, the Skylawn facility has operated with a County-issued use permit
       since 1955. lbe discussion below addresses whether the previous conditions of approval
       (those from the recent Use Permit Renewal PLN 2000-00166, in italics below) have been
       met and whether they should be retained, revised, or eliminated.

       1. 	    This Use Permit Renewal approval applies to the documents, plans, and previously
              approved projects and amendments in this report (e.g, the mortuarylfuneral home,
              Eternity Gardens and Bat Ling interment projects) submitted to and approved by the
              Zoning Hearing Officer on May 6,2010. The Use Permit shall be validfor jive years
              following the date offinal use permit approval, or superseded pursuant by the expira­
               tion terms mandated under Skylawn 's pending Master Use Permit (PLN 2010-00026)
               if approved In either case, the applicant shallfile for a renewal ofthis permit six
               months prior to expiration with the County Planning and Building Department. All
               renewal dates shall be measured from the date ofthe jinal approval. In the event the
              pending Master Use Permit is not approved, minor modifications to this permit may
               be approved by the Community Development Director ifthey are deemed not to
               intensify the use ofthe Skylawnfacility and are considered in keeping and in com­
              pliance with the scope and conditions ofthis permit. A ny projects that do not fall
               under this "minor mod{fication" category shall be subject to a formal amendment
               ofthe Use Permit, including any other zoning permits (i.e., RMD Permit, Grading
               Permit) required, along with applicable application fees.

              Compliance with Condition? Yes. The Use Permit Renewal was approved by the
              Zoning Hearing Officer on May 6,2010. This Master Use Permit will incorporate
              all previous (if stilI applicable) conditions of approval and supersede the recently


                                                  - 4­
       approved renewal. Similar conditions regarding the renewal schedule and the
       provisions for minor modifications will be included in the conditions of approval
       for the new Master Use Permit.

       Recommend to Retain Condition? Yes, but modified to reflect the project-specific
       details and renewal schedule associated with the 20-year Master Use Permit.

2. 	   The applicant shall adhere to their submitted proposal whereby they agree to selj~
       regulate application ofany pesticide, herbicide or fertilizer, and shall not apply such
       substances during any climatic conditions (i.e., winds, rain) whereby such substances
       could leach toward and onto or be blown easterly toward the adjacent SFPUC lands.

       Compliance with Condition? Yes. Sky lawn has developed and implemented a
       pesticide and herbicide management plan.

       Recommend to Retain Condition? No. California Food and Agricultural Code
       Section 11501.1 prohibits any local government agency attempts to regulate the use
       of pesticides, herbicides, fertilizers, etc. However, Sky lawn has submitted a plan
       that outlines their internal practices/procedures (Attachment N) intended to result
       in continued compliance with all applicable California Food and Agricultural Code
       regulations in perpetuity.

3. 	   The previously submitted maintenance surety deposit for the landscaping associated
       with the Mortuary project shall be reduced to $2,500. The initial deposit shall be
       refunded upon receipt ofa new depositfor the $2,500 amount. This revised deposif
       shall be kept until and refunded by February 26. 2012 (5 years from their original
       planting) upon confirmation that the trees have continued to grow toward their
       intended height for the screening purposes they were requiredjor.

       Compliance with Condition? Yes. The $2,500 surety deposit was received and has
       since been released after confirming that all landscaping is healthy and is providing
       the degree of screening required by previous conditions of approval.

       Recommend to Retain Condition? No. The condition has been met and need not be
       retained.

4. 	   Skylawn's waste storage and removal plan shall continue to be in compliance with
       County Environmental Health requirements.

       Compliance with Condition? Yes. The Skylawn facility has remained in compliance
       with all applicable Environmental Health Division standards and regulations.
       Elements of the proposed Phase I development may, when undertaken, trigger
       additional Environmental Health review and will require ongoing compliance with
       all applicable codes and ordinances.

       Recommend to Retain Condition? Yes.




                                            5­
5. 	    Skylawn shall continue to work with the SFPUC, GGNRA, and the Bay Area Ridge
        Trail Council to accommodate the Bay Area Ridge Trail currently proposed on
        Skylavvn 's property along its eastern boundary per the adopted alternative as
        discussed in the SFPUC's 1999 Draft EIRfor its Watershed Management Plan.
        The site plan ofany proposed Skylawn project along or near the trail shall show its
        actual designated trail boundaries to the degree that they are known at the time of
        that projecf 's subsequent submittal and review. While Skylawn agrees to cooperate
        in the trail's development, they shall be under no financial or maintenance obliga­
        tions associated with the trail acquisition or development as a condition ofthis
        permit. In the event the pending Master Use Permit is approved, this requirement
        shall be more explicitly reviewed and mandated regarding the recording ofthe
        agreement and the actual construction ofthe trail.

        Compliance with Condition? Yes. Sky lawn continues to cooperate with all
        stakeholders in the development of the portion of the Bay Area Ridge Trail that
        would traverse the eastern portion of its property.

        Recommend to Retain Condition? Yes, but modified to remove references to the
        "pending Master Use Permit."

6. 	    The proposed "Preservation and Environmental Management Zone" shall be held
        in abeyance and considered as part o/Skylawn 's pending and proposed Long Term
        Master Use Permit (PLN 2010-00026).

        Compliance }pith Condition? Yes. As a condition of the Master Use Permit's
        approval, Skylawn will be required to formally record the Environmental Protection
        Zone.

        Recommend to Retain Condition? Yes, but modified to require that the Environ­
        mental Management Zone be recorded prior to the issuance of any Phase I
        development permits.

7. 	    The landscaping installed around the westerly and southerly perimeters ofSkylawn 's
        existing mausoleum building shall be maintained so that it achieves its maximum
        screening ability as required. Other than as recommended by a licensed arborist due
        to the trees' health (whose report shall be submitted to the Planning Departmentfor
        review and approval), they shall not be trimmed or topped.

        Compliance with Condition? Yes. The trees appear to be healthy and continue to
        provide a greater degree of screening. This landscaping element serves a critical
        visual screening purpose and must continue to be maintained in perpetuity.

        Recommend to Retain Condition? Yes.

 8. 	   Allfuture landscaping throughout the Skylawn cemetery facility shall be comprised of
        non-invasive and non-exotic species ofgroundcovers, shrubs, andflowers (including



                                           -6­
       plant species with soil-binding characteristic!!) andlor trees appropriate to Coastal
       San Mateo County and the adjacent Watershed area. All landscaping throughout
       the Skylawn cemeteryfacility shall be properly maintained and shall be designed
       with efficient irrigation practices to reduce runoff, promote surface filtration, and
       minimize the use offertilizers, herbicides, and pesticides, which can contribute to
       runoffpollution.

       Compliance with Condition? Yes. As mentioned in the recent Use Permit Renewal,
       the two most recent Skylawn projects (the Eternity Gardens interment facility and
       the major landslide repair project) resulted in new landscaping that included non­
       invasive, non-exotic plant species and appropriate irrigation techniques designed to
       reduce runoff.

       Recommend to Retain Condition? Yes, though this condition will be reconfigured
       and combined with new elements to ensure ongoing compliance.

9. 	   All existing or any new exterior lighting located anywhere on Skylawn '5; property
       shall be corrected, placed, and designed such that no light glare is visiblefrom any
       public road or viewing location from within any surrounding scenic corridor. Where
       necessary or applicable, the applicant shall submit an exterior lighting plan to the
       Planning Department for review and approval to ensure that this standard is met.
       Such a plan shall include the location ofall exterior lighting elements, including the
       manl{facturer 's spec!ficationsfor type, design, height, and candle-power. Any and
       all new freestanding light fixtures shall not exceed four (4) feet in height and shall be
       placed and designed such that no light glare is visible from any public road or view­
       ing location from within any surrounding scenic corridor. Any existing or new
       exterior lightingfixtures mounted to any building or structure shall be limited to
       those requiredform minimum security and safety purposes at those respective
       facilities. The glare jrom such lighting shall not be visible from any public road or
        viewing locationjrom within any surrounding scenic corridor and shall be confined
       to those facilities. No up-lighting or display lighting intended to illuminate any
        building, structure, or surrounding landscaping shall be allowed.

       Compliance with Condition ? Yes. All lighting continues to comply with this
       condition. While no new lighting fixtures are proposed at this time, exterior
       lighting plans will be required to ensure that all future lighting required by new
       cemetery development comply with this condition. It is understood that all of the
       new cemetery development proposed under the Master Use Permit will not and
       cannot be lit for after-dark public/client use.

       Recommend to Retain Condition? Yes.

]O. 	 Any new elec/ric or telephone utilities serving any new structure or/acUity through­
      out Skylawn 's property shall be place entirely underground, leading/rom the
      closest existing utility pole to the project site. Such undergrounding shall clearly
      be indicated on any required building plans.



                                           -7­
     Compliance with Condition? Yes. All recently installed utilities have been installed
     to the satisfaction of the Community Development Director.

     Recommend to Retain Condition? Yes. Any new utilities that may be required by
     Phase 1 development will be required to comply with this condition.

11. 	 Grading activities shall be restricted to those necessary to accommodate excavation
      for new cemetery graves within the existing interment areas. Erosion control mea­
      sures, where needed or applicable, shall always be implemented. Any new expansion
      ofinterment areas or construction ofroadways as indicated on the Master Plan may
      require a grading permit and shall require an amendment to this Use Permit.

     Compliance with Condition? Yes. All recent grading activity has been conducted
     according to the requirements stipulated in this condition.

     Recommend to Retain Condition? Yes, but modified to eliminate the requirement
     for an amendment to the Use Permit. The new Master Use Permit conditions of
     approval will address both general maintenance/operational grading and the specific
     construction-related earthwork proposed by future Phase 1 development.

12. 	 While private memorial or mausoleum structures are appropriate within the
      improved interment area limits ofthe cemetery, they may require building permits.
      {(they are proposed to be located such that they are visible from any public road or
      viewing location within any surrounding scenic corridor, Skylawn shall submit a site
      plan and appropriate elevations to the Planning Departmentfor review to determine
      if the development mandates any additional Planning review and permits, including
      amendment 10 this Use Permit. Regardless o/the level ofreview, such development
      shall always include the necessary erosion and sediment controls and stormwater
      drainage elements as required by County and State stormwater permit requirements.

     Compliance with Condition? Yes.

     Recommend to Retain Condition? Yes, but modified to eliminate the requirement
     for an amendment to the Use Permit. The references to erosion and sediment controls
     will also be removed from this condition to avoid unnecessary redundancy (the
     Master Use Permit's conditions of approval will include more specific and expansive
     conditions relative to erosion and sediment controls).

13. 	 The applicant shall seed all disturbed areas (beyond the improved portions ofany
      new project site) with a native grassland mix applied in conjunction with mulch and
      tackifier, as directed and overseen by the applicant's landscape architect, as soon as
      grading or clearing activities are completed in order to minimize the potential estab­
      lishment and expansion ofexotic plant species into newly-graded areas. Where a
       building permit is required, Planning staffshall confirm that such revegetation!
      reseeding has been adequately applied prior to the Building Inspection Section's
      final inspection ofthe project's respective bUilding permit.



                                        -8­
              Compliance with Condition? Yes. All recently disturbed areas were appropriately
              mulched and reseeded to the satisfaction of the Community Development Director.
              This condition shall continue to be applied to both minor disturbances and those
              created by larger Phase 1 development projects, as they occur.

              Recommend to Retain Condition? Yes.

       14. 	 Any ongoing operation or new (even ilconsider "minor") development on Skylawn's
             property shall always be in compliance with County Fire Authority requirements.

              Compliance with Condition? Yes.

              Recommend to Retain Condition? Yes.

       15. 	 Any ongoing operation or new (even ilconsidered "minor") development on
             Skylawn 's property shall always be in compliance with County Environmental
             Health requirements.

              Compliance with Condition? Yes.

              Recommend to Retain Condition? Yes

B. 	   CONFORMANCE WITH SAN MATEO COUNTY GENERAL PLAN

       Staff has reviewed the proposed project against the policies contained in the San Mateo
       County General Plan (GP) and found the project to be consistent with the goals and
       objectives contained therein. Those GP policies found to be applicable to this project
       are discussed below.

       1. 	   Chapter J - Vegetative, Water, Fish and Wildlife Resources. Policies 1.22 through
              1.26 seek to protect vegetation, water, fish and wildlife resources by regulating the
              location and design of development. Additionally, the Sensitive Habitats Section,
              including Policies 1.27 through 1.32, regulates development within and adjacent to
              sensitive habitats in order to protect critical vegetative, water, fish, and wildlife
              resources.

              The Master Use Permit will regulate the cemetery's expansion over the next 20 years.
              Specifically, the Master Use Permit will authorize the addition of new burial facilities
              within the Phase I development area. The Phase 1 area (see Attachments E and K)
              is located just north of the most recent Skylawn development (Eternity Gardens) in
              an area that contains primarily gently rolling hills with seasonal grasses. While
              there are very few trees in this area, a series of sensitive habitat areas (including
              creeks, wetlands, and protected plant/animal habitat) are located directly north and
              west of the proposed Phase 1 development. The foIlowing discussion summarizes
              the information presented in both the Biological Resources Constraints and




                                                  -9

Opportunities Evaluation and the Mitigated Negative Declaration (Attachment M.I).
Please refer to these attachments for a more detailed discussion.

a. 	   Wildlife Resources. The San Francisco garter snake, California red-legged frog,
       and bay checkerspot butterfly are known to occur in the area and portions of the
       property appear to support each species' respective habitat. While Skylawn
       intends to avoid any potentially hannful activities to any protected wildlife
       species (and a series of mitigation measures are intended to reduce potential
       impacts to these protected species), Skylawn must obtain an Incidental Take
       Permit from the United States Fish and Wildlife Service (USFWS) to ensure
       no unlawful take of said species. Proof of such USFWS approval must be
       submitted to the Planning and Building Department prior to issuance of any
       Phase 1 grading or building permits. Conditions of Approval Nos. 34-41 have
       also been added to ensure that Phase 1 development does not have any adverse
       impact to wildlife species in the area.

b. 	   Vegetative Resources. The Phase 1 area consists mostly of non-native annual
       grasslands, with a large portion of these grasslands having a very high density
       of Italian thistle and other weedy species. There is a small area of coastal scrub
       and one small seasonal wetland within the Phase 1 area. The Biological
       Resources Constraints and Opportunities Evaluation (prepared and submitted
       by the project biologist) lists a series of special-status plant species that have
       been documented in the area. However, few are expected to occur within the
       project area due to a lack of appropriate soils types and potential habitat. No
       special-status plant species were observed in the Phase 1 area during the
       focused surveys conducted by Vollmar Consulting in May and June 2009.
       Based on these survey results, it is not expected that special-status plant species
       are currently present in the Phase 1 area. This is based on: (l) the negative
       survey results; (2) that only the outer edge of coastal scrub habitat extends into
       the Phase 1 area and this area was accessible and surveyed; and (3) most of the
       area has been subject to large historic disturbances as evidenced by the very
       high density of weedy species within the annual grasslands. Because rare plant
       surveys are generally valid for three years, additional surveys will be required
       prior to any grading or construction activities beginning after 2012. Conditions
       of Approval Nos. 31-32 have been added to ensure that appropriate clearance
       surveys be conducted and appropriate mitigation and/or avoidance measures
       taken to avoid any significant impacts to vegetative resources in the area.

c. 	   Water and Fish Resources. The Skylawn property contains portions of
       two tributaries of Pilarcitos Creek (Albert Canyon Creek in the southern
       portion of the property and an unnamed tributary along the western portion
       of the property) and series of seasonal wetlands. The Phase 1 area does not
       contain nor is it directly adjacent to any creeks or tributaries. It does, however,
       include a small seasonal wetland around which Skylawn has agreed to design
       all Phase 1 development so as not to disturb the existing conditions. Because
       no work is proposed within any streams, creeks, wetlands, or any waterways,



                                     - 10­
            the primary potential impacts that could result from Phase 1 projects are
            erosion, sedimentation, and hydrograph modification. These potential impacts
            could result from either (1) grading and construction operations themselves
            and/or (2) post construction impacts resulting from the newly altered landscape.
            However, the implementation of Conditions of Approval Nos. 9-29 will
            mitigate these impacts to a less-than-significant level.

       The conditions of approval listed in Attachment A include a series of mitigation,
       minimization, and avoidance measures that will reduce any potentially-significant
       impacts to a less-than-significant level. Adherence to the conditions of approval and
       those required by the USFWS Incidental Take Permit and NPDES Permit will ensure
       no long term adverse effects on vegetation, water, fish, or wildlife resources.

2. 	   Chapter 2 -- Soil Resources Policies. Policies 2.17 (Regulate Development to
       Minimize Soil Erosion and Sedimentation) and 2.32 (Regulate Excavation, Grading,
       Filling. and Land Clearing Activities Against Accelerated Soil Erosion) seek to
       ensure that development proposals include measures to minimize soil erosion and
       sedimentation. Phase 1 development is expected to include primarily large areas of
       traditional lawn burial, with smaller areas of high-density mausoleum/columbarium
       facilities and garden crypts. Each of these projects, as they occur, will require vary­
       ing degreesltypes of grading. Lawn burial areas will require minor grading to create
       relatively level burial areas out of the gently sloping terrain that currently exists in
       these areas. Mausoleum and columbarium structures will require larger cuts into the
       eastern ridge areas so that they can be set into the hillside rather than protrude above
       the ridgeline. Some grading and engineering will also be required for the road net­
       work to access these new facilities. Total earthwork for all Phase 1 projects is not
       expected to exceed 50,000 cubic yards over the permit's 20-year term.

       For each of these Phase 1 projects the applicant will be required to file separate
       grading permit applications that will describe the degree of grading to be accom­
       plished, the method for controlling construction related erosion and sedimentation,
       and all permanent stormwater control systems proposed. Conditions of Approval
       Nos. 9-29 will regulate grading and construction operations and require that the
       applicant: (l) submit grading and drainage plans, to be reviewed by the Planning
       and Building Department and Department of Public Works, for each Phase 1 project;
       (2) implement the approved plan and install all construction related best management
       practices (BMPs) prior any grading or construction activities; (3) periodically inspect
       (particularly during/after significant weather events) and maintain all approved mea­
       sures to insure that they continue to function properly throughout the life of the
       project; and (4) submit proof of filing a Notice of Intent (NOI) with the State Water
       Resources Control Board (SWRCB) and implement the approved Stormwater
       Pollution Prevention Plan (SWPPP) prior to any grading or construction activities.
       Enforcing these conditions of approval (along with the provisions of the Grading
       Ordinance), will ensure compliance with all Soils Resources Policies and will limit
       soil erosion and sedimentation to the extent possible.




                                           - 1J   ­
3. 	   Chap-leI' 4 ~ Visual Quality Policies. Policies 4.14 (Appearance 0/ Nevil Develop­
       ment) and 4.21 (Scenic Corridors), along with all of the Scenic Roads and Corridors,
       Architectural Design/or Rural Scenic Corridors, and Site Planning/or Rural Scenic
       ('orridors Policies, are applicable to this project. These policies seek to protect and
       enhance the natural visual character of scenic areas by promoting good design, site
       relationships, and other aesthetic considerations. The Visual Quality Policies' goals
       and objectives include minimizing grading and tree/vegetation removal, locating
       structures to blend with the existing scenic qualities of the site, and designing
       structures to include compatible colors, materials, and architectural styles.

       While the subject parcel is located in a hilltop setting, the site's existing natural
       topography is such that a large majority of the property is screened from most
       surrounding viewpoints. The most visible areas of the property are those along the
       ridgeline that traverses the eastern portion of the property. While some high-density
       interment facilities are intended for this area, all such facilities will be set into the
       hillside so as not to protrude above the ridgeline. Additionally, any new utilities are
       required to be located underground. The project, as proposed and conditioned, will
       not have any significant permanent visual impact on the scenic qualities of the area
       and is consistent with the goals and objectives of the applicable Visual Resources
       Policies, Resource Management Development Review Criteria, and scenic corridor
       regulations.

4. 	   Chapler 5 ~ Historical and Archaeological R(3sources Policies. Policies 5.20
       (Sile Survey) and 5.21 (Site Trealmen!) require that the applicant take appropriate
       precautions to avoid damage to historical and archaeological resources. A literature
       review was completed by the Northwest Information Center (NWIC) in order to
       identify any cultural resources on the project site. According to the review, there
       have been six cultural resource studies that cover approximately 20% of the project
       site. Previously assessed areas on the project site do not contain any recorded cultural
       resources. Federal, state and local inventories also do not include recorded cultural
       resources on the project site. The NWIC report also indicates there are no Native
       American resources in or adjacent to the proposed project area referenced in the
       ethnographic literature.

       Native American cultural resources in this part of San Mateo County are normally
       found along ridges, on midslope benches, in valleys, and adjacent to intermittent
       and perennial watercourses. The project site consists of a number of these environ­
       mental settings and features, as it is located on Cahill Ridge, and includes lands along
       the slopes of the mountain, including drainage canyons and tributaries of Pilarcitos
       Creek. Given the similarity of environmental factors on the project site and the
       ethnographic sensitivity of the area, there is a possibility that unrecorded Native
       American cultural resources exist 011 the project site. Condition of Approval No. 42
       will ensure that any previously unrecorded archaeological/cultural resources be
       protected and appropriate avoidance and mitigation measures implemented.




                                           - 12 ­
5. 	   Chapter 9 - Rural Land Use Policies. General Open Space Policies 9.40
       (Maintenance ofthe Open Space Character ofLands Designated as General Open
       Space) and 9.42 (Development Standardsfor Land U'ie Compatibility in General
       Open Space Lands) seek to regulate the development of rural lands in a way that
       maintains the open space character of the area. The Master Use Permit is consistent
       with these policies because Phase 1 development will occur primarily in areas that are
       minimally visible from surrounding viewpoints. The nature of the proposed cemetery
       development (particularly the large areas of traditional and "green" lawn burial) will
       remain consistent with the open space characteristics of the property. None of the
       high-density interment structures will protrude above the ridgeline and will not
       detract from the scenic qualities of the surrounding area.

       While the expansion of the Bay Area Ridge Trail is not formerly part of the Phase 1
       development, ongoing conversations with the Golden Gate National Recreation Area
       (GGNRA), SFPUC, and Bay Area Ridge Trail Council are intended to result in a
       portion of the trail traversing the eastern part of the Skylawn property. This recrea­
       tional use would be consistent with GP Policy 9.35 (Encourage Existing and
       Potential Public Recreation Land Uses) because it would fill a critical gap in the
       current trail. The proposed cemetery expansion is also consistent with Policy 9.43
       (San Francisco Watershed Lands) because it will have no impact on the adjacent
       SFPUC Watershed property.

6. 	   Chapter 10- Water Supply Policies. Policy 10.19 (Domestic Wafer Supply)
       encourages the use of domestic wells in rural areas and Policy 10.20 (Well Location
       and Construction) seeks to guide the location of domestic wells in a safe and efficient
       manner. Water is supplied to the site by two sources: an existing water well and
       water from the Coastside County Water District (District). The District supplies
       non-potable water to the project site for irrigation of the burial lawns and associated
       landscaping. The source of District provided water for this portion of the County is
       the California Water Service contracts for water from the Hetch Hetchy and Crystal
       Springs Reservoir water systems. The proposed Master Land Use Plan (MLUP)
       would increase the demand for non-potable water from the District for irrigation and
       landscape purposes. However, this increased demand for water from the District
       would not result in an increased extraction of groundwater resources in the area.

       The existing cemetery currently irrigates approximately 83 acres oflawn. The
       estimated total irrigated lawn associated with all Phase I development is approxi­
       mately 15 acres, which is 18% of the area of irrigated lawn in the existing cemetery.
       This project conservatively assumes that the traditional lawn would require irrigation
       at a similar water demand (per acre) for the existing cemetery. Between 2008 and
       2009, the cemetery consumed approximately 41 million gallons of water to irrigate
       approximately 83 acres of turf. Assuming the same infrastructure and plant materials
       as currently exist, the additional 15 acres of lawn associated with Phase 1 develop­
       ment would generate a demand for approximately 7 million gallons of water per year.
       However, future irrigation system efficiency improvements and the use of drought
       resistant turf (such as those that would be implemented by Phase I development)



                                          - 13 ­
           would reduce the demand of water for irrigation. All Phase 1 projects will make use
           of native species that are appropriate to hillside ecology and that reduces the carbon
           footprint caused by the maintenance of trees, shrubs, and ground cover. The use of
           native materials and native plants, including drought and fire resistant plants would
           be used to the extent feasible throughout the proposed developed areas. Alternative
           sources of irrigated water that may be available to the project applicant (including
           wastewater reuse) will be pursued to meet the future irrigation needs to further reduce
           water demand. Condition of Approval No.8 will ensure compliance with all Model
           Water Efficient Landscape Ordinance requirements according to Assembly Bill 1881
           (effective January I, 20 10).

           The private water well, located near the old quarry site, provides potable water to the
           funeral home, reception building, and the old administration building (that is not
           currently in use). The well has a capacity to produce 6 to 16 gallons of water per
           minute (gpm) and feeds a 1O,OOO-gallon tank that in turn feeds the potable water
           system. The current capacity needed for the existing cemetery is 6 gpm. As the
           project would not include improvements that require potable water, there would
           not be increased demand for this well water as a result of the project. As such, the
           proposed MLUP would not result in impacts to groundwater resources through
           extraction.

           Phase I development would convert a moderate amount of undeveloped land into
           impervious surfaces through the construction of burial structures. However, the
           majority of the new cemetery development would have large areas of lawn, pervious
           pavements for the proposed roadways, vegetated buffer zones, and infiltration
           trenches to allow for groundwater recharge. Furthermore, the project's proposed
           storm drainage system would provide clean water to the natural drainage channels
           at the same rate at which they receive water in the current, pre-development state;
           no more and no less. As such, implementation of the MLUP would not interfere
           substantially with groundwater recharge such that it would result in a deficit in
           aquifer volume or lowering of the local groundwater table.

    7. 	   Chapter 11 -:- Wastewater Policies. Policies 11.10 (Wastewater Management in
           Rural Areas) and 11.13 (Septic Tank Maintenance) ensure that wastewater will be
           adequately and safely disposed of in rural areas. Proposed Phase 1 development will
           not result in the construction of any buildings or increased capacity of the existing
           wastewater system. Any future proposals would need to be reviewed and approved
           by the County's Environmental Health Division prior to implementation.

C   CONFQRMANCE WITH ZONING REGULATIONS

    1. 	   Minor Development Review Procedure

           San Mateo County Zoning Regulations Section 6458.3 defines minor development
           as "any development which, following examination of environmental information, is
           qualified for a Negative Declaration or Categorical Exemption." Because a Mitigated



                                              - 14 ­
       Negative Declaration was published for this project, it qualifies as a minor develop­
       ment and is subject to Section 6458 (Minor Development Review Procedure). All
       such minor development within the RM Zoning District is subject to the issuance of a
       certificate of compliance, which certifies that all applicable criteria contained within
       Chapter 20A.2 (Development Review Criteria) have been met. The Development
       Review Criteria, as they relate to this project, are listed and discussed below in
       Section C.2 of this report.

2. 	   Resource Management Development Review Criteria

       The applicable development review criteria are listed and discussed in detail below.

       a. 	   Environmental Quality Criteria. The project meets all applicable Environ­
              mental Quality Criteria contained in Section 6324.1. The primary potential
              environmental impacts addressed in the Mitigated Negative Declaration include
              the following:

              (1) 	 Erosion/Sedimentation: Grading and construction activities have the
                    potential to create erosion and sedimentation impacts to the existing
                    natural landscape. However, Conditions of Approval Nos. 9-29 will
                    ensure that all such activities will be properly mitigated to reduce these
                    impacts to a less-than-significant level. While Phase 1 projects will
                    include the introduction of new impervious surfaces (roadways, burial
                    facilities. etc.), a large portion of the area will include traditional and/or
                    natural lawn burial areas. Permanent stormwater control measures are
                    required to ensure continued compliance with the County Drainage Policy
                    and NPDES permit requirements. Conditions of Approval Nos. 9-29 will
                    ensure compliance with all applicable storm water management regula­
                    tions. The proposed roadways will also utilize pervious materials
                    wherever possible.

              (2) 	 Plant/Wildlife: As indicated in the Biological Constraints and Oppor­
                    tunities Report (prepared by Pacific Biology and dated July 7, 2009), a
                    number of protected plant and wildlife species have the potential to
                    occur on and adjacent to the Phase I project areas. Very few species
                    are considered likely to occur in the project area; however, Conditions
                    of Approval Nos. 30-44 have been included to ensure that appropriate
                    avoidance and mitigation measures are taken to prevent any adverse
                    impacts to any special status plant and wildlife species that may be
                    present on-site.

              (3) 	 Sensitive Areas: Phase 1 development will not encroach into any wetland
                    areas or infringe upon any stands of native vegetation. A large majority
                    of the Phase 1 project areas consists of invasive seasonal grasses that
                    will be replanted, wherever possible, with native plant species that are
                    visually and biologically appropriate for the area. Conditions of



                                            - 15 ­
            Approval Nos. 30-44 have been included to ensure that no sensitive
            areas are impacted during the implementation of Phase 1 projects.

       (4) 	 Pesticide Use: California Food and Agricultural Code Section 11501.1
             prohibits local government entities from attempting to regulate the use
             of pesticides, herbicides, fertilizers, etc. Skylawn has, however, agreed
             to abide by the best management practices for fertilizer and pesticide
             application included in Attachment N. Said agreement, coupled with
             Skylawn's ongoing compliance with the Food and Agricultural Code
             regulations, will ensure no adverse impacts resulting from any fertilizer
             or pesticide use.

b. 	   Site Design Criteria. The project meets all applicable Site Design Criteria
       contained in Section 6324.2. The Phase I project area was carefully selected to:

       (1) 	 Minimize exterior visual impacts on the surrounding state scenic corridors.
             Most of the proposed development will only be visible from the property's
             interior and will not be visible above the existing eastern ridge. None of
             the proposed Phase 1 projects will include any elements that protrude
             above the ridge and will not be overly visible from any points within the
             adjacent State and County scenic corridors.

       (2) 	 Minimize total grading quantity required. The Phase I area will consist
             primarily of traditional lawn burial areas that will require only modest
             grading activities in order to create moderately flat burial areas. Other
             burial proposed structures (mausoleum and columbarium) will be set
             into the hillside so as not to protrude above the eastern ridge. Proposed
             roadways will consist only of those that are minimally required to ensure
             safe access and circulation throughout the new burial areas.

       (3) 	 Minimize impacts to sensitive plants, animals, and habitats and preserve
             native vegetation. Areas of particularly steep slopes, thick forest, or poor
             soil stability will be avoided. The project also specifically avoids the
             adjacent wetlands and sensitive habitat areas.

       The Conditions of Approval included in Attachment A will ensure compliance
       with all Site Design Criteria.

c. 	             The proposal meets the Utilities criteria contained in Section 6324.3
       primarily because it does not include the addition of any utilities. No new
       buildings are proposed that would result in an increased need for water or
       septic system capacity. Condition of Approval Nos. 7 and 28 require that
       any new utility lines (for any minor light fixtures) be installed underground.

d. 	   Water Resources Criteria. The water resources criteria seek to ensure that
       development proposals: (1) include as little grading as possible, (2) minimize



                                     - 16 ­
              changes in vegetative cover, (3) manage surface water runoff, and (4) imple­
              ment erosion and sedimentation controls to assure stability of downstream aqua­
              tic environments. The implementation of Conditions of Approval Nos. 9-29
              (previously discussed in the Environmental Quality Criteria section) will reduce
              the potential water quality impacts to a less-than-significant level.

       e. 	   Cultural Resources Criteria. Condition of Approval No. 42 has been added
              to ensure that the project will not have an adverse impact to cultural or
              archaeological resources in accordance with Cultural Resources Criteria
              Sections 6324.5(a-c).

       f. 	   Slope Instability Area Criteria. There appear to have been a number of land­
              slides and slope stability issues on the subject parceL Slope stability ranges
              from "poor" to "good" on the 1973 Geotechnical Hazards Synthesis Map
              (Sheet No.2). However, Conditions of Approval Nos. 20-21 have been added
              to ensure compliance with all the Slope Instability Area Criteria contained in
              Section 6326.4.

3. 	   Compliance with Grading Ordinance (Chapter 8, Division VII, San Mateo County
       Ordinance Code)

       In order to approve a grading permit for up to 50,000 cuhic cards of earthwork, the
       Planning Commission must make the following findings pursuant to Section 8604.6
       of the San Mateo County Ordinance Code. The findings are listed below followed by
       discussion regarding compliance:

       a. 	   The granting ofthe permit will not have a significant adverse effic! on the
              environment. Staff completed an Initial Study, pursuant to California
              Environmental Quality Act (CEQA) regulations, and determined that the
              project, if undertaken with appropriate mitigation measures, would not have
              a significant adverse impact on the environment. The Mitigated Negative
              Declaration's mitigation measures have been incorporated into staffs
              recommended conditions of approval in Attachment A to this report. The
              potential soil erosion, sedimentation, and hydrograph modification impacts
              associated with the grading proposed as part of Phase 1 development will be
              reduced to a less-than-significant level. Conditions of Approval Nos. 9-29 will
              ensure that no significant environmental impacts occur as a result of this project.

       b. 	   The project confOrms to the criteria o[Chapter 8, Division VIl, o(the San
              Mateo County Ordinance Code, including the standards refi:;renced in Section
              8605. The project, as proposed and conditioned, conforms to standards in
              the Grading Ordinance, including those relative to an erosion and sediment
              control plan, dust control plan, fire safety, and the timing of grading activity.
              Conditions of Approval Nos. 9-29 have been included in Attachment A to
              ensure compliance with the County's Grading Ordinance.




                                            - 17 ­
              c. 	   The project is consistent with the General Plan. The project has been reviewed
                     against the applicable policies of the San Mateo County General Plan and found
                     to be consistent with its goals and objectives. Please refer to Section B of this
                     report for detailed discussion regarding the project's compliance with General
                     Plan Policies.

       4. 	   Use Permit Findings

              In order to approve the Master Use Permit, the Planning Commission must make the
              following findings:

              a. 	   That the establishment, maintenance and/or conducting of the proposed use will
                     not, under the circumstances of this particular case, be detrimental to the public
                     welfare or injurious to property or improvements in said neighborhood. Staff
                     recommends that this finding can be made as a result of the implementation of
                     the mitigation measures and conditions of approval, which will reduce all
                     potentially significant impacts to a less-than-significant level.

              b. 	   That the approval ofthis Master Use Permit for Skylawn Cemetery is necessary
                     for the public health, safety, convenience or welfare of the community. Staff
                     recommends that this finding can be made because the Sky lawn facility pro­
                     vides unique yet critical services to the residents of San Mateo County in that it
                     is a major interment facility, offering a full array of funeral and burial services
                     at the site.

D. 	   REVIEWING AGENCIES

       The following departments, agencies, and organizations have reviewed the proposal and
       offered comments and conditions of approval relative to their respective standards:

       San Mateo County Building Inspection Section
       San Mateo County Department of Public Works
       San Mateo County Geotechnical Section
       San Mateo County Environmental Health Division
       Cal-Fire

E. 	   ENVIRONMENTAL REVIEW

       Pursuant to California Environmental Quality Act (CEQA) regulati~ns, staff conducted an
       Initial Study and determined that the project, as proposed and conditioned, would not have
       a significant impact on the environment. A Mitigated Negative Declaration was published
       on October 30,2010 and the review period ended November 30,2010. The resulting
       mitigation measures have been incorporated into this permit's conditions of approval
       (see Attachment A).




                                                   - 18 ­
       During the project's review period, staff received comment letters from two reviewing
       agencies: United States Fish and Wildlife Service (USFWS) and California Depal1ment of
       Transportation (CaITrans). Their comments are discussed in detail below.

       a. 	   United States Fish and Wildlife Service. USFWS wanted to ensure that the applicant
              apply for an Incidental Take Permit due to the potential impacts to the San Francisco
              garter snake, California red-legged frog, and bay checkerspot butterfly. After a
              conference call with USFWS staff, Planning and Building Department staff and a
              number of Skylawn representatives, the applicant agreed to work with USFWS in
              obtaining an Incidental Take Permit for the project. This requirement has been
              included in the conditions of approval listed in Attachment A.

       b. 	   California Department of Transportation. CalTrans wanted to ensure that the
              project sponsor obtain an encroachment permit prior to any roadwork within their
              right-of-way (ROW). CalTrans also wanted to review the traffic analysis prepared
              by CH2M Hill, which was not included in the referral packet. In response, Sky lawn
              proposed to repave and re-stripe this ROW area in order to better direct vehicles
              approaching/exiting Skylawn's facility. A condition of approval has been added to
              ensure this improvement occurs.

A TTACHMENTS

A. 	   Recommended Findings and Conditions of Approval
B. 	   Location Map
C. 	 Project Site and Vicinity Map
D. 	 Site Plan
E. 	 Phasing Plan
F. 	 Geology and Slope Analysis Map
G. 	 Plant Communities Map
H. 	 Composite Geological and Biological Constraints Map
I. 	 Site Topography and Drainage Map
J. 	 Soils Map
K. 	 Phase I Site Plan
L.1. 	 Phase I Sections (Burial Facilities, Drainage, Slope Details)
L.2. 	 Phase 1 Sections (Roadway Details)
L.3. 	 Phase 1 Sections (Architectural Renderings)
M.l. 	Mitigated Negative Declaration
M.2. United States Fish and Wildlife Service Comments
M.3 	 Cal Trans Comments
N. 	 Skylawn's Pesticide, Herbicide, etc., BMPs

JC:pac - JXCV0509 _ WPU.DOC




                                                - 19 ­
                                                                                        Attachment A

                                       County of San Mateo 

                                 Planning and Building Department 


            RECOMMENDED FINDINGS AND CONDITIONS OF APPROVAL


Permit or Project File Number: PLN 2010-00026 	                      Hearing Date: August J 0, 2011

Prepared By: Joe Camicia, Project Planner                   For Adoption By: Planning Commission


RECOMMENDED FINDINGS

Regarding the Environmental Review, Find:

1. 	   That the Negative Declaration is complete, correct, and adequate and prepared in accor­
       dance with the California Environmental Quality Act (CEQA) and applicable State and
       County guidelines.

2. 	   That, on the basis of the Initial Study, comments received hereto, and testimony presented
       and considered at the public hearing, there is no substantial evidence that the project, as
       mitigated by the mitigation measures contained in the Negative Declaration, will have a
       significant effect on the environment.

3. 	   That the Negative Declaration reflects the independent judgment of San Mateo County.

4. 	   That the mitigation measures identified in the Negative Declaration, agreed to by the
       applicant, placed as conditions of approval, and identified as part of this public hearing,
       have been incorporated into the Mitigation Monitoring and Reporting Plan in conformance
       with California Public Resources Code Section 21081.6.

Regarding the Use Permit Renewal and Adoption of a 20-year Master Use Permit, Find:

5. 	   That the establishment, maintenance and/or conducting ofthe proposed use will not, under
       the circumstances of this particular case, be detrimental to the public welfare or injurious to
       property or improvements in said neighborhood as the implementation of the mitigation
       measures and conditions of approval will reduce all potentially significant impacts to a
       less-than-significant level.

6. 	   That the approval of this Master Use Permit for Skylawn Cemetery is necessary for the
       public health, safety, convenience or welfare of the community as it provides uniq ue yet
       critical services to the residents of San Mateo County in that it is a major interment facility,
       offering a full array of funeral and burial services at the site.




                                                 - 20­
Regarding the Resource Management Permit, Find:

7. 	   That the project is consistent with the goals, objectives, and regulations of the Resource
       Management Zoning District, Development Review Procedures, and Development Review
       Criteria. Specifically, the proposal, as conditioned, is consistent with the Vegetative,
       Water, Fish, and Wildlife Resources, Soil Resources, and Visual Quality Policies.

Regarding the Grading Permit, Find:

8. 	   That the granting of the permit will not have a significant adverse effect on the
       environment. Staff performed an Initial Study, pursuant to California Environmental
       Quality Act (CEQA) regulations, and determined that the project, if undertaken with
       appropriate mitigation measures, would not have a significant adverse impact on the
       environment and this Commission agrees with staffs determination for the reasons stated
       in the staff report. The Mitigated Negative Declaration's mitigation measures have been
       incorporated into the recommended conditions of approval to ensure that the project will
       have no adverse impacts to the environment.

9. 	   That the project conforms to the criteria of Chapter 8, Division VII, of the San Mateo
       County Ordinance Code, including the standards referenced in Section 8605. The project,
       as proposed and conditioned, conforms to standards in the Grading Ordinance, including
       those regarding an erosion and sediment control plan, dust control plan, fire safety, and the
       timing of grading activity.

10. 	 That the project is consistent with the San Mateo County General Plan. The project has
      been reviewed against the applicable policies of the General Plan and found, as proposed
      and conditioned, to be consistent with its goals and objectives.

RECOMMENDED CONDITIONS OF APPROVAL

General Procedural Conditions

1. 	   This approval applies only to the proposal, documents, and plans described in this
       report and submitted to and approved by the Planning Commission on August 10, 2011.
       Modifications beyond that which was approved by the Planning Commission will be
       subject to review and approval by the Community Development Director and may require
       review at a public hearing. Minor modifications that are consistent with the intent of, and
       in substantial conformance with, this approval may be approved at the discretion of the
       Community Development Director.

2. 	   The Master Use Permit, Resource Management Permit, Grading Permit, and Architectural
       Review Permit approval shall be valid for twenty (20) years (Phase 1) from the date of this
       approval (i.e., through August 10, 2031). If continuation of this use is desired, the appli­
       cant shall file a use permit renewal application with the Planning and Building Department
       six months prior to the permit's expiration and pay the fees applicable at that time. Any




                                                - 21 ­
        further cemetery development beyond the Phase 1 projects included in this permit shall be
        reviewed against the regulations in place at the time of application.

3. 	    Skylawn's waste storage and removal plan shall continue to be in compliance with County
        Environmental Health requirements.

4. 	    Skylawn shall continue to work with the SFPUC, GGNRA, and the Bay Area Ridge Trail
        Council to accommodate the Bay Area Ridge Trail currently proposed on Skylawn's
        property along its eastern boundary per the adopted alternative as discussed in the SFPUC's
        1999 Draft EIR for its Watershed Management Plan. The site plan of any proposed
        Skylawn project along or near the trail shall show its actual designated trail boundaries
        to the degree that they are known at the time of that project's subsequent submittal and
        review. While Skylawn agrees to cooperate in the trail's development, they shall be under
        no financial or maintenance obligations associated with the trail acquisition or development
        as a condition of this permit The easement and/or agreement for this area must be
        recorded prior to its inclusion in the Bay Area Ridge Trail.

5. 	    The Environmental Management Zone shall be recorded with the County Recorder's Office
        prior to the issuance of any Phase 1 grading or building permits.

6. 	    The landscaping installed around the westerly and southerly perimeters of Skylawn 's
        existing mausoleum building shall be maintained so that it achieves its maximum screening
        ability as required. Other than as recommended by a licensed arborist due to the trees'
        health (whose report shall be submitted to the Planning Department for review and
        approval), they shall not be tIimmed or topped.

7. 	    All existing or any new exterior lighting located anywhere on Skylawn's property shall
        be corrected, placed, and designed such that no light glare is visible from any public road
        or viewing location from within any surrounding scenic corridor. Where necessary or
        applicable, the applicant shall submit an exterior lighting plan to the Planning and Building
        Department for review and approval to ensure that this standard is met. Such a plan shall
        include the location of all exterior lighting elements, including the manufacturer's speci­
        fications for type, design, height, and candle-power. Any and all new freestanding light
        fixtures shall not exceed four (4) feet in height and shall be placed and designed such that
        no light glare is visible from any public road or viewing location from within any sur­
        rounding scenic corridor. Any existing or new exterior lighting fixtures mounted to any
        building or structure shall be limited to those required for minimum security and safety
        purposes at those respective facilities. The glare from such lighting shall not be visible
        from any public road or viewing location from within any surrounding scenic corridor and
        shall be confined to those facilities. No existing or future interment projects shal I include
        lighting for after-dark services or visitation except for any such lighting deemed necessary
        for previously cited minimum safety/security purposes. No up-lighting or display lighting
        intended to illuminate any building, structure, or surrounding landscaping shall be allowed.

 8. 	   All Phase 1 projects shall comply with the Model Water Efficient Landscape Ordinance 

        according to Assembly Bill 1881 (effective January 1, 2010). Prior to issuance of any 




                                                 - 22 

       Phase 1 grading or building permits, the applicant shall submit all applicable studies,
       analyses, reports, and proposals to the San Mateo County Planning and Building
       Department for review and approvaL

Construction/Grading Conditions

9. 	   This grading permit approval shall act as the master (umbrella) grading permit throughout
       the 20-year development of Phase 1. Total earthwork quantities for all Phase] develop­
       ment shall not exceed 50,000 cubic yards. Prior to commencement of any such grading
       or land clearing activities, the applicant must obtain a separate grading permit for each
       individual Phase I project. Each grading permit application will be reviewed by Planning
       and Building Department staff to ensure compliance with the Grading Ordinance, the
       Mitigated Negative Declaration prepared for this project, and National Pollutant Discharge
       Elimination System (NPDES) regulations. No site disturbance may occur until a complete
       "hard card" has been issued for each project.

10. 	 When submitting grading permit applications for each Phase 1 project, the applicant
      shall submit a grading and drainage plan (including calculations) to the Planning and
      Building Department and the Department of Public Works prior to the issuance of any
      project related grading or building permits. The grading and drainage plan shall include all
      requirements listed in Grading Ordinance Section 8604.1.a.5 (Application Requirements).
      The drainage plan shall also include a narrative describing the type, size, and location of
      all permanent stormwater controls to be utilized in order to ensure compliance with the
      County's Drainage Policy, the San Mateo County Water Pollution Prevention Plan
      (SMCWPPP). and NPDES Provision C.3. Said plan must contain project-specific erosion
      and sediment control measures that are best suited to address both construction related
      impacts and ongoing post construction storm water management. The plan shall adhere to
      the San Mateo Countywide Stormwater Pollution Prevention Program "General
      Construction and Site Supervision Guidelines," including:

       a. 	   Stabilizing all denuded areas and maintaining erosion control measures continuously
              between October 15 and April 15. Stabilizing shall include both proactive measures,
              such as the placement of hay bales or coir netting, and passive measures, such as
              revegetating disturbed areas with plants propagated from seed collected in the
              immediate area.

       b. 	   Storing, handling, and disposing of construction materials and wastes properly, so
              as to prevent their contact with storm water.

       c. 	   Controlling and preventing the discharge of all potential pollutants, including pave­
              ment cutting wastes, paints, concrete, petroleum products, chemicals, wash water or
              sediments, and non-stormwater discharges to storm drains and watercourses.

       d. 	   Using sediment controls or filtration to remove sediment when dewatering the site
              and obtaining all necessary permits.




                                                 - 23 ­
     e. 	   Avoiding cleaning, fueling, or maintaining vehicles on-site, except in a designated
            area where wash water is contained and treated.

     f. 	   Delineating with field markers clearing limits, easements, setbacks, sensitive or
            critical areas, buffer zones, trees and drainage courses.

     g. 	   Protecting adjacent properties and undisturbed areas from construction impacts
            using vegetative buffer strips, sediment barriers or filters, dikes, mulching, or other
            measures as appropriate.

     h. 	   Performing clearing and earth-moving activities only during dry weather.

     1. 	   Limiting and timing applications of pesticides and fertilizers to prevent polluted
            runoff.

     J. 	   Limiting construction access routes and stabilizing designated access points.

     k. 	   A voiding tracking dirt or other materials off-site; cleaning off-site paved areas and
            sidewalks using dry sweeping methods.

     I. 	   The contractor shall train and provide instructions to all employees and 

            subcontractors regarding the construction best management practices. 


J j. 	 For any Phase 1 project that will disturb more than one (1) acre, the applicant shall file
     a Notice of Intent (NOl) with the State Water Resources Control Board (SWRCB) and
     shall submit proof of filing said NOI to the Planning and Building Department prior
     to beginning of any grading or construction activities. The applicant and all grading/
     construction contractors shall adhere to all conditions and regulations associated with
     the State General Construction Activity NPDES Permit.

12. 	 For all Phase 1 projects, the approved project-specific Erosion and Sediment Control Plan
      must be fully implemented and the measures inspected by County Planning and Building
      Department staff prior to the commencement of any construction and/or grading activities
      and shall be maintained throughout the duration of the project. Erosion control measures
      shall be routinely inspected and any deficiencies shall be immediately corrected. All
      erosion and sediment control measures must be maintained in manner that prevents
      sediment and other pollutants from leaving the project site and protects all exposed
      earth surfaces from erosive forces to the maximum extent possible.

13. 	 The applicant shall seed all disturbed areas (beyond the improved portions of any new
      project site) with a native grassland mix applied in conjunction with mulch and tackifier,
      as directed and overseen by the applicant's landscape architect, as soon as grading or
      clearing activities are completed in order to minimize the potential establishment and
      expansion of exotic plant species into newly-graded areas. Where a building permit is
      required, Planning staff shall confirm that such revegetation/reseeding has been adequately




                                                - 24 ­
     applied prior to the Building Inspection Section's final inspection of the project's
     respective building permit.

14. 	 The engineer who prepared the approved Grading and Drainage Plan shall be responsible
      for the inspection and certification of the grading as required by Section 8606.2 of the
      Grading Ordinance. The engineer's responsibilities shall include those relating to non­
      compliance detailed in Section 8606.5 of the Grading Ordinance.

15. 	 At the completion of work, the engineer who prepared the approved Grading and Drainage
      Plan shall certify, in writing, that all grading, lot drainage, and drainage facilities have been
      completed in conformance with the approved plans, as conditioned, and the Grading
      Ordinance. Said engineer shaIl also submit a signed "as-graded" grading plan conforming
      to the requirements of Section 8606.6 of the Grading Ordinance.

16. 	 The applicant shall submit a dust control plan to the Planning and Building Department
      prior to the issuance of any Phase 1 grading hard cards. The approved measures shall be
      implemented and inspected prior to beginning any grading and/or construction activities
      and shall be maintained for the duration of the project. The plan shall, at minimum, include
      all the "Basic Control Measures" listed in Table 2 of the BAAQMD CEQA Guidelines:

     a. 	   Water all active construction areas at least twice daily.

     b. 	   Cover all trucks hauling soil, sand and other loose materials or require all trucks to
            maintain at least 2 feet of freeboard.

     c. 	   Pave, apply water three times daily, or apply (non-toxic) soil stabilizers on alJ
            unpaved access roads, parking areas and staging areas at construction sites.

     d. 	   Sweep daily (with water sweepers) all paved access roads, parking areas and staging
            areas at construction sites.

     e. 	   Sweep streets daily (with water sweepers) if visible soil material is carried onto
            adjacent public streets.

     Additional project-specific measures may be required in order to ensure that construction
     related activities do not generate elevated levels of dust particulates at any point throughout
     the duration of the project.

17. 	 Unless approved in writing and in advance by the Community Development Director,
      no grading shall be allowed during the winter season (October 15 to April 15) to avoid
      potential soil erosion.

18. 	 No grading shall commence until a schedule of all grading operations has been submitted
      to and reviewed and approved by the Department of Public Works and the Planning and
      Building Department. The submitted schedule shall include a schedule for winterizing
      the site. If the grading operations timetable calls for the grading to be completed in one



                                                - 25 ­
     grading season, then the winterizing plan shall be considered a contingent plan to be
     implemented if work falls behind schedule. The applicant shall submit monthly updates
     of the schedule to the Depaliment of Public Works and the Planning and Building
     Department. All submitted schedules shall describe the work in detail and shall
     project the grading operations through completion of the project.

19. 	 The applicant shall submit, for review by the Department of Public Works and the
      appropriate Fire District, a plan and profile of: (1) the existing and proposed access from
      the nearest publicly maintained roadway to the proposed project site, and (2) any new
      roadways proposed during Phase 1 development. When appropriate, this plan and profile
      shall be prepared from elevations and alignment shown on the roadway improvement plans.
      The roadway plan shall also include and show specific provisions and details for both the
      existing and the proposed drainage patterns and drainage facilities. All new areas shall
      meet Cal-Fire access requirements including slope, surface, weight, and width requirements
      at time of building or grading permit application.

20. 	 A design level geotechnical investigation of the Phase 1 area shall be performed prior to
      any project grading. The report shall include a static and seismic slope stability analysis
      of the Phase 1 area to be graded and developed. The specific mitigation measures to be
      utilized in order to stabilize identified landslides and areas of potential seismically induced
      landslides in the Phase 1 area shall be presented in the report. The report shall be sub­
      mitted to the San Mateo County Planning and Building Department for review by the
      County Geologist prior to the issuance of any grading hard cards.

21. 	 Any fills used at the project site shall be properly placed with keyways and subsurface
      drainage, and adequately compacted following the recommendations of the final geo­
      technical report and geotechnical engineer, in order to significantly reduce fill sediment.
      Underground utilities shall be designed and constructed using flexible connection points
      to allow for differential settlement.

22. 	 Prior to the issuance of any grading permits, the applicant shall submit, to the Department
      of Public Works for review and approval, a plan for any off-site hauling operations. This
      plan shall include, but not be limited to, the following information: (1) size of trucks,
      (2) haul route, (3) disposal site, (3) dust and debris control measures, and (4) time and
      frequency of haul trips. As part of the review ofthe submitted plan, the County may
      place such restrictions on the hauling operation, as it deems necessary.

23. 	 Pursuant to San Mateo County Ordinance Section 8605.5, all equipment used in grading
      operations shall meet spark arrester and fire fighting tool requirements, as specified in the
      California Public Resources Code.

24. 	 Noise levels produced by proposed construction activities shall comply with the San
      Mateo County Noise Ordinance contained in Chapter 4.88 (Noise Control) of the County
      Ordinance Code. Construction activities shall be limited to the hours from 7:00 a.m. to
      6:00 p.m., Monday through Friday, and 9:00 a.m. to 5:00 p.m. on Saturday. Construction
      operations shall be prohibited on Sunday and any national holiday.



                                                - 26 ­
25. 	 Foundation plans shall be submitted to the Planning and Building Department for review
      prior to issuance of any Phase 1 building permits. All foundation excavations shall be
      observed during construction by the geotechnical engineer to ensure that subsurface con­
      ditions encountered are as anticipated. As-built documentation shall also be submitted to
      the Planning and Building Department prior to the permit's final inspection.

26. 	 Where building permits are required, the applicant shall apply for and be issued a building
      permit prior to beginning any construction activities. Building permits may be required for
      proposed structures including mausoleum/columbarium facilities, retaining walls, storage
      tanks, permanent storm water retention!treatment facilities, etc.

27. 	 The applicant shall comply with the County Green Building Ordinance. Ordinance
      No. 04411, and any revision thereto in effect at the time of building permit application.

28. 	 Any new electric or telephone utilities serving any new structure or facility throughout
      Skylawn's property shall be placed entirely underground, leading from the closest existing
      utility pole to the project site. Such undergrounding shall clearly be indicated on any
      required building plans.

29. 	 The project applicant (or authorized contractor) shall submit a safety plan for the develop­
      ment of Phase J. The safety plan shall include measures to reduce and minimize accidents
      on-site and measures that address the proper procedures to clean up and contain spills. The
      safety plan shall be approved by the County Building Inspection Section prior to the start
      of construction activity on the site.

Biological/Resource Protection Conditions

{The following Conditions ofApproval (Nos. 30--44) include mitigation measures intended
to minimize and/or avoid potentially significant impacts to sensitive habitat areas and
protected plant/wildlife species.]

30. 	 Prior to commencement of any Phase 1 project, Skylawn must obtain an Incidental Take
      Permit from the United States Fish and Wildlife Service and provide proof of such
      authorization to the Planning and Building Department. All recommended mitigation!
      avoidance measures must be implemented prior to beginning any Phase 1 grading or
      construction activities and must be maintained throughout the duration of the project.

31. 	 An updated rare plant survey shall be conducted by a qualified botanist prior to any
      construction activities commencing after the spring of 20 12. Should any rare plant
      species be identified, these popUlations should be avoided to the extent practicaL If
      removal of special-status plant species is required, transplanting to a suitable location in
      the Environmental Protection Zone will be considered as the first option. Given that the
      rare plant species of primary concern are evergreen shrubs or lilies, transplanting should be
      feasible. Prior to the transplanting of any rare plant species, a plant relocation plan shall be
      developed by a qualified botanist. At a minimum, the plan shall demonstrate the feasibility
      of replacing the number of individual plants to be removed at a I: I ratio. The plan shall, at



                                                - 27 ­
     minimum, specify the following: (1) the location of mitigation sites in the Environmental
     Protection Zone or other suitable locations; (2) methods for harvesting seeds and salvaging
     and transplantation of individual bulbs/plants to be impacted; (3) site preparation pro­
     cedures for the mitigation site; (4) a schedule and action plan to maintain and monitor
     the mitigation area; (5) a list of criteria and performance standards by which to measure
     success of the mitigation site(s); (6) measures to exclude unauthorized entry into the
     mitigation areas; and (7) contingency measures in the event that mitigation efforts are
     not successful. The plan shall be subject to the approval of the Planning and Building
     Depaltment prior to the removal of any special-status plant species.

32. 	 Prior to any grading or construction activities within or adjacent to the Land and Water
      Management Zones, a qualified botanist shall conduct a survey of the immediate work
      areas to determine whether any rare plant species are present. If any such species are
      identified, the botanist shall consult with Planning and Building Department staff to
      determine how to proceed. No grading or construction activities shall occur in the area
      until the botanist and County staff have agreed on an appropriate course of action that
      will minimize adverse impacts to special-status plant species in the area.

33. 	 Prior to the commencement of construction activities, a tree survey shall be conducted
      by a qualified arborist indicating all trees within or adjacent to Phase 1 construction areas.
      At a minimum, the survey shall identify the size (diameter at breast height), species, and
      condition of the trees. The survey shall also identify which of these trees are considered
      protected, significant, or heritage trees. The project applicant shall implement tree
      protection measures to insure said trees are not damaged during construction. These
      measures may include protective fencing, prohibiting construction/grading activities
      within the dripline of trees to be preserved, or other appropriate measures approved by
      the Planning and Building Department. This use permit does not authorize the removal
      of any trees and any future tree removal proposals would need to be reviewed against the
      Zoning Regulations and General Plan policies in place at that time.

34. 	 Prior to initial vegetation removal and/or grading activities in the upland portions of the
      construction zone, pre-construction clearance surveys shall be conducted for California
      red-legged frog and San Francisco garter snake by a qualified biologist. Should either
      species be identified, construction activities shall be immediately halted until the frog (or
      snake) leaves the construction zone on its own, or is removed by a qualified biologist in
      possession of an appropriate permit and authorized by the United States Fish and Wildlife
      Service (USFWS). The USFWS shall be immediately notified if either species is observed.

35. 	 Prior to the commencement of construction activities within 50 feet of a wetland or riparian
      woodland, a pre-construction clearance survey of the area shall be conducted by a qualified
      biologist for California red-legged frogs and San Francisco garter snake. Should either
      species be identified, construction activities should be halted until the animal leaves the
      construction zone on its own, or is removed by a qualified biologist in possession of an
      appropriate permit and authorized by the USFWS. If it is determined that no red-legged
      frogs or garter snakes are present, temporary exclusionary fencing shall then be installed
      around the perimeter of the wetland/riparian woodland and adjacent construction areas.



                                                 28 ­
     The fencing shall be maintained throughout the duration of construction activities near the
     wetland/riparian area. The adequacy of the fencing to prevent frogs and snakes from
     entering the construction zone shall be approved by a qualified biologist prior to the
     commencement of construction activities and shall be inspected daily to ensure it
     continues to operate effectively.

36. 	 This use permit approval does not authorize any grading or construction activities within
      any wetland areas. In order to prevent the accidental removal of wetland habitat (and
      potentially damaging habitat of an endangered wildlife species) a qualified biologist shall
      determine and mark in the field the extent of all wetland areas in and adjacent to Phase 1
      development zones. Any grading or construction activities within 50 feet of any wetland
      habitat shall be referred to and reviewed by the San Mateo County Planning and Building
      Department and USFWS prior to commencement of any construction activities. Prior to
      any disturbance within 50 feet of wetland habitats, proof of consultation with and approval
      by USFWS shall be submitted to the Planning and Building Department.

37. 	 The San Francisco garter snake is a California Fully Protected Species, which means that
      the California Department ofFish and Game (CDFG) cannot authorize the take of the
      species and needs to ensure the adequacy of the avoidance measures to be implemented.
      Therefore, the CDFG shall be consulted prior to the implementation of construction activi­
      ties and any further recommended avoidance measures shall be implemented. Prior to any
      disturbance within 50 feet of wetland habitats, proof of consultation with and approval by
      CDFG shall be submitted to the Planning and Building Department.

38. 	 The outer limits of the stand of native grassland located within the Land and Water
      Management Zone adjacent to Phase 1 development area shall be identified by a qualified
      biologist and marked with wooden stakes or other equivalent markers. Land management
      activities shall not be allowed within the identified area, unless the timing and nature of the
      activity is found to not pose a threat to bay checkerspot butterfly by a qualified biologist.

39. 	 No earlier than 30 days prior to the commencement of any construction activities in coastal
      scrub or woodland habitats, a survey shall be conducted to determine if acti ve woodrat
      nests (stick houses) with young are present within the disturbance zone or within 50 feet of
      the disturbance zone. If active woodrat nests with young are identified, a fence shall be
      erected around the nest site at a distance adequate to provide the woodrat sufficient forag­
      ing habitat at the discretion of a qualified biologist. Clearing and construction within the
      fenced area would be postponed or halted until young have left the nest. A qualified
      biologist should serve as a construction monitor during those periods when disturbance
      activities will occur near active nest areas to ensure that no inadvertent impacts on these
      nests occur. If woodrats or nests are observed within the disturbance footprint outside
      ofthe breeding period, individuals should be relocated to a suitable location within the
      Environmental Protection Zone by a qualified biologist in possession of a scientific
      collecting permit. This will be accomplished by dismantling woodrat nests (outside
      of the breeding period), to allow individuals to relocate to suitable habitat within the
      adjacent Environmental Protection Zone. The Environmental Protection Zone contains
      large expanses of suitable wood rat habitat that would be protected.



                                                - 29­
40. 	 (ftrees or structures are to be removed during the breeding season of native bat species
      (generally April 1 through August 31 in California), the presence of active bat maternity
      roosts should be evaluated by a qualified biologist. If the trees/structures to be removed
      are determined to provide potential bat roosting habitat, a focused survey should then be
      conducted to determine if an active maternity roost of a special-status bat species is present.
      Should an active maternity roost of a special-status bat species be identified, the roost
      should not be disturbed until the roost is vacated and juveniles have fledged, as determined
      by the biologist. Once all young have fledged, the tree/structure may be removed.

41. 	 If a construction project would commence anytime during the nesting/breeding season of
      native bird species potentially nesting on the site (typically February through August in the
      project region), a pre-construction survey of the project vicinity for nesting birds shall be
      conducted. This survey shall be conducted by a qualified biologist (i.e., experienced with
      the nesting behavior of bird species of the region) within two weeks of the commencement
      of construction activities. The intent of the survey would be to determine if active nests of
      special-status bird species or other species protected by the Migratory Bird Treaty Act
      and/or the California Fish and Game Code are present within the construction zone or
      within 500 feet of the construction zone. The survey area would include all trees and
      shrubs in the construction zone and a surrounding 500 feet area. The survey should be
      timed such that the last survey is concluded no more than two weeks prior to initiation
      of construction. If ground disturbance activities are delayed following a survey, then an
      additional pre-construction survey should be conducted such that no more than two weeks
      will have elapsed between the last survey and the commencement of ground disturbance
      activities.

      If active nests are found in areas that could be directly affected or are within 500 feet of
      construction and would be subject to prolonged construction-related noise, a no disturbance
      buffer zone shall be created around active nests during the breeding season or until a qual­
      ified biologist determines that all young have fledged. The size of the buffer zones
      and types of construction activities restricted within them will be determined through
      consultation with the CDFG, taking into account factors such as the following:

      a. 	   Noise and human disturbance levels at the construction site at the time of the survey
             and the noise and disturbance expected during the construction activity;

      b. 	   Distance and amount of vegetation or other screening between the construction site
             and the nest; and

      c. 	   Sensitivity of individual nesting species and behaviors of the nesting birds.

      Limits of construction to avoid an active nest shall be established in the field with flagging,
      fencing, or another appropriate barrier and construction personnel should be instructed on
      the sensitivity of nest areas. The biologist shall serve as a construction monitor during
      those periods when construction activities would occur near active nest areas of special­
      status bird species to ensure that no impacts on these nests occur.




                                                - 30 ­
42. 	 If archaeological and/or cultural resources are encountered during grading or construction
      activities, work shall be temporarily halted in the vicinity of the discovered materials and
      workers shall avoid altering the materials and their context until a qualified professional
      archaeologist has evaluated the situation and provided appropriate recommendations. The
      project applicant or archaeologist shall immediately notify the Current Planning Section of
      any discoveries made and shall provide the Current Planning Section with a copy of the
      archaeologist's report and recommendations prior to any further grading or construction
      activity in the vicinity.

43. 	 Any proposed dry wells exceeding 10 feet in total depth shall comply with the San Mateo
      County well ordinance.

44. 	 The Department ofFish and Game has determined that this project is not exempt from
      Department of Fish and Game California Environmental Quality Act filing fees for the
      Initial Study and Mitigated Negative Declaration pursuant to Fish and Game Code Section
      711.4. The applicant shall pay to the San Mateo County Recorder's Office an amount of
      $2,094.00 with in four (4) days of completion of the appeal period, which period expires on
      August 25, 2011 unless these permits are appealed to the San Mateo County Board of
      Supervisors and a new decision date is determined.

Skylawn Memorial Park Access/Roadway Improvements

45. 	 The project applicant shall prepare a plan that involves repaving, striping, and, if deemed
      necessary, additional signage to improve access to and exiting from the Skylawn facility
      onto Highways 35 and 92. This plan shall be submitted to both CalTrans and the County
      Planning and Building Department for review and approval. The plan shall be imple­
      mented and completed prior to the completion of the next interment project as anticipated
      in the Master Use Permit and including the completion of the Eternity Gardens project,
      the second phase of which is yet to be initiated. No new signage is to be installed until
      reviewed and approved by the Planning and Building Department and/or CalTrans (if
      proposed within CalTrans right-of-way). This use permit does not authorize the use of
      temporary signage or banners on the Skylawn property or within CalTrans right-of-way.

JC:pac - JXCV0509 _ WPU.DOC




                                              - 31 ­
                                                       Location Map
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   B
 File Numbers:   PLN 2009-00026
                                                                        CDR8\plan10-00026 8-01-11 rp
         Project Location Map
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   C
 File Numbers:   PLN 2009-00026
                                                                        CDR8\plan10-00026 8-01-11 rp
         Long Range Cemetery Development
         and Environmental Protection Plan
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   D
 File Numbers:   PLN 2009-00026
                                                                        CDR8\plan10-00026 8-01-11 rp
         }
             2011 - 2031   25 - 50 yrs



             2032 - 2300   25 - 50 yrs
                           Increments each




         Phasing Plan
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   E
 File Numbers:             PLN 2009-00026
                                                                        CDR8\plan10-00026 8-01-11 rp
         Geology and Slope Analysis
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   F
 File Numbers:   PLN 2009-00026
                                                                        CDR8\plan10-00026 8-01-11 rp
                           Plant Communities and Phasing
                           Plant Communities and Phasing
San Mateo County Planning Commission Meeting
Applicant:   Skylawn Memorial Park Master Plan   Attachment:   G
File Numbers: PLN 2010-00026
                                                                   CDR8\plan10-026 8-02-11 rp
Composite Geological and
Biological Planning Criteria
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   H
 File Numbers:   PLN 2009-00026
                                                                        CDR8\plan10-00026 8-01-11 rp
Site Topography and Drainage
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   I
 File Numbers:   PLN 2009-00026
                                                                        CDR8\plan10-00026 8-01-11 rp
          Soils Map
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   J
 File Numbers:   PLN 2009-00026
                                                                        CDR8\plan10-00026 8-01-11 rp
Master Development Plan - Phase 1
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   K
 File Numbers:   PLN 2009-00026
                                                                        CDR8\plan10-00026 8-01-11 rp
Facility Development and Environmental
Management Systems on Sloping Land
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   L1
 File Numbers:   PLN 2009-00026
                                                                         CDR8\plan10-00026 8-01-11 rp
                                                      Phase 1 - Section Study
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan          Attachment:   L2
 File Numbers:   PLN 2009-00026
                                                                                CDR8\plan10-00026 8-01-11 rp
 Earth Sheltered Burial Facilities
 on East Ridge
San Mateo County Planning Commission Meeting
 Owner/Applicant: Skylawn Memorial Park Master Plan   Attachment:   L3
 File Numbers:   PLN 2009-00026
                                                                         CDR8\plan10-00026 8-01-11 rp
        COUNTY OF SAN MATEO, PLANNING AND BUILDING DEPARTMENT

                              NOTICE OF INTENT TO ADOPT 

                               NEGATIVE DECLARATION 


A notice, pursuant to the California Environmental Quality Act of 1970, as amended (Public
Resources Code 21,000, et seq.), that the following project: Skylawn Memorial Park Master
(20-year) Use Permit, when adopted and implemented, will not have a significant impact on the
environment.

FILE NO.: PLN 2010-00026

OWNER: Skylawn Lifemark Center at Skylawn Memorial Park

APPLICANT: Skylawn Memorial Park

ASSESSOR'S PARCEL NOS.: 056-550-020 and 056-550-030

PROJECT LOCAnON: North ofthe junction of Highway 35 (Skyline Boulevard) and
Highway 92 (HalfMoon Bay Road), San Mateo.

PROJECT DESCRIPTION

The Lifemark Group (Skylawn), project applicant, has prepared a Development Agreement (DA)
and Master Land Use Plan (MLUP) for the Skylawn Memorial Park project for all cemetery de­
velopment anticipated over the next 20 years. As part of a previous amendment to Skylawn's
Use Permit for the construction of their mortuary/administrative facility in 2002 (County File
No. PLN 2000-00166), Condition of Approval No. 22 required that a "Preservation and Envi­
ronmental Management Zone" be identified and that a plan identifying said zone would be
submitted, reviewed and recorded "prior to the issuance of any building or grading permit
associated with any future road or ground burial expansion." In response to that condition, the
project applicant has prepared a DA and MLUP that identifies an Environmental Protection
Zone and developable areas on the project site. While the intent of the MLUP is to guide the
development and expansion of the Sky lawn facility over the next 20 years, it is but one phase
of seven phases of development to occur sequentially over the course of many more years as
additional interment facilities become necessary.

The subject MLUP (20 years; Phase 1) includes a development plan that protects and preserves
sensitive lands within the project site and is consistent with the regulations, goals and policies
of the San Mateo County zoning and General Plan land use regulations. This Initial Study
evaluates only the development proposed to occur within Phase 1 as indicated in the enclosed
Phasing Plan dated April 12, 2010, which is expected to occur between 2010 and 2030.

Proposed Development

As cited earlier, this initial Study strictly focuses on Skylawn's proposed development within 

Phase 1 to occur over the next 20 years. This current proposal stems from the Skylawn's ten­

tatively proposed seven-phased development plan for the 226 acres to be developed over many 


                                                 1

more years. The areas adjacent to the existing cemetery uses (Phases 1,2 and 3) would be
developed first followed by the outlying areas along the ridges and to the north. Figure 5
illustrates the location of the seven development phases on the property. The types of burial
facilities being requested by the cemetery customers are changing; there appears to be a trend
in the cemetery market toward cremation and for environmentally "green" or "natural" burial
options and a trend away from traditional lawn burials. With the decline of traditional lawn
burials, burial facilities are likely to accommodate cremation and outdoor garden crypts that
result in cemetery landscapes that are far denser than those today (i.e., high-density burial
development). For the proposed MLUP, these high-density outdoor burial areas would be
concentrated adjacent to new roadways throughout the site, typically located in currently
natural areas where land is too steep to economically develop for traditional lawn buriaL
These high-density burial facilities take the form of various types of internment:

o	    Concentrated ground burial private estates, where the family "estate" areas are separated
      by retaining walls with burial vaults in the ground; an example of this is the recently
      completed Eternity Garden internment, a re-contoured development accessed by a
      roadway (the estates accessed by walkways) on downward sloping land just southwest
      ofthe Phase 1 area.

e	    Garden mausoleums are typically granite-faced crypts where the casket (full body burial)
      slides horizontally (e.g., into a vertical wall retained and benched into a sloping hillside)
      into concrete compartments. Such internment areas would also be accessed by roadway(s),
      with the crypt areas accessed by walkways.

G     Columbaria or columbariurn is similar to the construction of garden mausoleums, except
      that the actual crypts are much smaller since they're typically used to house cremation
      urns.

o	    The garden mausoleums and columbaria proposed in Phase 1 would range between three
      and seven crypts high and could be up to 25 feet high and set into the existing grade in
      terraces approximately 20 feet deep and highly landscaped to shield the exposed sides.
      The net view exposure due to the terracing would be approximately 5 feet or less. These
      would be set into the earth as retaining walls (see Figure 6). As the cross-sections of the
      cited Figures show, such development - despite grade alterations and re-contouring of the
      land - would generally be at or below the pre-existing topography.

 fl   The natural (or "Green") burial areas would be placed outside of the traditional burial
      areas and serve as both a visual and environmental buffer between the cemetery and the
      Environmental Protection Zone. These natural burial areas would be accessed on foot
      through a series of unpaved pedestrian trails. Natural burial areas would not be irrigated
      and the burial architecture would be constructed of materials that use textures and colors
      that would blend into the natural landscape of the hillside developments. This system
      would integrate the burial structures into the natural grade of the site, minimizing the
      hydrological and visual impacts on the landscape.

 Both traditional and natural burial areas are also being proposed as part of Phase 1 development.
 The traditional lawn burial areas would be placed adjacent to new roadways and the high-density


                                                 2

burial internment developments described above. A major element of Phase I would combine
elements of all of the above. Parking would be accommodated along both existing and proposed
cemetery roads except where needed to insure adequate handicapped accessibility.

FINDINGS AND BASIS FOR A NEGA TIVE DECLARATION

The Current Planning Section has reviewed the initial study for the project and, based upon
substantial evidence in the record, finds that:

1. 	   The project will not adversely affect water or air quality or increase noise levels
       substantially.

2. 	   The project will not have adverse impacts on the flora or fauna of the area.

3, 	   The project will not degrade the aesthetic quality of the area.

4. 	   The project will not have adverse impacts on traffic or land use.

5, 	   In addition, the project will not:

       a. 	   Create impacts which have the potential to degrade the quality of the environment.

       b. 	   Create impacts which achieve short-term to the disadvantage of long-term
              environmental goals.

       c. 	   Create impacts for a project which are individually limited, but cumulatively
              considerable.

       d. 	   Create environmental effects which will cause substantial adverse effects on human
              beings, either directly or indirectly.

The County of San Mateo has, therefore, determined that the environmental impact of the project
is insignificant.

MITIGATION MEASURES included in the project to avoid potentially significant effects:

Mitigation Measure 1: A design level geotechnical investigation of the Phase 1 area shall be
perfonned prior to any project grading. The report shall include a static and seismic slope stabil­
ity analysis of the Phase 1 area to be graded and developed. The specific mitigation measures to
be utilized in order to stabilize identified landslides and areas of potential seismically induced
landslides in the Phase 1 area shall be presented in the report. The report shall be submitted to
the San Mateo County Planning and Building Department for review by the County Geologist
prior to commencement of any grading or construction activities.




                                                   3
Mitigation Measure 2: The applicant shall obtain a grading pennit hard card from the Planning·
and Building Department prior to commencement of any grading or construction activities.

Mitigation Measure 3: Prior to beginning any construction activities, the applicant shall submit
an Erosion and Sediment Control Plan for review and approval by the San Mateo County
Planning and Building Department. The plan must be fully implemented and inspected by
County Planning and Building Department staff prior to the commencement of any construction
and/or grading activities and shall be maintained throughout the duration ofthe project. Erosion
control measure deficiencies, as they occur, shall be immediately corrected. The goal is to
prevent sediment and other pollutants from leaving the project site and to protect all exposed
earth surfaces from erosive forces. Said plan shall adhere to the San Mateo Countywide
Stonnwater Pollution Prevention Program "General Construction and Site Supervision
Guidelines," including:

a. 	    Stabilizing all denuded areas and maintaining erosion control measures continuously
        between October 15 and April 15. Stabilizing shall include both proactive measures, such
        as the placement of hay bales or coir netting, and passive measures, such as revegetating
        disturbed areas with plants propagated from seed collected in the immediate area.

b. 	    Storing, handling, and disposing of construction materials and wastes properly, so as to
        prevent their contact with stonnwater.

c. 	    Controlling and preventing the discharge of all potential pollutants, including pavement
        cutting wastes, paints, concrete, petroleum products, chemicals, wash water or sediments,
        and non-stormwater discharges to storm drains and watercourses.

d. 	    Using sediment controls or filtration to remove sediment when dewatering the site and
        obtaining all necessary permits.

e. 	    A voiding cleaning, fueling, or maintaining vehicles on-site, except in a designated area 

        where wash water is contained and treated. 


f. 	    Delineating with field markers clearing limits, easements, setbacks, sensitive or critical 

        areas, buffer zones, trees and drainage courses. 


g. 	    Protecting adjacent properties and undisturbed areas from construction impacts using 

        vegetative buffer strips, sediment barriers or filters, dikes, mulching, or other measures as 

        appropriate. 


 h. 	   Perfonning clearing and earth-moving activities only during dry weather.

 1. 	   Limiting and timing applications of pesticides and fertilizers to prevent polluted runoff.

J. 	    Limiting construction access routes and stabilizing designated access points.



                                                    4

k.   A voiding tracking dirt or other materials off-site; cleaning off-site paved areas and
     sidewalks using dry sweeping methods.

L    The contractor shall train and provide instructions to all employees and subcontractors
     regarding the construction best management practices.

Mitigation Measure 4: The applicant shall submit a grading and drainage plan (including cal­
culations) to the Planning and Building Department and the Department of Public Works prior to
the issuance of any project related grading or building permits. The grading and drainage plan
shall include all requirements listed in Grading Ordinance Section 8604.1.a.5 (Application
Requirements). The drainage plan shall also include a narrative describing the type, size, and
location of all permanent stormwater controls to be utilized in order to ensure compliance with
the County's Drainage Policy, the San Mateo County Water Pollution Prevention Plan
(SMCWPPP), and NPDES Provision C.3.

Mitigation Measure 5: Unless approved in writing and in advance by the Community
Development Director, no grading shall be allowed during the winter season (October 15 to
April 15) to avoid potential soil erosion. The applicant shall submit a letter to the Current
Planning Section, prior to the issuance ofthe grading hard card, which illustrates the
approximate grading schedule, including start and end dates.

Mitigation Measure 6: Any fills used at the project site shall be properly placed with keyways
and subsurface drainage, and adequately compacted following the recommendations of the final
geotechnical report and geotechnical engineer, in order to significantly reduce fill sediment.
Underground utilities shall be designed and constructed using flexible connection points to allow
for differential settlement.

Mitigation Measure 7: Foundation plans shaH be submitted to the Planning and Building
Department for review prior to issuance of building permits. All foundation excavations shall be
observed during construction by the geotechnical engineer to ensure that subsurface conditions
encountered are as anticipated. As-built documentation shaH also be submitted to the Planning
and Building Department.

Mitigation Measure 8: The project applicant shall file a Notice of Intent (NOI) with the State
Water Resources Control Board (SWRCB) and shall submit proof of filing said NOI to the
Planning and Building Department prior to beginning any grading or construction activities.
The applicant and all grading/construction contractors shall adhere to all conditions and
regulations associated with the State General Construction Activity NPDES Permit.

Mitigatiog Measure 9: An updated rare plant survey shall be conducted by a qualified botanist
prior to any construction activities commencing after the spring of 2012. Should any rare plant
species be identified, these popUlations should be avoided to the extent practical. If removal of
special-status plant species is required, transplanting to a suitable location in the Environmental
Protection Zone will be considered as the first option. Given that the rare plant species of
primary concern are evergreen shrubs or lilies, transplanting should be feasible. Prior to the


                                                 5

transplanting of any rare plant species, a plant relocation plan shall be developed by a qualified
botanist. At a minimum, the plan shall demonstrate the feasibility of replacing the number of
individual plants to be removed at a I: 1 ratio. The plan shall, at minimum, specify the following:
(1) the location of mitigation sites in the Environmental Protection Zone or other suitable loca"
tions; (2) methods for harvesting seeds and salvaging and transplantation of individual bulbs/
plants to be impacted; (3) site preparation procedures for the mitigation site; (4) a schedule and
action plan to maintain and monitor the mitigation area; (5) a list of criteria and performance
standards by which to measure success of the mitigation site(s); (6) measures to exclude
unauthorized entry into the mitigation areas; and (7) contingency measures in the event that
mitigation efforts are not successful. The plan shall be subject to the approval of the Planning
and Building Department prior to the removal of any special-status plant species.

Mitigation Measure 10: Prior to any grading or construction activities within or adjacent to the
Land and Water Management Zones, a qualified botanist shall conduct a survey of the immediate
work areas to determine whether any rare plant species are present. If any such species are ident­
ified, the botanist shall consult with Planning and Building Department staff to determine how
to proceed. No grading or construction activities shall occur in the area until the botanist and
County staff have agreed on an appropriate course of action that will minimize adverse impacts
to special-status plant species in the area.

Mitigation Measure 11: Prior to the commencement of construction activities, a tree survey
shall be conducted by a qualified arborist indicating all the trees that could be removed or
otherwise harmed during Phase 1 construction. At a minimum, the survey shall identify the size
(diameter at breast height), species, and condition of the trees. The survey shall also identify
which of these trees are considered protected, significant, or heritage trees. If any such trees are
identified by the arborist within Phase I project areas, the project applicant shall implement tree
protection measures to insure said trees are not damaged during construction. These measures
may include protective fencing, prohibiting construction/grading activities within the dripline of
trees to be preserved, or other appropriate measures approved by the Planning and Building
Department.

Mitigation Measure 12: Prior to initial vegetation removal and/or grading activities in the
upland portions of the construction zone, pre-construction clearance surveys shall be conducted
for California red-legged frog and San Francisco garter snake by a qualified biologist. Should
either species be identified, construction activities shall be immediately halted until the frog (or
snake) leaves the construction zone on its own, or is removed by a qualified biologist in
possession of an appropriate permit and authorized by the USFWS. The USFWS shall be
immediately notified if either species is o,bserved.

Mitigation Measure 13: Prior to the commencement of construction activities within 50 feet
of a wetland or riparian woodland, a pre-construction clearance survey of the area shall be
conducted by a qualified biologist for California red-legged frogs and San Francisco garter
snake. Should either species be identified, construction activities should be halted until the
animal leaves the construction zone on its own, or is removed by a qualified biologist in
possession of an appropriate permit and authorized by the USFWS. If it is determined that


                                                  6

no red-legged frogs or garter snakes are present, temporary exclusionary fencing shall then be
installed around the perimeter of the wetland/riparian woodland and adjacent construction areas.
The fencing shall be maintained throughout the duration of construction activities near the
wetland/riparian area. The adequacy of the fencing to prevent frogs and snakes from entering the
construction zone shall be approved by a qualified biologist prior to the commencement of
construction activities and shall be inspected daily to ensure it continues to operate effectively.

Mitigation Measure 14: In order to prevent the accidental removal of wetland habitat (and
potentially damaging habitat of an endangered wildlife species), a qualified biologist shall
determine and mark in the field the extent of all wetland areas in and adjacent to Phase 1
development zones. Any grading or construction activities within 50 feet of any wetland habitat
shall be referred to and reviewed by United Stated Fish and Wildlife Service (USFWS) prior to
commencement of any construction activities. Prior to any disturbance within 50 feet of wetland
habitats, proof of consultation with and approval by USFWS shall be submitted to the Planning
and Building Department.

Mitigation Measure 15: The San Francisco garter snake is a California Fully Protected Species,
which means that the California Department of Fish and Game (CDFG) cannot authorize the take
of the species and needs to ensure the adequacy of the avoidance measures to be implemented.
Therefore, the CDFG shall be consulted prior to the implementation of construction activities
and any further recommended avoidance measures shall be implemented. Prior to any
disturbance within 50 feet of wetland habitats, proof of consultation with and approval by CDFG
shall be submitted to the Planning and Building Department.

Mitigation Measure 16: The outer limits of the stand of native grassland located within the
Land and Water Management Zone adjacent to Phase 1 development area shall be identified by
a qualified biologist and marked with wooden stakes or other equivalent markers. Land
management activities shall not be allowed within the identified area, unless the timing and
nature of the activity is found to not pose a threat to bay checkerspot butterfly by a qualified
biologist.

Mitigation Measure 17: No earlier than 30 days prior to the commencement of any
construction activities in coastal scrub or woodland habitats, a survey shall be conducted to
determine if active woodrat nests (stick houses) with young are present within the disturbance
zone or within 50 feet of the disturbance zone. If active woodrat nests with young are identified,
a fence shall be erected around the nest site at a distance adequate to provide the woodrat
sufficient foraging habitat at the discretion of a qualified biologist. Clearing and construction
within the fenced area would be postponed or halted until young have left the nest. A qualified
biologist should serve as a construction monitor during those periods when disturbance activities
will occur near active nest areas to ensure that no inadvertent impacts on these nests occur. If
woodrats or nests are observed within the disturbance footprint outside of the breeding period,
individuals should b~ relocated to a suitable location within the Environmental Protection Zone
by a qualified biologist in possession of a scientific collecting permit. This will be accomplished
by dismantling woodrat nests (outside of the breeding period), to allow individuals to relocate to
suitable habitat within the adjacent Environmental Protection Zone. The Environmental
Protection Zone contains large expanses of suitable woodrat habitat that would be protected.



                                                 7

Mitigation Measure 18: Iftrees or structures are to be removed during the breeding season of
native bat species (generally April 1 through August 31 in California), the presence of active
bat maternity roosts should be evaluated by a qualified biologist. If the trees/structures to be
removed are determined to provide potential bat roosting habitat, a focused survey should then
be conducted to determine if an active maternity roost of a special-status bat species is present.
Should an active maternity roost of a special-status bat species be identified, the roost should not
be disturbed until the roost is vacated and juveniles have fledged, as determined by the biologist.
Once all young have fledged, the tree/structure may be removed.

Mitigation Measure 19: If a construction project would commence anytime during the nesting/
breeding season of native bird species potentially nesting on the site (typically February through
August in the project region), a pre-construction survey of the project vicinity for nesting birds
shall be conducted. This survey shall be conducted by a qualified biologist (Le., experienced
with the nesting behavior of bird species of the region) within two weeks of the commencement
of construction activities. The intent of the survey would be to determine if active nests of
special-status bird species or other species protected by the Migratory Bird Treaty Act and/or
the California Fish and Game Code are present within the construction zone or within 500 feet
of the construction zone. The survey area would include all trees and shrubs in the construction
zone and a surrounding 500 feet area. The survey should be timed such that the last survey is
concluded no more than two weeks prior to initiation of construction. If ground disturbance
activities are delayed following a survey, then an additional pre-construction survey should be
conducted such that no more than two weeks will have elapsed between the last survey and the
commencement of ground disturbance activities.

If active nests are found in areas that could be directly affected or are within 500 feet of
construction and would be subject to prolonged construction-related noise, a no disturbance
buffer zone shall be created around active nests during the breeding season or until a qualified
biologist determines that all young have fledged. The size of the buffer zones and types of
construction activities restricted within them will be determined through consultation with the
CDFG, taking into account factors such as the following:

a. 	   Noise and human disturbance levels at the construction site at the time of the survey and
       the noise and disturbance expected during the construction activity;

b. 	   Distance and amount of vegetation or other screening between the construction site and the
       nest; and

c. 	   Sensitivity of individual nesting species and behaviors of the nesting birds.

Limits of construction to avoid an active nest shall be established in the field with flagging,
fencing, or another appropriate barrier and construction personnel should be instructed on the
sensitivity of nest areas. The biologist shall serve as a construction monitor during those periods
when construction activities would occur near active nest areas of special-status bird species to
ensure that no impacts on these nests occur.



                                                  8
Mitigation Measure 20: The applicant shall submit a dust control plan to the Planning and
Building Department prior to any Phase 1 grading or construction activities. The approved
measures shall be implemented prior to beginning any grading and/or construction activities
and shall be maintained for the duration of the project. The plan shall, at minimum, include
all the "Basic Control Measures" listed in Table 2 of the BAAQMD CEQA Guidelines (see
Appendix D):

a. 	   Water all active construction areas at least twice daily.

b. 	   Cover all trucks hauling soil, sand and other loose materials or require all trucks to
       maintain at least 2 feet of freeboard.

c. 	   Pave, apply water three times daily, or apply (non-toxic) soil stabilizers on all unpaved
       access roads, parking areas and staging areas at construction sites.

d. 	   Sweep daily (with water sweepers) all paved access roads, parking areas and staging areas
       at construction sites.

e. 	   Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent
       public streets.

Additional measures may be required in order to ensure that construction-related activities do not
generate elevated levels of dust particulates at any point throughout the duration of the project.

Mitigation Measure 21: The applicant shall comply with and follow all guidelines and regu­
latory requirements as stipulated by the County Environmental Health Division with regard to
their use and disposal of all chemicals and fluids resulting from the embalming processes that
occur at the Skylawn mortuary.

Mitigation Measure 22: The project applicant (or authorized contractor) shall submit a safety
plan for the development of Phase 1. The safety plan shall include measures to reduce and
minimize accidents on-site and measures that address the proper procedures to clean up and
contain spills. The safety plan shall be approved by the County Building Inspection Section
prior to the start of any construction or grading activity on the site.

Mitigation Measure 23: Noise levels produced by proposed construction activities shall
comply with the San Mateo County Noise Ordinance contained in Chapter 4.88 (Noise Control)
of the County Ordinance Code at all times. Construction activities shall be limited to the hours
from 7:00 a.m. to 6:00 p.m., Monday through Friday, and 9:00 a.m. to 5:00 p.m. on Saturday.
Construction operations shall be prohibited on Sunday and any national holiday.

Mitigation Measure 24: If archaeological and/or cultural resources are encountered during
grading or construction activities, work shall be temporarily halted in the vicinity of the dis­
covered materials and workers shall avoid altering the materials and their context until a
qualified professional archaeologist has evaluated the situation and provided appropriate re­


                                                   9

commendations. The project applicant or archaeologist shall immediately notify the Current
Planning Section of any discoveries made and shall provide the Current Planning Section with
a copy of the archaeologist's report and recommendations prior to any further grading or
construction activity in the vicinity.

RESPONSIBLE AGENCY CONSULTATION

San Mateo County Planning and Building Department



The San Mateo County Current Planning Section has reviewed the Environmental Evaluation of
this project and has found that the probable environmental impacts are insignificant. A copy of
the initial study is attached.

REVIEW PERIOD: October 28, 2010 to November 29,2010

All comments regarding the correctness, completeness, or adequacy of this Negative Declaration
must be received by the County Planning and Building Department, 455 County Center, Second
Floor, Redwood City, no later than 5:00 p.m., November 29,2010



Dave Holbrook
Project Planner, 650/363-1837




                                                     Dave Holbrook, Project Planner

DH:pac    DJHU0620 WPRDOC




                                              10 

                                                                      County of San Mateo 

                                                                Planning and Building Department 


                                                                       INITIAL STUDY 

                                                         ENVIRONMENTAL EVALUATION CHECKLIST 

                                                         (To Be Completed By Current Planning Section)


I.   BACKGROUND


     Project Title:   Skylawn Memorial Park Master Use Permit


     File No.:   PLN 2010-00026


     Project Location: 	 The project site is located just northwest of the intersection of Highway 92 (Half Moon Bay Road) and Highway 35 (Skyline Boulevard)
                         and adjacent to the San Francisco State Fish and Game RefugelWatershed lands to the east.


     Assessor's Parcel Nos.:    056-550-020 and 056-550-030


     Applicant/Owner:     Lifemark Group at Skylawn Memorial Park (Skylawn)


     Date Environmental Information Form Submitted:      February 4, 2010


     PROJECT DESCRIPTION

     Introduction

     The Lifemark Group (Skylawn), project applicant, has prepared a Development Agreement (DA) and Master Land Use Plan (MLUP) for the Skylawn
     Memorial Park project for all cemetery development anticipated over the next 20 years. As part of a previous amendment to Skylawn's Use Permit for the
     construction of their mortuary/administrative facility in 2002 (County File No. PLN 2000-00166), Condition of Approval No. 22 required that a "Preservation
     and Environmental Management Zone" be identified and that a plan identifying said zone would be submitted, reviewed and recorded "prior to the issuance
     of any building or grading permit associated with any future road or ground burial expansion." In response to that condition, the project applicant has
     prepared a DA and MLUP that identifies an Environmental Protection Zone and developable areas on the project site. While the intent of the MLUP is to
     guide the development and expansion of the Skylawn facility over the next 20 years, it is but one phase of seven phases of development to occur
     sequentially over the course of many more years as additional interment facilities become necessary.
The subject MLUP (20 years; Phase 1) includes a development plan that protects and preserves sensitive lands within the project site and is consistent with
the regulations, goals and policies of the San Mateo County zoning and General Plan land use regulations. This Initial Study evaluates only the development
proposed to occur within Phase 1 as indicated in the enclosed Phasing Plan dated April 12, 2010, which is expected to occur between 2010 and 2030.

Proposed Development

As cited earlier, this initial Study strictly focuses on Skylawn's proposed development within Phase 1 to occur over the next 20 years. This current proposal
stems from the Skylawn's tentatively proposed seven-phased development plan for the 226 acres to be developed over many more years. The areas
adjacent to the existing cemetery uses (Phases 1, 2 and 3) would be developed first followed by the outlying areas along the ridges and to the north. Figure
5 illustrates the location of the seven development phases on the property. The types of burial facilities being requested by the cemetery customers are
changing; there appears to be a trend in the cemetery market toward cremation and for environmentally "green" or "natural" burial options and a trend away
from traditional lawn burials. With the decline of traditional lawn burials, burial facilities are likely to accommodate cremation and outdoor garden crypts that
result in cemetery landscapes that are far denser than those today (I.e., high-density burial development). For the proposed MLUP, these high-density
outdoor burial areas would be concentrated adjacent to new roadways throughout the site, typically located in currently natural areas where land is too steep
to economically develop for traditional lawn burial. These high-density burial facilities take the form of various types of internment:

"   Concentrated ground burial private estates, where the family "estate" areas are separated by retaining walls with burial vaults in the ground; an example
    of this is the recently completed Eternity Garden internment, a re-contoured development accessed by a roadway (the estates accessed by walkways)
    on downward sloping land just southwest of the Phase 1 area.

o   Garden mausoleums are typically granite-faced crypts where the casket (full body burial) slides horizontally (e.g., into a vertical wall retained and
    benched into a sloping hillside) into concrete compartments. Such internment areas would also be accessed by roadway(s), with the crypt areas
    accessed by walkways.

3
    Columbaria or columbarium is similar to the construction of garden mausoleums, except that the actual crypts are much smaller since thetre typically
    used to house cremation urns.

o   The garden mausoleums and columbaria proposed in Phase 1 would range between three and seven crypts high and could be up to 25 feet high and
    set into the existing grade in terraces approximately 20 feet deep and highly landscaped to shield the exposed sides. The net view exposure due to the
    terracing would be approximately 5 feet or less. These would be set into the earth as retaining walls (see Figure 6). As the cross-sections of the cited
    Figures show, such development - despite grade alterations and re-contouring of the land - would generally be at or below the pre-existing topography.

o   The natural (or "Green") burial areas would be placed outside of the traditional burial areas and serve as both a visual and environmental buffer between
    the cemetery and the Environmental Protection Zone. These natural burial areas would be accessed on foot through a series of unpaved pedestrian
    trails. Natural burial areas would not be irrigated and the burial architecture would be constructed of materials that use textures and colors that would
    blend into the natural landscape of the hillside developments. This system would integrate the burial structures into the natural grade of the site,
    minimizing the hydrological and visual impacts on the landscape.

Both traditional and natural burial areas are also being proposed as part of Phase 1 development. The traditional lawn burial areas would be placed adjacent
to new roadways and the high-density burial internment developments described above. A major element of Phase 1 would combine elements of all of the
above. Parking would be accommodated along both existing and proposed cemetery roads except where needed to insure adequate handicapped
accessibility.


                                                                            2
II.   ENVIRONMENTAL ANALYSIS 


      Any controversial answers or answers needing clarification are explained on an attached sheet. For source, refer to pages 16 and 17. 


                                                                                                                IMPACT
                                                                                                                            YES                                        I
                                                                                                              Significant
                                                                                                Not           Unless
                                                                                           NO   Significant   Mitig"ed        Significant   Cumulative        SOURCE
      1.    LAND SUITABILITY AND GEOLOGY

           Will (or could) this project:


           a.   Involve a unique landform or biological area, such as beaches,
                                                                                           X                                                              B,F,O
                sand dunes, marshes, tidelands, or San Francisco Bay?

           b.   Involve construction on slope of 15% or greater?                                                   X                                      E,I

           c.   Be located in an area of soil instability (subSidence, landslide or
                                                                                                                   X                                      BC,D
                severe erosion)?

           d.   Be located on, or adjacent to a known earthquake fault?                               X                                                   BC,D

           e.   Involve Class I or Class II Agriculture Soils and Class III Soils
                                                                                           X                                                              M
                rated good or very good for artichokes or Brussels sprouts?

           f.   Cause erosion or siltation?                                                                        X                                      M,I

           g.   Result in damage to soil capability or loss of agricultural land?          X                                                             A,M

           h.   Be located within a flood hazard area?                                     X                                                              G


           i.   Be located in an area where a high water table may adversely
                                                                                                                                                          D
                                                                                           X
                affect land use?

           j.   Affect a natural drainage channel or streambed, or watercourse?                                    X                                     ,E



                                                                                      3

                                                                                                                                  IMPACT
                                                                                                                                              YES
                                                                                                                               .Significant
                                                                                                                 Not            Unless
                                                                                           NO
                                                                                       -------------­
                                                                                                                 Significant    Mitigated       Slgnifieant   Cumulative       SOURCE
2.   VEGETATION AND WILDLIFE

     Will (or could) this project:


     a.   Affect federal or state listed rare or endangered species of plant
                                                                                                                                     X                                     F
          life in the project area?

     b.   Involve cutting of heritage or significant trees as defined in the
                                                                                                                                     X                                     I,A
          County Heritage Tree and Significant Tree Ordinance?

     c.   Be adjacent to or include a habitat food source, water source,
          nesting place or breeding place for a federal or state listed rare                                                         X                                     F
          or endangered wildlife species?
                                                                                            -------------­




     d.   Significantly affect fish, wildlife, reptiles, or plant life?                                                              X                                     I
                                                                                                                   .
     e.   Be located inside or within 200 feet of a marine or wildlife
                                                                                            X                                                                              E,F,O
          reserve?

     f.   Infringe on any sensitive habitats?                                                                                        X                                     F

     g.   Involve clearing land that is 5,000 sq. ft. or greater (1,000 sq. ft.
          within a County Scenic Corridor), that has slopes greater than                                                             X
          20% or that is in a sensitive habitat or buffer zone?
                                                                                                             i                                                                      .......

                                                                                                             i
3.   PHYSICAL RESOURCES


     Will (or could) this project:


     a.   Result in the removal of a natural resource for commercial
          purposes (including rock, sand, gravel, oil, trees, minerals or                    X                                                                             I
          topsoil)?
                                                                                               ------------­                                                                            .....




                                                                                  4

                                                                                                          IMPACT
                                                                                                                      YES
                                                                                                        $ipific:ant
                                                                                         Not            Unless
                                                                                    NO   Signific:ant   Mitigated       Signiff~   Cumulative       SOURCE

     b.   Involve grading in excess of 150 cubic yards?                                                      X                                  I

     c.   Involve lands currently protected under the Williamson Act
                                                                                    X                                                           I
          (agricultural preserve) or an Open Space Easement?

     d.   Affect any existing or potential agricultural uses?                       X                                                           A,K,M

4.   AIR QUALITY. WATER QUALITY, SONIC

     Will (or could) this project:

     a.   Generate pollutants (hydrocarbon, thermal odor, dust or smoke
          particulates, radiation, etc.) that will violate existing standards of                             X                                  I,N,R
          air quality on-site or in the surrounding area?

     b.   Involve the burning of any material, including brush, trees and
                                                                                    X                                                           I
          construction materials?

     c.   Be expected to result in the generation of noise levels in excess
                                                                                               X                                                Ba,!
          of those currently existing in the area, after construction?

     d.   Involve the application, use or disposal of potentially hazardous
          materials, including pesticides, herbicides, other toxic                                           X                                  I
          substances, or radioactive material?

     e.   Be subject to noise levels in excess of levels determined
          appropriate according to the County Noise Ordinance or other              X                                                           A,Ba,Bc
          standard?

     f.   Generate noise levels in excess of levels determined appropriate
                                                                                                             X                                  I
          according to the County Noise Ordinance standard?




                                                                               5

                                                                                              --------­
                                                                                                                               IMPACT
                                                                                                                                           YES
                                                                                                                             SigAifiGant
                                                                                                               Not           Unless
                                                                                                          NO   Significant   Mitigated           Significant   Cumulative       SOURCE
                                                                                      -       ----------­




         g.   Generate polluted or increased surface water runoff or affect
                                                                                                                                  X                                         I
              groundwater resources?
                                                                                  -           ------------­




         h.   Require installation of a septic tank/leachfield sewage disposal
              system or require hookup to an existing collection system which                             X                                                                 S
              is at or over capacity?

    5.   TRANSPORTATION

         Will (or could) this project:

         a.   Affect access to commercial establishments, schools, parks,
                                                                                          1­
                                                                                          I
                                                                                                                     X                                                      A,I
              etc.?

         b.   Cause noticeable increase in pedestrian traffic or a change in
                                                                                                                     X                                                      A,I
              pedestrian patterns?

         c.   Result in noticeable changes in vehicular traffic patterns or
                                                                                                                     X                                                      I
              volumes (including bicycles)?

         d.   Involve the use of off-road vehicles of any kind (such as trail
                                                                                                          X                                                                 I
I
              bikes)?

         e.   Result in or increase traffic hazards?                                                                 X                                                      S

         f.   Provide for alternative transportation amenities such as bike                                                                                                 I
                                                                                                          X
              racks?
                                                                                                                                      ------­   ----­

I
         g.   Generate traffic which will adversely affect the traffic carrying                                                                                             S
                                                                                                                     X
              capacity of any roadway?




                                                                                  6

                                                                                                               IMPACT
                                                                                                                           yes
                                                                                                             Significant
                                                                                           Not               Un.
                                                                                      NO   Significant       Mitigated       Significant   Cumulative       SOURCE •
6.   LAND USE AND GENERAL PLANS

     Will (or could) this project:
                                                                                                 --------­




     a.   Result in the congregating of more than 50 people on a regular
                                                                                                 X                                                      I
          basis?

     b.   Result in the introduction of activities not currently found within
                                                                                      X                                                                 I
          the community?

     c.   Employ equipment which could interfere with existing
                                                                                      X                                                                 I
          communication and/or defense systems?

     d.   Result in any changes in land use, either on or off the project
                                                                                      X                                                                 I
          site?

     e.   Serve to encourage off-site development of presently
          undeveloped areas or increase development intensity of already
          developed areas (examples include the introduction of new or                X                                                                 1,0,5
          expanded public utilities, new industry, commercial facilities or
          recreation activities)?

     f.   Adversely affect the capacity of any public facilities (streets,
          highways, freeways, public transit, schools, parks, police, fire,
          hospitals), public utilities (electrical, water and gas supply lines,                  X                                                      1,5
          sewage and storm drain discharge lines, sanitary landfills) or
          public works serving the site?

     g.   Generate any demands that will cause a public facility or utility to
                                                                                      X                                                                 1,5
          reach or exceed its capacity?

     h.   Be adjacent to or within 500 feet of an existing or planned public
                                                                                      X                                                                 A
          facility?



                                                                                  7
                                                                                                                    IMPACT
                                                                                                                                 YES
                                                                                                                  :SIgnificant
                                                                                                 Not              Unless
                                                                                   -----­
                                                                                            NO   Significam       Mitigated        Significant   Cumulative       SOlilRCE
     i.   Create significant amounts of solid waste or litter?                                         X                                                      I

     j.   Substantially increase fossil fuel consumption (electricity, oil,
                                                                                                       X                                                      I
          natural gas, coal, etc.)?

     k.   Require an amendment to or exception from adopted general
                                                                                            X                                                                 B
          plans, specific plans, or community policies or goals?
                                                                                                              i


     I.   Involve a change of zoning?                                                       X                                                                 C

     m.   Require the relocation of people or businesses?                                   X                                                                 I

     n.   Reduce the supply of low-income housing?                                          X                                                                 I

     o.   Result in possible interference with an emergency response plan
                                                                                            X                                                                 S
          or emergency evacuation plan?

     p.   Result in creation of or exposure to a potential health hazard?                                               X                                     S

7.   AESTHETIC, CULTURAL AND HISTORIC

     Will (or could) this project:


     a.   Be adjacent to a designated Scenic Highway or within a State or
                                                                                                       X                                                      A,Bb
          County Scenic Corridor?

     b.   Obstruct scenic views from existing residential areas, public
                                                                                                       X                                                      A,I
          lands, public water body, or roads?

     c.   Involve the construction of buildings or structures in excess of                                                                                    I
                                                                                            X
          three stories or 36 feet in height?



                                                                              8

                                                                                                                                                        IMPACT
                                                                                                                                                            YES
                                                                                                                                                    II.bat.·
                                                                                                                       Not                          Unless
                                                                                                    NO                 Significant                  Mitilated    Significant   Cumulative                      SOURCE           I



              d.   Directly or indirectly affect historical or archaeological resources
                   on or near the site?                                                     I                                                             X
                                                                                                                                --------­                                                         ---­   --­
              e.   Visually intrude into an area having natural scenic qualities?                                             X
                                                                                                                                                                               --------­




III.   RESPONSIBLE AGENCIES. Check what agency has permit authority or other approval for the project.

                                               AGENCY                                                             YES                 NO                           TYPE OF APPROVAL
                                                                                                                                             --------



       U.S. Army Corps of Engineers (CE)                                                                           X
                                                                                          -------                                                                                   --------



       State Water Resources Control Board                                                                         X
                                                                                                                                                                                           --------



       Regional Water Quality Control Board                                                                        X

       State Department of Public Health                                                                                                 X

       San Francisco Bay Conservation and Development Commission (BCDC)                                                                  X
                                                                                                                                                                  -----                                         ---------



       U.S. Environmental Protection Agency (EPA)                                                                                        X

       County Airport Land Use Commission (ALUC)                                                                                         X

       CalTrans                                                                                                                          X
                                                                                                                                        ---------



       Bay Area Air Quality Management District                                                                    X
                                                                                                                  ---------                                                                                     -------



       U.S. Fish and Wildlife Service                                                                              X
                                                                                                                                                                                                                        -----



       Coastal Commission                                                                                                                X

       City                                                                                                                             X
       SewerlWater District:                                                                                                             X
                                                                                                    ---~   c---               ,-------- -­

       Other: California Department of Fish and Game                                                               X
                                                                                                           ----

                                                                                                                                                                                                                ----




                                                                                      9

IV.   MITIGATION MEASURES 

                                                                                                                              Yes                 No

      Mitigation measures have been proposed in project application. 	                                                         x
      Other mitigation measures are needed.                                                                                                        x

      The following measures are included in the project plans or proposals pursuant to Section 15070(b)( 1) of the State CEQA Guidelines:

      Mitigation Measure 1: A design level geotechnical investigation of the Phase 1 area shall be performed prior to any project grading. The report shall
      include a static and seismic slope stability analysis of the Phase 1 area to be graded and developed. The specific mitigation measures to be utilized in
      order to stabilize identified landslides and areas of potential seismically induced landslides in the Phase 1 area shall be presented in the report. The
      report shall be submitted to the San Mateo County Planning and Building Department for review by the County Geologist prior to commencement of any
      grading or construction activities.

      Mitigation Measure 2: The applicant shall obtain a grading permit hard card from the Planning and Building Department prior to commencement of any
      grading or construction activities.

      Mitigation Measure 3: Prior to beginning any construction activities, the applicant shall submit an Erosion and Sediment Control Plan for review and
      approval by the San Mateo County Planning and Building Department. The plan must be fully implemented and inspected by County Planning and
      Building Department staff prior to the commencement of any construction and/or grading activities and shall be maintained throughout the duration of the
      project. Erosion control measure deficiencies, as they occur, shall be immediately corrected. The goal is to prevent sediment and other pollutants from
      leaving the project site and to protect all exposed earth surfaces from erosive forces. Said plan shall adhere to the San Mateo Countywide Stormwater
      Pollution Prevention Program "General Constructibn and Site Supervision Guidelines," including:

      a. 	   Stabilizing all denuded areas and maintaining erosion control measures continuously between October 15 and April 15. Stabilizing shall include both
             proactive measures, such as the placement of hay bales or coir netting, and passive measures, such as revegetating disturbed areas with plants
             propagated from seed collected in the immediate area.

      b. 	   Storing, handling, and disposing of construction materials and wastes properly, so as to prevent their contact with stormwater.

      c. 	   Controlling and preventing the discharge of all potential pollutants, including pavement cutting wastes, paints, concrete, petroleum products,
             chemicals, wash water or sediments, and non-stormwater discharges to storm drains and watercourses.

      d. 	   Using sediment controls or filtration to remove sediment when dewatering the site and obtaining all necessary permits.

      e. 	   Avoiding cleaning, fueling, or maintaining vehicles on-site, except in a deSignated area where wash water is contained and treated.

      f. 	   Delineating with field markers clearing limits, easements, setbacks, sensitive or critical areas, buffer zones, trees and drainage courses.




                                                                                   10
g.   Protecting adjacent properties and undisturbed areas from construction impacts using vegetative buffer strips, sediment barriers or filters, dikes,
     mulching, or other measures as appropriate.

h.   Performing clearing and earth-moving activities only during dry weather.

i.   Limiting and timing applications of pesticides and fertilizers to prevent polluted runoff.

j.   Limiting construction access routes and stabilizing designated access pOints.

k.   Avoiding tracking dirt or other materials off-site; cleaning off-site paved areas and sidewalks using dry sweeping methods.

I.   The contractor shall train and provide instructions to all employees and subcontractors regarding the construction best management practices.

Mitigation Measure 4: The applicant shall submit a grading and drainage plan (including calculations) to the Planning and Building Department and the
Department of Public Works prior to the issuance of any project related grading or building permits. The grading and drainage plan shall include all
requirements listed in Grading Ordinance Section 8604.1.a.5 (Application Requirements). The drainage plan shall also include a narrative describing the
type, size, and location of all permanent stormwater controls to be utilized in order to ensure compliance with the County's Drainage Policy, the San Mateo
County Water Pollution Prevention Plan (SMCWPPP), and NPDES Provision C.3.

Mitigation Measure 5: Unless approved in writing and in advance by the Community Development Director, no grading shall be allowed during the winter
season (October 15 to April 15) to avoid potential soil erosion. The applicant shall submit a letter to the Current Planning Section, prior to the issuance of
the grading hard card, which illustrates the approximate grading schedule, including start and end dates.

Mitigation Measure 6: Any fills used at the project site shall be properly placed with keyways and subsurface drainage, and adequately compacted
following the recommendations of the final geotechnical report and geotechnical engineer. in order to significantly reduce fill sediment. Underground
utilities shall be designed and constructed using flexible connection pOints to allow for differential settlement.

Mitigation Measure 7: Foundation plans shall be submitted to the Planning and Building Department for review prior to issuance of building permits.
foundation excavations shall be observed during construction by the geotechnical engineer to ensure that subsurface conditions encountered are as
anticipated. As-built documentation shall also be submitted to the Planning and Building Department.

Mitigation Measure 8: The project applicant shall file a Notice of Intent (NOI) with the State Water Resources Control Board (SWRCB) and shall submit
proof of filing said NOI to the Planning and Building Department prior to beginning any grading or construction activities. The applicant and all
grading/construction contractors shall adhere to all conditions and regulations associated with the State General Construction Activity NPDES Permit.

Mitigation Measure 9: An updated rare plant survey shall be conducted by a qualified botanist prior to any construction activities commencing after the
spring of 2012. Should any rare plant species be identified, these populations should be aVOided to the extent practical. If removal of special-status plant
species is required, transplanting to a suitable location in the Environmental Protection Zone will be considered as the first option. Given that the rare
plant species of primary concern are evergreen shrubs or lilies, transplanting should be feasible. Prior to the transplanting of any rare plant species, a
plant relocation plan shall be developed by a qualified botaniSt. At a minimum, the plan shall demonstrate the feasibility of replacing the number of
individual plants to be removed at a 1: 1 ratio. The plan shall, at minimum, specify the following: (1) the location of mitigation sites in the Environmental
Protection Zone or other suitable locations; (2) methods for harvesting seeds and salvaging and transplantation of individual bulbs/plants to be impacted;
(3) site preparation procedures for the mitigation site; (4) a schedule and action plan to maintain and monitor the mitigation area; (5) a list of criteria and

                                                                             11
performance standards by which to measure success of the mitigation site(s); (6) measures to exclude unauthorized entry into the mitigation areas; and
(7) contingency measures in the event that mitigation efforts are not successful. The plan shall be subject to the approval of the Planning and Building
Department prior to the removal of any special-status plant species.

Mitigation Measure 10: Prior to any grading or construction activities within or adjacent to the Land and Water Management Zones, a qualified botanist
shall conduct a survey of the immediate work areas to determine whether any rare plant species are present. If any such species are identified, the
botanist shall consult with Planning and Building Department staff to determine how to proceed. No grading or construction activities shall occur in the
area until the botanist and County staff have agreed on an appropriate course of action that will minimize adverse impacts to special-status plant species
in the area.

Mitigation Measure 11: Prior to the commencement of construction activities, a tree survey shall be conducted by a qualified arborist indicating all the
trees that could be removed or otherwise harmed during Phase 1 construction. At a minimum, the survey shall identify the size (diameter at breast
height), species. and condition of the trees. The survey shall also identify which of these trees are considered protected, significant, or heritage trees. If
any such trees are identified by the arborist within Phase 1 project areas, the project applicant shall implement tree protection measures to insure said
trees are not damaged during construction. These measures may include protective fencing, prohibiting construction/grading activities within the dripHne
of trees to be preserved, or other appropriate measures approved by the Planning and Building Department.

Mitigation Measure 12: Prior to initial vegetation removal and/or grading activities in the upland portions of the construction zone, pre:-construction
clearance surveys shall be conducted for California red-legged frog and San Francisco garter snake by a qualified biologist. Should either species be
identified, construction activities shall be immediately halted until the frog (or snake) leaves the construction zone on its own, or is removed by a qualified
biologist in possession of an appropriate permit and authorized by the USFWS. The USFWS shalf be immediately notified if either species is observed.

Mitigation Measure 13: Prior to the commencement of construction activities within 50 feet of a wetland or riparian woodland, a pre-construction
clearance survey of the area shall be conducted by a qualified biologist for California red-legged frogs and San Francisco garter snake. Should either
species be identified, construction activities should be halted until the animal leaves the construction zone on its own, or is removed by a qualified biologist
in possession of an appropriate permit and authorized by the USFWS. If it is determined that no red-legged frogs or garter snakes are present, temporary
exclusionary fencing shall then be installed around the perimeter of the wetland/riparian woodland and adjacent construction areas. The fencing shall be
maintained throughout the duration of construction activities near the wetland/riparian area. The adequacy of the fencing to prevent frogs and snakes
from entering the construction zone shall be approved by a qualified biologist prior to the commencement of construction activities and shall be inspected
daily to ensure it continues to operate effectively.

Mitigation Measure 14: In order to prevent the accidental removal of wetland habitat (and potentially damaging habitat of an endangered wildlife
species) a qualified biologist shall determine and mark in the field the extent of all wetland areas in and adjacent to Phase 1 development zones. Any
grading or construction activities within 50 feet of any wetland habitat shall be referred to and reviewed by United Stated Fish and Wildlife Service
(USFWS) prior to commencement of any construction activities. Prior to any disturbance within 50 feet of wetland habitats, proof of consultation with and
approval by USFWS shall be submitted to the Planning and Building Department.

Mitigation Measure 15: The San Francisco garter snake is a California Fully Protected Species, which means that the California Department of Fish and
Game (CDFG) cannot authorize the take of the species and needs to ensure the adequacy of the avoidance measures to be implemented. Therefore, the
CDFG shall be consulted prior to the implementation of construction activities and any further recommended avoidance measures shall be implemented.
Prior to any disturbance within 50 feet of wetland habitats, proof of consultation with and approval by CDFG shall be submitted to the Planning and
Building Department.


                                                                            12
Mitigation Measure 16: The outer limits of the stand of native grassland located within the Land and Water Management Zone adjacent to Phase 1
development area shall be identified by a qualified biologist and marked with wooden stakes or other equivalent markers. Land management activities
shall not be allowed within the identified area, unless the timing and nature of the activity is found to not pose a threat to bay checkerspot butterfly by a
qualified biologist.

Mitigation Measure 17: No earlier than 30 days prior to the commencement of any construction activities in coastal scrub or woodland habitats, a survey
shall be conducted to determine if active wood rat nests (stick houses) with young are present within the disturbance zone or within 50 feet of the
disturbance zone. If active woodrat nests with young are identified, a fence shall be erected around the nest site at a distance adequate to provide the
wood rat sufficient foraging habitat at the discretion of a qualified biologist. Clearing and construction within the fenced area would be postponed or halted
until young have left the nest. A qualified biologist should serve as a construction monitor during those periods when disturbance activities will occur near
active nest areas to ensure that no inadvertent impacts on these nests occur. If wood rats or nests are observed within the disturbance footprint outside of
the breeding period, individuals should be relocated to a suitable location within the Environmental Protection Zone by a qualified biologist in possession
of a scientific collecting permit. This will be accomplished by dismantling wood rat nests (outside of the breeding period), to allow individuals to relocate to
suitable habitat within the adjacent Environmental Protection Zone. The Environmental Protection Zone contains large expanses of suitable wood rat
habitat that would be protected.

Mitigation Measure 18: If trees or structures are to be removed during the breeding season of native bat species (generally April 1 through August 31 in
California), the presence of active bat maternity roosts should be evaluated by a qualified biologist. If the trees/structures to be removed are determined
to provide potential bat roosting habitat, a focused survey should then be conducted to determine if an active maternity roost of a special-status bat
species is present. Should an active maternity roost of a special-status bat species be identified, the roost should not be disturbed until the roost is
vacated and juveniles have fledged, as determined by the biologist. Once all young have fledged, the tree/structure may be removed.

Mitigation Measure 19: If a construction project would commence anytime during the nesting/breeding season of native bird species potentially nesting
on the site (typically February through August in the project region), a pre-construction survey of the project vicinity for nesting birds shall be conducted.
This survey shall be conducted by a qualified biologist (Le., experienced with the nesting behavior of bird species of the region) within two weeks of the
commencement of construction activities. The intent of the survey would be to determine if active nests of special-status bird speCies or other species
protected by the Migratory Bird Treaty Act and/or the California Fish and Game Code are present within the construction zone or within 500 feet of the
construction zone. The survey area would include all trees and shrubs in the construction zone and a surrounding 500 feet area. The survey should be
timed such that the last survey is concluded no more than two weeks prior to initiation of construction. If ground disturbance activities are delayed
following a survey, then an additional pre-construction survey should be conducted such that no more than two weeks will have elapsed between the last
survey and the commencement of ground disturbance activities.

If active nests are found in areas that could be directly affected or are within 500 feet of construction and would be subject to prolonged construction­
related noise, a no disturbance buffer zone shall be created around active nests during the breeding season or until a qualified biologist determines that all
young have fledged. The size of the buffer zones and types of construction activities restricted within them will be determined through consultation with
the CDFG, taking into account factors such as the following:

a.   Noise and human disturbance levels at the construction site at the time of the survey and the noise and disturbance expected during the construction
     activity;

b.   Distance and amount of vegetation or other screening between the construction site and the nest; and

c.   Sensitivity of individual nesting species and behaviors of the nesting birds.

                                                                            13 

Limits of construction to avoid an active nest shall be established in the field with flagging, fencing, or another appropriate barrier and construction
personnel should be instructed on the sensitivity of nest areas. The biologist shall serve as a construction monitor during those periods when construction
activities would occur near active nest areas of special-status bird species to ensure that no impacts on these nests occur.

Mitigation Measure 20: The applicant shall submit a dust control plan to the Planning and Building Department prior to any Phase 1 grading or
construction activities. The approved measures shall be implemented prior to beginning any grading and/or construction activities and shall be maintained
for the duration of the project. The plan shall, at minimum, include all the "Basic Control Measures" listed in Table 2 of the BAAQMD CEQA Guidelines
(see Appendix D):

a. 	   Water all active construction areas at least twice daily.

b. 	   Cover all trucks hauling soil, sand and other loose materials or require all trucks to maintain at least 2 feet of freeboard.

c. 	   Pave, apply water three times daily, or apply (non-toxic) soil stabilizers on all unpaved access roads, parking areas and staging areas at construction
       sites.

d. 	   Sweep daily (with water sweepers) all paved access roads, parking areas and staging areas at construction sites.

e. 	   Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent public streets.

Additional measures may be required in order to ensure that construction-related activities do not generate elevated levels of dust particulates at any point
throughout the duration of the project.

Mitigation Measure 21: The applicant shall comply with and follow all guidelines and regulatory requirements as stipulated by the County Environmental
Health Division with regard to their use and disposal of ali chemicals and fluids resulting from the embalming processes that occur at the Skylawn
mortuary.

Mitigation Measure 22: The project applicant (or authorized contractor) shall submit a safety plan for the develo'pment of Phase 1. The safety plan shall
include measures to reduce and minimize accidents on-site and measures that address the proper procedures to clean up and contain spills. The safety
plan shall be approved by the County Building Inspection Section prior to the start of any construction or grading activity on the site.

Mitigation Measure 23: Noise levels produced by proposed construction activities shall comply with the San Mateo County Noise Ordinance contained in
Chapter 4.88 (Noise Control) of the County Ordinance Code at all times. Construction activities shall be limited to the hours from 7:00 a.m. to 6:00 p.m.,
Monday through Friday, and 9:00 a.m. to 5:00 p.m. on Saturday. Construction operations shall be prohibited on Sunday and any national holiday.

Mitigation Measure 24: If archaeological and/or cultural resources are encountered during grading or construction activities, work shall be temporarily
halted in the vicinity of the discovered materials and workers shall avoid altering the materials and their context until a qualified professional archaeologist
has evaluated the situation and provided appropriate recommendations. The project applicant or archaeologist shall immediately notify the Current
Planning Section of any discoveries made and shall provide the Current Planning Section with a copy of the archaeologist's report and recommendations
prior to any further grading or construction activity in the vicinity.




                                                                               14 

v.    MANDATORY FINDINGS OF SIGNIFICANCE

                                                                                                                                                                             I
                                                                                                                                                Yes           No
      1. 	   Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or         X

             wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or 

             animal, or eliminate important examples of the major periods of California history or prehistory? 


      2. 	   Does the project have the potential to achieve short-term environmental goals to the disadvantage of long-term                                    X

             environmental goals? 


      3. 	   Does the project have possible environmental effects which are individually limited, but cumulatively considerable?                  X
                                                                                                                                                                     -----



      4. 	   Would the project cause substantial adverse effects on human beings, either directly or indirectly?                                  X



      On the basis of this initial evaluation:

                      I find the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared
                      by the Current Planning Section.
     -----
                      I find that although the proposed project could have a significant effect on the environment. there WILL NOT be a significant effect in this
                      case because of the mitigation measures in the discussion have been included as part of the proposed project. A NEGATIVE
             X        DECLARATION will be prepared.

               I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is
     _ _ _ _ _ required.




                                                                                           Dave Holbrook


                                                                                           Project Planner 

      Date                                                                                 (Title) 





                                                                                    15 

VI.   SOURCE LIST 


      A	     Field Inspection

      B. 	 County General Plan 1986

             a. 	   General Plan Chapters 1-16
             b. 	   Local Coastal Program (LCP) (Area Plan)
             c. 	   Skyline Area General Plan Amendment
             d. 	   Montara-Moss Beach-EI Granada Community Plan
             e. 	   Emerald Lake Hills Community Plan

      C. 	 County Ordinance Code

      D. 	 Geotechnical Maps

             1. 	   USGS Basic Data Contributions

                    a.   #43 Landslide Susceptibility
                    b.   #44 Active Faults
                    c.   #45 High Water Table

             2. 	   Geotechnical Hazards Synthesis Maps

      E. 	 USGS Quadrangle Maps, San Mateo County 1970 Series (See F. and H.)

      F. 	   San Mateo County Rare and Endangered Species Maps, or Sensitive Habitats Maps

      G. 	 Flood Insurance Rate Map - National Flood Insurance Program

      H. 	 County Archaeologic Resource Inventory (Prepared by S. Dietz, AC.RS.) Procedures for Protection of Historic and Cultural Properties - 36 CFR
           800 (See R)

      I. 	   Project Plans or ElF

      J. 	   Airport Land Use Committee Plans, San Mateo County Airports Plan

      K. 	   Aerial Photography or Real Estate Atlas - REDI

             1. 	   Aerial Photographs, 1941, 1953,1956,1960,1963,1970
             2. 	   Aerial Photographs, 1981
             3. 	   Coast Aerial Photos/Slides, San Francisco County Line to Ario Nuevo Point, 1971
             4. 	   Historic Photos, 1928-1937 


                                                                                 16 

    L.   Williamson Act Maps

    M.   Soil Survey, San Mateo Area, U.S. Department of Agriculture, May 1961

    N.   Air Pollution Isopleth Maps - Bay Area Air Pollution Control District

   O.    California Natural Areas Coordinating Council Maps (See F. and H.)

    P.   Forest Resources Study (1971)

   Q.    Experience with Other Projects of this Size and Nature

   R     Environmental Regulations and Standards:

         Federal 	      Review Procedures for CDBG Programs                           24 CFR Part 58
                        NEPA 24 CFR 1500-1508
                        Protection of Historic and Cultural Properties                36 CFR Part 800
                        National Register of Historic Places
                        Floodplain Management                                         Executive Order 11988
                        Protection of Wetlands                                        Executive Order 11990
                        Endangered and Threatened Species
                        Noise Abatement and Control                                   24 CFR Part 51 B
                        Explosive and Flammable Operations                            24 CFR 51C
                        Toxic Chemicals/Radioactive Materials                         HUD 79-33
                        Airport Clear Zones and APZ                                   24 CFR 510

         State 	        Ambient Air Quality Standards                                 Article 4, Section 1092
                        Noise Insulation Standards

   S.    Consultation with Departments and Agencies:

         a.   County Health Department
         b.   City Fire Department
         c.   California Department of Forestry
         d.   Department of Public Works
         e.   Disaster Preparedness Office
         f.   Other

DH:pac - DJHU0619_WPH.DOC
FRM00018 table format.doc
(1/22/07)


                                                                                 17
                                  COUNTY OF SAN MATEO 

                                Planning and Building Department 


                              Initial Study Pursuant to CEQA 

            Project Narrative and Answers to Questions for Negative Declaration 

                                 File No.: PLN 2010-00026 

                        Skylawn Memorial Park Master Use Permit 



PROJECT DESCRIPTION

Introduction

The Lifemark Group (Skylawn), project applicant, has prepared a Development Agreement
(DA) and Master Land Use Plan (MLUP) for the Skylawn Memorial Park project for all
cemetery development anticipated over the next 20 years. As part of a previous amendment
to Skylawn' s Use Permit for the construction of their mortuary/administrative facility in 2002
(County File No. PLN 2000-00166), Condition of Approval No. 22 required that a "Preservation
and Environmental Management Zone" be identified and that a plan identifying said zone would
be submitted, reviewed and recorded "prior to the issuance of any building or grading permit
associ~ted with any future road or ground burial expansion." In response to that condition, the
project applicant has prepared a DA and MLUP that identifies an Environmental Protection
Zone and developable areas on the project site. While the intent of the MLUP is to guide the
development and expansion of the Skylawn facility over the next 20 years, it is but one phase
of seven phases of development to occur sequentially over the course of many more years as
additional interment facilities become necessary.

The subject MLUP (20 years; Phase I) includes a development plan that protects and preserves
sensitive lands within the project site and is consistent with the regulations, goals and policies of
the San Mateo County zoning and General Plan land use regulations. This Initial Study
evaluates only the development proposed to occur within Phase 1 as indicated in the enclosed
Phasing Plan dated April 12, 2010, which is expected to occur between 2010 and 2030.

Note: This document references Appendices A (Planning Constraints and GIS Analysis), 

B (Biological Constraints and Opportunities Report), C (A ir Emissions Report), and E (Traffic 

and Transportation Report). These appendices are available for review at the County Planning 

Department. 


Finally, while most of the Figures references in this document show information relating to the
entire Skylawn Memorial Park facility and are entitled "Skylawn Memorial Park Master Plan,"
its critical to repeat that the "project" is restricted to only Phase 1 (Figure 9, 10, and 11) of
Skylawn's long range plan.

Project Location and Setting

Location. The approximately 521-acre project site is located in an unincorporated portion of
San Mateo County that is bordered to the south by Highway 92 (see Figure 1). Undeveloped
lands, managed by the San Francisco Public Utility Commission (SFPUC), border the property
to the north and east. Privately owned land that is generally undeveloped (with the exception of
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limited agricultural uses) borders a portion of the property to the west. At its closest point, the
property is located approximately 0.8 miles to the west of Crystal Springs Reservoir. Portions of
the project site are located within the following 7.5-minute USGS quadrangles: San Mateo, Half
Moon Bay, Montara Mountain, and Woodside.

Setting. An aerial overview of the existing conditions of the project site is included as Figure 2.
Within the approximately 52 I-acre project site, approximately 94 acres are currently developed
with cemetery-related uses, while the remaining 427 acres are undeveloped. A paved roadway
provides access throughout the existing cemetery uses on the site and continues in a northerly
direction past the existing cemetery along the eastern property border. A former quarry, located
in the northern portion of the site, is accessed via a dirt road. Several buildings that are leased to
a private company for radar equipment are located in the far northern portion of the site. A
vacant two-story building is located in the eastern portion of the site, north of the existing
cemetery land uses. Two vacant water tanks and a maintenance shed are also located on-site. A
number of telecommunications facilities are located just east of the dirt access road between the
existing cemetery and the Phase I development area.

The project site is located on the southwest side of Montara Mountain, along the northern
expanses of Cahill Ridge. Elevations at the site range from 400 to 1,000 feet above mean sea
level. The majority of the project site consists of rolling landscape with hills and canyons. The
southern portion slopes southward toward Albert Canyon Creek (a tributary to Pilarcitos Creek),
which crosses the southern portion of the site. The topography of the northern portion of the
project site slopes westward toward a second, unnamed tributary of Pilarcitos Creek, which
traverses the western portion of the project site. The slope on the project site ranges from 0% to
over 30%, as shown on Figure 3. The site contains areas characterized as coastal scrub, annual
grassland, with small areas of purple needlegrass grassland, wetlands, willow riparian woodland,
and Douglas fir woodland. The primary soils in the project vicinity consist of gently sloping to
very steep upland soils that are well drained to somewhat excessively drained. There is lack of
shallow groundwater given that the project site is located on a high ridge.

Existing Land Use and Zoning Designations

The San Mateo County General Plan designates the project site as General Open Space. The site
is zoned Resource Management (RM) by the County's Zoning Map, which allows such uses as
hotels, restaurants, commercial recreation facilities and cemeteries upon securing a use permit
and RM Development Review Permit. While a western portion ofthe Skylawn property is
located within the Coastal Zone (CZ) and subject to the jurisdiction of the California Coastal
Commission (refer to Figure 2), none of the proposed Phase 1 development is within the CZ.
Figure 2 also shows the portion of the site that is within the Highway 92 County Scenic Corridor.
Again, the Phase 1 development area is not located within said scenic corridor, but the eastern
ridge portions of the Phase 1 area may be visible from various locations within the Skyline and
Highway 1-280 State Scenic Corridors.
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Master Land Use Plan

  Cemetery Planning Criteria, Opportunities, and Constraints Analysis. In creating the MLUP,
  Skylawn attempted to achieve two primary goals: (I) protect and preserve all sensitive lands
 on and around the project site, and (2) maximize the use of all land areas deemed suitable for
  cemetery development. The location ofthe land contained within the Environmental Protection
 Zone and areas deemed suitable for cemetery development were identified through a thorough
 opportunities and constraints analysis (Appendices A and B). The analysis included coastal and
  scenic corridor limit verification, preliminary storm drainage and environmental management
  zones design, surface drainage evaluation, internal and external viewshed analysis, biological
  and planning constraints identification and long-term cemetery facility programming and phasing
  development. Geologic investigations of surface conditions and past geotechnical studies were
  used to establish limits of future cemetery development areas that would have minimal impacts
  on the physical environment. Slopes in excess of 30% were considered a limiting factor to
  development except where such slopes were isolated or where these slopes were man-made and
  would be stabilized for improved environmental and public safety. Existing drainage systems on
. the site were evaluated to establish strategies for stormwater management that would have mini­
  mal impact on the configuration of the natural drainage channels and to achieve minimal change
  to the quantity and quality of the water currently entering channels on-site. Biological surveys
  were conducted to identify and map the location of plant communities associated with locally
  occurring special-status species and suitable habitat for special-status species. Biologically
  sensitive areas were generally excluded from the proposed development zone and are separated
  from the development zone by buffer zones.

The constraints analysis identified 226 acres of new cemetery development that could be devel­
oped on-site and 201 acres of land that should be preserved in the Environmental Protection
Zone (see Figure 4). Natural burial lands, which are accessible only by foot, and land and water
management zones were also identified as shown in Figure 4. New roads would be constructed
to provide access to the new cemetery development and minor improvement would be made to a
small portion ofthe Bay Area Ridge Trail that runs along the eastern edge of the site. Additional
detailed information regarding these project features is provided below.

 Proposed Development

 As cited earlier, this initial Study strictly focuses on Skylawn's proposed development within
 Phase 1 to occur over the next 20 years. This current proposal stems from the Skylawn's ten­
 tatively proposed seven-phased development plan for the 226 acres to be deVeloped over many
 more years. The areas adjacent to the existing cemetery uses (Phases 1,2 and 3) would be
 developed first followed by the outlying areas along the ridges and to the north. Figure 5
 illustrates the location of the seven development phases on the property. The types of burial
 facilities being requested by the cemetery customers are changing; there appears to be a trend
 in the cemetery market toward cremation and for environmentally "green" or "natural" burial
 options and a trend away from traditional lawn burials. With the decline of traditional lawn
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burials, burial facilities are likely to accommodate cremation and outdoor garden crypts that
result in cemetery landscapes that are far denser than those today (i.e., high-density burial
development). For the proposed MLUP, these high-density outdoor burial areas would be
concentrated adjacent to new roadways throughout the site, typically located in currently
natural areas where land is too steep to economically develop for traditional lawn burial.
These high-density burial facilities take the form of various types of internment:

•	   Concentrated ground burial private estates, where the family "estate" areas are separated
     by retaining walls with burial vaults in the ground; an example of this is the recently
     completed Eternity Garden internment, a re-contoured development accessed by a
     roadway (the estates accessed by walkways) on downward sloping land just southwest
     of the Phase 1 area.

     Garden mausoleums are typically granite-faced crypts where the casket (full body burial)
     slides horizontally (e.g., into a vertical wall retained and benched into a sloping hillside)
     into concrete compartments. Such internment areas would also be accessed by roadway(s),
     with the crypt areas accessed by walkways.

G    Columbaria or columbarium is similar to the construction of garden mausoleums, except
     that the actual crypts are much smaller since they're typically used to house cremation
     urns.

o	   The garden mausoleums and columbaria proposed in Phase 1 would range between three
     and seven crypts high and could be up to 25 feet high and set into the existing grade in
     terraces approximately 20 feet deep and highly landscaped to shield the exposed sides.
     The net view exposure due to the terracing would be approximately 5 feet or less. These
     would be set into the earth as retaining walls (see Figure 6). As the cross-sections of the
     cited Figures show, such development despite grade alterations and re-contouring of the
     land would generally be at or below the pre-existing topography.

I'    The natural (or "Green") burial areas would be placed outside of the traditional burial
      areas and serve as both a visual and environmental buffer between the cemetery and the
      Environmental Protection Zone. These natural burial areas would be accessed on foot
      through a series of unpaved pedestrian trails. Natural burial areas would not be irrigated
      and the burial architecture would be constructed of materials that use textures and colors
      that would blend into the natural landscape of the hillside developments. This system
      would integrate the burial structures into the natural grade of the site, minimizing the
      hydrological and visual impacts on the landscape.
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Both traditional and natural burial areas· are also being proposed as part of Phase I development.
The traditional lawn burial areas would be placed adjacent to new roadways and the high-density
burial internment developments described above. A major element of Phase I (see Figures 9-11)
would combine elements of all of the above. Parking would be accommodated along both
existing and proposed cemetery roads except where needed to insure adequate handicapped
accessibility.

Phase 1 Project Area. Phase 1 to occur over the next 20 years - encompasses approximately
35 acres of presently undeveloped area. Development would occur north of the existing
cemetery facilities abutting the Environmental Protection Zone area as shown in Figure 4. Of the
35 acres, about half of that (see Figure 9) is located toward the upper, easterly portion (generally
east of Cahill Road), and would be developed with a combination of tiered high-density
internment development (e.g., garden mausoleums, family estates, columbarium walls, all
accessed by vehicular roadways and internal walkways) interlaced with traditional lawn burial (it
is assumed that the majority of the cemetery market will continue to request traditional lawn
burial for the next 30 to 40 years). This portion of the development would include significant
grading (due to the degree of sloping topography) and the improvement and widening of Cahill
Road.

West of the development cited above would be a new roadway accessing traditional lawn burials
and some columbarium walls. Again, due to existing downward sloping topography, this would
involve some significant grading. The cited roadway would end in a circled cul-de-sac, beyond
which is the proposed natural burial area accessed by trails (requiring only minimal grading and
vegetation removal to accommodate burial and trails). This westerly half ofthe total 35 acres
also includes a storrnwater management/collection area and is generally bordered on all sides
by a Land and Water Management Zone (see discussion below), including a protected area
for storm water management and environmental buffer for the previously cited pennanent
Environmental Protection Zone (EPZ).

Land and Water Management Zone. The MLUP includes a Land and Water Management Zone
intended to act as a buffer between the new cemetery development and the Environmental
Protection Zone. The Land and Water Management Zone will provide adequate land area to
accomplish grading operations and storm water management systems in order to eliminate or
minimize adverse impacts to the Environmental Protection Zone (and the project site as a
whole). This would include cutting or filling of existing grades where required to achieve
useable slopes for traditional ground burial, and for the development of infrastructure, retaining
walls, storm water retention systems, and structural burial facilities including columbaria and
mausoleums that occur within a designated cemetery development zone. The configuration and
dimension of the Land and Water Management Zone has been designed based on the following

• A modern natural burial is an environmentally sustainable alternative to existing funeral practices where the body 

  is buried directly in and returned to the earth to decompose naturally and be recycled into new life. The body is 

 'prepared for burial without chemical preservatives and 	is buried in a simple shroud or biodegradable casket that 

  might be made from locally harvested wood, wicker or recycled paper. 

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conditions: (1) the existing slope gradient; (2) the presence of sensitive biological resources; (3)
the type of development proposed; and (4) the localized storm water management requirements
and strategies. Earthwork, landscaping, and structural components of the water management
systems may occur within this land and water management zone as part ofthe project's water
management strategy to control and manage the quantity and quality of storm water draining into
the Environmental Protection Zone from the cemetery's developed areas. Any areas within the
Land and Water Management Zone that are modified would be restored to a natural landscape to
the greatest extent possible.

Environmental Protection Zone. No development or any ground disturbing activities would
occur in the approximately 20 I-acre Environmental Protection Zone, with the exception of the
maintenance of existing and/or future utility line easements. This area would be preserved in its
natural state throughout the life of the project.

Infrastructure

The project would not expand utilities such as wastewater, potable water service, and circulation
systems beyond those necessary to provide services to the new cemetery development. No addi­
tional office or customer service areas would be developed and no new buildings are proposed,
with the exception of a new maintenance shed in the eastern ridges of the project site. It is anti­
cipated that a minor increase in employees would occur through buildout of the MLUP to help
maintain landscaping and lawns; however, the number of services is expected to remain constant
at approximately 600 burials per year. The project would, due to grading and re-contouring of
land, alter the existing on-site drainage system and increase water demand for irrigation
purposes, as described below.

Stormwater Drainage and Runoff Management Systems. The majority of the existing cemetery
improvements on the project site have no defined drainage system. Surface water runoff,
including irrigation, flows along the natural topography of the site (sheet flow) and eventually
infiltrates into the soil or enters into the natural drainage channels on-site. There are two areas
on-site that have a defined drainage system: a detention system adjacent to the funeral home and
reception building and a detention system along the farthest reaching cul-de-sac on the north­
western boundaries of the existing cemetery. These detention systems collect surface water
runoff and filter pollutants.

The project includes stormwater management strategies that would minimally impact the con­
figuration of the natural drainage channels so as to achieve minimal change to the quantity and
quality of the water entering the channels. Where any grade alterations are made by project
improvements, vegetated slope retention systems would be used to transition to existing grade,
if possible. Stormwater management strategies may be premised on a system of "stormwater
source-control," which would hold the water as close to where it falls as possible, thereby mini­
mizing the need to transport or store large quantities of water. These "localized containment
systems" would include bioswales to capture and allow for controlled infiltration of stormwater ,
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extensive subdrainage systems to intercept shallow subsurface flows, oversized storm water pipes
to serve as localized "storage basins", and where appropriate, the creation of new wetlands for
stormwater absorption. Earth retaining mausoleum structures would incorporate source-control
systems for stormwater management.

The project's engineering goal is to provide clean water to the natural drainage channels at the
same rate and quality at which they receive water in the current, pre-development state. The
County requires post-construction stormwater control systems as part of their obligations under
Provision C.3 of the Municipal Regional Stormwater NPDES Permit (MRP) recently adopted by
the State Water Resources Control Board in October 2009. As such, all project storm water
management strategies would be designed in accordance with the County's requirements
mandated under Provision Co3.

Irrigation. The existing cemetery currently irrigates approximately 83 acres of lawn. The esti­
mated total irrigated lawn associated with all Phase 1 development is approximately 15 acres,
which is 18% of the area of irrigated lawn in the existing cemetery . For the purposes of this
CEQA document, this project conservatively assumes that the traditional lawn would require
irrigation at a similar water demand (per acre) for the existing cemetery. Between 2008 and
2009, the cemetery consumed approximately 41 million gallons of water to irrigate approxi­
mately 83 acres of turf. Assuming the same infrastructure and plant materials as currently exist,
the additional 15 acres of lawn associated with Phase 1 development would generate a demand
for approximately 7 million gallons of water pear year. However, future irrigation system
efficiency improvements and the use of drought resistant turf would reduce the demand of water
for irrigation. Future landscape development would make an effort to employ the use of native
species that are visually appropriate to hillside ecology and that reduce the carbon footprint of
maintenance of trees, shrubs, and ground cover. The use of native materials and native plants,
including drought and fire resistant plants would be used to the extent feasible throughout the
proposed developed areas. Alternative sources of irrigated water that may be available to the
project applicant will be pursued to meet the future irrigation needs to further reduce water
demand.

Construction and Grading Operations

As previously cited, much of the internment development and its access, overall, constitute about
30 acres ofthe 35-acre Phase I area. The total earthwork quantity required to construct each
facility will be determined during the building permit stages for each area within Phase 1;
however, the total grading quantity for the entire Phase 1 area is not expected to exceed 40,000
cubic yards of combined cut and filL All grading activity will be governed by the San Mateo
County Ordinance Code Section 8600, the regulations guiding "Excavating, Grading, Filling and
Clearing on Lands in Unincorporated San Mateo County" (Grading Ordinance). Thus, as each
internment project element is proposed to occur during Phase 1 (as approved), Skylawn would
apply for the requisite grading and building permits. The grading permit (albeit not processed as
a discretionary, appealable permit) would allow both Skylawn and the Planning and Building
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Department to ensure compliance with all applicable conditions and mitigations associated with
this CEQA document and Skylawn's MLUP.

Approach to CEQA Evaluation

The proposed DA and MLUP include a long-range development plan that spans many more
years into the future. The phases of development would occur sequentially and independent of
each another. CEQA regulations generally require that a project's elements and impacts be
evaluated cumulatively and in their entirety rather than conducting separate evaluations of each
phase. Because Skylawn's MLUP intends to guide development many more years in the future,
certain methodologies for the impact analyses cannot reliably predict the environmental impacts
ofthe project so far into the future. So while Sky lawn Memorial Park has contemplated further
development as indicated in their MLUP, this Initial Study only includes the analysis of the
Phase 1 development proposals as identified in Skylawn's application to the County Planning
and Building Department. Phase 1 development encompasses an area of approximately 35 acres
and is anticipated to occur over the next 20 years, between 201 0 and 2030. Any additional
development that may be contemplated in the future would be subject to the federal, state, and
local regulations in effect at that time

ANSWERS TO QUESTIONS

1. 	   LAND SUITABILITY AND GEOLOGY

       a. 	   Will (or could) this project involve a unique landform or biological area, such as
              beaches, sand dunes, marshes, tidelands, or San Francisco Bay?

              No. The project site does not contain a unique landform such as beaches, sand dunes,
              marshes, sandstone rock outcrops, tidelands or portions of the San Francisco Bay.

       h.     Will (or could) this project involve construction on slope of 15% or greater?

              Yes, Significant Unless Mitigated. A geology and geotechnical hazards assessment
              was conducted to identify slopes and other geotechnical constraints on the site. The
              information was collected from published maps, air photography, and surveys on-site.
              According to the assessment, the majority of the project site consists of rolling land­
              scapes with hills and canyons that slope toward the tributaries of Pilarcitos Creek.
              The slope on the project site ranges from 0% to over 30% as shown on Figures 3
              and 13. According to the preliminary geotechnical analysis conducted as part of this
              project, landslides have occurred in portions ofthe project site, and some landslides
              on-site have been repaired through geotechnical measures. Based on the geotechnical
              assessment, the potential for slope instability exists at the project site. The con­
              struction on about 30 acres (of the total 35 acres) of new cemetery development
              during Phase 1 could activate or reactivate landslides on that portion of the project
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           site. Implementation of Mitigation Measure 1 below would reduce the impacts of
           slope instability to a less than significant level.

           Mitigation Measure 1: A design level geotechnical investigation of the Phase 1 area
           shall be performed prior to any project grading. The report shall include a static and
           seismic slope stability analysis of the Phase 1 area to be graded and developed. The
           specific mitigation measures to be utilized in order to stabilize identified landslides
           and areas of potential seismically induced landslides in the Phase 1 area shall be
           presented in the report. The report shall be submitted to the San Mateo County
           Planning and Building Department for review by the County Geologist prior to
           commencement of any grading or construction activities.

           The potential for soil instability in the Phase 1 project areas could also lead to erosion
           and/or sedimentation if the project were to be undertaken without appropriate mitiga­
           tion. The implementation of Mitigation Measures 2 - 5 will reduce the risk of both
           construction-related and post-construction impacts to a less than significant level.

           Mitigation Measure 2: The applicant shall obtain a grading permit hard card from
           the Planning and Building Department prior to commencement of any grading or
           construction activities.

           Mitigation Measure 3: Prior to beginning any construction activities, the applicant
           shall submit an Erosion and Sediment Control Plan for review and approval by the
           San Mateo County Planning and Building Department. The plan must be fully imple­
           mented and inspected by County Planning and Building Department staff prior to the
           commencement of any construction and/or grading activities and shall be maintained
           throughout the duration of the project. Erosion control measure deficiencies, as they
           occur, shall be immediately corrected. The goal is to prevent sediment and other
           pollutants from leaving the project site and to protect all exposed earth surfaces from
           erosive forces. Said plan shall adhere to the San Mateo Countywide Stormwater
           Pollution Prevention Program "General Construction and Site Supervision
           Guidelines," including:

           a. 	 Stabilizing all denuded areas and maintaining erosion control measures con­
                tinuously between October 15 and April 15. Stabilizing shall include both
                proactive measures, such as the placement of hay bales or coir netting, and
                passive measures, such as revegetating disturbed areas with plants propagated
                from seed collected in the immediate area.

           b. 	 Storing, handling, and disposing of construction materials and wastes properly, so
                as to prevent their contact with stormwater.
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         c. 	 Controlling and preventing the discharge of all potential pollutants, including
              pavement cutting wastes, paints, concrete, petroleum products, chemicals, wash
              water or sediments, and non-stormwater discharges to storm drains and
              watercourses.

         d. 	 Using sediment controls or filtration to remove sediment when dewatering the site
              and obtaining all necessary permits.

         e. 	 Avoiding cleaning, fueling, or maintaining vehicles on-site, except in a designated
              area where wash water is contained and treated.

         f. 	 Delineating with field markers clearing limits, easements, setbacks, sensitive or
              critical areas, buffer zones, trees and drainage courses.
         g. 	 Protecting adjacent properties and undisturbed areas from construction impacts
              using vegetative buffer strips, sediment barriers or filters, dikes, mulching, or
              other measures as appropriate.

         h. 	 Performing clearing and earth-moving activities only during dry weather.

         1. 	   Limiting and timing applications of pesticides and fertilizers to prevent polluted
                runoff.

         J. 	 Limiting construction access routes and stabilizing designated access points.

         k. 	 Avoiding tracking dirt or other materials off-site; cleaning off-site paved areas
              and sidewalks using dry sweeping methods.

          l. 	 The contractor shall train and provide instructions to all employees and
               subcontractors regarding the construction best management practices.

          Mitigation Measure 4: The applicant shall submit a grading and drainage plan
          (including calculations) to the Planning and Building Department and the Department
          of Public Works prior to the issuance of any project related grading or building per­
          mits. The grading and drainage plan shall include all requirements listed in Grading
          Ordinance Section 8604.1.a.5 (Application Requirements). The drainage plan shall
          also include a narrative describing the type, size, and location of all permanent
          stormwater controls to be utilized in order to ensure compliance with the County's
          Drainage Policy, the San Mateo County Water Pollution Prevention Plan
          (SMCWPPP), and NPDES Provision C.3.

          Mitigation Measure 5: Unless approved in writing and in advance by the
          Community Development Director, no grading shall be allowed during the winter
          season (October 15 to April 15) to avoid potential soil erosion. The applicant shall
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            submit a letter to the Current Planning Section, prior to the issuance of the grading
            hard card, which illustrates the approximate grading schedule, including start and end
            dates.

     c. 	   Will (or could) this project be located in an area of soil instability (subsidence,
            landslide or severe erosion)?

            Yes, Significant Unless Mitigated. Uplift, erosion, and subsequent re-deposition
            of sedimentary rocks within the project region have been driven by the strike-slip
            movement of the tectonic plates (earthquakes) and the associated northeast oriented
            compressional stress. Within the project vicinity, bedrock is the predominant base
            rock and is blanketed by Quaternary sedimentary deposits. Various subunits of the
            Franciscan Complex underlie the surficial soils on the project site; namely Cretaceous
            and Jurassic Greenstone (fg), limestone (ft), sandstone (fs), and lesser amounts of
            melange and serpentine. These units tend to occur in northwest trending bands along
            Cahill Ridge and are overlain in areas by a relatively thin layer of Holocene slope
            wash, ravine fill, and colluvium (Qsr).

            The primary soils in the project vicinity recognized by the United States Department
            of Agriculture (USDA) soil identification system are of the Gazos series. The Gazos
            series consist of gently sloping to very steep upland soils that are well drained to
            somewhat excessively drained. These soils have formed in weathered products of
            semi-hard shales of the Purisma, Chico, and similar formations, and are found in
            the Coast Range at elevations below 1,500 feet below mean sea level, generally in
            ravines and on the sides of valleys. The distribution of the various soil types on the
            project site are depicted in Figure 7.

            Due to the fact that the project site is located on a high ridge, has a lack of shallow
            groundwater, and is underlain by hard bedrock, the potential for liquefaction to occur
            is generally low. However, additional instability of underlying units may be attri­
            buted to differential settlement, soil creep, or the triggering of localized slumps or
            landslides in response to grading at the site. Of particular concern for the proposed
            MLUP are deep fills planned for the new cemetery development and the underlying
            native material that may be subject to differential settlement. Differential settlement
            could adversely affect the foundations of the burial structures or underground utilities.
            This impact is considered potentially significant prior to mitigation. However, the
            implementation of Mitigation Measure 1 (discussed in Item 1.b above) and Mitigation
            Measures 6 and 7 (listed below) would reduce the impacts of development on poten­
            tially unstable geologic or soil units in the Phase 1 area to a less than significant level.

            Mitigation Measure 6: Any fills used at the project site shall be properly placed
            with keyways and subsurface drainage, and adequately compacted following the
            recommendations of the final geotechnical report and geotechnical engineer, in order
ANSWERS TO QUESTIONS
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            to significantly reduce fill sediment. Underground utilities shall be designed and
            constructed using flexible connection points to allow for differential settlement.

            Mitigation Measure 7: Foundation plans shall be submitted to the Planning and
            Building Department for review prior to issuance of building permits. All foundation
            excavations shall be observed during construction by the geotechnical engineer to
            ensure that subsurface conditions encountered are as anticipated. As-built docu­
            mentation shall also be submitted to the Planning and Building Department.

     d. 	 WilJ (or could) this project be located on, or adjacent to a known earthquake
          fault?

            Yes, Not Significant. The project site is located on the northwest trending ridgeline
            on the San Francisco Peninsula in the northern portion of the Santa Cruz Mountains.
            The San Francisco Peninsula is a relatively narrow geographic land feature that has
            been developed on a basement oftectonically mixed Cretaceous- and Jurassic-age
            (70 to 200 million years old) rocks of the Franciscan Complex. The San Andreas
            Fault is the dominant feature in this system, nearly spanning the length of California,
            and capable of generating large earthquakes. Many sub-parallel or branch faults
            within the San Andreas system are equally active. One such sub-parallel branch,
            the Pilarcitos is a potentially active fault that is mapped as transecting the project
            site in the form of several branch surface terraces. Figure 3 shows the approximate
            location of the Pilarcitos fault. In accordance with generally accepted standards of
            practice for "potentially active faults," a 25-foot setback for non-habitable structures
            is typically established. As a guide in the master plan concept, the project applicant
            has established no-build zones based on a 25-foot setback along each of the mapped
            surface traces of the Pilarcitos fault extending through the site. Site-specific studies
            would be appropriate (depending on the nature of the proposed construction) to
            confirm the presence and actual location of any surface terrace of the Pilarcitos fault
            within the new cemetery land use areas. The new maintenance shed that is proposed
            to be constructed as part of Phase 1 is more than 1,000 feet from the fault line.

            There is a high probability that the project site will be subject to violent ground
            shaking from an earthquake during the life of the proposed MLUP. However, the
            proposed ML UP would not result in any permanent residents on the site, nor would
            it construct new buildings that would house new employees, Therefore, impacts
            associated with strong seismic shaking would not be significant.

     e. 	   Will (or could) this project involve Class I or Class II Agriculture Soils and
            Class III Soils rated good or very good for artichokes or Brussels sprouts?

            No. Class I and Class II soils consist of a wide variety of soils that may be used to
            cultivate crops. The soils are nearly level, deep, well drained, and easily worked.
ANSWERS TO QUESTIONS
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              The soils present on the project site generally consist of erosive silty loams on
              moderate to steep slopes, and are rated by the National Resource Conservation
              Service as Class III through VII Agricultural Soils. The project site consists of
              soils with limitations that make them generally unsuitable for cultivation. I Therefore,
              the soils on the project site are not considered good for artichokes or Brussels sprouts,
              or any other crop cultivation, and no impact would occur as a result of project
              implementation.

        f.    Will (or could) this project cause erosion or siltation?

              Yes, Significant Unless Mitigated. The majority of the existing cemetery land uses
              on the project site have a defined drainage system comprised of overland collection,
              piping and point release. Rainwater and irrigation runoff also flow along the natural
              topography of the project site, eventually infiltrating into the soils andlor draining
              directly into the natural drainage channels that lead to Pilarcitos Creek. There are two
              areas on the project site that have defined drainage systems. The first is a detention
              system adjacent to the funeral home and reception building. Rainwater and irrigation
              runoff in the area of the funeral home and reception building is directed into a dry
              pond detention basin. Any sediment andlor larger pollutant particles settle to the
              bottom of the basin before the collected water is released into the drainage channels
              and seasonal tributaries of Pilarcitos Creek. The rate of release is set to mimic the
              pre-development storm water runoff flow rate. The second area on the project site
              with a defined drainage system is along the furthest reaching cul-de-sac on the
              northwestern boundary of the existing cemetery land uses. Vegetated bioswales
              (drainage ditches) line either side of the roadway. Stormwater runoff from the
              roadway is collected into the bioswales. Like the detention system, larger particles
              and pollutants are naturally filtered out by the vegetation before the water infiltrates
              the soils andlor is released directly into natural drainage channels.

              During construction, site grading activities could disturb and expose soils that could
              become mobilized by stormwaters. This could lead to an increase in sediment load
              and deposition in Pilarcitos Creek and its associated tributaries that cross the project
              site. The USDA soil survey for San Mateo County identifies soils on the project site
              as moderate to highly susceptible to erosion. According to the National Pollutant
              Discharge Elimination System (NPDES) permit, all construction projects that involve
              the disturbance of more than 1 acre must prepare and implement a Stormwater Pollu­
              tion and Prevention Plan (SWPPP). Because each of the development phases of the
              project would involve the clearing and grading of more than 1 acre, the project would
              be subject to the provisions ofthe NPDES permit related to erosion and sedimenta­
              tion prevention during construction.



I   NRCS Web Soil Survey, October 15,2009.
ANSWERS TO QUESTIONS
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           In compliance with the NPDES regulations, Mitigation Measure 8 will require the
           project applicant to file a Notice of Intent (NOI) with the State Water Resources
           Control Board (SWRCB) prior to the start of construction and prepare a SWPPP. The
           SWPPP would include site-specific best management practices to reduce soil erosion.
           The SWPPP would also include locations and specifications of recommended soil
           stabilization techniques, such as placement of straw wattles, silt fence, berms, and
           storm drain inlet protection. The SWPPP would depict staging and mobilization
           areas with access routes to and from the site for heavy equipment. The SWPPP
           would include temporary measures to reduce erosion to be implemented during
           construction, as well as permanent measures.

           County staff will review the SWPPP to ensure adequate compliance with State and
           County standards and will visit the site during grading and construction to ensure
           compliance with the S WPPP, as well as note any violations, which would be cor­
           rected immediately. Consistency with the provisions of the NPDES permit, as
           mandated by the County and S WRCB, would ensure that impacts related to soil
           erosion and sedimentation during project construction would be minimal.

           Mitigation Measure 8: The project applicant shall file a Notice of Intent (NOl) with
           the State Water Resources Control Board (SWRCB) and shall submit proof of filing
           said NOI to the Planning and Building Department prior to beginning any grading or
           construction activities. The applicant and all grading/construction contractors shall
           adhere to all conditions and regulations associated with the State General Con­
           struction Activity NPDES Permit.

           In planning for all phases of the project, the roads and proposed improvements
           have been designed to follow the natural topography of the project site to the extent
           feasible. This approach would minimize any alterations of the natural drainage of the
           project site. Vegetated slope retention systems would be used to transition to existing
           grade to the extent feasible where grade alternations are made by project improve­
           ments. Other proposed stormwater management strategies would be premised on a
           system of "stormwater source controL" This means holding the water as close to
           where it falls as possible, thereby minimizing the need to transport or store large
           quantities of water. These "localized containment systems" would include bioswales
           to capture and allow for controlled infiltration of stormwater, extensive subdrainage
           systems to intercept shallow subsurface flows, oversized stormwater pipes to serve as
           localized "storage basins", and, where appropriate, the creation of new wetlands for
           stormwater absorption. Additionally, pervious pavements would be used on all road­
           ways to allow for a more natural infiltration pattern, which would help reduce the
           need for other treatment measures. The engineering goal is to provide clean water
           to the natural drainage channels at the same rate at which they receive water in the
           current, pre-development state. The County requires post-construction stormwater
           control systems as part of their obligations under Provision C.3 of the Countywide
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             municipal storm water NPDES permit. As such, all project stormwater management
             strategies would be designed in accordance with the County's requirements mandated
             under Provision C.3. Implementation of Mitigation Measures 2 - 5 and 8 would en­
             sure that impacts related to soil erosion and sedimentation during project construction
             or future operation would not be significant

     g. 	    Will (or could) this project result in damage to soil capability or loss of agricul­
             turalland?

             No. 	 The project site is partially developed with existing cemetery land uses and is
             characterized by a rolling landscape with moderate to steep hills. The soil types are
             not suitable to support agriculture as described above under Item I.e. Furthermore,
             the project site is considered "Urban and Built-up Land" and "Grazing Land" by the
             California Department of Conservation Farmland Mapping and Monitoring Program
             (FMMP). 2 Grazing land classification is described as "land on which the existing
             vegetation is suited to the grazing of livestock". FMMP land classifications that
             surround the project site are "Grazing" and "Other" (non-agricultural) land.
             Therefore, no impact would occur.

     h. 	 Will (or could) this project be located within a flood hazard area?

             No. According to the Flood Insurance Rate Maps (FIRM) produced by the Federal
             Emergency Management Agency (FEMA), the project site is not located in a flood
             hazard zone, and is not in an area that may be inundated by a IOO-year flood.
             Therefore, project implementation would not place people or structures within a
             flood zone?

      i. 	   Will (or could) this project be located in an area where a high water table may
             adversely affect land use?

             No. Although localized springing of groundwater occurs at some points within the
             project area, based on a review of historical aerial photos, the geologic mapping and
             reconnaissance of the project site, these occurrences appear to be the result of focused
             seepage in closely spaced fractures within the Franciscan Complex sandstone. The
             project site, located on a high ridge underlain at shallow depths by hard bedrock, is
             not located in an area known to have a shallow ground water table. Furthermore, the
             Gazos soil series mapped at the site is characterized as having no known occurrences
             of high groundwater. Water wells on Cahill Ridge typically draw water from hun­
             dreds of feet below the ground surface. The new cemetery land uses would therefore
             not be located in an area where a high water table could adversely affect the land use.

2 California Department of Conservation Farmland Mapping and Monitoring Program, San Mateo County Important
  Farmland 2008, May 2009.
3 San Mateo County Flood Zones Map, 2005. FEMA Firmette
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       j. 	   Will (or could) this project affect a natural drainage channel or streambed, or
              watercourse?

              Yes, Significant Unless Mitigated. The grading operations and the introduction
              of small areas of impervious surfaces have the potential to change the quantity and
              velocity of stormwater runoff both within the project site and further downslope. If
              the project were undertaken without appropriate mitigation measures, these changes
              to the physical landscape could adversely affect Pilarcitos Creek and its tributaries
              (and potentially other water bodies further downstream; see Figure 13). However, as
              discussed above in Items l.b and 1.f, the implementation of Mitigation Measures 2 - 5
              and 8 will reduce those potential impacts to a less than significant level, both during
              construction and throughout the day-to-day operations of the Skylawn facility.

2. 	   VEGETATION AND WILDLIFE

       a. 	   Will (or could) this project affect federal or state listed rare or endangered
              species of plant life in the project area?

              Yes, Significant Unless Mitigated. The Biological Resources Constraints and
              Opportunities Evaluation (Pacific Biology 2008) prepared for the project site
              provides a detailed discussion of the biological resources present and potential
              impacts to sensitive biological resources resulting from the implementation of the
              proposed MLUP. This report is included in its entirety in Appendix B, and the
              relevant discussions are summarized and incorporated into the analysis below.
              Biological evaluations and field surveys conducted as part of the analysis include:
              (1) A review of the California Natural Diversity Database (CNDD) and the
              California Native Plant Society (CNPS) Online Inventory of Rare and Endangered
              Plants; (2) reconnaissance-level field surveys and plant community mapping con­
              ducted by Pacific Biology on May 11 and 21, and June 16, 2009; and (3) rare plant
              surveys and botanical inventory conducted by Vollmar Consulting on May 8, 11, and
              21, 2009 and June 26, 2009.

              The project site is located in an area with very sparse existing development. With
              the exception of the existing developed cemetery uses, the site and immediately sur­
              rounding areas are undeveloped. The proposed MLUP would develop portions of
              the site along a ridgeline and bordering areas. Albert Canyon Creek (a tributary to
              Pilarcitos Creek) crosses the southern portion of the Skylawn property, and the
              southern portion of the property appears to drain to this creek. An unnamed tributary
              of Pilarcitos Creek traverses the western portion of the site and the western portion of
              the site drains to this tributary. A third unnamed drainage channel is located in the
              far southern portion of the site, near the cemetery entrance from Highway 92. The
              locations of these creeks are shown in Figure 8. All three of the creeks are located
              outside of areas that would be directly affected by the proposed MLUP. A series of
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
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         seasonal drainages also occur to the east of the site. These drainages cross the land
         managed by the San Francisco Public Utility Commission and drain to Crystal
         Springs Reservoir (Figure 8).

         The Skylawn property contains six distinct plant communities, including coastal
         scrub, annual grassland, purple needlegrass grassland, wetlands, willow riparian
         woodland, and Douglas fir woodland. Coastal scrub and annual grassland are the
         predominant plant communities on the site. Coastal scrub generally occurs on the
         slopes of the site as well as in scattered locations in the flatter areas of the northern
         portion of the site. Annual grasslands occur in the northern, central, and western
         portion of the project site. These grasslands areas are dominated by non-native,
         annual grass species and weedy vegetation. There are relatively large clusters of
         native grasslands (i.e., purple needlegrass grassland) in the northern portion of the
         site, as well as several smaller pockets scattered throughout the area. These native
         grasslands are dominated by purple needlegrass (Nassella pulchra) and occur in areas
         with thinner soils. Areas containing wetland-associated vegetation such as seeps,
         seasonal/perennial wetlands, and willow riparian woodlands are scattered throughout
         the site. Douglas fir woodland occurs in the far northern portion of the project site.
         These plant communities are described in further detail in Appendix B and their
         locations are shown in Figure 8.

         As shown in Figure 8, the Phase 1 area primarily consists of non-native annual grass­
         lands, with a large portion ofthese grasslands having a very high density of Italian
         thistle (Carduus pycnocephalus) and other weedy species. Only a small area of coastal
         scrub habitat occurs in the Phase 1 area, while larger areas of this habitat type occur
         within the associated Land Water Management Zones. A seasonal wetland occurs in
         the central portion of the Phase 1 area. Wetland associated plant species in this wet­
         land include rush (Juncus sp.), poison hemlock (Conium maculatum), and rabbitsfoot
         grass (Polypogon monspeliensis). Another wetland area extends into the southwest
         portion ofthe Phase 1 area, which contains rush, stinging nettle (Urtica dioica ssp.
         h%sericea), poison hemlock, and horsetail (Equisetum sp.). Immediately downslope
         of this second wetland there is a willow riparian woodland associated with a natural
         drainage. The willow woodland continues downslope to the west, crossing the Land
         Water Management Zone and enters the Environmental Protection Zone. A seasonal
         wetland also borders the northwest portion of the Phase 1 area.

          As shown in Appendix B, Figure 3B, numerous special-status plant species have been
          documented in the project area. The vast majority of these species are associated
          with serpentine or volcanic soils, which do not occur on the project site. However,
          areas containing potential habitat for special-status plant species are present in
          portions of the project site. In particular, the native grasslands, rocky areas, and
          openings within and along the outer margins of coastal scrub, provide habitat
          conditions potentially suitable for rare plants.
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           No special-status plant species were observed during the focused surveys conducted
           by Vollmar Consulting in 2009. The project site was surveyed for special-status
           plants as thoroughly as possible during two survey efforts conducted in early to mid
           May and late June. However, there are several plant taxa that would have been
           difficult to observe outside their blooming periods, such that in the absence of
           conducting early spring surveys, the presence ofthese plants on the site cannot be
           ruled out from the entire project site. These species include Montara manzanita
           (Arctostaphylos montaraensis), which blooms between January and March, western
           leatherwood (Dirca occidentalis), which blooms between January and March and
           occasionally until April, and fragrant fritillary (Fritillaria liliacea), which blooms
           between February and April. The remnant fruits of fragrant fritillary should have
           been observable during the May surveys, at least within more open habitats. Early
           blooming special-status plant taxa associated with coastal scrub habitat (e.g., western
           leatherwood) would have been particularly challenging to observe without flowers
           given that not all coastal scrub areas were accessible. The Skylawn Memorial Park
           2009 Sensitive Botanical Resources Survey Report (Vollmar Consulting, 2009) is
           included in its entirety in Appendix B and provides further details on the rare plant
           survey methodology and findings.

           Based on the 2009 survey results, it is not expected that special-status plant species
           are currently present in the Phase 1 area. This is based on: (1) the negative survey
           results; (2) that only the outer edge of coastal scrub habitat extends into the Phase 1
           area and this area was accessible and surveyed; and (3) most of the area has been
           subject to large historic disturbances as evidenced by the very high density of weedy
           species within the annual grasslands. However, rare plant survey results are generally
           only considered valid by the scientific community and natural resources agencies for
           up to three years as conditions on a project site can change. Additional rare plant
           surveys would be required for Phase 1 construction activities commencing after 2012
           to demonstrate that rare plant species are not present at that time. Therefore, in the
           absence of updated rare plant surveys, Phase 1 construction activities commencing
           after 2012 could result in the loss ofrare plant species. The loss ofrare plant species
           would be considered to be a significant impact. The implementation of Mitigation
           Measures 9 and 10 will reduce that risk to a less than significant level.

           Miti2ation Measure 9: An updated rare plant survey shall be conducted by a quali­
           fied botanist prior to any construction activities commencing after the spring of 2012.
           Should any rare plant species be identified, these populations should be avoided to the
           extent practical. Ifremoval of special-status plant species is required, transplanting
           to a suitable location in the Environmental Protection Zone will be considered as
           the first option. Given that the rare plant species of primary concern are evergreen
           shrubs or lilies, transplanting should be feasible. Prior to the transplanting of any
           rare plant species, a plant relocation plan shall be developed by a qualified botanist.
           At a minimum, the plan shall demonstrate the feasibility of replacing the number of
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          individual plants to be removed at a 1: 1 ratio. The plan shall, at minimum, specify
          the following: (l) the location of mitigation sites in the Environmental Protection
          Zone or other suitable locations; (2) methods for harvesting seeds and salvaging
          and transplantation of individual bulbs/plants to be impacted; (3) site preparation
          procedures for the mitigation site; (4) a schedule and action plan to maintain and
          monitor the mitigation area; (5) a list of criteria and performance standards by which
          to measure success of the mitigation site(s); (6) measures to exclude unauthorized
          entry into the mitigation areas; and (7) contingency measures in the event that
          mitigation efforts are not successful. The plan shall be subject to the approval of
          the Planning and Building Department prior to the removal of any special-status
          plant species.

          Mitigation Measure 10: Prior to any grading or construction activities within or
          adjacent to the Land and Water Management Zones, a qualified botanist shall conduct
          a survey of the immediate work areas to determine whether any rare plant species are
          present. If any such species are identified, the botanist shall consult with Planning
          and Building Department staff to determine how to proceed. No grading or con­
          struction activities shall occur in the area until the botanist and County staff have
          agreed on an appropriate course of action that will minimize adverse impacts to
          special-status plant species in the area.

     h.   Will (or could) this project involve cutting of heritage or significant trees as
          defined in the County Heritage Tree and Significant Tree Ordinance?

          Yes, Significant Unless Mitigated. Based on the information contained in the Bio­
          logical Constraints and Opportunities Report (Appendix B) and site visits conducted
          by staffto the Phase 1 project area, it is unlikely that any significant or heritage trees
          will be proposed for removal during project implementation. However, in order to
          ensure that no such trees will be harmed or removed during grading and construction
          activities, Mitigation Measure 11 will be implemented to reduce the risk to a less than
          significant level.

          Mitigation Measure 11: Prior to the commencement of construction activities, a
          tree survey shall be conducted by a qualified arborist indicating all the trees that could
          be removed or otherwise harmed during Phase 1 construction. At a minimum, the
          survey shall identify the size (diameter at breast height), species, and condition of
          the trees. The survey shall also identify which ofthese trees are considered protected,
          significant, or heritage trees. If any such trees are identified by the arborist within
          Phase 1 project areas, the project applicant shall implement tree protection measures
          to insure said trees are not damaged during construction. These measures may in­
          clude protective fencing, prohibiting construction/grading activities within the
          dripline of trees to be preserved, or other appropriate measures approved by the
          Planning and Building Department.
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     c. 	   Will (or could) this project be adjacent to or include a habitat food source, water
            source, nesting place or breeding place for a federal or state listed rare or endan­
            gered wildlife species?

            Yes, Significant Unless Mitigated. The latest version of the CNDDB was reviewed
            to identify documented occurrences of special-status wildlife species within 5 miles
            of the project site. Based on the CNDDB, the following special-status wildlife
            species have been documented within 5 miles of the property: California red-legged
            frog, San Francisco garter snake, steel head, bay checkerspot butterfly, mission blue
            butterfly, monarch butterfly, Myrtle's silverspot, San Francisco lacewing, Edgewood
            blind harvestman, San Francisco dusky-footed woodrat, hoary bat, western pond
            turtle, saltmarsh common yellow throat, and Alameda song sparrow. These species
            are further discussed below and their locations relative to the project site are shown in
            Appendix B, Figure 3A. Additional information about these species is contained in
            Appendix B.

            California Red-legged Frog. The California red-legged frog (Rana draytonii) is
            a federally listed threatened species and a California Species of Special Concern.
            Breeding adults are often associated with deep (greater than 2 feet) still or slow
            moving water and dense, shrubby riparian or emergent vegetation, but frogs have
            been observed in shallow sections of streams and ponds that are devoid of vegetative
            cover. This semi-aquatic species also utilizes non-aquatic habitats for refuge and
            dispersal. It rests and feeds in riparian vegetation and the moisture and cover of
            the riparian zone may facilitate dispersaL During periods when water is absent,
            California red-legged frogs may take refuge in moist areas within riparian habitats
            and small mammal burrows in surrounding upland areas.

            As shown in Appendix B, Figure 3B, California red-legged frogs have been
            documented in several locations near the Skylawn property. The closest of these
            locations (CNDDB Occurrence #243) is from the portion of Albert Canyon Creek
            immediately to the south ofthe Skylawn property boundary. According to the
            CNDDB, an adult frog was identified at this location in 1997 and the occurrence
            was described as "random wandering by an adult frog in an attempt to colonize a
            new site." The CNDDB also reports that one juvenile and three adult California
            red-legged frogs were observed at this location in September 2007. Other nearby
            occurrences of California red-legged frogs have been documented from a pond in
            Pilarcitos Creek (approximately 1.1 mile north of the Skylawn property), and from
            Sky Line Quarry (approximately 0.6 mile east ofthe Skylawn property).

            Potential breeding habitat for California red-legged frog on the Skylawn property
            is limited to Albert Canyon Creek (in the far southern portion of the property), the
            unnamed tributary to Pilarcitos Creek (in the western portion of property), and the
            unnamed drainage along the southeastern portion of the property. These creeks are
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           all located outside of areas that would be directly affected by the implementation of
           the proposed MLUP. Large portions of these creeks contain dense vegetation, and do
           not appear to contain deep, open water habitats generally associated with California
           red-legged frog breeding sites. However, the drainages were not fully explored due
           to access issues (e.g., dense poison oak), the general nature of the field surveys, and
           because all three of the tributaries are outside of areas proposed for development.
           Therefore, it is assumed that suitable breeding habitat for California red-legged frog
           occurs within these three creeks.

           The wetlands, seeps, and aquatic habitats within and bordering the future develop­
           ment areas do not provide suitable California red-legged frog breeding habitat. The
           seeps and wetlands do not contain more than several inches of standing water, and
           therefore, do not contain water of adequate depth to support California red-legged
           frog breeding and tadpole development. The existing on-site reservoir contains deep
           water, but it does not provide suitable breeding habitat as it is lined with tarps and
           does not contain emergent vegetation or other suitable substrate for egg mass attach­
           ment. However, the future cemetery development areas contain potential California
           red-legged frog dispersal and refuge habitat. California red-legged frogs are known
           from nearby areas including Pilarcitos Creek and Albert Canyon Creek. Therefore, it
           is assumed that California red-legged frogs use the tributaries of Pilarcitos Creek,
           including the on-site portions of Albert Canyon Creek, the unnamed tributary to
           Pilarcitos Creek (western portion of the property), and the unnamed drainage along
           the southeastern portion of the property, for movement, dispersal, and!or refuge.
           The species could leave the riparian zone of these tributaries and disperse across or
           temporarily occur within the upland portions of the future cemetery development
           areas, including Phase I development areas. It is also possible that individual frogs
           could disperse across the land managed by the San Francisco Public Utility Com­
           mission (to the east of the property) and temporarily occur in upland portions ofthe
           property while moving toward the drainages to the west and south of the Skylawn
           property. Additionally, the year-round moisture provided by the seeps, wetlands,
           and riparian woodlands within and bordering the future cemetery development areas
           could attract California red-legged frogs (especially during dry periods) and provide
           refuge habitat for the species.

           California red-legged frogs are potentially present within Albert Canyon Creek
           (southern portion of the property), the unnamed tributary to Pilarcitos Creek (western
           portion of the property), and the unnamed drainage along the southeastern portion of
           the property. These drainages would not be directly affected by development of
           Phase 1 of the proposed MLUP. However, if uncontrolled, associated development
           activities could degrade the quality of surface runoff from the Sky lawn property that
           enters these drainages, which could adversely affect the quality of the habitat and
           individual California red-legged frogs. Of primary concern would be runoff into the
ANSWERS TO QUESTIONS
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          unnamed tributary to Pilarcitos Creek, which is generally located downslope of the
          Phase I development area.

          California red-legged frogs could also potentially disperse from the on-site drainages,
          or drainages on the San Francisco Public Utility Commission land, onto upland
          portions of the Phase 1 area. The possibility of this would be the highest during
          and immediately following rain when the species is more likely to disperse across
          upland habitats, but not necessarily limited to these periods. Additionally, as
          shown in Figure 8, two wetlands are located within the Phase 1 area and another
          is located adjacent to it. A willow woodland also extends into the Phase I Water
          Management Zone. These wetland and riparian areas could provide refuge (non­
          breeding) habitat for individual frogs. In the event that California red-legged frogs
          are present during construction activities, individual frogs could be harmed. The loss
          or harm of any California red-legged frogs would be a significant impact. Mitigation
          Measures 12 - 14 will reduce these risks to a less than significant level.

          Mitigation Measure 12: Prior to initial vegetation removal and/or grading activities
          in the upland portions of the construction zone, pre-construction clearance surveys
          shall be conducted for California red-legged frog and San Francisco garter snake by a
          qualified biologist. Should either species be identified, construction activities shall be
          immediately halted until the frog (or snake) leaves the construction zone on its own,
          or is removed by a qualified biologist in possession of an appropriate permit and
          authorized by the USFWS. The USFWS shall be immediately notified if either
          species is observed.

          Mitigation Measure 13: Prior to the commencement of construction activities with­
          in 50 feet of a wetland or riparian woodland, a pre-construction clearance survey of
          the area shall be conducted by a qualified biologist for California red-legged frogs
          and San Francisco garter snake. Should either species be identified, construction
          activities should be halted until the animal leaves the construction zone on its own, or
          is removed by a qualified biologist in possession of an appropriate permit and author­
          ized by the USFWS. Ifit is determined that no red-legged frogs or garter snakes are
          present, temporary exclusionary fencing shall then be installed around the perimeter
          of the wetland/riparian woodland and adjacent construction areas. The fencing shall
          be maintained throughout the duration of construction activities near the wetland/
          riparian area. The adequacy of the fencing to prevent frogs and snakes from entering
          the construction zone shall be approved by a qualified biologist prior to the com­
          mencement of construction activities and shall be inspected daily to ensure it
          continues to operate effectively.

          Mitigation Measure 14: In order to prevent the accidental removal of wetland habi­
          tat (and potentially damaging habitat of an endangered wildlife species), a qualified
          biologist shall determine and mark in the field the extent of all wetland areas in and
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         adjacent to Phase 1 development zones. Any grading or construction activities within
         50 feet of any wetland habitat shall be referred to and reviewed by United Stated Fish
         and Wildlife Service (USFWS) prior to commencement of any construction activities.
         Prior to any disturbance within 50 feet of wetland habitats, proof of consultation
         with and approval by USFWS shall be submitted to the Planning and Building
         Department.

         San Francisco Garter Snake. The San Francisco garter snake (Thamnophis sirtalis
         tetrataenia) is a federally and state listed endangered species, and a California Fully
         Protected Species. This subspecies is only known to occur in San Mateo County
         and extreme northern Santa Cruz County. The subspecies most often occurs in the
         vicinity of standing water, chiefly including ponds, lakes, marshes, and sloughs.
         The species has also been observed in the vicinity of slow-moving streams. Within
         these habitats, it prefers dense cover and water depths of at least I-foot (CNDDB).
         Emergent and bank-side vegetation such as cattails (Typha spp.), bulrushes (Scirpus
         spp.), and spike rushes (Juncus spp.) apparently are preferred and used for cover.
         Observations suggests that upland sites such as grassy hillsides near drainages and
         ponds are used for basking, rodent burrows away from standing water for shelter
         and escape, and low lying marsh areas for feeding and reproduction. The principal
         prey of the San Francisco garter snake are California red-legged frogs, but also may
         include Pacific tree frog (Hyla regilla), immature California newts (Taricha torosa),
         and recently metamorphosed western toad (Bufo boreas) (USFWS 1985).

         As shown in Appendix B, Figure 3A, the two closest documented occurrences of
         San Francisco garter snake are from approximately 3 miles to the north and 3 miles
         to the east of the site. The precise location of these occurrences is not provided by
         the CNDDB due to the sensitivity of the subspecies, but they appear to be from near
         the far northern and southern ends of Crystal Springs Reservoir. The occurrence to
         the north (CNDDB Occurrence #10) was documented in 1987 from an "old reservoir
         with lots of floating aquatic vegetation and good shore cover." The occurrence to the
         east (CNDDB Occurrence #2) was last documented in 2004 from a "marsh area along
         a reservoir edge." The Recovery Plan for San Francisco garter snake (USFWS 1985)
         reports that San Francisco garter snake occurs near the Crystal Springs Reservoir
         (which at its closest point is less than I-mile from the project site).

          The project site does not contain the preferred habitat of the San Francisco garter
          snake, as freshwaters marshes, ponds, lakes, and sloughs are not present. How~ver,
          potential aquatic habitat for the subspecies is present on and bordering the project site
          in Albert Canyon Creek, the unnamed tributary to Pilarcitos Creek, and the unnamed
          drainage along the southeastern portion of the site. These creeks are all located out­
          side of areas that would be directly affected by the implementation of the proposed
          MLUP. Albert Canyon Creek and the unnamed tributary to Pilarcitos Creek are
          separated from portions of the property where future development would occur by
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         steep slopes and dense coastal scrub habitat. The unnamed drainage along the south­
         eastern portion of the site is separated from the future development areas by a road
         and developed cemetery uses. These drainages contain dense vegetation within and
         bordering large portions of the channel, which may limit their suitability for San
         Francisco garter snake. Also, there are also not grassy areas adjacent to the on-site
         portions of these drainages that provide typical basking habitat.

         In the event that San Francisco garter snake was to occur in one of the creeks, it
         could occur on the project site while moving across coastal scrub habitat to access
         grasslands or while dispersing (potentially toward Crystal Springs Reservoir). San
         Francisco garter snake could also be attracted to the seeps, wetlands, and riparian
         areas on the site. However, the steep slopes and dense scrub vegetation that separates
         the drainages from the portions of the property where future development would
         occur limits (but does not preclude) the potential of the subspecies from temporarily
         occurring in these areas. Given the known occurrence of San Francisco garter snake
         at Crystal Springs Reservoir, it is also possible that individual snakes could disperse
         across the land managed by the San Francisco Public Utility Commission and tempo­
         rarily occur in the future development areas while moving toward the drainages to the
         west and south of the project site.

         San Francisco garter snake is potentially present within Albert Canyon Creek
         (southern portion of the property), the unnamed tributary to Pilarcitos Creek (western
         portion of the property), and the unnamed drainage along the southeastern portion of
         the property. These drainages would not be directly affected by development of
         Phase 1 of the proposed MLUP. However, if uncontrolled, associated development
         activities could degrade the quantity and quality of surface runoff from the Skylawn
         property that enters these drainages, which could then adversely affect the quality of
         the habitat and individual garter snakes. Of primary concern would be runoff into the
         unnamed tributary to Pilaricitos Creek, which is generally located downslope of the
         Phase 1 development area.

         San Francisco garter snake could also potentially disperse from the on-site drainages
         or drainages on the San Francisco Public Utility Commission land onto upland
         portions of the Phase 1 area. Additionally, the wetland and riparian areas located
         within and adjacent to the Phase 1 area could attract individual garter snakes. In
         the event that a San Francisco garter snake is present during construction activities,
         individual snakes could be harmed. The loss or harm to any San Francisco garter
         snake would be considered to be a significant impact. Mitigation Measures 2 - 5
         and 8, above, would be implemented to control surface water runoff and to maintain
         the current water quality and quantity entering the nearby drainages. Mitigation
         Measures 12-14, above, would be implemented to address the potential occurrence
         of San Francisco garter snake within upland and wetland/riparian areas. Mitigation
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         Measure 15, below, will also be implemented to reduce impacts to a less than
         significant level.

          Mitigation Measure 15: The San Francisco garter snake is a California Fully
          Protected Species, which means that the California Department of Fish and Game
          (CDFG) cannot authorize the take of the species and needs to ensure the adequacy of
          the avoidance measures to be implemented. Therefore, the CDFG shall be consulted
          prior to the implementation of construction activities and any further recommended
          avoidance measures shall be implemented. Prior to any disturbance within 50 feet
          of wetland habitats, proof of consultation with and approval by CDFG shall be sub­
        . mitted to the Planning and Building Department.

         Steelhead. Steelhead (Oncorhyncus mykiss) that are part of the Central California
         Coast Evolutionarily Significant Unit (ESU) are federally listed as threatened.
         Steelhead are the anadromous form of O. mykiss. O. mykiss have a highly flexible
         life history and may follow a variety of life history patterns including freshwater
         residents (non-migratory) at one extreme and individuals that migrate to the open
         ocean (anadromous) at another extreme. Intermediate life history patterns include
         fish that migrate within the stream (potamodromous), fish that migrate only as far
         as estuarine habitat, and fish that migrate to near-shore ocean areas.

         Based on the CNDDB, the closest documented occurrence of steelhead is
         approximately 2 miles to the west of the project site. This occurrence (CNDDB
         Occurrence #3) is from Apanolio Creek, which is a tributary of Pilarcitos Creek.
         Potential habitat for steelhead is present on and bordering the project site within
         Albert Canyon Creek and the unnamed tributary to Pilarcitos Creek. Both of
         these creeks have a hydrologic connection to Pilarcitos Creek and steelhead could
         be present. An evaluation of the suitability of these creeks for steelhead was not
         conducted given that the creeks would not be directly impacted by the development
         that would be allowed by the MLUP.

         The creeks on and bordering the project site would not be directly affected by the
         development that would be allowed by the MLUP. However, the future cemetery
         uses associated with the development of Phase 1 could degrade the quality of surface
         runoff from the project site that enters the drainages on and bordering the site.
         This could adversely affect the quality of the aquatic/riparian habitat and its use
         by steelhead, which would be considered to be a significant impact. Mitigation
         Measures 2 - 5 and 8, above, would be implemented to control surface water runoff
         and to maintain the current water quality and quantity entering the nearby drainages.
         No additional mitigation is necessary.

         Bay Checkerspot Butterfly. The bay checkerspot butterfly (Euphydryas editha
         bayensis) is a federally listed threatened species. Typical habitat of the bay
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         checkerspot butterfly occurs on shallow, serpentine derived or similar soils,
         which support the butterfly's larval food plants as well as nectar sources for adults.
         The primary larval host plant of the bay checkerspot butterfly is dwarf plantain
         (Plantago erecta). In many years, bay checkerspot larvae require a secondary host
         plant species, when the plantain dries up while larvae are still feeding. Under these
         conditions, the larvae move onto purple owl's clover (Castilleja densiflora) or
         exserted paintbrush (Castilleja exserta), which remain edible later in the season than
         dwarf plantain. Optimal habitat contains substantial densities of Plantago erecta,
         plus at least one of the secondary larval host plant species and nectar plants for adults.
         Plant species commonly visited for nectar include desert parsley (Lomatium spp.),
         California goldfields (Lasthenia californica), and tidy tips (Layla platyglossa). The
         butterfly is usually associated with populations of Plantago erecta in grasslands on
         serpentine soils. However, the species is not restricted to serpentine soils and has
         been found in native grasslands in non-serpentine soils that contain Plantago erecta
         and adult nectar sources.

         As shown in Appendix B, Figure 3A, bay checkerspot butterfly have been docu­
         mented at two locations approximately 2 miles to the east of the project site. Based
         on the CNDDB, one of these occurrences (CNDDB Occurrence #3) was extirpated in
         1977 due to the construction ofI-280 and severe drought. The other occurrence
         (CNDDB Occurrence #6) is associated with serpentine grasslands at Crystal Springs
         Reservoir. This population was believed extirpated after the construction ofI-280,
         but a remnant colony was discovered north of the original colony location. Accord­
         ing to the CNDDB, the current status of this population is unknown and no bay
         checkerspot butterflies were observed at the location between 1989 and 1993. The
         CNDDB indicates that this colony is "potentially extirpated." Based on the CNDDB,
         the only known surviving bay checkerspot butterfly colony in San Mateo County is
         from Edgewood County Park. This occurrence (CNDDB Occurrence #16) is located
         approximately 5 miles to the southeast of the project site.

         Some of the larger native grassland areas on the Skylawn property provide potentially
         suitable habitat for bay checkerspot butterfly (see Appendix B, Figure 4), but they
         contain some factors that detract from their potential suitability. These native
         grasslands contain several characteristics associated with bay checkerspot butterfly
         colonies, including a high density of native grasses, and the primary and secondary
         larval host plants of the species. However, the native grasslands on the project site do
         not appear to be on serpentine soils, which are typically associated with persistent bay
         checkerspot butterfly colonies. No evidence of serpentine soils is observable on-site
         and no serpentine soils have been mapped on or bordering the site. The closest
         mapped occurrences of serpentine soils are from Crystal Springs Reservoir and are
         associated with the San Andreas Rift Zone. Flowering plants are present within and
         bordering the native grasslands, but the most common adult nectar plants of bay
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           checkerspot butterfly were not observed in or near the native grasslands during
           botanical surveys conducted in 2009.

           Given the absence of serpentine soils, the on-site native grasslands could provide
           "tertiary" habitat for bay checkerspot butterfly as described by the USFWS. Tertiary
           habitat areas contain both larval food plants and occur on soils not derived from
           serpentine, but which have similarities to serpentine-derived soils. All known tertiary
           habitat areas have been located in areas mapped geologically as Franciscan formation
           (such as those on the project site), and tertiary habitat has not historically supported
           dense or persistent populations of bay checkerspot butterfly.

           As shown in Appendix B, Figure 4, there are two relatively small stands of purple
           needlegrass grassland in the Phase 1 area. One of these grasslands contains the larval
           host plant ofthe bay checkerspot butterfly. This grassland provides potential, but
           marginal habitat for bay checkerspot butterfly given its small size and that it is
           relatively isolated from other areas of potential habitat for the species. This native
           grassland is located completely within the Land and Water Management Zone. The
           second native grassland area, which is also small, does not contain the larval host
           plants of the bay checkerspot butterfly and does not provide suitable habitat for the
           species. While the potential for bay checkerspot butterfly to use the one grassland
           containing the host plants is considered to be relatively low, a focused survey has not
           been conducted. Should activities within the Land and Water Management Zone
           disturb the native grassland in question, there could be a loss of bay checkerspot
           butterfly and habitat used by the species. Therefore, potential impacts to bay
           checkerspot butterfly from the implementation of Phase 1 of the proposed MLUP
           are potentially significant. The implementation of Mitigation Measure 16 will
           reduce these potential impacts to a less than significant level.

           Mitigation Measure 16: The outer limits of the stand of native grassland located
           within the Land and Water Management Zone adjacent to Phase 1 development area
           shall be identified by a qualified biologist and marked with wooden .stakes or other
           equivalent markers. Land management activities shall not be allowed within the
           identified area, unless the timing and nature of the activity is found to not pose a
           threat to bay checkerspot butterfly by a qualified biologist.

           San Francisco Dusky-footed Woodrat. The San Francisco dusky-footed woodrat
           (Neotomafuscipes annectens) is a California Species of Special Concern. The
           dusky-footed woodrat (N. fuscipes) is fairly common and widespread throughout
           the Coast Range and the northern interior of California. The subspecies, the San
           Francisco dusky-footed woodrat, is believed to be restricted to the San Francisco Bay
           Area. Dusky-footed woodrats are highly arboreal (Kelly 1990). Evergreen or live
           oaks and other thick-leaved trees and shrubs are important habitat components for this
           species (Kelly 1990, Williams et. al. 1992). Woodrats build nests (i.e., stickhouses),
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         which are often the result of work by several generations of woodrats, by piling up
         sticks, rocks, and other available material. This woodrat is semi-colonial and often
         lives with others in the same area. The breeding period for the dusky-footed woodrat
         is generally in the spring, but potentially extends through July. Several woodrat nests
         were incidentally observed in the coastal scrub habitats on the project site during
         various surveys (see Appendix B, Figure 4). Additionally, the CNDDB contains an
         occurrence ofa woodrat nest to the southwest of the property boundary. Given these
         occurrences, it is assumed that numerous other woodrat nests are present within the
         on-site coastal scrub and woodland habitats.

         Implementation of Phase 1 of the proposed MLUP would include construction
         activities within coastal scrub areas that provide suitable habitat for the San Francisco
         dusky-footed woodrat. Therefore, the loss of woodrat nests and individual woodrats
         could occur and related impacts would be potentially significant. The implementation
         of Mitigation Measure 17 will reduce this risk to a less than significant level.

         Mitigation Measure 17: No earlier than 30 days prior to the commencement of any
         construction activities in coastal scrub or woodland habitats, a survey shall be con­
         ducted to determine if active woodrat nests (stick houses) with young are present
         within the disturbance zone or within 50 feet of the disturbance zone. If active
         woodrat nests with young are identified, a fence shall be erected around the nest
         site at a distance adequate to provide the woodrat sufficient foraging habitat at the
         discretion of a qualified biologist. Clearing and construction within the fenced area
         would be postponed or halted until young have left the nest. A qualified biologist
         should serve as a construction monitor during those periods when disturbance
         activities will occur near active nest areas to ensure that no inadvertent impacts on
         these nests occur. If woodrats or nests are observed within the disturbance footprint
         outside of the breeding period, individuals should be relocated to a suitable location
         within the Environmental Protection Zone by a qualified biologist in possession of a
         scientific collecting permit. This will be accomplished by dismantling woodrat nests
         (outside of the breeding period), to allow individuals to relocate to suitable habitat
         within the adjacent Environmental Protection Zone. The Environmental Protection
         Zone contains large expanses of suitable woodrat habitat that would be protected.

          Hoary Bat. The hoary bat (Lasiurus cinereus) is included on the Special Animals
          List maintained by the CDFG. This bat is a forest species, typically roosts alone
          beneath clusters of leaves during spring, summer, and fall. This bat species, and
          potentially other special-status bat species, could roost in the on-site woodland
          habitats and within the existing structures on the project site.

          No trees or structures are proposed to be removed in conjunction with the imple­
          mentation of Phase 1 development. However, should any trees or structures require
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         removal for an unforeseen reason, Mitigation Measure 18 will minimize the risk of
         disturbing roosting bats within trees or structures proposed for removal.

         Mitigation Measure 18: Iftrees or structures are to be removed during the breeding
         season of native bat species (generally April 1 through August 31 in California), the
         presence of active bat maternity roosts should be evaluated by a qualified biologist.
         If the trees/structures to be removed are determined to provide potential bat roosting
         habitat, a focused survey should then be conducted to determine if an active maternity
         roost of a special-status bat species is present. Should an active maternity roost of a
         special-status bat species be identified, the roost should not be disturbed until the
         roost is vacated and juveniles have fledged, as determined by the biologist. Once all
         young have fledged, the tree/structure may be removed.

         Western Pond Turtle. Western pond turtle (CZemmys marmorata) is a California
         Species of Special Concern. This turtle primarily inhabits aquatic habitats, including
         ponds, slow moving streams, lakes, marshes, and canals. The species frequently
         basks on logs or other objects out of the water. Western pond turtles also require
         upland oviposition (i.e., egg laying) sites in the vicinity (typically within 200 meters,
         but as far as 400 meters) of the aquatic site.

          Based on the CNDDB, the species has been documented on numerous occasions at
          Crystal Springs Reservoir. Potential aquatic habitat for the species on and bordering
          the Skylawn property is limited to Albert Canyon Creek and the unnamed tributary to
          Pilarcitos Creek. Both of these creeks are separated from future development areas
          by steep slopes and dense coastal scrub habitat. Additionally, both of these drainages
          contain dense riparian vegetation within and bordering large portions of the channel,
          which is not typical of habitat used by western pond turtles. The implementation of
          Phase 1 ofthe proposed MLUP does not include the direct disturbance of any aquatic
          habitat suitable to support western pond turtle. Additionally, it is considered unlikely
          that pond turtles (if present) would traverse the steep slopes and dense scrub vegeta­
          tion that separate the drainages crossing the Skylawn property from the development
          areas. However, the implementation of Phase 1 of the proposed MLUP could de­
          grade the quality of surface runoff from the Skylawn property that enters the
          drainages on and bordering the site. This could adversely affect the quality of the
          aquatic/riparian habitat and its use by western pond turtle, which would be considered
          to be a significant impact. Mitigation Measures 2 - 5 and 8, above, would be imple­
          mented to control surface water runoff and to maintain the current water quality and
          quantity entering the nearby drainages. No additional mitigation is necessary.

          Rapfors and other bird species. The woodlands on the project site provide suitable
          nesting habitat for Cooper's hawk (Accipiter cooperii), a special-status raptor species.
          Suitable nesting habitat is also present for other raptor species such as red-tailed hawk
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         (Buteo jamaicensis) and red-shouldered hawk (Buteo lineatus). The on-site trees
         and the coastal scrub habitat also provides potential nesting habitat for numerous
         passerine bird species. Future construction activities could result in the direct loss
         of an active bird nest or the noise-related abandonment of an active nest. The active
         nest's ofraptors and other native bird species are protected by the Migratory Bird
         Treaty Act and the California Fish and Game Code.

         The implementation of Phase 1 of the proposed MLUP is not expected to result in the
         removal of trees used by a nesting Cooper's hawk or other bird species. However,
         loud noise associated with construction activity has the potential to disturb nesting
         occurring in close proximity to the construction zone and result in the abandonment
         of an active nest. The loss of a nest of a special-status bird species would be a poten­
         tially significant impact. Additionally, the removal of an active bird nest would con­
         flict with the protection afforded to such nests by the Migratory Bird Treaty Act and
         California Fish and Game Code.

         Mitigation Measure 19: If a construction project would commence anytime during
         the nesting/breeding season of native bird species potentially nesting on the site
         (typically February through August in the project region), a pre-construction survey
         of the project vicinity for nesting birds shall be conducted. This survey shall be con­
         ducted by a qualified biologist (i.e., experienced with the nesting behavior of bird
         species of the region) within two weeks of the commencement of construction
         activities. The intent of the survey would be to determine if active nests of special­
         status bird species or other species protected by the Migratory Bird Treaty Act and/or
         the California Fish and Game Code are present within the construction zone or within
         500 feet of the construction zone. The survey area would include all trees and shrubs
         in the construction zone and a surrounding 500 feet area. The survey should be timed
         such that the last survey is concluded no more than two weeks prior to initiation of
         construction. If ground disturbance activities are delayed following a survey, then an
         additional pre-construction survey should be conducted such that no more than two
         weeks will have elapsed between the last survey and the commencement of ground
         disturbance activities.

          If active nests are found in areas that could be directly affected or are within 500 feet
          of construction and would be subject to prolonged construction-related noise, a
          no-disturbance buffer zone shall be created around active nests during the breeding
          season or until a qualified biologist determines that all young have fledged. The size
          of the buffer zones and types of construction activities restricted within them will be
          determined through consultation with the CDFG, taking into account factors such as
          the following:
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         a. 	   Noise and human disturbance levels at the construction site at the time of the
                survey and the noise and disturbance expected during the construction activity;

         b. 	   Distance and amount of vegetation or other screening between the construction
                site and the nest; and

         c. 	   Sensitivity of individual nesting species and behaviors of the nesting birds.

         Limits of construction to avoid an active nest shall be established in the field with
         flagging, fencing, or another appropriate barrier and construction personnel should be
         instructed on the sensitivity of nest areas. The biologist shall serve as a construction
         monitor during those periods when construction activities would occur near active
         nest areas of special-status bird species to ensure that no impacts on these nests occur.

         .Mission Blue Butterfly. The mission blue butterfly (Plebejus icarioides missionensis)
         is a federally-listed endangered species. The species is associated with coastal scrub
         and grassland habitats on the San Francisco peninsula that contain one or more of the
         three larval host plants, including Lupinus albifrons, L. variicolor, and L. formosus.
         The species has a limited range and now occurs only in northern San Mateo County
         (San Bruno mountain and a small colony on the Milagra Ridge), San Francisco
         County (Twin Peaks and McClaren Park), and Marin County (small pockets on the
         Southern Headlands and Fort Baker). Based on the CNDDB, the closest documented
         occurrence of mission blue butterfly is approximately 4 miles north of the project site.
         This occurrence (CNDDB Occurrence #11) is from northern San Mateo County, near
          San Andreas Dam. This occurrence is described as being the southern limit of the
          species' distribution. Because the project site is located approximately 4 miles to the
          south of the species' known distribution, the mission blue butterfly is not expected to
         occur and no related impacts would occur as a result of project implementation.

         Myrtle's Silverspot. Myrtle's silverspot (Speyeria zerene myrtleae) is a federally
         endangered species. This species is currently restricted to the foggy coastal dunes/
         hills of the Point Reyes peninsula and is extirpated from coastal San Mateo County
         (CNDDB). The project site is located outside ofthe species' known distribution.
         Therefore, the species is not expected to occur and no related impacts would occur.

         Monarch Butterfly. Winter roost sites ofthe monarch butterfly (Danaus plexippus)
         are considered to be sensitive by the CDFG. Wintering sites in California are associ­
         ated with wind-protected groves of large trees (primarily eucalyptus or pines) with
         nectar and water sources nearby, generally near the coast. The trees are generally
         along a ridgeline and are subject to relatively strong winds. As wind-protected groves
         of trees are not present, and because no winter roosts have been reported from the
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            project site, monarch butterfly winter roost sites are not expected. Therefore, impacts
            to this species would not be significant.

            Edgewood Blind Harvestman. The Edgewood blind harvestman (Calicina minor) is
            included on the Special Animals List maintained by the California Department of
            Fish and Game (CDFG 2008). The species occupies locations under boulders or
            logs in serpentine areas. It is known to occur at Edgewood County Park and near a
            spring on County Road 14 north of Crystal Springs Dam. Serpentine soils are not
            present on the Skylawn property. Given the absence of suitable habitat, this species
            is not expected to occur. Therefore, impacts to this species would not be significant.

            Saltmarsh Common Yellow throat and Alameda Song Sparrow. The saltmarsh
            common yellowthroat (Geothlypis trichas sinuosa) and Alameda song sparrow
            (Melospiza melodia pusillula) are both California Species of Special Concern.
            These bird species are associated with salt marsh habitats, which do not occur on
            or near the project site. Therefore, these species would not be affected by future
            development activities and no related impacts are expected to occur.

     d. 	   Will (or could) this project significantly affect fish, wildlife, reptiles, or plant
            1ife?

            Yes, Significant Unless Mitigated. Please see the responses to Items 2.a and 2.c
            above.

     e. 	   Will (or could) this project be located inside or within 200 feet of a marine or
            wildlife reserve?

            No. The project is not located inside or within 200 feet of a marine or wildlife
            reserve.

     f. 	   Will (or could) this project infringe on any sensitive habitats?

            Yes, Significant Unless Mitigated. The CDFG Wildlife and Habitat Data Analysis
            Branch has developed a List o/California Terrestrial Natural Communities. The
            most recent version of this list, dated September 2003, is derived from the CNDDB
            and is intended to supersede all other lists developed from the CNDDB. It is based
            on the detailed classification put forth in A Ivfanualo/California Vegetation (Sawyer
            and Keeler-Wolf 1995) and is structured to be compatible with previous CNDDB
            lists. The primary purpose ofthe CNDDB classification is to assist in the character­
            ization of the rarity of various vegetation types. For the purposes of this analysis,
            plant communities denoted on the list as "high priority for inventory in CNDDB" in
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              the September 2003 version are considered to be "sensitive." Based on this classi­
              fication, the on-site purple needlegrass grasslands are considered to be a sensitive
              plant community by the CDFG. The on-site Douglas fir woodland would also be
              considered to be a sensitive plant community if it is determined to be native to the
              Skylawn property and not planted.

              Douglas fir woodland does not occur in the Phase I area. As shown in Appendix B,
              Figure 4, there are two relatively small stands of purple needlegrass in the Phase I
              area. The larger of these stands is located entirely within the Land and Water Man­
              agement Zone and would not be developed (see Mitigation Measure 16 above). The
              second native grassland area is located in a designated future development area. This
              stand of native grasses is small and is surrounded by non-native annual grasslands
              (Figure 8). The impacts any future development phases may have on this area will
              need to be reviewed under the regulations in effect at that time.

       g. 	   Will (or could) this project involve clearing land that is 5,000 sq. ft. or greater
              (1,000 sq. ft. within a County Scenic Corridor), that has slopes greater than 20%
              or that is in a sensitive habitat or buffer zone?

              Yes, Significant Unless Mitigated. Slopes on the project site range from 0% to over
              30%. Ifuncontrolled, construction-related activities on steep slopes could result in
              erosion and sedimentation into nearby drainages and result in hydrograph modi­
              fication to Pilarcitos Creek and its tributaries. Erosion and sedimentation could
              adversely affect the biological value of nearby creeks and other habitats by filling
              pools (in drainages), creating conditions favorable to non-native plant species,
              and other factors. Therefore, impacts from construction activities on steep slopes
              are considered potentially significant. As described in Items l.b and 1.f above, best
              management practices will be implemented during construction in adherence with
              local regulations to protect water quality to local waterways. Additionally, all
              project storm management strategies would be designed in accordance with the
              County's requirements mandated under Provision C.3. Implementation of
              Mitigation Measures 2 - 5 and 8 will ensure that impacts related to soil erosion
              and sedimentation during project operation would not be significant.

3. 	   PHYSICAL RESOURCES

       a. 	   Will (or could) this project result in the removal of a natural resource for
              commercial purposes (including rock, sand, gravel, oil;trees, minerals or
              topsoil)?
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                No. The project would not result in the removal of a natural resource for commercial
                purposes. While the project may involve removal of vegetation, trees, and soils
                associated with construction, these materials would not be reused for commercial
                purposes. Mineral deposits on the project site are not designated as an available
                resource recovery site option (see Item 3.b below). Therefore, no impact would
                occur.

         b. 	 Will (or could) this project involve grading in excess of 150 cubic yards?

                Yes, Significant Unless Mitigated. As previously discussed in Items l.b and 1.f, the
                potential impacts associated with slope stability, erosion, and water quality will be
                reduced to a less than significant level through the implementation of Mitigation
                Measures 2 - 5 and 8.

         c. 	   Will (or could) this project involve lands currently protected under the
                Williamson Act (agricultural preserve) or an Open Space Easement?

                No. Neither of the project parcels is currently protected under the Williamson Act or
                encumbered by any open space easements.

         d.     Will (or could) this project affect any existing or potential agricultural uses?

                No. Because there are no agricultural resources present on the project site, the
                project would not affect any agricultural resources or operations. 4 No prime
                farmland, unique farmland, or farmland of statewide importance would be converted
                to non-agricultural uses, and no environmental changes would result that could cause
                the indirect conversion of farmland to non-agricultural use.

4. 	     AIR QUALITY, WATER QUALITY, SONIC

         a. 	   Will (or could) this project generate pollutants (hydrocarbon, thermal odor, dust
                or smoke particulates, radiation, etc.) that will violate existing standards of air
                quality on-site or in the surrounding area?

                Yes, Significant Unless Mitigated. The cemetery development that would be
                allowed by the proposed MLUP would generate pollutant emissions as a result of its
                construction and subsequent operational activities. Operational emissions include
                both stationary and mobile source emissions, such as emissions from landscape


4	   California Department of Conservation Farmland Mapping and Monitoring Program, San Mateo County Important
     Farmland 2008, May 2009.
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
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         maintenance equipment. However, the largest contribution of emissions would be
         from mobile sources, specifically vehicles coming to and leaving the site. During
         project construction, air emissions would be generated from the use of heavy-duty
         diesel construction equipment, site grading, and construction worker vehicles.

         In 2009, the Bay Area Air Quality Management District (BAAQMD) set quantitative
         significance thresholds for construction emissions and new thresholds for operations
         emissions of Reactive Organic Gases (RaG), Nitrous Oxide (NOx), particulate
         matter less than ten microns in size (PMIO), and particulate matter less than 2.5
         microns in size (PM25)' These thresholds are identified in Table 2, BAAQMD
         CEQA Thresholds of Significance. As a conservative approach to this analysis, the
         project's construction impacts to air quality were evaluated using these proposed
         significance thresholds.

                                      Table 2 - BAAQMD CEQA Thresholds of Significance
         ;-----~-----r--------__r---~----------~
                                         Construction Related                          Operational Related
            Criteria Air Pollutants
                and Precursors           Max. Daily Emissions             Max. Daily Emissions       Annual Emissions
                                            (pounds1day)                     (pounds/day)             (tons per year)
                                                    54                            54                         10
                                                                                                             10



                                           1\A,,,,,,n.,mQnt   Practices                                      10

                                                                                       average), 20.0 ppm (1-hour average)


         The amount of emissions generated by the construction of Phase 1 would be highly
         variable and dependent on the size of the area disturbed, amount of grading activity,
         soil conditions, and meteorological conditions, including wind direction. The devel­
         opment of Phase 1 is likely to occur in sub-phases. The first sub-phase would be the
         construction of the paved roadways. Next, the lower portions of Phase 1 would be
         developed, as this area would provide the traditional lawn burial areas that will likely
         be in higher demand in the near future. The last sub-phase would be the development
         of the upper portion of Phase 1 (East Ridges). As previously discussed in the project
         description, Phase 1 is anticipated to occur over the next 20 years. As a conservative
         assumption, construction emission estimates for Phase I assumed that the entire
         area (35 acres) of Phase 1 proposed for development would be graded over a period
         of6 weeks.

         Based on the URBEMIS 2007 (Version 9.2.4) model for the project, it is estimated
         that temporary construction emissions would not exceed the BAAQMD significance
         thresholds, even if the entire Phase 1 area was graded over a short period of time
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
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          (refer to Appendix C for the URBEMIS model results). Furthermore, while project
          construction would result in the emissions of criteria pollutants, such air quality
          impacts would be temporary and localized in nature.

          According to the BAAQMD CEQA Guidelines, the primary pollutant of concern
          during construction is particulate matter from fugitive dust. While the BAAQMD
          does not require quantification of dust emissions during construction, it does empha­
          size implementation of all feasible control measures to minimize the generation of
          fugitive dust. The BAAQMD has provided a list of dust control measures in their
          CEQA Guidelines that, when fully implemented, would significantly reduce fugitive
          dust during construction activities. The implementation of Mitigation Measure 20
          will minimize the air quality impacts associated with construction-related dust
          particulates to a less than significant leveL

          Mitigation Measure 20: The applicant shall submit a dust control plan to the
          Planning and Building Department prior to any Phase 1 grading or construction
          activities. The approved measures shall be implemented prior to beginning any
          grading and/or construction activities and shall be maintained for the duration of
          the project. The plan shall, at minimum, include all the "Basic Control Measures"
          listed in Table 2 of the BAAQMD CEQA Guidelines (see Appendix D):

          a. 	   Water all active construction areas at least twice daily.

          b. 	   Cover all trucks hauling soil, sand and other loose materials or require all trucks
                 to maintain at least 2 feet of freeboard.

          c. 	   Pave, apply water three times daily, or apply (non-toxic) soil stabilizers on all
                 unpaved access roads, parking areas and staging areas at construction sites.

          d. 	   Sweep daily (with water sweepers) all paved access roads, parking areas and
                 staging areas at construction sites.

          e. 	   Sweep streets daily (with water sweepers) if visible soil material is carried onto
                 adjacent public streets.

          Additional measures may be required in order to ensure that construction-related
          activities do not generate elevated levels of dust particulates at any point throughout
          the duration of the project.

          After the construction phase is complete, normal cemetery operations would still
          have the potential to generate pollutants that could violate BAAQMD standards.
          BAAQMD screening criteria require that a detailed air quality analysis be conducted
          for projects generating more than 2,000 vehicle-trips per day because their associated
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
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            emissions could be above the BAAQMD significance thresholds for ROG, NO x,
            PMJO and PM2.5. As shown in Section 5, Transportation, vehicle trips anticipated
            to be generated by Phase 1 of the project would be a maximum of 108 trips per day,
            well below the threshold of2,000 daily trips established in the BAAQMD Guidelines
            where a quantitative air quality assessment is required. Therefore, the operational
            impacts for the lands uses that would be allowed by Phase 1 of the MLUP would
            not be considered to emit significant quantities of criteria pollutants that cause a
            new air quality violation or contribute to an existing one. No additional mitigation
            is required.

     b. 	   Will (or could) this project involve the burning of any material, including brush,
            trees and construction materials?

            No. The project would not include or result in the burning of any material, including
            brush, trees, and construction materials.

     c. 	   Will (or could) this project be expected to result in the generation of noise levels
            in excess of those currently existing in the area, after construction? .

            Yes, Not Significant. Construction activities could generate temporary noise levels
            that exceed the existing conditions. After the construction phase is complete, normal
            cemetery operations are not expected to result in significantly elevated noise within or
            surrounding the project site. As discussed in Section 5, Transportation below, Phase
            1 of the project is anticipated to generate a maximum of 108 new daily vehicle trips,
            which would be distributed throughout the local roadways in the project vicinity.
            This minimal increase in traffic volume associated with the project would not result
            in a perceptible increase in ambient noise on or off the project site. Furthermore,
            there are no sensitive land uses along the roadways cemetery patrons would travel
            to get to the project site. Internal roadways would have reduced speed limits between
            5 and 10 miles per hour (mph). As such, internal traffic would not generate a signifi­
            cant amount of noise on the project site. Therefore, impacts are not considered to be
            significant.

     d. 	   Will (or could) this project involve the application, use or disposal of potentially
            hazardous materials, including pesticides, herbicides, other toxic substances, or
            radioactive material?

            Yes, Simificant Unless Mitigated. The existing Sky lawn Memorial Park facility
            utilizes small amounts of hazardous materials for the general maintenance ofthe
            cemetery lawns and facilities, as well as body embalming. Maintenance personnel
            are knowledgeable of the proper handling and disposal of hazardous materials asso­
            ciated with the general maintenance ofthe facility. Mitigation Measure No. 21
            requires that Skylawn continue to comply with all County Environmental Health
ANSWERS TO QUESTIONS
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           Division requirements regarding the use and disposal of all chemicals associated with
           embalming processes.

           The presence of small amounts of oils, lubricants, and fertilizers is therefore not
           considered an environmental concern. Chemical waste from embalming activities is
           removed from the project site by licensed hazardous waste management companies
           and properly disposed off-site. Expansion of the existing facility would not
           significantly change the current use of hazardous products on the project site.

           With regard to the use of pesticides, herbicide and other products, Skylawn's devel­
           oped facility, as well as their proposed expansion, includes a significant expanse of
           turf grass, gardens, trees and other landscaping on which such products are and will
           be used. Section 11501.1 of the California Food and Agricultural Code prohibits
           any action by a local government to prohibit or otherwise regulate the use of pesti­
           cides, herbicides, fertilizers, etc. This is meant to ensure uniformity of pesticide use
           throughout the state so that each user of pesticides knows what is required of them
           no matter where in California they may be using the material (unless it is a restricted
           material). Skylawn must comply with all such regulations as stipulated and enforced
           by the County Agricultural Commissioner (CAC) for the application and use of all
           such products. The pesticide registration process through the United States Environ­
           mental Prote~tion Agency (USEPA) and California Environmental Protection Agency
           (CaI/EPA) ensures that when such products are used in accordance with the product
           label, the environmental impact would be less than significant.

           Each County has an Agricultural Commissioner who is the local representative for
           the State and who enforces compliance with both federal and state regulations. If
           there is concern regarding pesticide misuse, or environmental contamination, the
           Agricultural Commissioner is the local enforcement agency. Additionally, there are
           some pesticides that rise to a higher level of concern "restricted materials," and the
           Agricultural Commissioner may additionally condition (or deny) the use of these
           products depending on local and application site-specific conditions. Restricted
           materials may be restricted by state or federal regulation or both. The local permit
           process to use restricted materials involves a site visit by the Agricultural Commis­
           sioner to assess site conditions (environmental, sensitive sites, endangered species,
           water courses, etc.) to make a determination as to whether use of the material is
           justified, and then either denying use of the product, or if approved, issuing a permit
           that contains site-specific conditions to ensure there are no unintended impacts.

           The federal registration process through USEP A involves testing for health and
           environmental impacts, safety and efficacy. If such testing determines that the
           product is effective and can be used safely and without health or environmental
           impacts, a label is developed that specifies how the material is to be used safely,
           without health or environmental impacts. It is through the registration process that
ANSWERS TO QUESTIONS
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           "less than significant" impact levels is determined, whereby the product label speci­
           fies how the product is to be used so it is used effectively but safely, without health
           or environmental impacts.

           CallEPA has their own registration process that further refines USEP A's process (and
           may even reject some federally registered materials), while the State's Department
           of Pesticide Regulations has developed general pesticide use laws and regulations
           that both reinforces the federal label regulations and provides prohibitions and allow­
           ances about how pesticide applications are made to additionally ensure no health or
           environmental effects.

           These established regulations cited above require that Skylawn use pesticides in
           accordance with the product label and state regulations to ensure no off~site
           movement of the product and no significant impacts to water quality.

           In addition to that as required by the USEP A and Cal/EP A as administered through
           the CAC (but not in place of or superceding such regulations), Skylawn has offered
           the following management practices that they currently and will continue to follow
           regarding the application of such products at their facility:

           o       Skylawn does not and will not apply fertilizer or herbicide products within
                   25 feet of Sky lawn 's property line boundaries.

           o       Skylawn does not and will not apply fertilizer products containing a nitrate
                   source if nitrogen within a 72-hour window of a "significant" rainfall event
                   (where greater than II2-inch is predicted).

                   Before application, Skylawn will and does inspect and clean gutters, catch
                   basins and bio-filtering retention ponds to ensure that any water runoff is
                   properly bio-filtered prior to dissipation.

                   Skylawn does and will immediately, following a fertilizer application (that
                   evening) wash the product into the upper soil profile. Turf grass has the ability
                   to absorb nitrogen within 24-48 hours. Irrigation following a fertilizer applica­
                   tion is preformed in short periods to minimize runoff.

           •       Sky lawn does and will utilize slow-release products that provide lower risk of
                   runoff.

               •   Skylawn does not and will not apply herbicide products within 25 feet of
                   Skylawn's property line boundaries.
ANSWERS TO QUESTIONS
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         •	     Skylawn does not and will not apply herbicide products within a 4-hour window
                of any rainfall event (where showers are predicted).

                Skylawn does not and will not apply herbicide products when wind speeds
                exceed 5 miles per hour.

         .. 	   Before application, Skylawn does and will inspect and clean gutters, catch
                basins and bio-filtering retention ponds to ensure that any water runoff is
                properly bio-filtered prior to dissipation.

                Skylawn does and will apply such products early in the morning to allow plant
                absorption and prevent the evening irrigation from washing the product off the
                plant.

                Skylawn does and will wash off equipment on turf areas that will absorb any
                such products that may wash off the equipment.

          e	    Only Skylawn's best trained (senior) staff may apply any such products, under
                the supervision of a licensed applicator.

         Given the above, no significant environmental or human health hazards are expected
         to occur in connection with the small amounts of hazardous materials utilized by
         daily cemetery operations. However, the construction activities associated with the
         implementation of Phase 1 will include the use of vehicles operated with fuels,
         including gasoline and diesel. Other minor amounts of hazardous material may be
         present at the site during construction activities. Accidental spills of fuels and other
         hazardous materials could potentially create a hazardous situation on and off-site.
         Proper safety procedures would minimize the event of a hazardous situation related to
         construction accidents. The following mitigation measure is proposed for Phase 1
         and would reduce the impact to a less than significant level.

          Mitigation Measure 21: The applicant shall comply with and follow all guidelines
          and regulatory requirements as stipulated by the County Environmental Health
          Division with regard to their use and disposal of all chemicals and fluids resulting
          from the embalming processes that occur at the Skylawn mortuary.

          Mitigation Measure 22: The project applicant (or authorized contractor) shall
          submit a safety plan for the development of Phase 1. The safety plan shall include
          measures to reduce and minimize accidents on-site and measures that address the
          proper procedures to clean up and contain spills. The safety plan shall be approved
          by the County Building Inspection Section prior to the start of any construction or
          grading activity on the site.
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    e. 	    Will (or could) this project be subject to noise levels in excess of levels
            determined appropriate according to the County Noise Ordinance or other
            standard?

            No. 	 The subject site is located in a rural area atop coastal ridge as is far removed
            from any potential sources of significant noise that would be in excess of the County
            Noise Ordinance. Moderate traffic from the nearby roadways is the main source of
            any noise on the project site. However, these roadways are separated from the exist­
            ing cemetery at a far enough distance (at least 400 feet at any location, and even
            farther away for any point within the Phase 1 development area) where any traffic­
            related noise attenuates to a less than significant level by the time it reaches the ears
            of cemetery patrons.

     f. 	   Will (or could) this project generate noise levels in excess of levels determined
            appropriate according to the County Noise Ordinance standard?

            Yes, Significant Unless Mitigated. As mentioned in Item 4.c, grading and con­
            struction activities may temporarily generate elevated noise levels during Phase 1
            implementation. However, none of the most sensitive receptors listed in County
            Noise Ordinance Section 4.88.330, including single-family or multiple-family
            residences, schools, hospitals, churches, or public libraries are located in close
            proximity to the Skylawn facility. Further, County Noise Ordinance Section 4.88.360
            specifically exempts noise sources associated with demolition, construction, repair,
            remodeling, or grading of any real property, provided said activities do not take place
            between the hours of 6:00 p.m. and 7:00 a.m. weekdays, 5:00 p.m. and 9:00 a.m.
            on Saturdays or at any time on Sundays and any national holiday. Mitigation
            Measure 22 will ensure that Skylawn comply with all provisions of the County
            Noise Ordinance throughout the duration of the project.

            Mitigation Measure 23: Noise levels produced by proposed construction activities
            shall comply with the San Mateo County Noise Ordinance contained in Chapter 4.88
            (Noise Control) of the County Ordinance Code at all times. Construction activities
            shall be limited to the hours from 7:00 a.m. to 6:00 p.m., Monday through Friday, and
            9:00 a.m. to 5:00 p.m. on Saturday. Construction operations shall be prohibited on
            Sunday and any national holiday.·

     g. 	   Will (or could) this project generate polluted or increased surface water runoff
            or affect groundwater resources?

            Yes, Sbroificant Unless Mitigated. Please see the responses to Items l.b and 1.f
            above. All potential surface water quality impacts will be reduced to a less than
            significant level through the implementation of Mitigation Measures 2 - 5 and 8.
ANSWERS TO QUESTIONS
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         Water is supplied to the site by two sources: an existing water well and water
         from the Coastside County Water District (District). The District supplies non­
         potable water to the project site for irrigation of the burial lawns and associated
         landscape. The source of District-provided water for this portion of the County is
         the California Water Service contracts for water from the Hetch Hetchy and Crystal
         Springs Reservoir water systems. The proposed MLUP would increase the demand
         for non-potable water from the District for irrigation and landscape purposes.
         However, this increased demand for water from the District would not result in
         an increased extraction of groundwater resources in the area.

          The private water well, located near the old quarry site, provides potable water to the
          funeral home, reception building, and the old administration building (that is not cur­
          rently in use). The well has a capacity to produce 6 to 16 gallons of water per minute
          (gpm), and feeds a 1O,OOO-gallon tank that in turn feeds the potable water system.
          The current capacity needed for the existing cemetery is 6 gpm. As the project would
          not include improvements that require potable water, there would not be increased
          demand for this well water as a result of the project. As such, the proposed MLUP
          would not result in impacts to groundwater resources through extraction.

          Implementation of the proposed MLUP would convert a moderate amount of
          undeveloped land into impervious surfaces through the construction of burial
          structures. However, the majority of the new cemetery development would have
          large areas of lawn, pervious pavements for the proposed roadways, vegetated buffer
          zones, and infiltration trenches to allow for groundwater recharge. Furthermore, the
          project's proposed storm drainage system would provide clean water to the natural
          drainage channels at the same rate at which they receive water in the current, pre­
          development state; no more and no less. As such, implementation of the MLUP
          would not interfere substantially with groundwater recharge such that it would
          result in a deficit in aquifer volume or lowering of the local groundwater table.
          No additional mitigation is necessary.

     h. 	 Will (or could) this project require installation of a septic tanklleachfield sewage
          disposal system or require hookup to an existing collection system which is at or
          over capacity?

          No. The proposed new cemetery development does not include the installation of
          new septic systems and/or leach fields or require hookup to the septic system in the
          existing cemetery facilities. However, should it be determined that a septic tank is
          necessary, the installation of the tank would be conducted in adherence with federal,
          state, and local regulations, and would include review by the San Mateo County
          Environmental Health Division.
ANSWERS TO QUESTIONS
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5. 	   TRANSPORTATION

       a. 	   Will (or could) this project affect access to commercial establishments, schools,
              parks, etc.?

              Yes, Not Significant. There are no commercial establishments or public buildings
              within I-mile of the project site. Furthermore, the project does not propose any
              alterations to the existing site access driveway or nearby roadways. The Fifield­
              Cahill Ridge Trail is the closest public recreational facility to the project site, and is
              located in the SFPUC lands to the east. The newly opened (2003) 10-mile trail starts
              at Skyline Quarry at Highway 92 and extends northward to the watershed boundary at
              the Portola Ridge gate. There it connects with the Golden Gate National Recreation
              Area (GGNRA's) trail system and the Sweeney Ridge section of the Bay Area
              Ridge Trail, which is open to the public. One trailhead location is located at the
              existing cemetery gate on the project site. Public access through the project site to
              the Fifield-Cahill Ridge Trail would continue to be accommodated using existing
              and new cemetery roads or pathways (see Figure 3), which would be constructed as
              close to the topographic ridgeline as is practical. Trail users may be temporarily
              inconvenienced by construction activities (partial and temporary trail blockages,
              noise, etc.); however project implementation will not have any long-term impacts to
              commercial establishments or public facilities.

       h. 	   Will (or could) this project cause noticeable increase in pedestrian traffic or a
              change in pedestrian patterns?

              Yes, Not Significant. Phase 1 includes the development of approximately 35 acres
              of new cemetery facilities in an area that is currently undeveloped. The development
              of Phase 1 areas, which currently have little or no pedestrian traffic, will result in
              minor increases in pedestrian visits to the newly created burial facilities. Visitors will
              be served by newly paved roadways and dedicated pedestrian pathways that meander
              threw the newly developed Phase 1 area. These minor changes to pedestrian traffic
              and/or patterns are not expected to result in any significant environmental impacts.

       c. 	   Will (or could) this project result in noticeable changes in vehicular traffic
              patterns or volumes (including bicycles)?

              Yes, Not Significant. The project site is located adjacent to and north of Highway 92
              at the junction of Highway 35 (Skyline Boulevard). Regional access to the site is
              provided from the east via 1-280. Highway 92 provides direct access to the project
              site from the northeast and west. Highway 35 provides direct access to the project
              site from the south and the north. The project site has one main entry driveway on
              eastbound Highway 92, which shares the same centerline as Highway 35. The
              surrounding roadway network was previously shown in Figure 1. The following is
              a brief description ofthe roadways that provide access to the project site:
ANSWERS TO QUESTIONS
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         •	    Interstate 280 (1-280) is a north-south freeway in California that serves the San
               Francisco Bay Area (north to San Francisco, south to San Jose). 1-280 connects
               to Highway 92 approximately 1.5 miles northeast ofthe project site. In the
               project vicinity, 1-280 has four lanes in each direction. According to traffic
               counts published by the California Department of Transportation (CalTrans)
               in 2008, the average daily traffic volume on 1-280 near the junction with
               Highway 92 was 104,000 vehicles per day.
               Highway 92 is a northeast-southwest roadway that wraps around the southern
               boundary of the project site. It is an undivided two-lane highway that has one
               lane in each direction. According to CalTrans, in 2008, the average daily traffic
               volume on Highway 92 near the southern junction with Highway 35 was 29,000
               vehicles per day.

               Highway 35 (Skyline Boulevard) is a north-south roadway that shares an
               alignment with Highway 92 for about 2 miles approaching the project site
               from the east. Just south of the project site, Highway 35 diverges from the
               Highway 92 alignment and continues as a north-south roadway, also named
               Skyline Boulevard. There are two junctions for Highway 92/Highway 35; one
               at each end ofthe shared alignment. For the traffic analysis of this project, the
               Highway 92/Highway 35 intersection refers to the southemmostjunction, which
               is adjacent to the project site. In the project vicinity, Highway 35 is an un­
               divided two-lane roadway that has one lane in each direction. According to
               CalTrans, in 2008, the average daily traffic volume on Highway 35 near the
               southern junction with Highway 92 was 2,450 vehicles per day.

         @     Skylawn Memorial Park Driveway is a north-south, undivided two-lane private
               road that leads to the project site from Highway 92.

         Study Intersections. A traffic analysis was conducted by CH2 MHILL for the
         proposed MLUP (Appendix E). This traffic analysis includes two unsignalized
         intersections: Skylawn Memorial Park DrivewaylHighway 92 and Highway 921
         Highway 35.

         Conditions Scenarios. The study intersection levels of ser.vice (LOS) were evaluated
         during the weekday a.m. (7:00 a.m. to 9:00 a.m.) and p.m. (4:00 p.m. to 6:00 p.m.)
         peak periods under the following scenarios:

          •	   Existing Conditions: Existing intersection condition based on traffic counts
               collected by CH2M Hill in May, 2009.

          •	   2030 Baseline Conditions: Trips from approved but not yet completed projects
               added to the Existing Conditions. This is defined as the 2030 Baseline Condi­
               tions, without project. Baseline condition traffic volumes were derived from the
               County's 2030 Travel Forecast Model, which predicts Countywide increases in
ANSWERS TO QUESTIONS
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                 traffic based on the Association of Bay Area Governments (ABAG) land use
                 projections for the region.

                 2030 Baseline plus Project Conditions: Trips from the project are added to
                 the 2030 Baseline Conditions for comparison to determine the effects of the
                 project trip generation.

           The resulting delay is expressed using level of service (LOS), where LOS A repre­
           sents free-flow activity and LOS F represents overcapacity operation. The relation­
           ship of delay and LOS at unsignalized intersections is summarized in Table 3,
           Unsignalized Intersection LOS Criteria.

                                   Table 3 - Unsignalized Intersection LOS Criteria
                                                     Unsignalized Intersection Control Delay
                          Level of Service (LOS)
                                                         . per Vehicle (Seconds)
                                                                        ---'----1
                                    A                                 ~10.0
                                    B                              >10.0 ~ 15.0




           Significance Criteria. The City/County Association of Governments (CICAG), as the
           Congestion Management Agency for San Mateo County, is required to prepare and
           adopt a Congestion Management Program (CMP) on a biennial basis. The purpose
           of the CMP is to identify strategies to respond to future transportation needs, develop
           procedures to alleviate and control congestion, and promote Countywide solutions.
           Per the C/CAG Policy on Traffic Impact Analysis (2006), a project is considered to
           have a significant impact if it meets one or more of the following criteria:

           •	    If the project will cause an intersection currently in compliance with the adopted
                 LOS standard to operate at a level of service that violates that standard.

           •	    If the cumulative analysis indicates that the combination of the proposed project
                 and future cumulative traffic demand will result in an intersection currently in
                 compliance with the adopted LOS standard to operate at a level of service that
                 violates that standard and the proposed project increases average control delay
                 at the intersection by four (4) seconds or more.
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         •	    If the project will add any additional traffic to an intersection that is currently
               not in compliance with its adopted level of service standard as established in
               the CMP.

         According to the CMP, adopting LOS standards based on geographic differences
         helps to prevent future congestion levels from getting worse than anticipated at the
         time the CMP was published. As none of the project study intersections are
         specifically included in the list of CMP intersections, the adopted LOS standard for
         similar facilities, LOS E, in the study area was implemented.

         Existing Conditions. Existing weekday midday peak hour and the Saturday midday
         peak hour turning movement counts were collected on Friday May 15,2009, and
         Saturday May 16,2009, respectively. Existing weekday and Saturday peak hour
         turning movement counts are illustrated in Figure 10 and the associated LOS are
         presented in Table 4, Intersection LOS - Existing Conditions. Overall, both inter­
         sections operate at an acceptable LOS for all turning movements during weekday
         and Saturday peak hours.

                                 Table 4 -Intersection LOS -    Existing~Conditions
                   r-----
                              Intersection
                                                    I          Intersection Operation            I
                                                                                                 i
                   i                                i    Average DelayA           LOS
                   IWeekday Peak H~ur               I	                    I                      I
                     1. Skylawn Memorial Park 	                                                  i
                                                              0.41                    A
                   · Driveway/Highway 92                                                         I
                       2. Highway 92/Highway 35               1.60                    A          I
                   · Saturday Peak Hour                                                          I
                   I 1. Skylawn Memorial Park                                                    i
                                                              1.43                    A
                   · Driveway/Highway 92
                       2. Highway 921Highway 35               4.26                    A
                       Source: CH2M Hill, 2009
                       Notes: 	 AAverage Delay is a weighted average of al/ movements' delays.
                                                                                                 I

          2030 Baseline Conditions. As previously discussed, 2030 Baseline Condition traffic
          volumes were derived from the County's 2030 Travel Forecast Model. Weekday and
          Saturday peak hour turning movement counts under 2030 Baseline Conditions are
          illustrated in Figure 11 and the associated LOS are presented in Table 5, Intersection
          LOS 2030 Conditions. Overall, both intersections operate at an acceptable LOS for
          all turning movements during weekday and Saturday peak hours.
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                                              Table 5- Intersection LOS 2030 Conditions
         I           Intersection                                         Intersection Operation
                                                           Average OelayA                              LOS
                                               2030 Baseline          2030 Baseline                     I 2030 Baseline
             Weekday Peak Hour
                                          i

                                          I
                                                                  I
                                                                       plus Project
                                                                                       2030 Baseline
                                                                                                                      -,
                                                                                                             plus Project   •
                                                                                                                            I

                                                                 I

             1, Skylawn Memorial Park     I          0.5                    0.7              A
         i   Driveway/Highway 92                                  I
                                                                 1
         I 2. Highway 92/Highway 35       I          3.0                    3.0              A                    A
         Katu'day P..k Hou,                                                                             I
             1. Skytawn Memorial Park                            I
                                                     3.1                  14.2               A                    B
             Driveway/Highway 92                                  i
                                                                                                        I
         KHighWay 921Highway 35                     19.6                  19.8               C                    C
              Source: CH2M Hill, 2009
         I    Notes: AAvera9e Delay is a wei9hted average of all movements' delays.


         Trip rates published by the Institute of Transportation Engineers (lTE), Trip Genera­
         tion, 8th Edition, 2008 were used to estimate the traffic generated by the development
         of Phase 1. ITE rates for "Cemetery" land use were used for determining A.M. and
         P.M. peak hour traffic volumes. Under the proposed MLUP, up to approximately
         35 acres of new cemetery development would be constructed during Phase 1, which is
         expected to occur over the next 20 years. The trip generation estimates for the entire
         buildout of Phase 1 were applied to the County's long-range traffic forecasts, which
         extend out to year 2030. Because weekday midday peak hour ITE trip rates were not
         available, the weekday P.M. peak hour ITE rate was used instead. Furthermore, the
         direction of the trips ("in" and "out" of the project site) were based on actual
         observations, rather than based on ITE's sample observations.

             As a conservative approach, all trips generated by Phase 1 of the proposed MLUP
             were considered to be new trips to the study area. As shown in Table 6, Phase 1 Trip
             Generation Estimates, the proposed MLUP is estimated to generate approximately
             57 trips per weekday peak hour, and 108 trips per Saturday peak hour.

             However, it should be noted that the expansion of burial areas within the existing
             cemetery do not typically result in the cumulative addition of traffic. New burial
             areas are frequently visited in the first years of operation, but as these areas become
             older, the frequency of memorial services and visitors decrease. The vehicle trips
             are more likely to shift from the older areas of the cemetery to the newer areas, and
             would not result in a cumulative addition of vehicle trips. Furthermore, the existing
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
Page 48


            cemetery currently serves approximately 600 burials per year. The same number of
            annual burials is expected after full buildout ofthe proposed MLUP.


            L     Land Use
                                           Table 6 -Phase 1 Trip Generation Estimates
                                    Weekday (Friday) Midday Peak Hour              Saturday Midday Peak Hour
            I                       Rate        In   !
                                                         Out      Total     Rate         In     I   Out       Total
            I Cemetery (35 acres)   1.64       87%       11%      100%       3.09       65% 	   i   35%       100%
            ~Number ofTrips       I--      I   50         7        57         --         70         38    i    108    !

            _Source: CH2M Hill, 2009


            The resulting project generated trips were distributed onto the surrounding roadway
            network based on existing and anticipated travel patterns in the project site. The
            associated LOS are presented in Table S. Overall, both intersections operate at an
            acceptable LOS for all turning movements during weekday and Saturday peak hours.
            While motorists would experience a slight increase in average delay with the
            implementation of the proposed MLUP, the delays experienced would not be
            significant.

     d. 	 Will (or could) this project involve the use of off-road vehicles of any kind (such
          as trail bikes)?

            No. While the proposed Phase 1 activities would temporarily include the use of
            construction vehicles, no long-term use of off-road vehicles is proposed or expected
            to result from the project. The Bay Area Ridge Trail on the eastern ridge portion of
            the property is for pedestrian use only and would not allow off-road vehicles.

     e. 	   Will (or could) this project result in or increase traffic hazards?

            Yes, Not Significant. As discussed in Item S.c above, the project would not generate
            a substantial amount of motor vehicle trips in the project vicinity above existing con­
            ditions. Implementation of Phase 1 would not involve the redesign of geometric
            features on public roadways. Internal roadways within the new cemetery develop­
            ment would have reduced speed limits (S - 10 mph) and are not expected to create
            traffic-related hazards.

     f. 	   Will (or could) this project provide for alternative transportation amenities such
            as bike racks?

            No. As previously discussed under Item S.b, above, the project would not increase
            pedestrian or bicycle traffic nor would it create a significant change in pedestrian
            patterns. Although no bicycle racks are proposed as part of the MLUP, the new
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
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              cemetery development would not prevent the use of bicycles on the project site.
              Internal roadways within the new cemetery development would be safe for bicyclists
              and motorists to share. Therefore, no impact would occur.

       g. 	   Will (or could) this project generate traffic which will adversely affect the traffic
              carrying capacity of any roadway?

              Yes, Not Significant. As previously discussed in Item 5.c, the project is expected to
              result in minor increases in vehicle traffic along nearby roadways. However, the
              traffic study undertaken by CH2M Hill concluded that both existing and post-project
              conditions would remain at acceptable LOS levels and would not significantly impact
              the carrying capacity of local roadways.

6. 	   LAND USE AND GENERAL PLANS

       a. 	 Will (or could) this project result in the congregating of more than 50 people on
            a regular basis?

              Yes, Not Significant. With the implementation of Phase 1 of the MLUP, the number
              of memorial services would remain as it is today, which is approximately 600 burials
              per year. Attendance at these services is extremely variable, but can result in the
              congregation of more than 50 people on a regular basis. This type of attendance
              is typical of the existing cemetery development. As discussed in Section 5,
              Transportation, development of the new Phase 1 areas is not anticipated to generate
              traffic that would cause a significant impact to the local roadways and intersections in
              the project area. Additionally, the congregation of people on-site is for memorial
              purposes and would not result in loud noise sources. People would congregate in an
              area that has been developed and would be discouraged to enter undeveloped portions
              of the site. Sky lawn Memorial Park encourages people to leave the site prior to
              darkness. Given the above, no physical impact would be expected to occur to the
              existing environment from the congregation of more than 50 people on a regular
              basis.

       b. 	 Will (or could) this project result in the introduction of activities not currently
            found within the community?

              No. The project involves the expansion of the existing cemetery use within the
              Skylawn Memorial Park property. The project would not introduce activities not
              currently found within the community and no impact would occur.
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
Page 50


     c. 	   Will (or could) this project employ equipment which could interfere with
            existing communication and/or defense systems?

            No. Implementation of the project would include the temporary use of standard
            construction equipment. The types of construction vehicles that may be used include
            dozers, graders, street sweepers, dump trucks, and construction worker vehicles.
            Equipment that may be used by future employees and/or patrons of the project site
            may include gardening equipment and personal electronics. While it is unknown
            exactly what specific types of equipment may be used upon project implementation,
            the equipment allowed by law for both construction and private commercial use
            would not likely interfere with existing communication and/or defense systems.
            Therefore, no impact would occur.

     d. 	 Will (or could) this project result in any changes in land use, either on or off the
          project site?

            No. The project does not involve the introduction of any land uses not already
            lawfully occurring on the subject property. The expansion of cemetery facilities is
            not expected to result in any changes in land use either on or off the project site.

     e. 	   Will (or could) this project serve to encourage off-site development of presently
            undeveloped areas or increase development intensity of already developed areas
            (examples include the introduction of new or expanded public utilities, new
            industry, commercial facilities or recreation activities)?

            No. While the project would result in the expansion of the Skylawn facility, it would
            not result in any new or expanded public utilities, new industry, or new commercial
            facilities. Implementation of Phase 1 development would result in new roadways to
            provide access to new cemetery burial areas on the site. However, these roadways
            would be private and would not provide access to other portions of the County and
            are therefore not considered growth inducing. Additionally, the trail proposed on-site
            (and discussed in Item 5.a) would be an extension of the existing Bay Area Ridge
            Trail and would not provide a new trailhead. Therefore, visitors coming to the site to
            specifically access the trail would not be expected as no parking would be provided
            for access to the trail. Given the above, impacts are considered to be not significant.

     f. 	   Will (or could) this project adversely affect the capacity of any public facilities
            (streets, highways, freeways, public transit, schools, parks, police, fire, hospitals),
            public utilities (electrical, water and gas supply lines, sewage and storm drain
            discharge lines, sanitary landfills) or public works serving the site?
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
Page 51


           Yes, Not Significant. Please see Item 5.c for details regarding the minor increases in
           vehicle traffic expected as a result of development of Phase 1. The traffic study
           conducted by CH2M Hill concluded that this minor increase will not have a
           significant affect on the capacity of local streets, highways, or freeways.

           While Phase 1 development may result in a minimal increase in employment, the
           project will not encourage any significant increase in population that would affect
           public transit usage or the capacity of nearby schools, parks, or hospitals. Similarly,
           the minor increases in visitors (and new employees) to the site caused by Phase 1
           development would not substantially increase demand for emergency services or
           increase the frequency of emergency response calls to the project site.

           Public Utilities. Pacific Gas and Electric (PG&E) provides electricity and gas supply
           services to the project site. Under the proposed MLUP, no additional office or cus­
           tomer service areas would be developed and no new buildings are proposed. None
           of the new burial structures and roadways would be artificially lighted except for
           shielded and low mounted safety lighting integrated into steps and walls at pedestrian
           walks. This safety lighting would consist of solar powered fixtures. As such, project
           improvements would not require the expansion of electricity and gas supply services.

           Private septic systems currently serve the existing cemetery improvements on the
           project site. At this time the proposed MLUP does not include any plans for the
           installation of septic systems.

           A description of the existing and proposed drainage systems on the project site are
           described under Item l.r Because the proposed stormwater discharge systems would
           achieve minimal change to the quantity and quality of the water entering these
           channels, the project would not adversely affect the capacity of the County's storm
           drain systems in the vicinity of the project site.

           The project site is contracted with Allied Waste to dispose of all non-hazardous solid
           waste, which includes green debris such as tree branches and floral bouquets, con­
           crete and granite, paper, and general garbage. Approximately two large dumpsters
           (about 400 cubic feet total) of solid waste are hauled off on a monthly basis. As the
           project would not significantly increase the frequency of memorial services on the
           project site, it is not anticipated that the proposed improvements would increase
           the amount of solid waste generated by the cemetery. The waste collected from the
           project site is ultimately hauled to the Ox Mountain Landfill in HalfMoon Bay. Ox
           Mountain Landfill has a permit from the California State Integrated Waste Manage­
           ment Board to operate until 2018, with a total permitted capacity of 35.9 million
           cubic yards. The maximum daily waste tonnage that it is permitted to receive is
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
Page 52


            3,598 tons, which is approximately 1.3 million tons per year. The amount of waste
            generated by the project on a yearly basis would be insignificant when compared to
            the total amount of solid waste the landfill is permitted to accept. Therefore, no
            impact would occur.

            The project site is currently provided with non-potable water by the Coastside County
            Water District (District) under a special contract. 5 Under this agreement, the project
            applicant is only entitled to receive non-potable water from the District's surplus
            water supply. In the event that the District no longer has surplus water supply
            (i.e., the normal demands from the growth of the District's service area reach the
            maximum water supply, or severe drought occurs), the District's water supply to the
            project site would be terminated.

            The existing cemetery has a reported 83 acres of irrigated landscape and used
            41 million gallons of non-potable water from the District during the fiscal year of
            2008-2009. 6 It is the District's second-largest irrigation customer. 7 The only existing
            water main to the project site extends from Cahill Ridge/Pilarcitos Canyon. There is
            one pump station located on Cahill Ridge, near the entrance gate to the Fifield-Cahill
            Ridge Trail, and a second located in the west ridge area of the project site.

            The District receives water from multiple sources including the City and County of
            San Francisco's regional system, operated by SFPUC, Crystal Springs Reservoir,
            Pilarcitos Well Field, Denniston Project, and Denniston Wells. The District produces
            a gross total of 880 million gallons of water from these sources. According to the
            District's Urban Water Management Plan (UWMP), the District currently has 26
            customers with 49 active dedicated irrigation meters. Irrigation water use generally
            consumes 7% of the total annual water use. Most irrigation costumers include
            athletic fields, homeowner's associations, city parks, and small commercial sites.
            As part of the District's Large Landscape Conservation program (BMP 5), all 26
            customers with dedicated landscape irrigation meters receive bi-monthly water use
            budgets, which compare the customer's actual water use with an estimated budgeted
            water based on landscape size, historic evapotranspiration, precipitation, and climate.
            This measure has been providing dedicated landscape meter customers (including the
            project site) with landscape water budgets since 2002. This measure is currently
            active.

            As of July 2005, two major recycled water feasibility studies have been completed
            that analyze the quantity, future customers, cost, and feasibility of using recycled

5 Personal communication with Kathleen Brannon, Coasts ide County Water District, October 27,2009. 

6 ibid 

7 CCWD-UWMP, 2005 

ANSWERS TO QUESTIONS
File No. PLN 2010-00026
Page 53


              water. In April 2009, the Sewer Authority Mid-Coastside Wastewater Treatment
              Facility began a Recycled Water Pilot Study for the provision of a recycled water
              supply to the District. Recycled water from this pilot study will be distributed by the
              District to the Ocean Colony Golf course for irrigation. s Although the District does
              not currently produce or sell recycled water to its customers, it is discussed in the
              UWMP as a potential future water supply source. The UWMP also recognizes the
              project site as a potential customer to use recycled water for turf irrigation, where the
              use of recycled water at the cemetery would allow for an increase in water availability
              during dry periods. To date, no funding has been requested for the provision of
              recycled water to the project site.

              Table 7, Projected Normal Water Supply and Demand Comparison - Acre Feet per
              Year (AFY), represents the District's estimate for future water supply production
              and future water demand up to the year 2030. Forecasting future water demand is
              accomplished by determining the growth in the number of water service accounts in
              a wholesale customer service area. These estimates included an expected reduction
              from local supply sources due to permitting, water quality, andlor drought issues.
              The SFPUC estimates that iflocal water supply sources are reduced due the above
              factors, then the District will need to compensate by finding new sources of supply
              (i.e., recycled water and or implementing more stringent conservation measures) and
              gradually increasing the amount of water purchased from the SFPUC. As the project
              site is under special contract with the District, and is therefore not considered within
              the "wholesale customer service area," these forecasted demand comparisons did not
              include the potential expansion of the existing cemetery on the project site.

                Table 7 - Projected Normal Water Supply vs. Demand Comparison - Acre Fee per Year (AFY)
                                                 2015           2020      I    2025      I     2030
                Supply Totals                    3,405          3,506          3,565           3,632
                Demand Totals                    3,361          3,473          3,473           3,585
                                                                          •




                Difference                        44             33       I
                                                                                 92      i
                                                                                                47
                Difference as %of Supply         1.3%           0.9%      !
                                                                               2.6%      I     1.3%
                Source: CCWD UWMP, 2005


               According to the District's 2005 Urban Water Management Plan (UWMP), the
               SFPUC can meet the demands of its retail and wholesale customers in years of
               average and above average precipitation. However, the SFPUC can reduce water
               deliveries to wholesale customers during periods of water shortage. Under the
               District's Water Shortage Contingency Plan, mandatory water waste prohibitions
             . would come into effect when water supply shortages reach 20% of the normal year

8   Sewer Authority Mid-Coastside Wastewater Treatment Facility, Recycled Water Information and Reports.
    Available at: http://www.samcleanswateLorglrw.htm; Last Accessed: November 25, 2009.
ANSWERS TO QUESTIONS
File No. PLN 20 J 0-00026
Page 54


               conditions. As previously discussed, the District's water supply to the project site
               would be terminated under these types of drought conditions.

               Phase 1 of the project would increase the acreage of irrigated landscape by a total of
               15 acres and therefore increase water supply demands from the District. Based on the
               project site's current irrigation usage, Phase 1 would increase the cemetery's water
               demand by 7.4 Million Gallons per Year (MGY), which would be equivalent to
               approximately 22 AFy. 9 This increased demand could be accommodated by the
               District's projected normal water supply through the year 2030. While the District
               does not provide water supply projections past the year 2030, it is anticipated that
               new water supply resources (i.e. recycled water, desalination, etc.) may also be
               available in order to accommodate the anticipated development of the region.

               As previously discussed, the proposed MLUP would be subject to the existing water
               supply contract with the project applicant. As such, in the event of a severe drought
               year, or long periods of water shortage, the District may decide to discontinue water
               services to the project site in an effort to conserve water for domestic, potable uses.
               Because the proposed MLUP does not include homes and/or institutions that require
               potable water resources, a discontinuation ofthe District's water services would only
               affect irrigation practices on the project site. Increased water demands from the
               implementation of the proposed MLUP would therefore not affect the District's water
               supply, as the District's right to restrict and/or discontinue service to the project site
               would prevent the increased demands from interfering with water entitlements.
               Therefore, the impact to water entitlements and the ability of the District to serve the
               existing and future water demand, with project implementation, is not considered
               significant.

        go 	   Will (or could) this project generate any demands that will cause a public facility
               or utility to reach or exceed its capacity?

               No. 	 See Item 6.f above.

        h. 	   Will (or could) this project be adjacent to or within 500 feet of an existing or
               planned public facility?

               No. There are no existing or planned public facilities within 500 feet of the project
               site.

        i.     Will (or could) this project create significant amounts of solid waste or litter?




9   1 mgd = 1,120 AFY
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
Page 55


             Yes, Not Significant. While the goal of the Phase I grading and construction
             operations is to keep all earthwork on-site, it is possible that these activities would
             temporarily generate minimal amounts of earth materials that would need to be
             disposed of at the Ox Mountain LandfilL Day-to-day cemetery operations would not
             produce significant amounts of solid waste and would be served by a landfill with
             sufficient permitted capacity.

     j. 	    Will (or could) this project substantially increase fossil fuel consumption
             (electricity, oil, natura] gas, coal, etc.)?

             Yes, Not Significant. Cemetery operations would require moderate amounts of
             fossil fuel consumption for electricity and heating systems. Construction vehicles and
             personal automobiles would also require gasoline or diesel to operate. However, the
             duration of construction and the small number of private vehicles that would utilize
             the new cemetery development is not considered a substantial increase in fossil fuel
             consumption in the project area. Refer to Item 5.c above for a discussion ofthe
             number of new vehicle trips the new cemetery development would generate.

     k. 	 Will (or could) this project require an amendment to or exception from adopted
             general plans, specific plans, or community policies or goals?

             No. While the operation of a cemetery/interment facility is not specifically listed as
             a permitted use in Section 6315 (Permitted Uses) within the Resource Management
             (RM) Zoning District, cemeteries are allowed in any zoning district upon the issuance
             of a use permit pursuant to Zoning Regulations Section 6500.c.3. Skylawn Memorial
             Park has operated with a County-issued use permit at this location since 1955,
             including its most recent iteration as Use Permit PLN 2000-00166, which was ini­
             tially approved in June 2002 and renewed in May 20 I 0 (the proposed Master Use
             Permit PLN 2010-00026 is currently under consideration is meant to replace all
             previous permits and encompass all current and future Skylawn operations). The
             Skylawn facility has been found to be in compliance with all applicable Zoning
             Regulations and General Plan policies at each use permit renewal since its issuance
             in 1955.

             The proposed Phase 1 development is consistent with the existing cemetery use, the
             RM zoning regulations, and the applicable General Plan Open Space policies. The
             project will not require any amendments or exceptions for the General Plan or any
             other adopted County plans, policies, or goals. The implementation of the mitigation
             measures proposed in this document will also ensure compliance with County
             Ordinance Code Section 8600 (Grading Ordinance).

      l. 	   Will (or could) this project involve a change of zoning?
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
Page 56


              No. As discussed in Item 6.k above, the project is consistent with the San Mateo
              County Zoning Regulations. A change of zoning is not necessary in order to
              complete Phase I of MLUP.

       m. 	 Will (or could) this project require the relocation of people or businesses?

              No. The project does not involve the relocation of people or businesses.

       n. 	   Will (or could) this project reduce the supply oflow-income housing? 


              No. The project will have no impact on the supply of low-income housing. 


       o. 	   Will (or could) this project result in possible interference with an emergency
              response plan or emergency evacuation plan?

              No. Please see response to Item 5.c above. Implementation of the proposed MLUP
              would not change the circulation or configuration of existing roadways. Access to the
              project site would be provided by the existing roadways. Therefore, no impact would
              occur.

       p. 	   Will (or could) this project result in creation of or exposure to a potential health
              hazard?
              Yes, Significant Unless Mitigated. Please see response to Item 4.d above. Imple­
              mentation of the proposed MLUP would include activities associated with park
              maintenance and embalming that occur on a regular basis. There would be a
              moderate amount of vehicle trips associated with the cemetery patrons. However,
              it is not expected that the new cemetery development would create or expose existing
              or future Skylawn employees and patrons to health hazards. Implementation of
              Mitigation Measure 22, above, will reduce the risk of construction related health
              hazards to a less than significant level.

7. 	   AESTHETIC. CULTURAL AND HISTORIC

       a. 	   Will (or could) this project be adjacent to a designated Scenic Highway or within
              a State or County Scenic Corridor?

              Yes, Not Significant. The Skylawn property is partially located within the Highway
              92 scenic corridor and is near the 1-280 and Skyline State Scenic Corridors. The
              Phase 1 project area is not located within any of the above-mentioned corridors.
              Portions of the eastern ridgeline within Phase 1 are partially visible from viewpoints
              within Skyline and 1-280 scenic corridors.

              The majority of the new cemetery proposed in the MLUP would be located within
              an internally oriented valley formed by the primary north/south Cahill ridge and a
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
Page 57


            significant secondary ridge running southeast to northwest through the middle of
            the site. As shown in Figure 4, new cemetery development in Phase 1 would occur
            immediately north of the existing cemetery area. This area is not visible from the
            local roadways or the selected viewpoints as 'shown in the visual simulations (Figures
             14 and 15). Because no development is proposed on top of the ridgelines on the site,
            future development would not be visible to travelers using 1-280. Therefore, impacts
            to scenic corridors and highways would not be significant.

     b. 	 Will (or could) this project obstruct scenic views from existing residential areas,
          public lands, public water body, or roads?

            Yes, Not Significant. As previously discussed under Item 7.a, above, all Phase 1
            burial/Interment facilities and structures would be set into the existing topography of
            the project site and would not be visible from the local roadways or sensitive
            viewpoints and would therefore not affect off-site views from scenic vistas.

     c. 	   Will (or could) this project involve the construction of buildings or structures in
            excess of three stories or 36 feet in height?

           No. None of the proposed improvements (mostly consisting of retaining walls
           associated with garden mausoleums, family estates and columbarium walls) would
           exceed 36 feet in height. Therefore, no impact would occur.
      d. 	 Will (or could) this project directly or indirectly affect historical or archaeo­
           logical resources on or near the site?

            Yes, Significant Unless Mitigated. A literature review was completed by the
            Northwest Information Center (NWIC) in order to identify any cultural resources on
            the project site. According to the review, there have been six cultural resource studies
            that cover approximately 20% of the project site. Previously assessed areas on the
            project site do not contain any recorded cultural resources. Federal, state, and local
            inventories also do not include recorded cultural resources on the project site. The
            NWIC report also indicates there are no Native American resources in or adjacent to
            the proposed project area referenced in the ethnographic literature.

            Native American cultural resources in this part of San Mateo County are normally
            found along ridges, on midslope benches, in valleys, and adjacent to intermittent and
            perennial watercourses. The project site consists of a number of these environmental
            settings and features, as it is located on Cahill Ridge, and includes lands along the
            slopes of the mountain, including drainage canyons and tributaries of Pilarcitos
            Creek. Given the similarity of environmental factors on the project site and the
            ethnographic sensitivity of the area, there is a possibility that unrecorded Native
            American cultural resources exist on the project site. Adherence to Mitigation
ANSWERS TO QUESTIONS
File No. PLN 2010-00026
Page 58


            Measure 23 will reduce the risk of disturbing previously undiscovered cultural
            resources to a less than significant level.

            Mitigation Measure 24: If archaeological and/or cultural resources are encountered
            during grading or construction activities, work shall be temporarily halted in the
            vicinity ofthe discovered materials and workers shall avoid altering the materials and
            their context until a qualified professional archaeologist has evaluated the situation
            and provided appropriate recommendations. The project applicant or archaeologist
            shall immediately notify the Current Planning Section of any discoveries made and
            shall provide the Current Planning Section with a copy of the archaeologist's report
            and recommendations prior to any further grading or construction activity in the
            vicinity.

            A review of historical maps indicates roadways/fence lines on the project site as early
            as 1859, and several buildings are depicted in the 1915 topographic maps. The 1956
            San Mateo topographic maps also indicate a quarry, four buildings, and one wireless
            receiving station, all within the project site. Although the formal inventories con­
            ducted for the project site have not identified recorded cultural resources, these
            unrecorded buildings/structures meet the Office of Historic Preservation minimum
            age standard that buildings, structures, and other objects 45 years or older may be
            of historical value.

            Just beyond the Phase 1 development area there is a vacant two-story, relatively
            intact building located along the eastern ridges approximately 1,000 feet north ofthe
            existing cemetery. The historical significance of the building is unknown; however,
            the building has unofficially been referred to as an old Coast Guard post by the
            project applicant. Development proposed in Phase 1 of the MLUP would not result
            in the demolition of this structure.

     e. 	   Will (or could) this project visually intrude into an area having natural scenic
            qualities?

            Yes, Not Significant. See responses to Items 7.a and 7.b above.

DH:pac - DJHU0618_WPH.DOC
                     United States Department of the Interior 	
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                                FISH AND WIL1)LIFE SERVICE 	
                                  Sacramento Fish and Wildlife Office
                                   2800 Cottage Way, Room W-2605
                                                                                                             -
                                                                                                             Col


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                                                                                                             =
                                                                                                             <
                                  Sacramento, Califomia 95825-1846

In Reply Refer To:
8I420-20II-TA-0076
                                                                   JAN 19 2011  ~:;1
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Mr. Dave Holbrook                                                                        CJ
                                                                                         "        ill
San Mateo County Planning and Building Department                                                  <
                                                                                                   IIi
Second Floor
455 County Center                                                                                   o
Redwood City, California 94603

Subject: 	       Comments on the Notice of Intent to Adopt Negative Declaration for the Skylawn
                 Memorial Park Master (20-year) Use Pennit

Dear Mr. Holbrook:

This letter is in response to the San Mateo County (County), Notice ofIntent to Adopt Negative
Declaration (Notice) for the Skylawn Memorial Park Master (20-year) Use Permit (Project).
Your Notice was received by this office of the U.S. Fish and Wildlife Service (Service) on
October 27,2010. The purpose of this letter is to provide comments to the County as requested
in the Notice. Per a phone conversation with Mr. Holbrook on December 20, 2010, these
comments are being submitted after the closing of the comment period. The Service is issuing
this letter under the authority of the Endangered Species Act of 1973, as amended (16 U.S.C.
1531 et seq.) (Act). Our comments and recommendations are provided to assist you with your
environmental review of the project and are not intended to preclude future comments from the
Service.

This document is based on: (1) the Notice of Intent to Adopt Negative Declaration received on
October 27,2010; (2) the Initial Study Pursuant to CEQA Project Narrative and Answers to
Questions for Negative Declaration File No.: PLN 2010-00026, Skylawn Memorial Park Master
Use Permit (Project Narrative); (3) the Initial Study Environmental Evaluation Checklist for the
Project; and (4) other information available to the Service. Ofnotable absence from the Service
resources for these comments are: the "Biological Resources Constraints and Opportunities
Evaluation", the results of a 2009 focused botanical survey conducted by Vollmar Consulting,
the Development Agreement, and the Master Land Use Plan for Skylawn Memorial Park. All of
the aforementioned documents are referenced in the Project Narrative.

The Service is concerned about the potential adverse effects ofthe proposed project on a number
of listed species. The listed species include but are not limited to; the threatened California red­
legged frog (Rana draytonii) (CRLF), endangered San Francisco garter snake (Thamnophis
Mr. Dave Holbrook                                                                                2

sirtalis tetrataenia) (SFGS), and the threatened bay checkerspot butterfly (Euphydryas editha
bayensis).

The County determined that the Project will not have a significant impact on the environment.
The project is tied into a Development Agreement and Master Land Use Plan for the Skylawn
Memorial Park and is one phase of seven phases of development to occur sequentially based on
interment needs well into the future. Phase 1 will affect 35 acres of the 521 acre property.
Currently 94 acres are developed and 226 acres are designated for development with 201 acres
scheduled for preservation as a "Preservation and Environmental Management Zone". Phase 1
development will include; concentrated ground burial private estates, garden mausoleums for full
body burials, columbaria for internment of cremains, and "green" burial areas.

Comments

The Service does not concur with the County that the proposed project and mitigation measures
will have no adverse effect on federally threatened and endangered species. We suggest that the
County contact the Service to discuss the appropriate medium for authorization of incidental take
oflisted species during the proposed development project(s) and proposed mitigation measures.

 The Service is interested in assisting the County of San Mateo and/or the applicant in the
 development of a project that has no adverse effect on federally listed species such as the
 California red-legged frog, San Francisco garter snake, and the bay checkerspot butterfly. If you
 have any questions regarding our comments, please contact Dan Cordova or Ryan Olah at the
 l~lt,er.head"address, telephone 916-414-6600, or via electronic mail (Dan_ Cordova@fWs.gov;
'Ryan_ Qlah.@fWs.gov).


                                                  Sincerely,




                                                  Christopher D. Nagano
                                                  Division Chief, Endangered Species Program
~WCALlFORNIA                                                                                                                            .... G~ove""m.!.!>!!.Qr
                BUSINESS. TRANSPORTATION AND HOUSING A~GE~N~C2..Y_ _ _ _ _ _ _ _ _ _ _2:>A~RN..."O"",LD",-S""C HW""'-WAR"",Z"",EN"""E""'GG ER~.
                                                                                                             ...


DEPARTMENT OF TRANSPORTATION
III GRAND AVENUE
P. O. BOX 23660
OAKLAND. CA 94623-0660
PHONE (510) 622-5491                                                                                                                      Flex your power!        .....
FAX (510) 286-5559                                                                                                                      Be energy efficient!      Ii
TTY 711
                                                                                                                                                                   e
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                                                                                                                                                                  t:
                                                                                                                                                                  <
    November 30, 2010 

                                                                                                            SM092153 

                                                                                                            SM-92-5.25 

                                                                                                            SCH# 2010102045 

     Mr. David Holbrook 

     Department of Public Works 

     San Mateo County 

     455 County Center, Second Floor 

     Redwood City, CA 94063 


     Dear Mr. Holbrook:

     Skylawn Memorial Park Master Land Use Permit - Mitigated Negative Declaration

     Thank you for including the California Department of Transportation (Department) in the
     environmental review process for the Skylawn Memorial Park Master Land Use Permit project.
     The following comments are based on the project's Mitigated Negative Declaration (MND). As
     the lead agency, the County of San Mateo is responsible for all project mitigation, including any
     needed improvements to state highways. The project's fair share contribution, financing,
     scheduling, implementation responsibilities and lead agency monitoring should be fully
     discussed for all proposed mitigation measures. Required roadway improvements should be
     completed prior to issuance of the Certificate of Occupancy. Since an encroachment permit is
     required for work in the state right of way (ROW), and the Department will not issue a permit
     until our concerns are adequately addressed, we strongly recommend that the County work with
     both the applicant and the Department to ensure that our concerns are resolved during the
     environmental review process, and in any case prior to submittal of a permit application.
      Additional comments may follow pending the review of technical plans and during the
     encroachment permit process; see the end of this letter for more information regarding
     encroachment permits.

     Highway Operations
     Page 46 refers to a Figure 10 that is meant to illustrate turning movements and counts for the
     State Route (SR) 921Skylawn Memorial Park Driveway and SR 92135 intersections. However,
     the figure included in the document depicts the Ridges-Section D. Please provide the correct
     Figure 10 along with the data and analysis indicated in the report.

     Our field observations indicate there could be an impact at the SR 92/Skylawn Memorial Park
     Driveway on eastbound SR 92 traffic during the time burial services conclude. Do you provide
     flagman traffic control during this time? Please discuss mitigation measures to alleviate any

                                                "Caltrans improlles mobility across California"
                             --,J   -­


 'November 30, 2010 

  Page 2 



outbound traffic and through traffic conflicts at this intersection.

Cultural Resources
The project environmental document must include documentation of a current archaeological
record search from the Northwest Information Center of the California Historical Resources
Information System if construction activities are proposed within state ROW. Current record
searches must be no more than five years old. The Department requires the records search, and if
warranted, a cultural resource study by a qualified, professional archaeologist, to ensure
compliance with California Environmental Quality Act (CEQA), Section 5024.5 of the
California Public Resources Code and Volume 2 of the Department's Standard Environmental
Reference (hnp:llser.dot.ca.gov). These requirements, including applicable mitigation, must be
fulfilled before an encroachment permit can be issued for project-related work in state ROW;
these requirements also apply to National Environmental Policy Act (NEPA) documents when
there is a federal action on a project. Work subject to these requirements includes, but is not
limited to: lane widening, channelization, auxiliary lanes, and/or modification of existing features
such as slopes, drainage features, curbs, sidewalks and driveways within or adjacent to state
ROW.

EncroaehmentPennu
Please be advised that work that encroaches onto the state ROW reqUires an encroachment
permit that is issued by the Department. To apply, a completed encroachment permit application,
environmental documentation, and five (5) sets of plans. clearly indicating state ROW, must be
submitted to: Office of Permits, California DOT, District 4, P.O. Box 23660, Oakland, CA
94623-0660. Traffic-related mitigation measures will be incorporated into the construction plans
during the encroachment permit process. See the following website link for more information:
http://www.dot.ca.gov/hqltraffops/developserv/permits.

 Please feel free to call or email Sandra Finegan of my staff at (510) 622-1644 or 

 sandra finegan@dot.ca.gov with any questions regarding this letter. 


 Sincerely,


 ~J~
 LISA CARBONI 

 District Branch Chief 

 Local Development - Intergovernmental Review 





                                     "Cal/ranI improves mobiUry across California"
                              Best Management Practices 


                           Fertilizer and Pesticide Application 


Management practices to minimize fertilizer runoff:
  • 	 We do not apply fertilizer or herbicide products within 25 feet of property line
       boundaries.
  • 	 We do not apply fertilizer products containing a Nitrate source of Nitrogen within
       a 72 hour window of a "significant" rainfall event (greater than W' predicted).
  ®	   Before application, we inspect and clean gutters, catch-basins and bio-filtering
       retention ponds to ensure that any water run-off is properly bio-filtered prior to
       dissipation.
   e 	 We irrigate immediately following a fertilizer application (that evening) to wash
       the product into upper soil profile.
   • 	 Turfgrass has the ability to absorb nitrogen within 24-48 hours.
   e 	 Irrigation following a fertilizer application is performed in short periods to 

       minimize run-off. 

   • 	 We wash off equipment on turf areas that will absorb any nutrients that may wash
       off the machine. 

   .. We utilize slow-release products that provide lower risk of runoff. 

   .. Only our best trained (senior staff) make fertilizer applications. 


Management practices to minimize pesticide contact on non-target areas:
  (II)   We do not apply herbicide products within 25 feet of property line boundaries.
  ®      We do not apply herbicide products within a 4 hour window of any rainfall event
         (showers predicted).
  ill>   We do not apply herbicide products when wind speeds exceed 5 mph.
   (;) 	 Before application, we inspect and clean gutters, catch-basins and bio-filtering
         retention ponds to ensure that any water run-off is properly bio-filtered prior to
         dissipation.
   e 	 We apply early in the morning to allow plant absorption and prevent the evening
         irrigation from washing the product off the plant.
   ~ 	 We wash off equipment on turf areas that will absorb any pollutants that may
         wash off the machine.
    III  Only our best-trained (senior staff) make pesticide applications, under the
         supervision of a licensed applicator.

                                                                                     3/1112010

				
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