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2017-06 (EG)RESOLUTION NO. PC 2017-06 A RESOLUTION OF THE CITY OF ENCINITAS PLANNING COMMISSION APPROVING A MINOR USE PERMIT AND COASTAL DEVELOPMENT PERMIT FOR THE CONSTRUCTION OF A NEW DETACHED HOBBY SHED EXCEEDING THE STANDARD MAXIMUM AREA FOR THE PROPERTY LOCATED AT 653 CAMINO EL DORADO (CASE NO. 16-072 MIN/CDP; APN 258-141-12) WHEREAS, Shanna Johnson submitted an application for a Minor Use Permit and Coastal Development Permit to construct a new detached hobby shed exceeding the standard maximum area for the property located at 234 Fifth Street, legally described in Exhibit A; WHEREAS, the Planning Commission conducted a duly noticed public hearing on March 16, 2017; NOW, THEREFORE, BE IT RESOLVED that the Encinitas Planning Commission hereby APPROVES Case No. 16-072 MIN/CDP based on the following Environmental Determination and Findings: Section 1. California Environmental Quality Act Determination The project has been determined to be exempt from environmental review pursuant to Section 15303(e) of the California Environmental Quality Act (CEQA) Guidelines. Section 15303(e) exempts accessory (appurtenant) structures including detached accessory structures. The project meets the criteria for the exemption. The project does not qualify as one of the exceptions prescribed under Section 15300.2 of the CEQA Guidelines and no historic resources are affected by the proposed project. Section 2. Discretionary Action(s) Findings Based on the findings for a Use Permit as per Encinitas Municipal Code Section 30.74.070 and the aforementioned analysis, Planning Commission has made the following findings to support the approval, with conditions: Findings for Minor Use Permit Explanation of Finding 1. The location, size, design or operating characteristics of the proposed project will be incompatible with or will adversely affect or will be materially detrimental to adjacent uses, residences, buildings, structures or natural resources, with consideration given to, but not limited to: a. The inadequacy of public facilities, Previously developed properties surround the services and utilities to serve the proposed site and all public utilities are in place to serve project. the project. Page 1 of 12 Findings for Minor Use Permit Explanation of Finding b. The unsuitability of the site for the type and The suitability and intensity of development of intensity of use or development, which is the proposed detached hobby shed was proposed. reviewed. The request to exceed the standard allowable area for the hobby shed is not significant in nature relative to the size of the 1.16-acre lot, the resultant bulk and mass, and building height of the proposed building, and its location on the property, and will not be inconsistent with the established character of the community since many homes are on similarly-sized half-acre lots in area consistent with the zoning. The size of the proposed detached hobby shed has been analyzed in light of its surroundings and it has been determined that, as conditioned, the development will be compatible with and complement the surrounding land uses and residential structures. Additionally, the proposed project'meets all applicable zoning requirements as outlined in the Encinitas Municipal Code for projects located in the RR2 zone. The project is consistent with all RR2 zone development regulations and proposes no encroachment into the steep slope areas. Public improvements and utility services are available to serve the site. c. The harmful effect, if any, upon Previously developed residential properties environmental quality and natural surround the subject property. There are no resources of the city. environmental issues associated with the project. The project has been determined to be exempt from environmental review pursuant to Section 15303(e) of the California Environmental Quality Act (CEQA) Page 2of12 Findings for Minor Use Permit Explanation of Finding 2. The impacts of the proposed project will The proposed project, as conditioned, is adversely affect the policies of the consistent with the policies of the General Encinitas General Plan or the provisions of Plan, and applicable provisions of the this Code; or Encinitas Municipal Code. The project will blend in and will complement the unique rural character of the Old Encinitas area. The request to exceed the standard allowable area for the hobby shed is not significant in nature relative to the size of the 1.16-acre lot, the resultant bulk and mass, and building height of the proposed hobby shed, and its location on the property, and would not be inconsistent with the established character of the community since many homes are on similarly-sized half-acre lots in area consistent with the zoning. The project meets all of the zoning standards of the RR2 zone, including setbacks, lot coverage, parking and building height. The City's third party geotechnical consultant (Geopacifica) concluded that the geotechnical reports and addendum provided as a part of the project review have addressed all site conditions and have provided all the necessary information to satisfy the requirements of the Encinitas Municipal Code. 3. The project fails to comply with any other As conditioned, the project complies with all regulations, conditions or policies imposed applicable policies of the General Plan, Local by this Code. Coastal Program, applicable provisions of the Municipal Code, and with all applicable development standards of the underlying RR2 zone and would be required to comply with all applicable Building and Fire codes through the standard building permit plan checking Page 3o/12 Based on the findings for a Coastal Development Permit as per Encinitas Municipal Code Section 30.80.090 and the aforementioned analysis, Planning Commission has made the following findings to support the approval, with conditions: Finding for Coastal Development Permit Explanation of Finding 1. The proposed project is consistent The proposed hobby shed complies with all with the certified Local Coastal Program of the City of Encinitas. development standards of the RR2 zone including those related to height, area and setbacks. The project is consistent with the policies of the City's certified Local Coastal Program including the General Plan and the Municipal Code. Based upon the information contained in the site - specific geotechnical letter report, the applicant has demonstrated that the structure would not encroach into the steep slope area of the Hillside /Inland Bluff Overlay. The City's third party geotechnical consultant (Geopacifica) concluded that the geotechnical reports and addendum provided as a part of the project review have addressed all site conditions and have provided all the necessary information to satisfy the requirements of the Encinitas Municipal Code. 2. The proposed project is consistent The project conforms to Public Resources Code with the certified Local Coastal Section 21000 (CEQA). The project has been Program of the City of Encinitas. determined to be exempt from environmental review The proposed development pursuant to California Environmental Quality Act conforms with Public Resources (CEQA) Guidelines Sections 15303(e). The project Code Section 21000 et al. (CEQA) meets the criteria of the exemption. None of the and that there are no feasible exceptions in CEQA Guidelines Section 15300.2 mitigation measures or feasible exists and no historic resources will be impacted by alternatives available which would the proposed project. substantially lessen any significant adverse impact that the activity may have on the environment. 3. For projects involving development This finding is not applicable because the property is between the sea or other body of not located between the sea and the nearest public water and the nearest public road, road. approval shall include a specific finding that such development is in conformity with the public access and public recreation policies of Section 30200 et seq. of the Coastal Act. Page 4 of 12 The above eOVnOOOl8Dta| determination and findings are supported by the DliDUt8S, OlapS. and exhibits, all of which are herein incorporated by reference. BE IT FURTHER RESOLVED that based on the Environmental Determination and Findings henainbefor8 adopted by the Planning Commission, Case No. 18-072 C}DP is hereby subject ho the conditions iO Exhibit B. PASSED AND ADOPTED this 16 th day of March, 2017, by the following vote, to wit: Mvp�o ml- pa'� 4c�reSt ry NOTE: This 8CUOO is subject to Chapter 1.04 of the K8uOiCip8| Code, which specifies time |inlhS for legal challenges. Page 5of12 EXHIBIT "A" RESOLUTION NO. PC 2017 -06 CASE NO. 16 -072 MIN /CDP LEGAL DESCRIPTION PARCEL 1: ALL THAT PORTION OF THE SOUTHEAST QUARTER OF THE NORTH EASTQUARTER OF SECTION 15, TOWNSHIP 13 SOUTH, RANGE 4 WEST, SAN BERNARDINO BASE AND MERIDIAN IN THE CITY OF ENCINITAS, COUNTY OF SAN DIEGO STATE OF CALFORNIA - ACCORDING TO UNITED STATES GOVERN MENTSURVEY APPROVED APRIL 19, 1881, DESCRIBED AS FOLLOWS: BEGINNING AT THE SOUTHEAST CORNER OF THE NORTH EASTQUARTER OF SECTION 15; THENCE NORTH 0 °50' 14" EAST ALONG THE EAST LINE OFSAID SECTION 15,506.51 FEET TO THE TRUE POINT OF BEGINNING: THENCE ALONG SAD EAST LINE NORTH 0° 50'14" EAST 127 FEET THENCE PARALLEL WITH THE SOUTH LINE OF SAID SOUTHEAST QUARTER OF THENORTHEAST QUARTERNORTH 890 39'52" WEST 430 FEET, THENCE SOUTH0950 14 WEST 127 FEET TO A LINE WHICH ISDRAWN THROUGH THE TRUE POINT OF BEGINNING PARALLEL WITH THE SOUTHERLY LINE OF SAID LOT, THENCE ALONG SAD PARALLEL LINE SOUTH 890 39'52 "EAST 430 FEET TO THE TRUE POINT OF BEGINNING. EXCEPTING THEREFROM ALL OF THE MINERALS, MINERAL DEPOSITS, MINERALOILS AND NATURAL.GASES OF EVERY KIND AND NATURE, TOGETHER WITH THE RIGHT TO ENTER UPON AND OCCUPY THE SAD PREMISES FOR THE PURPOSE OF PROSPECTING DRILLING FORMINING ORREMOVING MINERALS, MINERAL OILS AND GASES AS RESERVED INDEED RECORDED AUGUST 15, 1921 IN BOOK 860, PAGE 36 OF DEEDS. 90091 :01 AN EASEMENT FOR ROAD AND PUBLIC UTILITY PURPOSES OVER THOSE STRIPS OF LAND AS DELINEATED AND DESIGNATED AS "30.00 FEET ROAD EASEMENT ON RECORD OF SURVEYMAP NO. 2385, FILED IN THE OFFICE OF The COUNTY RECORDER JANUARY 30, 1950, LYING SOUTHERLY OF THE NORTHERLY LINE OF THE ABOVE DESCRIBED PARCEL AND ITS WESTERLY PROLONGATION. EXCEPTING THEREFROM THOSE PORTIONS THEREOF LYING WITH IN PARCEL NO. 1 ABOVE. Page 6 of 12 Sci EXHIBIT "B" RESOLUTION NO' PC 2017-06 Case No. 16-072 MIN/CDP A I- Applicant: Shanna Johnson Location: O53 Camino BDorado � SPECIFIC CONDITIONS: SC2 At any time after two years from the date of this approval, on March 16, 2019, at 5 p.m., or the expiration date of any extension granted in accordance with the Municipal Code. the City may require a noticed public hearing to be scheduled before the authorized agency to determine if there has been demonstrated a good faith intent to proceed in F8|i8OCe OD this approval. If the authorized agency finds that 2 good faith intent to proceed has not been dennonstn@ted, the application aho|| be deemed expired as of the above date (or the expiration date of any extension). The determination of the authorized 8O8OCy may be appealed to the City Council within 15 days Of the date of the determination. 8C5 This project iG conditionally approved aa set forth on the application and project druvvngn stamped received by the City on February 2, 2017, consisting of four sheets including a Slope Analysis (11 inches by 14 inches), Site Plan /Sheet 1\. Elevations (Sheet 2). Construction Details (Sheet S1\ all designated ae approved by the Planning Commission OO yWaPCh 10' 2017, and Sh8U not be altered without express authorization by the Planning and Building Department. SCA Prior to building permit isGU@OC8' Pursuant to Chapter 30.343.030 (Hillside/Inland Bluff [}vRdav\, phO[ to the recording fiD8| OCCUp8Ocy, the 8nniC8[t Sh8U eX8CUt8 and F8COrd an easement placing all steep S|Opae of 2596 gradient or more in a slope prosHn/8UOn Gas8[O8Ot 0O the satisfaction of the P|8ODiOg and Building O8p8rtDlgDL Said 888erOHDt shall prohibit grading or p|8ceOO8Dt Of any StRu{tUF8 within Said Steep S|Op8 8Fe8S unless authorized by the City VfEncinitas. SCB The following conditions shall be completed and/or fulfilled to the satisfaction of the Engineering Services Division: Prior to is8U8DC8 of grading Or building p8[Dlit. the 3pO|iC8[d shall dedicate to the City of Encinitas an Easement for Public Street Right-of-Way along the property's frontage to ensure a center line to property line distance of 30 feet. 2. The project's Report Of Preliminary (]8OtHChOiC8| |DV8Gtg8bOD prepared by Christian VVh8H|8[ Engineering identifies approximately five and one-half feet Of unsuitable Dl8t8[|8| at the |UC8tiOD of the p[OpOS8d structure. Consistent with the report's F8OO[D[D8Od8bODg. the applicant shall either remove and reS0Dlp8Ctthe GOi| under the supervision Of the project's S0i|SSngineerORpu}vide a deepened and reinforced fOUDd8bOD system t0 CO0p8DG8te for the pOL8Oti8||y CQ0pF8SSib|8 material. A Page 7of1u grading plan and permit shall be obtained from the City of Encinitas Jremedial grading is to be performed. 3. As shown OD the K8|N/CDP site plan, the applicant shall provide stO[nlvva[er quality treatment facilities to collect and treat the runoff generated by all new and/or n9nnovoU and replaced impervious surfaces. Additiona||y, any increase in runoff naau|bng from an increase in impervious surface shall be mitigated by sizing and designing the |yNP facilities to the HyWP sizing [8qUi[e09OtG with 8 |OVV8[ flow threshold of 0.5C>2 to eOGun* no net increase in CnOeo lot drainage. The treatment facility IMPs shall be located entirely within private property. The cross section of the IMP facility 0n the Site Plan oho|| show 10-inohas ofponding. This facility shall be sized On the site plan for an effective area equal t0 8.596 of the new Or nap|aCSd impervious surface area. 4. The existing survey monuments per RyOS2385shall be referenced oD the site plan and shall bg protected in-p|aoe. K any monument ia disturbed or destroyed it shall be replaced by licensed land surveyor and a Corner Record or Record of Survey shall be filed with the County prior tO release Ofsecurities. G1 STANDARD CONDITIONS: CONTACT THE PLANNING AND BUILDING DEPARTMENT REGARDING COMPLIANCE WITH THE FOLLOWING CONDITION(S): G2 This approval may be appealed to the City Council within 15 calendar days from the date of this approval iD accordance with Chapter 1.12Ofthe W1UOidpu| Code. G4 Prior to building permit issuance, the owner shall onuo8 o covenant regarding real property to be recorded. Said covenant shall set forth the tannS and conditions of this grant of approval and shall be of form and content satisfactory to the Planning & Building Director. The [)vvner(a) agree, in acceptance of the conditions of this approval, to waive any d8i0G Of liability Gg8iDS1 the City and 8g[8eG to iDd8N0Oifv, hold h8FOl|8SS and defend the City and City's eDlp|Oy8eS relative tO the action tO approve the project. G5 Aop[Ov8| of this request shall not waive cOn0D|i8OD8 with any sections of the K8UDiCip8| Code and all other applicable City regulations in effect at the time of Building Pannb issuance unless specifically waived herein. G10 All retaining and other freestanding walls, feOC8S, and eDC|OSUR}S Sh8|| be 3[Chit9CtU[8||y designed in 8 manner similar to, and consistent with, the primary structures (e.g. stucco- coated masonry, split-face block or slump stone). These items shall be approved bythe P|3DOiOg and Building O8p8rtOl8Ot prior to the iSSUaDC8 Of building and/or grading permits. G12 Prior to any use of the project site pursuant to this permit, all conditions of approval contained h8[8iD shall be completed Or S8cUn8d to the satisfaction Of the Planning and Building Department. G13 The applicant Shg|| pay development fees at the established rate. Such fa8S may include, but not b8 limited to: Permit and Plan Checking Fees, Water and Sewer Service Feao, School Fees, Traffic Mitigation Feos, Rood Control Mitigation Fees, Park Page 8of1u Mitigation Fees, and Fire Mitigation/Cost Recovery Fees. Arrangements to pay these fees shall be made prior tVbuilding permit issuance tO the satisfaction 0f the Planning and Building and Engineering Services Departments. The applicant is advised to contact the Planning and Building Department regarding Pork Mitigation Rmea. the Engineering Services Department regarding Hood Control and Traffic Fees, applicable School District(s) regarding School Fees, the Fire Department regarding Fire K8iUg8UOO/Coot Recovery FH8S, and the applicable Utility Departments or Districts regarding Water and/or Sewer Fees. G18 Garages enclosing required parking spaces shall bekept available and usable for the parking Of OVVO8r/ieO8Ot vehicles at all hOles' and may not be rented or conveyed separately from the appurtenant dwelling unit. G21 All utility connections shall be designed 03 coordinate with the @[Chit8CtU[8| 8keDl8DtG Of the Site so as not to be exposed except where necessary. Locations of pad mounted tr2DSfDODe[G' Dlei8[ boxes, and other utility related items Gh8U be included in the site p|8O SUbO0iUBd with the building permit 8pp|iC8bUO with an appropriate SCnBHOiDg treatment. Tnansf0Onera, h*nnina| boxeo, meter nabinets, pedeato|a, ducts and other facilities may be placed above ground provided they are screened with landscaping. USE PERMITS U1 At all ti[D88 during the 8fheCtV8 period of this permit, the nBSpOOSib|8 p8dv 8h8U obtain and Dl@iDt8iD in valid force and 8fheC1' each and every license and permit required by governmental agency for the operation of the authorized activity. U2 In the 8V8Dt that any of the conditions of this p8rOld are not satisfied, the Planning and Building Department shall cause a noticed hearing to be set before the authorized agency to determine whether the City of Encinitas should revoke this permit. iJ3 Upon 8 ShOVVOg of compelling public necessity demonstrated at D0bCed h88hOg' the City Of EOCiDit8S, acting through the authorized 8g8DCy' may add, 8Ol8Dd, or delete conditions and regulations contained iD this permit. U4 Nothing in this permit Sh3U relieve the applicant from complying with conditions and regulations generally imposed upon activities similar iDnature to the activity authorized by this permit. U5 Nothing in this permit 8h8U authorize the applicant to intensify the authorized activity beyond that which is specifically described in this permit. U7 Any fUtU[8 OlQdUiC8tODs to the @pp[OV8d project will be [8v8VV8d [e|GUVe to the findings for substantial CODfOrD8nDe with 8 use permit COOt8iD8d in SeCUOO 30.74.105 Of the Municipal Code. MOdifiC8UOOS beyond the scope described therein will require submittal of an amendment to the use permit and approval by the authorized agency. U8 All project grading Gh8U OODf000 with that shown OO the approved project p|8OS. K DO grading is proposed on the 8pp[OV8d p|8DG' Or subsequent grading plans are inconsistent with the grading shown ODthe approved plans, 8 use permit modification for such grading shall be obtained from the authorized agency Ofthe City prior to iSSUGnCe of grading or building permits. Page 8of1u CONTACT THE ENCINITAS BUILDING DIVISION REGARDING COMPLIANCE WITH THE FOLLOWING CONDITION(S): B2R The applicant Gh8U Submit o c0nnokah* set Of construction plans to the Building Division for p|aOCh8Ck processing. The submittal Gh8U include o GOi|G/Ge0t8ChOica| Report, GtnJ{tU[8| ca|CW|8bOOS. and State Energy 0Ornp|iaOC8 documentation (Title 24\. COOSt[u[tiOD p|8DS shall iDC|Ud8 a site p|8D' 8 fOUOd8tiOO p|8D' floor and nDOf framing p|ano. floor plan(s), section detoi|e, exterior e|evaUons, and materials specifications. Submitted plans must show compliance with the |@baat adopted editions of the California Building Code (The UDifO[[D Building Code with California A[D8OdDl8OtS' the California Mechanical, Electrical and Plumbing Codes). These oonnrnentG are preliminary only. A COOOpF8h8OSiVe p|aOChBCk will be CODlp|8t8d prior to permit iSSU@DCe and additional technical COd8 [gquiP8OleDtS may be identified and changes tO the originally submitted plans may be required. F1 FIRE CONDITION(S): CONTACT THE ENCUNITAS FIRE DEPARTMENT REGARDING COMPLIANCE WITH THE FOLLOWING CONDITION(S): F13 ADDRESS NUMBERS: Approved numbers and/or addresses shall be placed on all new and existing buildings and 81 appropriate additional locations 880Jb8 plainly visible and legible from the street Or roadway fronting the property from 8iUle[ di[gCU0D Of approach. Said numbers shall contrast with their buukorOund, and shall meet the following FDiDiDluDl standards as to size: 4 inches high with 8 1/2- inch DtnDk8 width for residential buildings, 8 iDCh8S high with 3 1/2-iOCh stroke for CODlDl8FCi8| and rDU|ti-fgDli|y [gGid8Dti3| buildings, 12 inches high with 8 1-inch stroke for iDdUSt[i8| buildings. Additional OU0b8n5 Gh8|| be required where deemed O9CSGS8ry by the Fire K8a[Sh3|, such as rear access doors, building corners, and entrances to commercial centers. CONTACT THE ENGINEERING SERVICES DEPARTMENT REGARDING COMPLIANCE WITH THE FOLLOWING CONDITION(S): E2 All City Codes, Regu|8tiODS. and pO|i[j88 in effect at the time Of building/grading permit issuance shall apply. E3 All drawings submitted for Engineering permits are required tn reference the NAV[]88 datum; the NG\/[}28 datum will not beaccepted. EG1 Grading Conditions EG3 The developer shall obtain 8 grading permit prior to the commencement nfany clearing or grading of the site. EG4 The grading for this project is defined in Chapter 23.24 of the Encinitas Municipal Code. Grading shall be performed under the observation of a civil engineer whose responsibility it Page mof10 shall b8tOcoordinate site inspection and testing [Oensure compliance 0f the work with the approved grading plan, submit required reports to the Engineering 8enviC8e Director and verify compliance with Chapter 23.24Ofthe Encinitas Municipal Code. EG5 No grading shall occur outside the limits of the project unless u letter of permission is obtained from the owners of the affected properties. EG8 88p@[8t8 grading plans shall be submitted and 8ppFOV8d and G8pon3t8 grading pHrnoihS issued for b000Vv or disposal sites if located within the city limits. EG8 A soils/geological/hydraulic report (as applicable) shall be prepared by a qualified engineer licensed bythe State Of California tD perform such work. The report shall be submitted with the first grading p|8D submittal and nhg|| be approved prior to issuance of any grading permit for the project. EG8 Prior to hauling did or construction materials to any proposed construction site within this project the deve|Op8reho|| submit to and receive approval from the Engineering Services Director for the pnJpnG8d haul route. The developer shall comply with all conditions and requirements the Engineering Services Director may impose with regards to the hauling operation. EG14 A grading permit aho|| be obtained for this project un|8SG the proposed grading is exempt under section 23.24.080 of the Municipal Code. If the proposed grading is exempt from permit requirement, the Owner shall provide o precise site plan prior to approval of a building permit. The building site p|8O Sh3|| provide design for dr8iD8Q8 irOpnDV8OO9DtS, erosion c0Otno|. storm water pollution COntno|. and on-site pavement. ED1 Drainage Conditions ED2/\ An ennGi0D COOtPO| system Sh8|| be designed and iDSt8||8d OOSihedU[iDg all cOOSt[U[tiOO activity. The Sysi8Dl shall pPeV8Di discharge of G8dinl8Ot and all other pollutants onto adjacent streets and into the ohornn drain ayab3Dl. The City of Encinitas Best Management Practice Manual shall be employed to determine appropriate storm water pollution control practices during CODSt[UCtiOn. E[J5 The owner shall pay the Current local drainage area fee prior to issuance of the building permit for this project or shall COOGt[UCt drainage SySt8Dls in COOforO8OC8 with the K8aGt8[ Drainage P|@O and City of Encinitas Standards as n3qUiF8d by the Engineering G8rviC8S Director. E[)O The owner of the subject property shall execute a hold honn|eae covenant regarding drainage across the adjacent property prior to approval of the any grading or building permit for this project. ES1 Street Conditions E85 Prior to any work being performed in the public right-of-way, 8 right-of-way COOSt[UCtiOD permit shall be obtained from the Engineering Services Director and appropriate fees paid, iO addition 03 any other permits required. Page 11u(12 EU1 Utilities Conditions EU4 All proposed utilities within the project shall be installed underground including existing utilities unless exempt by the Municipal Code. ESW1 Storm Water Pollution Control Conditions ESW5 The project must meet storm water quality and pollution control requirements. The applicant shall design and construct landscape and /or turf areas and ensure that all flows from impervious surfaces are directed across these areas prior to discharging onto the street. A Grading Plan identifying all landscape areas designed for storm water pollution control (SWPC) and Best Management Practice shall be submitted to the City for Engineering Services Department approval. A note shall be placed on the plans indicating that the modification or removal of the SWPC facilities without a permit from the City is prohibited. ESW9 For storm water pollution control purposes, all runoff from all roof drains shall discharge onto grass and landscape areas prior to collection and discharge onto the street and /or into the public storm drain system. Grass and landscape areas designated for storm water pollution control shall not be modified without a permit from the City. A note to this effect shall be placed on the Grading plan. ES1 Street Conditions ES5 Prior to any work being performed in the public right -of -way, a right -of -way construction permit shall be obtained from the Engineering Services Director and appropriate fees paid, in addition to any other permits required. Page 12 of 12