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HomeMy WebLinkAbout03 CUP 02-017 DR 02-017Report to the ITEM #3 Planning Commission DATE: SEPTEMBER 23, 2002 SUBJECT: CONDITIONAL USE PERMIT 02-017 AND DESIGN REVIEW 02-017 APPLICANT: VERIZON WIRELESS 15505 SAN CANYON AVENUE IRVINE, CA 92718 TETRA TECH WIRELESS 357 VAN NESS WAY, SUITE 150 TORRANCE, CA 90501 ATTN: JOHN KOOS PROPERTY OWNERS: SOUTHERN CALIFORNIA EDISON 2244 WALNUT GROVE AVENUE ROSEMEAD, CA 91770 ATTN: ERIC MANUEL LOCATION: 2031 BRYAN AVENUE ZONING: RESIDENTIAL AGRICULTURAL (RA) ENVIRONMENTAL STATUS: THIS PROJECT IS CATEGORICALLY EXEMPT PURSUANT TO SECTION 15303, CLASS 3 OF TITLE 14, CHAPTER 3 OF THE CALIFORNIA CODE OF REGULATIONS (GUIDELINES FOR THE CALIFORNIA ENVIRONMENTAL QUALITY ACT) REQUEST: AUTHORIZATION TO ESTABLISH A WIRELESS FACILITY ON AN EXISTING UTILITY POLE AND OUTDOOR EQUIPMENT FOR VERIZON WIRELESS AT THE EXISTING SOUTHERN CALIFORNIA EDISON SUBSTATION. RECOMMENDATION That the Planning Commission adopt Resolution No. 3845 approving Conditional Use Permit 02-017 and Design Review 02-017. Planning Commission Report CUP 02-017 AND DR 02-017 September 23, 2002 Page 2 BACKGROUND The applicant is requesting approval to establish a wireless communication facility for Verizon Wireless. The site is zoned Residential Agricultural (RA) by the Tustin City Code and designated as Public and Institutional by the General Plan. The site is developed with an existing Southern California Edison substation and is bounded by a religious facility on the east, residences to the south across Bryan Avenue, a school (C.E. UTT Middle School) on the southwest, and single-family homes on the west (see Attachment A- Location Map). If Code Amendment 02-005, proposed as a separate application to refine the definition of minor wireless communication facilities, is recommended for approval by the Planning Commission and approved by the City Council, the proposed facility would be classified as a "Minor Wireless Communication Facility." Installation of a minor wireless communication facility requires approval of a Design Review application, and installation of this type of facility within a residential area requires a conditional use permit in accordance with Section 9276d of the Wireless Communication Facility and Guidelines. Condition No. 1.2 of Resolution No. 3845 states that any approval of Design Review 02-017 and Conditional Use Permit 02-017 will not become effective and no permits will be issued until any approval of the ordinance adopting Code Amendment 02-005 becomes effective. In addition, Condition No. 1.8 would require removal of the facility if the property is subsequently developed with a residential use. Project Description The project involves installing two (2) slimline antenna arrays with a total of four (4) antennas on an existing electrical transmission pole (utility pole), one (1) GPS antenna on a proposed utility rack, and outdoor equipment cabinets (Attachment B - Submitted Plans) as follows: The antenna arrays would be stacked and installed at a height of forty-five (45) feet on the existing eighty (80) foot high utility pole located approximately at the midpoint along the substation's northwestern property line. Each antenna would be four (4) feet in length and one (1) foot in width and be placed vertically on the surface of the pole and made or painted with the same color as the existing utility pole. The utility pole is located within a landscape area and is partially screened by the mature trees along Browning Avenue. A GPS antenna would be installed on a proposed six (6) foot tall utility rack to be located behind and screened by the existing eight (8) foot high chain link fence. The outdoor equipment would be located behind the existing eight (8) high block wall along Browning Avenue and would be accessed through a new chain link gate. Given that the height of the equipment is one and one-half (1~) feet lower that the height of the existing block wall and the location of the equipment located Planning Commission Report CUP 02-017 AND DR 02-017 September 23, 2002 Page 3 behind the existing block wall, the equipment enclosure will not be visible from the public right-of-way. Condition No. 2.2 would require the applicant to replace all perimeter chainlink fencing and gates with wrought iron fencing and gates to improve the aesthetics of the facility. The applicant has provided photosimulated views and line of sight drawings from Browning and Bryan Avenue (Attachment C- Submitted Photosimulations). Based on the submitted materials, the antennas would appear to be part of the intended utility pole and the GPS antenna and accessory equipment would be hidden behind the wall and fencing. ANAYLYSIS To approve the project, the Planning Commission will need to find that the establishment, maintenance, and operation of the facility will not be detrimental to the health, safety, morals, comfort, or general welfare of the persons residing or working in the neighborhood, improvements in the neighborhood, or general welfare of the community and that the location, size, and general appearance of the proposed facility will not impair the orderly and harmonious development of the area, the present or future development therein, or the occupancy as a whole. Staff is recommending approval of the project based on the following: As conditioned, approval of Conditional Use Permit 02-017 and Design Review 02- 017 will not become effective and no permits will be issued until any approval of the ordinance adopting Code Amendment 02-005 becomes effective. The site, although zoned Residential Agricultural (RA), is developed 'with a utility substation. Section 9276.g.3 of the Tustin City Code allows for a minor wireless communication facility to be located within a residentially zoned property provided that the wireless facility is to be removed if the property subsequently be developed with a residential use. Condition No. 1.8 has been included to require removal of the wireless facility if the property is subsequently developed with a residential use. The facility will not negatively affect adjacent residential areas in that the antennas will not be readily visible and will be screened with mature trees near the utility pole on which the antennas are located. The General Plan designates the site as Public and Institutional. The Public and Institutional land use designation allows for public and private uses such as utility substations and communication facilities. If Code Amendment No. 02-005 is approved, the project would be consistent with the policies and requirements of the Wireless Facilities Ordinance [TCC Section 9276(f)] that sets forth an order of preference for the location and screening of wireless communications facilities. The first preference is for cellular antennas to be located on existing structures or facilities. The antennas would be located on Planning Commission Report CUP 02-017 AND DR 02-017 September 23, 2002 Page 4 an existing utility pole, have subdued colors and non-reflective materials to match the existing pole, and be partially screened by existing mature trees. The GPS antenna will be located on a six (6) foot tall utility rack and the outdoor accessory equipment will be located within an enclosure. Both the GPS antenna and the outdoor accessory equipment will be screened from public view by the existing eight (8) foot high block wall and fencing. As conditioned, the applicant would be required to comply with FCC guidelines related to radio frequency emissions and submit a certificate of compliance to the City on an annual basis. J~s~'a Willkom Associate Planner Attachments: A, B. C. D. Karen Peterson Senior Planner .Location Map Submitted Plans Submitted Photosimulations Resolution No. 3845 S:\Cdd\PCREPORT~CUP 02-017 & DR 02-017 (Vedzon).DOC ATTACHMENT A Location Map LOCATION MAP pRoJECT NO. ADDRESS 0U ? 0Z'-01'1 'D~ zo:st 'lS~¥nN RVE. '1'VsTIN SOU 7H£RN ISRA£1.. CAI. IF ORNIA ~'EMPL £ EDISON ATTACHMENT B Submitted Plans ATTACHMENT C Submitted Photo-simulations Photograph Simulations Before Antennas ¥~wireless Project: Auto Center After Address: 2031 Bryan Avenue Photograph Simulations Before Antennas After Address: 2031 Bryan Avenue ATTACHMENT D Resolution No. 3845 RESOLUTION NO. 3845 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF TUSTIN, APPROVING CONDITIONAL USE PERMIT 02-017 AND DESIGN REVIEW 02-017 AUTHORIZING THE ESTABLISHMENT OF A MINOR COMMUNICATION WIRELESS FACILITY AT A HEIGHT OF FORTY-FIVE (45) FEET ON AN EXISTING EIGHTY (80) FOOT TALL UTILITY POLE LOCATED AT 2031 BRYAN AVENUE The Planning Commission does hereby resolve as follows: I. The Planning Commission finds and determines as follows: Ao A proper application, Conditional Use Permit 02-017 and Design Review 02-017, was filed by Verizon Wireless, requesting authorization to establish a minor wireless communication facility comprised of two (2) slimline antenna arrays with a total of four (4) antennas at a height of forty-five (45) feet on an existing eighty (80) foot high utility pole, one (1)GPS antenna on a proposed six (6) foot tall utility rack, and outdoor equipment cabinets within an enclosure on a property zoned for Residential Agricultural (RA) and designated as Public and Institutional by the General Plan. B. The site is designated Public and Institutional by'the General Plan, which provides for public and private uses such as utilities and communication facilities. The project has been reviewed for consistency with the Air Quality Sub-element of the City of Tustin General Plan and has been determined to be consistent with the Air Quality Sub-element. C. The site is zoned Residential. Agricultural (RA) by the Tustin City Code. If Code Amendment 02-005 is adopted by the City Council, the facility would be considered a minor wireless communication facility that is subject to approval of Design Review and a Conditional Use Permit. D, That a public hearing was duly noticed, called, and held on the project on September 23, 2002, by the Planning Commission. E', The establishment, maintenance, and operation of the facility will not be detrimental to the health, safety, morals, comfort, or general welfare of the persons residing or working in the neighborhood, improvements in the neighborhood, or general welfare of the community and that the location, size, and general appearance of the proposed facility will not impair the orderly and harmonious Resolution No. 3845 Page 2 Fo development of the area, the present or future development therein, or the occupancy as a whole as follows: . As conditioned, approval of Conditional Use Permit 02-017 and Design Review 02-017 will not become effective and no permits will be issued until any approval of the ordinance adopting Code Amendment 02-005 becomes effective. . The site, although zoned Residential Agricultural (RA), is developed with a utility substation. Section 9276.g.3 of the Tustin City Code allows for a minor wireless communication facility to be located within a residentially zoned property provided that the wireless facility is to be removed if the property subsequently be developed with a residential use. Condition No. 1.8 has been included to require removal of the wireless facility if the property is subsequently developed with a residential use. The facility will not negatively affect adjacent residential areas in that the antennas will not be readily visible and will be screened with mature trees near the utility pole on which the antennas are located. , If Code Amendment No. 02-005 is approved, the project would be consistent with the policies and requirements of Tustin City Code Section 9276(f) that sets forth an order of preference for the location and screening of wireless communications facilities. The first preference is for cellular antennas to be located on existing structures or facilities. The antennas would be located on an existing utility pole, have subdued colors and non-reflective materials to match the existing pole, and be partially screened by existing mature trees. , The GPS antenna will be located on a six (6) foot tall utility rack and the outdoor accessory equipment will be located within an enclosure. Both the GPS antenna and the outdoor accessory equipment will be screened from public view by the existing eight (8) foot high block wall and fencing. That the location, size, architectural features, and general appearance of the proposed project will not impair the orderly and harmonious development of the area, the present or future development therein, the occupancy thereof, or the community as a whole in that the antennas will be made part of the existing utility pole and that the outdoor equipment will be screened by the existing eight (8) foot high block wall. In making such findings, the Planning Commission has considered the following items: Resolution No. 3845 Page 3 1. Height, bulk, and area of buildings. 2. Setbacks and site planning. 3. Exterior materials and colors. 5. Towers, chimneys, roof structures, utility poles, flag poles, radio and television antennas. 6. Landscaping, parking area design, and traffic circulation. 7. Physical relationship of proposed structures to existing structures in the neighborhood. 8. Appearance and design relationship of proposed structures to existing structures and possible future structures in the neighborhood and public thoroughfares. G, As conditioned, the applicant is required to comply with Federal Communications Commission guidelines related to radio frequency emissions and submit a certificate of compliance to the City on an annual basis. Ho This project is Categorically Exempt pursuant to Section 15303, Class 3 of Title 14, Chapter 3 of the California Code of Regulations (Guidelines for the California Environmental Quality Act). II. The Planning Commission hereby approves Conditional Use Permit 02- 017 and Design Review 02-017 authorizing the establishment of a minor wireless communication facility comprised of two (2) slimline antenna arrays with a total of four (4) antennas at a height of forty-five (45) feet on an existing eighty (80) foot high utility pole, one (1) GPS antenna on a proposed six (6) foot high utility rack, and outdoor equipment cabinets within an enclosure on a property zoned Residential Agricultural (RA) and designated as Public and Institutional by the General Plan located at 2031 Bryan Avenue, subject to the conditions contained within Exhibit A attached hereto. PASSED AND ADOPTED by the Planning Commission of the City of Tustin, at a regular meeting on the 23rd day of September, 2002. STEPHEN V. KOZAK Chairperson ELIZABETH A. BINSACK Planning Commission Secretary Resolution No. 3845 Page 4 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN ) I, Elizabeth A. Binsack, the undersigned, hereby certify that I am the Planning Commission Secretary of the City of Tustin, California; that Resolution No. 3845 was duly passed and adopted at a regular meeting of the Tustin Planning Commission, held on the 23rd day of September, 2002. ELIZABETH A. BINSACK Planning Commission Secretary EXHIBIT A RESOLUTION NO. 3845 CONDITIONAL USE PERMIT 02-017 AND DESIGN REVIEW 02~)17 CONDITIONS OF APPROVAL GENERAL (1) 1.1 The proposed project shall substantially conform with the submitted plans for the project date stamped September 23, 2002, on file with the Community Development Department, as herein modified, or as modified by the Director of Community Development in accordance with this Exhibit. The Director of Community Development may also approve subsequent minor modifications to plans during plan check if such modifications are consistent with provisions of the Tustin City Code. The approval of Conditional Use Permit 02-017 and Design Review 02- 017 are subject to City Council approval of Code Amendment 02-005 through the adoption of Ordinance No. 1260. No permits shall be issued unless or until Ordinance No. 1260 becomes effective. (1) 1.3 The Conditional Use Permit 'and Design Review approvals shall become null and void unless building permits are issued within twelve (12) months of the date of this Exhibit. The subject project approval shall become null and void unless permits are issued within twelve (12) months of the date of this Exhibit and substantial construction is underway. Time extensions may be granted if a written request is received by the Community Development Department within thirty (30) days prior to expiration. (1) 1.4 All conditions in this Exhibit shall be complied with prior to the issuance of any building permits for this project or as specified, subject to review and approval of plans by the Community Development Department. 1.5 Approvals of Conditional Use Permit 02-017 and Design Review 02-017 are contingent upon the applicant and property owner signing and returning to the Community Development Department a notarized "Agreement to Conditions Imposed" form and the property owner signing and recording with the County Clerk-Recorder a notarized "Notice of Discretionary Permit Approval and Conditions of Approval" form. The forms shall be established by the Director of Community Development, and evidence of recordation shall be provided to the Community Development Department. (2) (3) (4) SOURCE CODES STANDARD CONDITION CEQA MITIGATION UNIFORM BUILDING CODE/S DESIGN REVIEW EXCEPTIONS (5) (6) (7) RESPONSIBLE AGENCY REQUIREMENTS LANDSCAPING GUIDELINES PC/CC POLICY Exhibit A Resolution No. 3845 Page 2 (1) 1.6 As a condition of approval of Conditional Use Permit 02-017 and Design Review 02-017, the applicant shall agree, at its sole cost and expense, to defend, indemnify, and hold harmless the City, its officers, employees, agents, and consultants, from any claim, action, or proceeding brought by a third-party against the City, its officers, agents, and employees, which seeks to attack, set aside, challenge, void, or annul an approval of the City Council, the Planning Commission, or any other decision-making body, including staff, concerning this project. The City agrees to promptly notify the applicant of any such claim or action filed against the City and to fully cooperate in the defense of any such action. The City may, at its sole cost and expense, elect to participate in defense of any such action under this condition. (1) 1.7 Design Review approval shall be reviewed by the Director of Community Development on September 23, 2007. The Director may recommend to the Planning Commission additional conditions or modifications to the existing conditions or facilities as part of such review to protect the public health, safety, and general welfare. (~) 1.8 Except as otherwise stated in Condition 1.2, Conditional USe Permit and Design Review approvals shall remain valid for a period not to exceed the term of the lease on the subject property, including any extension thereof or if the property is subsequently developed with a residential use. A copy of said lease agreement shall be submitted to the Community Development Director prior to. issuance of any permits. If the lease is extended or terminated, notice and evidence thereof shall be provided to the Community Development Director. Upon termination or expiration of the lease or if the property is subsequently developed with a residential use, the facilities shall be removed from the property. (***) 1.9 Operation of the wireless facility shall be in compliance with the methods of operation as proposed by the applicant and noted on the plans: a. The applicant (Verizon Wireless) recognizes that the frequencies used by the cellular facility located at 2031 Bryan Avenue are extremely close to the frequencies used by the City of Tustin for public safety. This proximity will require extraordinary "comprehensive advanced planning and frequency coordination" engineering measures to prevent interference, especially in the choice of frequencies and radio ancillary hardware. This is encouraged in the "Best Practices Guide" published by the Association of Public-Safety Communications Officials- International, Inc. (APCO) and as endorsed by the Federal Communications Commission (FCC). Prior to the issuance of any permits to install the facility, Verizon Wireless shall meet in good faith to coordinate the use of frequencies and equipment with the Communications Division of the Orange County Sheriff-Coroner Department to minimize, to the greatest extent possible, any interference with the Public Safety 800 MHz Countywide Exhibit A Resolution No. 3845 Page 3 Coordinated Communications System (CCCS). Similar consideration shall be given to any other existing or proposed wireless communications facility that may be located on the subject property. b, At all times, other than during the 24-hour cure period provided in item d. below, the applicant (Verizon Wireless) shall not prevent the City of Tustin from having adequate spectrum capacity on the City's 800 MHz radio frequency. Co Before activating its facility, the applicant (Verizon Wireless) shall submit to a post-installation test to confirm that the "advanced planning and frequency coordination" of the facility was successful in not interfering with the City of Tustin Public and Safety radio equipment. This test will be conducted by the Communications Division of the Orange County Sheriff-Coroner Department or a Division-approved contractor at the expense of the applicant. This post-installation testing process shall be repeated for every proposed frequency addition and/or change to confirm the intent of the "frequency planning" process has been met. d. The applicant (Verizon Wireless) shall provide a 24-hour phone number to which interference problems may be reported. This condition will also apply to all existing facilities (operated by Verizon Wireless) in the City of Tustin. e. The applicant (Verizon Wireless) shall provide a "single point of contact" in its Engineering and Maintenance Departments to ensure continuity on all interference issues. The name, telephone number, fax number, and e-mail address of that person shall be provided to the City's designated representative upon activation of the facility. The applicant (Verizon Wireless) shall ensure that lessee or other users shall comply with the terms and conditions of this permit and shall be responsible for the failure of any lessee or other users under the control of Sprint to comply. (***) 1.10 The applicant shall prepare a preliminary report within ninety (90) days of completion of the project demonstrating conformance with the national standards for safe human exposure to electromagnetic fields and radio frequency installation. Said report shall be submitted to the Community Development Department. (7) 1.11 The applicant and property owner shall be required to accommodate additional carriers that request to co-locate on the facility at a lease that is at fair market value. 1.12 Any violation of any of the conditions imposed is subject to the payment of a civil penalty of $100.00 for each violation, or such other amounts as the City Exhibit A Resolution No. 3845 Page 4 Council may establish by ordinance or resolution, and for each day the violation exists, subject to the applicable notice, hearing, and appeal process as established by the City Council ordinance. (1) 1.13 The applicant shall be responsible for costs associated with any necessary code enforcement action, including attorneys fees, subject to the applicable notice, hearing, and appeal process as established by the City Council by ordinance. (~) 1.14 Radio frequency emissions shall not exceed the radio frequency emission guidelines of the Federal Communication Commission (FCC) as such guidelines may be amended from time to time. 1.15 Prior to July 1,2003, and prior to each July 1 thereafter, the operator shall file with the City of Tustin Community Development Department a certification of compliance prepared by an independent third party qualified to measure radio frequency emissions. (4) 1.16 The antennas and related equipment enclosure shall be regularly maintained and inspected for safety and aesthetics. The applicant shall provide routine maintenance of the material and color of the antennas to ensure that they continue to match the existing utility pole. 1.17 If deemed necessary by the Community Development Director upon change of ownership, notices shall be mailed to property owners and/or tenants within a 1,000 foot radius of the site informing them that the project was approved and providing information as to how to contact the Federal Communications Commission for complaints regarding radio frequency interference. The applicant and/or property owner shall provide written notification to the City sixty (60) days in advance of a change of ownership. The cost of said notification shall be borne by the applicant and/or owner. PLAN SUBMITTAL (4) 2.1 The antennas shall be made or painted to match the existing utility pole. Proposed colors and materials shall be indicated on the elevations, submitted for review and approval by the Community Development Department, and subject to field inspection. (4) 2.2 The applicant shall replace all chain link gates along the perimeter of the property with wrought iron gates. PropOsed color and design shall be indicated on the elevations submitted for review and approval by the Community Development Department. (4) 2.3 No exterior cables shall be permitted. (3) 2.4 At plan check, submit seven (7) sets of construction plans and two (2) sets of structural calculations prepared by a licensed engineedarchitect. No field Exhibit A Resolution No. 3845 Page 5 changes shall be made without corrections submitted to and approved by the Community Development Department. (3) 2.5 Indicate on the title sheet the applicable codes, City, State, and Federal laws and regulations applicable at the time. The City is currently enforcing the following: · 1998 California Building Code; 1998 California Mechanical and Plumbing Codes; · 1998 California Electrical Code; · City of Tustin Grading and Security Ordinance; · City of Tustin Landscaping and Irrigation Guidelines; and · City of Tustin Private Improvements Standards. (3) 2.6 No part of the structure shall project beyond the property line. USE RESTRICTION (7) 2.7 The wireless communication facility shall not bear any signs or advertising devices other than certification, warning, or other required seals or signage, unless signage is approved by the City in accordance with the City of Tustin Sign Code. (7) 2.8 Within 90 days of commencement of operations, the applicant for wireless communication facilities that are located within 300 feet of residential areas or located on properties that are zoned residential shall provide a preliminary report and field report prepared by a qualified engineer that shows the operation of the facility is in conformance with the standard established by the American National Standards Institute (ANSI) and Institute of Electrical and Electronics Engineers (IEEE) for safe human exposure to electromagnetic fields (EMF) and radio frequency radiation (RFR). NOISE (7) 3.1 All construction operations including engine warm-up shall be subject to the provisions of the City of Tustin Noise Ordinance, as amended, and may take place only during the hours of 7:00 a.m. until 6:00 p.m., Monday through Friday, and 9:00 a.m. until 5:00 p.m. on Saturday unless the Building Official determines that said activity will be in substantial conformance with the Noise Ordinance and that public health and safety will not be impaired subject to application being made at the time of the permit for the work is awarded or during progress of the work. ORANGE COUNTY FIRE AUTHORITY (5) The applicant shall submit to the Fire Chief a list of the quantities of all hazardous, flammable and combustible materials, liquids or gases to be stored, used, or handled on-site. These liquids and materials shall be Exhibit A Resolution No. 3845 Page 6 classified according to the Uniform Fire Code using the "Orange County Fire Authority Chemical Classification Handout." The submittal shall provide a summary sheet listing each hazard class, the total quantity of chemicals stored per class, and the total quantity of chemicals used in that class. All forms of materials are to be converted to units of measure in pounds, gallons, and cubic feet. (5) 4.2 Prior to the issuance of a building permit, the applicant shall contact the Orange County Fire Authority Hazardous Materials Services Section at (714) 744-0463 to obtain a "Hazardous Materials Disclosure Chemical Inventory and Business Emergency Plan" packet. This shall be completed and submitted to the Fire Chief prior to the issuance of a building permit. (5) 4.3 Prior to the issuance of a building permit, plans for the fire alarm system shall be submitted to the Fire Chief for review and approval. Please note this condition applies only if an approved smoke detection system is required to be installed to protect the battery system. This system shall be operational prior to a final inspection approval. FEES (1) 5.1 Prior to issuance of any building permits, payment shall be made of all applicable fees, including but not limited to, the following. Payment shall be required based upon those rates in effect at the time of payment and are subject to change. ao Building plan check and permit fees to the Community Development Department based on the most current schedule. bo Orange County Fire Authority plan check and inspection fees to the Community Development Department based upon the most current schedule. (2) $.2 Within forty-eight (48) hours of approval of the subject project, the applicant shall deliver to the Community Development Department, a CASHIER'S CHECK payable to the County Clerk in the amount of $43.00 (forty-three dollars) to enable the City to file the appropriate environmental documentation for the project. If within such forty-eight (48) hour period that applicant has not delivered to the Community Development Department the above-noted check, the statute of limitations for any interested party to challenge the environmental determination under the provisions of the California Environmental Quality Act could be significantly lengthened.