HomeMy WebLinkAboutHCPC Resolution 2022-05 11/08/2022 DocuSign Envelope ID:079FF073-422D-4927-B24B-3D9A932153EE
RESOLUTION 2022-05
CITY OF PETALUMA
HISTORIC AND CULTURAL PRESERVATION COMMITTEE
APPROVING MAJOR HISTORIC SITE PLAN AND ARCHITECTURAL REVIEW
FOR RAMSEYAUCHETTI RESIDENCE
LOCATED AT 245 HOWARD STREET
APN: 006-243-019
FILE NO: PLSR-2022-0024
WHEREAS, Jeff Luchetti, requesting a Major Historic Site Plan and Architectural Review (HSPAR) for
alterations to an existing two-story residential structure located at 245 Howard Street (APN 006-243-019)
within the Residential 3 (R3) zoning district and within the Oakhill-Brewster District ("Project"); and
WHEREAS, the Project, given its location within a designated historic district, is subject to review by
the Historic and Cultural Preservation Committee consistent with Section 15.020 of Chapter 15 of the
Petaluma Implementing Zoning Ordinance; and
WHEREAS, the Oakhill-Brewster Historic District Preservation Guidelines and Standards, adopted by
the Petaluma City Council in 1990 through Ordinance No. 1796 N.C.S. provide guidance for new
construction to ensure that the characteristics which justify designation of the District are maintained; and
WHEREAS, with the exception of the historic building which will be retained, no other historic era
features are onsite; and
WHEREAS, on November 8, 2022, the Historic and Cultural Preservation Committee held a duly
noticed public hearing to consider the application, at which time all persons interested had the
opportunity to be heard; and
WHEREAS, on November 8, 2022, the Historic and Cultural Preservation Committee considered a
staff report analyzing the application, including the California Environmental Quality Act ("CEQA")
determination included therein; and
WHEREAS, a public notice of the Historic and Cultural Preservation Committee hearing was
published in the Petaluma Argus-Courier on October 28, 2022 and mailed to residents and occupants
within 500 feet of the Project site is in compliance with state and local law.
NOW THEREFORE, BE IT RESOLVED THAT:
A. The foregoing recitals are true and correct and incorporated herein by reference.
B. Based on the staff report, staff presentation, comments received and the public hearing, the Historic
and Cultural Preservation Committee makes the following findings based on substantial evidence in
the record:
California Environmental Quality Act
1. The Project is categorically exempt from the California Environmental Quality Act (CEQA),
pursuant to CEQA Section 15301 (Existing Facilities) which includes modifications to existing
structures and Section 15331 (Historical Resource Restoration/Rehabilitation) which includes
modifications to historic structures that are consistent with the Secretary of the Interior's Standards
for Rehabilitation. The ADIJ, which a ministerial building permit is required and does not require
discretionary review by the HCPC, is categorically exempt from the California Environmental
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Quality Act (CEQA), under Section 15303 (New construction or conversion of small structures) in
that the new construction a second dwelling unit in a zone which permits residential uses
Petaluma General Plan
2. The Project is consistent with the site's Land Use Map designation Residential 3(R3) in that a Major
HSPAR application for exterior alterations to a historic structure was submitted on September 9,
2022, as required, which would result in alterations to an existing two-story residential building on
an approximately 6,720 square foot lot.
3. The project is,for the reasons contained in the November 8,2022, Historic and Cultural Preservation
Committee staff report, consistent with the following General Plan policies:
Policy 1-P-3 Preserve the overall scale and character of established residential neighborhoods.
Policy 3-P-1 Protect historic and archaeological resources for the aesthetic, cultural, educational,
environmental, economic, and scientific contribution they make to maintaining
and enhancing Petaluma's character, identity and quality of life.
Historic Demolition Resolution No. 2017-122
4. The proposed demolition work that would occur to support the two-story rear addition, which
includes the removal of the existing one-story rear addition, is less than 50 percent of the subject
property's exterior building walls. Additionally, the project does not alter the maximum height of
the building and continues to support its existing rear ridgeline at approximately 25 feet. For these
reasons,the project has not been defined as a demolition consistent with Resolution No.2017-122.
Oakhill-Brewster Historic District Preservation Guidelines and Standards
5. Architectural -Style, Design, Arrangement, Texture, Materials, and Color
a. Style.The project extends and applies the residential building's existing Italianate architectural
style onto its new rear addition and exterior alterations. New roofing material, exterior siding
and trim, and window types are proposed to match existing features within the building. Diana
Painter's Historic Resource Evaluation (HRE) and Compliance report for the proposed design
states that the design also contains a Victorian approach, where the ornate and original
detailing are preserved in the front fapade and its side and rear facades are modest with
utilitarian features.The Italianate and Victorian architectural styles are 2 of 16 styles appearing
in the Historic District and the building is primarily identified as Italianate architecture. As such,
the project is consistent with this district guideline.
b. Design. The proposed project removes the existing one-story rear addition and modifies the
second-floor sunroom to incorporate a cohesive two-story rear addition, which organizes its
interior spaces on the ground and second floor to maximize its residential use.The existing one-
story addition and sunroom were not original to the building and were added after the
building was relocated to the property site on Howard Street. They also do not contain
elaborate architectural details, nor does it appear to have gained historical significance.The
building footprint is slightly adjusted for the new two-story rear addition, however, does not
alter the building's orientation and general form and does remain consistent with the
building's front facade in terms of scale, materials, and design motifs. As such, the project is
consistent with this district guideline.
6. Arrangement
a. Setback.The proposed rear addition is in-line with the building's existing setback and does not
modify or introduce new architectural features visible to the right-of-way to impact or alter the
building's current setbacks or existing character. As such, the project is consistent with this
district guideline.
b. Side Yards. Similarly to various other properties located within the Oakhill-Brewster Historic
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District and properties facing Howard Street, this building has a prominent front yard with
driveway access and side yards similar in proportion to those of the immediate neighborhood.
The rear addition does not alter the site's existing South side yard. As such, the project is
consistent with this district guideline.
c. Height. The project does not increase the residence's overall height. The building currently
contains two prominent gable roof ridgelines, the original and historic ridgeline is parallel to
Howard Street while the second ridgeline is perpendicular to the core building. The rear
addition extends the second ridgeline and does not introduce another height to the building.
As such, the project is consistent with this district guideline.
d. Roofline. The proposed rear addition extends the existing secondary ridge line, gable roof
pitch, and eave line and does not introduce a new height to the building. Previous additions
included the one-story rear addition which supported a low gable roof with a single dormer
and sunroom with a low-pitched shed roof. Residences within the immediate neighborhood
include gable, hip, and shed roof forms across a variety of architectural styles including the
adjacent Craftsman and Queen Ann architectural style.The core building's prominent roofline
remains as the building's highest elevation and its secondary rooflines lower in height and are
not visually prominent to the public right-of-way. As such, the project is consistent with this
district guideline.
e. Facade. The proposed project does not alter the appearance nor architectural style of the
building's front fapade.The rear addition extends the building's existing secondary gable roof,
eaveline, height, siding and trim, and window type. Each feature continues and coordinates
with the building's Italianate architectural style. Relocated and new windows align at a
continuous horizontal datum line and contain window caps and trims. New windows are not
equally spaced to indicate a consecutive rhythm, however, are placed in a balanced
location, reducing solid wall area and providing natural lighting to various living spaces on the
ground and second floor. The proposed design also provides additional privacy to the South
adjacent property by including obscure glass within four windows' lower sash on the left
(South) elevation which face the second-floor primary bedroom and bathroom. As such, the
project is consistent with this district guideline.
7. Texture and Materials. The project proposes materials that are consistent with the original
Italianate style of the residence. Proposed materials include siding and trim to match existing. No
additional or new materials are introduced to the building or its rear addition. As such the project
is consistent with this district guideline.
8. Color. The building's exterior, including its siding, trims, window frame and caps, and decorative
eave brackets are currently painted white.The project includes the building's rear addition, porch
enclosure, and its associated architectural features to be painted white after construction. The
colors and materials would remain consistent with the original core building and is appropriate
towards its Italianate architectural style.As such,the project is consistent with this district guideline.
9. Accessory Fixtures. The architectural drawing set does not include nor indicate additional
accessory fixtures to the building which are additional details that may enhance the design and
entrances to a residential building. It is recommended that appropriate lighting fixtures are
considered for a cohesive lighting scheme since the project includes the alteration of its entrances
to include a transom windows and its new rear addition to include two new French door
entrances. Draft Resolution COA #15 provides for administrative review of future lighting fixtures
following the historic district's design guidelines and the Secretary of the Interior's Standards for
the Treatment of Historic Buildings. As such, the project is consistent with this district guideline.
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10. Landscape
a. Fencing. No new landscape fencing,walls, and screening are a part of the proposed project.
As such, the project is consistent with this district guideline.
b. Plantings. No exterior landscaping or hardscape work, noting plantings nor paving, are
included in the project or indicated in the proposed architectural drawings. Draft Resolution
COA #16 provides for administrative review of future minor landscape and hardscape work
following the City's water restriction and landscape moratorium. As such, the project is
consistent with this district guideline.
c. Paving. No exterior landscaping or hardscape work, noting plantings nor paving, are included
in the project or indicated in the proposed architectural drawings. Draft Resolution COA #16
provides for administrative review of future minor landscape and hardscape work following
the City's water restriction and landscape moratorium. As such, the project is consistent with
this district guideline.
11. Public Access Easement and Dedication on Alleys. The site is not adjacent nor near a public
access nor alley. Therefore, this district guideline is not applicable.
12. Signs. The site is located in a residential zone (R3) and is used as a residential building. Therefore,
this district guideline for signage is not applicable.
Secretary of the Interior's Standards for the Treatment of Historic Properties
13. The Project is consistent with the Secretary of the Interior's Standards for the Treatment of Historic
Properties for Rehabilitation, as follows:
a. Standard #1: The building was historically built for residential use and its proposed design
intends to rehabilitate the building for a cohesive, efficient, and accommodating residence.
The building was relocated in 1907 and includes two later additions, and the building
continues to be located within a residentially zoned area with a historic district overlay. No
changes are proposed to the use of the building as a single-family residence. As such, the
project is consistent with this standard.
b. Standard #2: The project does not propose the removal of integral historic architectural
features related to the "Italianate" architectural style. The project does not alter or replace
original features from the "core" building, however, does include the rear addition, side rear
porch, and sunroom. The proposed work and designs for these alterations does not impact
the building historic character. As such, the project is consistent with this standard.
c. Standard #3: The project does not create a false sense of historical development and does
not add conjectural features or architectural elements from other buildings to the "core"
building's original Italianate architectural style. The proposed scope provides for a rear two-
story addition, side rear porch enclosure, windows, and doors to facilitate and optimize the
expansion of a residential building. As such, the project is consistent with this guideline.
d. Standard #4: As noted in the previous historical context section, the residential building has
been relocated from Kentucky Street to Howard Street, an area currently designated as the
Oakhill-Brewster Historic District. The building has also experienced remodeling with exterior
additions and minor alterations. Through the relocation and additions, the building has
continued to uphold the building's original Italianate architectural style. As determined from
the survey photographs provided with the HIRE, the building and its current site have
experienced changes since its original construction and additional historic significance has
not been acquired. As such, the project is consistent with this guideline.
e. Standard #5: As previously stated, the project will preserve the building's Italianate
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architectural features and continue its existing exterior finishes to the rear addition and side
rear porch enclosure to include roofing,siding, and trim to match existing.As such,the project
is consistent with this standard.
f. Standard #6:The project includes installation of a new asphalt shingle roof, replacement of a
deteriorating chimney,along with the restoration and replacement of damaged/dry rot siding
and trim. New asphalt shingle roof would provide for a cohesive and protective roofing barrier
and preserve the building from further deterioration. As directed by the California Historic
Building Code, Chapter 8, architectural features that pose life-safety hazards shall be
evaluated and require immediate action to abate such hazards. Section 8-706.5
(Nonstructural Features) specifically states "nonstructural features of historical structure, such
as exterior veneer, cornices and decorations,which might fall and create a life-safety hazard
in an earthquake, shall be evaluated. Their ability to resist seismic forces shall be verified, or
the feature shall be strengthened with improved anchorage when appropriate."Also,Section
8-901.4 (Safety Hazard) states "no person shall permit any safety hazard to exist on premises
under their control, or fail to take immediate action to abate such hazard." Therefore, it is
necessary to address the chimney's deteriorating condition and provide for an appropriate
replacement that preserves the building's character and exterior appearance.
The project description and surveyed photographs also confirms the building does contain
damage/dry rot siding and trim therefore the replacement of affected areas on the exterior
of the building are appropriate. Where the existing exterior materials no longer exist and/or
have deteriorated beyond repair, including the roofing, existing chimney, and exterior
materials for siding and trim, replacements are proposed to match the existing. As such, the
project is consistent with this guideline.
g. Standard #7: The project description and its architectural drawing set does not indicate the
use of chemical or physical treatments to the historic building. Draft Resolution COA #13
requires that chemical or physical treatments, if appropriate, will be undertaken using the
gentlest means possible is taken to avoid damage to the historic materials.
h. Standard#8:Some excavation is likely to occur as part of the rear addition and rear side porch.
However, these areas on the site have already experienced disturbance during the building's
relocation and later additions. Work of undisturbed ground is not a part of this project, and a
condition is included as a preventative measure to protect and preserve significant
archeological resources if potentially significant prehistoric or historic archeological resources
are encountered during the course of ground-disturbing activities (refer to Draft Resolution
COA#14). As such, the project is consistent with this standard.
i. Standard #9: As previously noted in the previous section for evaluation of the historic district's
"design" guideline, the proposed project removes the existing one-story rear addition and
modifies the second-floor sunroom to incorporate a cohesive two-story rear addition, which
organizes its interior spaces on the ground and second floor to maximize its residential use.The
rear addition continues the existing secondary ridgeline and is not differentiated in height
though maintains a cohesive height and does not introduce new architectural features. Most
importantly, the new work is compatible with the building's massing, size, scale, and
architectural features and does not impact the building's historic integrity.As such,the project
is consistent with this standard.
j. Standard#10:The proposed project removes the existing one-story rear addition and modifies
the second-floor sunroom to incorporate a cohesive two-story rear addition, which organizes
its interior spaces on the ground and second floor to maximize its residential use. The rear
addition continues the existing secondary ridgeline of the building and can be removed in the
future without impairing the core building's essential form and integrity. As such, the project is
substantially consistent with this standard.
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Implementing Zoning Ordinance
14. The Project is consistent with the site's Land Use Map designation Residential 3(R3) in that a Major
HSPAR application for exterior alterations to a historic structure was submitted on September 9,
2022, as required, which would result in alterations to an existing two-story residential building on
an approximately 6,720 square foot lot. The proposed project is subject to the objective
development standards contained in Table 4.3 of the IZO.The property continues to be consistent
with development standards including setbacks, height, and lot coverage with conditions noted
in Draft Resolution (Exhibit A).
15. The project is consistent with Chapter 15 (Preservation of the Cultural and Historic Environment), in
that it has been reviewed by the HCPC in accordance with the requirements contained in Section
15.070 of the IZO, and it has been determined that the proposed alterations will not adversely
affect the character, or the historical, architectural, or aesthetic interest or value of the district.
16. The Project is consistent with the Major Historic Site Plan and Architectural Review standards stated
in IZO Section 24.050, as follows:
a. The project proposes alterations to an existing Italianate two-story residential building which is
one of the inventoried styles listed in the Oakhill-Brewster Historic District. As such, the
architectural style is compatible with the overall character of the neighborhood and finds that
the project satisfies IZO Section 24.050(E)(1)(a).
b. The project does not alter the siting of the building on the property and therefore continues to
be appropriate for the site and other buildings in the neighborhood. As such, the sitting of the
structure on the property is not altered and finds that the project satisfies IZO 24.050(E)(1)(b).
c. Since the building continues to be of residential use,there are no proposed signage or outdoor
advertising structures proposed for the site. As such, finds that the project satisfies IZO
24.050(E)(1)(c).
d. The project includes a two-story rear extension and continues the existing ridgeline and
supports a bulk, height, and color appropriate for the site and compared to other structures
in the neighborhood. As such, finds that the project satisfies IZO 24.050(E)(1)(d).
D. Based on its review of the entire record herein, including the November 8, 2022 Historic and Cultural
Preservation Committee staff report, all supporting, referenced, and incorporated documents and all
comments received, the Historic and Cultural Preservation Committee hereby approves Historic Site
Plan and Architectural Review for the Project, subject to the conditions of approval attached hereto
as Exhibit 1.
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ADOPTED this 8th day of November 2022, by the following vote:
Commission Member Aye No Absent Abstain/Recused
Rinehart X
Perlis X
Pitingaro X
van Ommeren X
Whitley X
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DocuSigned by:
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Bill Rinehart, Chair
ATTEST: APPROVED AS TO FORM:
Signed by: DocuSigned by:
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Andrew Trippel, Planning Manager Dylan Brady, Assistant City Attorney
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Exhibit 1
CONDITIONS OF APPROVAL
Ramsey/Luchetti Residence
245 Howard Street
APN: 006-243-019
File No: PLSR-2022-0024
Standard Conditions of Approval
Planning Division
1. The plans submitted for building permit review shall be in substantial conformance with plans on
file with the Planning Division and revision dated September 9, 2022, except as may be modified
by the following conditions. A determination of substantial conformance shall be made by the
Planning Manager in writing during the plan check review process. Nothing shall preclude the
Planning Manager from referring a substantial conformance determination to the Historic and
Cultural Preservation Committee for review at a publicly noticed meeting.
2. The colors and materials shall be in substantial conformance with those noted on the plan set
except as modified by these conditions of approval.
3. The day following approval, the applicant shall provide a check made payable to the Sonoma
County Clerk, in the amount required and published by the Sonoma County Clerk to file the CEQA
Notice of Exemption ("NOE").
4. Prior to the issuance of any construction permits, these conditions of approval shall be included
with the plan set. A copy of the approved plans shall be maintained on-site when construction
activities are occurring.
5. This approval is granted for and contingent upon construction of the project as a whole, in a single
phase, with the construction and/or installation of all features approved and required herein.
Modifications to the project, including but not limited to a major change in construction phasing,
may require an amendment to this condition by the Historic and Cultural Preservation Committee
through the Site Plan and Architectural Review provided at IZO Section 24.050.
6. Consistent with IZO Section 24.050(I),this approval is effective for a twelve (12) month period unless
the permit has been exercised or unless an extension of time is approved in compliance with IZO
Section 24.050(J).
7. Prior to building permit issuance, all development impact fees shall be paid in full prior to final
inspection or issuance of a certificate of occupancy. The applicant/developer has 90 days from
the date of this approval to protest the imposition of fees pursuant to Government Code Section
66020. A protest of the imposition of fees shall be considered by the City Council at a public
hearing within 90 days after its filing, and the decision of the City Council shall be final.
8. The site shall be kept cleared at all times of garbage and debris. No outdoor storage shall be
permitted other than typical bulk materials, i.e., lumber, appliances, window systems, etc.,
temporarily stored through the normal course of construction.
9. Construction activities shall comply with performance standards specified in IZO Chapter 21
(Performance Standards), except that the permitted construction hours shall be as follows:
a. Monday through Friday: 8 a.m. to 6 p.m.
b. Saturday: 9:00 a.m. to 5:00 p.m.
c. Prohibited on Sundays and all holidays recognized by the City of Petaluma.
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10. Construction activities shall comply with the following measures, and all shall be noted on
construction documents:
a. Construction Hours/Scheduling: As noted above.
b. Construction Equipment Mufflers and Maintenance: All construction equipment powered
by internal combustion engines shall be properly muffled and maintained.
c. Idling Prohibitions: All equipment and vehicles shall be turned off when not in use.
Unnecessary idling of internal combustion engines is prohibited.
d. Equipment Location and Shielding: All stationary noise-generating construction
equipment,such as air compressors, shall be located as far as practical from the adjacent
homes. Acoustically shield such equipment when it must be located near adjacent
residences.
e. Quiet Equipment Selection: Select quiet construction equipment, particularly air
compressors, whenever possible. Motorized equipment shall be outfitted with proper
mufflers in good working order.
f. Staging and Equipment Storage: The equipment storage location shall be sited as far as
possible from nearby sensitive receptors.
g. Generators: No generators shall be utilized during nighttime hours (i.e., sunrise to sunset) to
power equipment (e.g., security surveillance) when normal construction activities have
ceased for the day. All such equipment should be powered through temporary electrical
service lines.
11. Prior to commencing construction activities, a sign shall be posted on the site regarding the
allowable hours of construction and contact information for complaints. Proof of sign installation
shall be provided to the Planning Manager prior to construction commencing.
12. The applicant shall defend, indemnify, and hold harmless the City or any of its boards,
commissions, agents, officers, and employees from any claim, action, or proceeding against the
City,its boards, commissions, agents, officers, or employees to attack,set aside,void, or annul any
of the approvals of the project, when such claim or action is brought within the time period
provided for in applicable State and/or local statutes. The City shall promptly notify the
applicants/developers of any such claim, action, or proceeding. The City shall coordinate in the
defense. Nothing contained in this condition shall prohibit the City from participating in a defense
of any claim, action, or proceeding and if the City chooses to do so appellant shall reimburse City
for attorneys' fees by the City.
Project-Specific Conditions of Approval
Planning Division
13. Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means
possible is taken to avoid damage to the historic materials.
14. The project is required to comply with measures to protect and preserve significant archeological
resources if potentially significant prehistoric or historic archeological resources are encountered
during the course of ground disturbing activities.
15. Administrative review shall be completed for future lighting fixtures following the historic district's
design guidelines and the Secretary of the Interior's Standards for the Treatment of Historic
Buildings.
16. Administrative review shall be completed for future minor landscape and hardscape work
following the City's water restriction and landscape moratorium.
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Building Division
17. Proposed project will require building permit application and construction plan approval in
compliance with current California Building Standards Code in CCR Title 24 as adopted by the
City of Petaluma. The Building Division reviews applications and plans in accordance with this
code. The applicant will need to demonstrate compliance with the construction documents.
18. Full plan submittal is required as applicable to project scope. Architectural, civil, structural,
mechanical, electrical, and plumbing systems are to be prepared by state licensed design
professionals.
19. Building permit construction documents are to include occupancy classifications, design
occupant load, general building area and height limitations, type of construction, and fire
sprinkler provisions data for each building on the subject parcel.
20. A soils report is required for foundation replacement when there is evidence of structural failure of
the existing foundation due to soil conditions.
21. Effective June 16, 2021, new buildings are required to have all electric construction as defined in
Petaluma Municipal Code 17.36 and permanent supply of electricity as the source of energy for
all space heating, water heating (including pools and spas), cooking appliances, and clothes
drying appliances, and has no natural gas or propane plumbing installed in the building.
22. For the 2019 Building Standards Code cycle effective June 16, 2021, the City of Petaluma has
adopted CalGreen at the Tier 1 level for wholly new buildings, with the exception Energy
Efficiency, which is adopted at the mandatory level only. Current code adoption at time of
building permit application will govern construction requirements.
Public Works (Utilities, Environmental, Water Conservation & Landscaping)
23. High Crown Driveway approach shall be replaced.
24. Encroachment permit is required for all work within the public right of way or within a City Utility
Easement.
25. Upgrade to 1.5"service, 1"meter,and double-check backflow if fire sprinklers are required. Existing
sewer lateral can be used for ADU if grades and hydraulics work otherwise a new sewer lateral will
be required. Utility fees will be required.
26. Project maybe subject to wastewater capacity fees due to the addition of accessory dwelling
units.
27. Refer to the City's website for current drought information, cityofpetaluma.org/drought. The
applicant shall be responsible to follow all requirements during construction.
28. If applicable, any project with a landscape area of 500 square feet or greater shall submit to the
City a complete landscape and irrigation documentation package consisting of all the required
elements found in the Landscape Water Use Efficiency Standards located in the Petaluma
Municipal Code (PMC) Section 15.17.050.
Fire Prevention Bureau
29. Fire sprinklers are required.
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30. Inspection by the Fire Marshal's Office required prior to final Building Department sign-off and/or
occupancy. 28-hour appointment notice required. Call 707-778-4389 or Email
FireMarshal@cityofpetaluma.org
Environmental
31. Based on the City's initial review of the application materials, the project appears to be eligible
for categorical exemption(s) under Section 15301 (Existing Facilities) of the California
Environmental Quality Act (CEQA),which allows modifications to existing structures, Section 15303
(New Construction or Conversion of Small Structures) which involves construction and location of
limited numbers of new, small facilities or structures such as accessory structures, and Section
15331 (Historical Resource Restoration/Rehabilitation), which includes modifications to historic
structures that are consistent with the Secretary of the Interior's Standards for Rehabilitation. Please
note that the project will need to demonstrate consistency with the corresponding Historic District
and the Secretary of Interior Guidelines in order to qualify for the Class 31 categorical exemption,
including the incorporation of recommendations included in the Historic Resource Survey and
Evaluation and Compliance with the Secretary of Interior's Standards for 245 Howard Street dated
June 27, 2022, prepared by Diana Painter of Painter Preservation. A decision to accept the
exemption would be made by the review authority.
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