Agenda Item
6b 25-1127Consideration of Proposed Major Use Permit and Categorical Exemption (PL-25-15), for The Derna Group to change the use of an existing 55-foot-tall tower for use as telecommunications tower. Project location: 1135 Watertrough Road, Clearlake Oaks (APN: 628-120-04).
My name is Darius, and I am a property owner and committee member in the Double Eagle Ranch subdivision. I am requesting that the Commission reject the categorical exemption for the proposed 5G tower at the former microwave site and require a full CEQA review.
The project has never undergone CEQA analysis. The original tower predates CEQA and has been dormant for decades. When I purchased my property in 2011, I and other residents were told it was permanently decommissioned. Several homes were built or bought with the understanding that the site was no longer an active facility. This change in surrounding residential use creates clear unusual circumstances under the Berkeley Hillside standard.
There is also a reasonable probability of significant environmental effects. The entire subdivision lies in a Very High Fire Severity Zone. The project introduces new ignition sources, heavy equipment, and increased traffic on private POA-maintained roads not designed for commercial use. Residents live here with the reasonable expectation of a quiet, rural environment—many entirely off-grid—and a commercial-scale facility conflicts directly with the established nature of the area. Multiple homes, including my own, have direct views of the site, creating aesthetic impacts that have never been studied.
Based on the information available to me, it is also troubling that CalFire’s project-specific comments, dated September 23, 2024, do not appear to have been included in the staff materials. These comments identify major deficiencies—no fire-suppression water plan, no verification of road standards, and required defensible-space measures. Without this information, the record does not contain the evidence needed to support a categorical exemption.
Because the site’s context has fundamentally changed, because the potential impacts are significant, and because essential state-agency analysis is missing from the record, the categorical exemption cannot legally apply. This is a textbook case of what a categorical exemption should NOT be used for, and I respectfully urge the Commission to require full CEQA review.
Thank you for your consideration.
This may be a duplicate comment, I attempted previously but do not see my comment in the log.
As a resident of the area I enthusiastically support repurposing of existing infrastructure to improve cell netowork coverage.
As a member of the Double Eagle Ranch Property Owners Association I believe that the contractors responsible for the project or the project owner should be required to either mitigate the effects of their traffic on the privately maintained roads they use or contribute monetarily alingside the property owners.