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HomeMy WebLinkAboutPD Recommendation Report COH-Parks & Rec (PL-SMA-2023-031) BMiloliiSMM-6/30/23 COUNTY OF HAWAI`I PLANNING DEPARTMENT RECOMMENDATION COUNTY DEPARTMENT OF PARKS AND RECREATION SPECIAL MANAGEMENT AREA USE PERMIT APPLICATION (PL-SMA-2023-000031) Upon careful review of the applicant's request against the guidelines for granting of a Special Management Area Use Permit, the Planning Director recommends that this requests to allow facility improvements and ADA improvements of the Miloli`i Beach Park be approved by the Planning Commission. Since this recommendation is made without the benefit of public testimony, the Director reserves the right to modify and/or alter this recommendation based upon additional information presented at the public hearing. This approval recommendation is based on the following: The County of Hawaii Department of Parks and Recreation is requesting a Special Management Area(SMA)Use Permit for its recreational facility improvements that are located at the Miloli`i Beach Park on approximately 1.41 acres of land located along the shoreline within the coastal village of Miloli`i. The park currently contains an unpermitted 80 ft by 40 ft covered pavilion, a basketball/volleyball court,parking area, a restroom, a water tank, a pump house, and firepits. The overall improvements that are being requested under SMA Use Permit(PL-SMA- 2023-000031) include the following: • Replacement of the existing pavilion; • Replacement of the existing comfort station; • Replacement of the non-potable water storage with a new potable water storage and booster pump station for the new comfort station; • Improvement of the parking lot to be ADA accessible; • Improvements of the walkways connecting the comfort station with the parking area and park facilities to be ADA accessible; • Reconstruction and resurfacing of the basketball/volleyball courts enclosed within a surrounding chain link fence; 1 • Construction of a new playground and a surrounding chain link fence; • Designation of a boat turnaround area; and • Installation of vehicular barriers to prevent unauthorized vehicles from accessing the shoreline and the pavilion. In 2019 the Board of Land an Natural Resources certified the shoreline for the subject property as delineated along the edge of the existing seawalls that surround the subject property. While the proposed improvements aim to remove and reconstruct the existing pavilion, the pavilion as well as new walkways improvements and a new boat turnaround area will be located within the minimum 40-foot shoreline setback area and therefore the Department of Parks and Recreation has concurrently applied for a SSV for these improvements. The Department of Parks and Recreation has also provided various alternatives to the project located within the Final Environmental Assessement(FEA) and ultimately settled on the Site Plan (Figure 3) as shown in the FEA. Additionally, Figure 8 of the FEA shows a complete list of the proposed improvements to the Miloli`i Beach Park while including the subject property's relation to the shoreline including the minimum 40-foot shoreline setback line and VE flood zone for the area. According to the applicant, construction of the project will begin once the granting of all necessary permits. The current estimated cost of the improvements is $1,750,000. The grounds for approving development within the Special Management Area are based on HRS, Chapter 205A-26(2) (Special Management Area guidelines) and Rule 9-11(e) of the Planning Commission Rules of Practice and Procedure. Planning Commission Rule 9- 11(e) states that the Planning Commission may permit the proposed development only upon finding that: 1. The development will not have any significant adverse environmental or ecological effect, except as any adverse effect is minimized to the extent practicable and clearly outweighed by public health, safety, or compelling public interests. 2. The development is consistent with the Special Management Area objectives, policies and guidelines as provided by Chapter 205A, HRS. 2 3. The development is consistent with the General Plan, Community Plan, Zoning Code, and other applicable ordinances. 4. The development will, to the extent feasible, reasonably protect native Hawaiian rights if they are found to exist, including specific factual findings regarding: a. The identity and scope of valued cultural historical or natural resources in the petition area, including the extent to which traditional and customary native Hawaiian rights are exercised in the petition area. b. The extent to which those resources including traditional and customary native Hawaiian rights,will be affected or impaired by the proposed action; and c. The feasible action, if any, to be taken by the Planning Commission to reasonably protect any valued cultural, historical, or natural resources including any existing traditional and customary native Hawaiian rights. In review of the SMA guidelines as listed under HRS 205A-26(2)(A), the proposed development will not have any significant adverse environmental or ecological effect, except as such adverse effect is minimized to the extent practicable and clearly outweighed by public health, safety, or compelling public interest. In considering the significance of potential environmental effects, the Commission shall consider the sum of those effects that adversely affect the quality of the environment and shall evaluate the overall and cumulative effects of the action on the Special Management Area. Such adverse effects shall include, but not be limited to, the potential cumulative impact of individual developments, each one of which taken in itself might not have a substantial adverse effect and eliminate planning options. The applicant has conducted an Environmental Assessment for the project, which resulted in a Finding of No Significant Impact(FONSI). Thus, it has been determined that the proposed Miloli`i Beach Park facility upgrades and ADA improvements will not have a significant adverse environmental or ecological effect upon the Special Management Area. In reviewing the proposed development against the factors that may constitute a substantial adverse effect as listed under Planning Commission Rule 9-10 (H) (1-10), most of the park is depicted within FEMA Flood Zone X. A small sliver to the north of the 3 property is located within Flood Zone AE with a base flood elevation of 7 feet and Flood Zone VE (coastal high hazard area) is located in the northwestern portion of the property with a base flood elevation of 10 feet. The proposed action has been designed to minimize construction in the VE Flood Zone while accomplishing the key goal of providing accessible facilities. The footprint of the existing pavilion will be relocated outside of the VE Flood Zone and into the X Flood Zone thus minimizing impacts from flooding. The applicant has considered the risk of sea level rise (SLR) and determined that given the long-time scenario and uncertainty associated with the risk, it is still prudent to undertake this project. The public benefits outweigh a no action alternative which could lead to losing critical functionality at a heavily used public recreation site. As such, the proposed development will not create a substantial adverse effect on the surrounding areas. Although the County Department of Parks and Recreation is steadily improving the accessibility of its facilities through individual projects,they are scattered around the island and would not tend to produce adverse cumulative impacts. Furthermore, the proposed project is not related to other activities in the region in such a way as to produce adverse cumulative effects or involve a commitment of larger actions. Because of the limited scale of development and planned mitigation, impacts to any terrestrial biological, beach, ocean and aquative resources can be avoided through adherence to Best Management Practices (BMPs). The project site is an existing landscaped park in heavy use with an existing pavilion requiring extensive maintenance and replacements that is required by a legal settlement to become ADA-accessible. In review of the application for the upgrades and improvements to the existing Miloli`i Beach Park, the project use would be consistent with SMA guidelines as it would benefit and not adversely affect public access to a heavily used recreational resource, as well as improving access to historic, scenic and open space resources. The proposed project will expand recreational use for disabled users of the park ensuring that shoreline uses such as fishing, surfing, and other water-dependent activities are allowed in an equitable manner. In review of the SMA guidelines as listed under HRS 205A-26, the proposed development is consistent with the objectives and policies as provided by Chapter 205A-26, HRS, and Special Management Area guidelines contained in Rule No. 9 of 4 the Planning Commission Rules of Practice and Procedure. The purpose of Chapter 205A, Hawaii Revised Statutes (HRS) and Special Management Area Rules and Regulations of the County of Hawaii,is to preserve,protect, and where possible,to restore the natural resources of the coastal zone areas. Therefore, special controls on development within an area along the shoreline are necessary to avoid permanent loss of valuable resources and the foreclosure of management options. The objectives and policies of Chapter 205A, HRS include, but are not limited to, the protection of coastal recreational resources, historic resources, scenic and open space resources, coastal ecosystem, marine resources, beaches, and controlling development in coastal hazard areas. The proposed development is consistent with the objectives and policies of the Coastal Zone Management Program (Chapter 205A, Hawai`i Revised Statutes)including: Coastal Recreational Resources: The County Park known as the Miloli`i Beach Park is approximately 1.41-acres in size. The project area is relatively flat with slopes ranging from 0 to 1.5% generally sloped toward the southern portion of the project site. Elevations on the project site range from 6.7-7.7 feet Mean Sea Level(MSL). The certified shoreline is located along the makai boundary along an existing seawall. The development has provided valuable public access to the Miloli`i area. The proposed accessibility improvements would not in any manner adversely affect any recreational resources, and the proposed project will expand and improve recreational uses for disabled users of the park. The proposed project would not restrict any shoreline uses such as fishing, surfing, and other water-dependent activities. Additionally, the proposed project would help the Applicant in its mission to provide adequate, accessible and diverse recreational opportunities for the public. Historic Resources: Miloli`i Beach Park, has historically been acknowledged as the heart of recreation for this portion of the South Kona coastline and is historically known as the last Native Hawaiian fishing village. An archaeological inventory survey for the project was conducted by Haun & Associates in accord with State Historic Preservation Division (SHPD) rules governing standards for archaeological reports (HAR-13-13-276). A copy of the report was included in Appendix B in the Final Environmental Assessment (FEA). Given the negative findings of the archeological assessment, the determination of effect for the proposed project is "no historic properties affected"; which was confirmed 5 by SHPD. A standard condition will be included to address possible inadvertent archeological finds during the construction of the project. Scenic and Open Space Resources: The subject property and general vicinity is identified as an area of natural beauty by the General Plan and is situated about 5 miles makai of Mamalahoa Highway. Distant views of the sea from the highway currently exist. Due to the topography of the land between Mamalahoa Highway and the subject property (at least 1,000 feet elevation difference) and the like for like improvements, would not impede current views from these highways to the sea. The proposed facility will improve public access to the shoreline and it will allow for local residents and visitors to continue to experience valuable scenic resources and open spaces preserved on the Big Island. Coastal Ecosystems and Marine Resources: Marine waters located off of the Kona coastline in this area are classified as Class AA. The objective of Class AA designation is to ensure these waters remain in their natural pristine state as nearly as possible with an absolute minimum of pollution or alteration of water quality from any human-caused source or action. Short-term impacts on the marine environment from construction projects in this area could potentially result from airborne dust and increased silt that collects in stormwater runoff directed towards the ocean. The use of drywells to address on-site drainage, not directing stormwater towards the ocean, and compliance with Chapter 27, Flood Control, Hawai`i County Code, will mitigate the potential impacts of increased stormwater inputs to the nearshore/ocean area. To address potential impacts of the proposed development on water quality, marine resources and coastal ecosystems the applicant will implement best management practices (BMPs) as part of the National Pollutant Dischange Elimination System (NPDES) permit process as well as complying with Chapter 10, Erosion and Sedimentation Control, Hawaii County Code, and State Department of Health (DOH)water pollution and control regulations. There is no municipal sewer system in Miloli`i. According to the applicant, the existing park is currently serviced by an Individual Wastewater System (IWS) comprised of a septic tank and leach field. Residents of the area have expressed concerns over high bacteria levels around the beach park. An IWSAssessment and Feasibility Study for Miloli`i Beach Park as shown in Appendix D of the FEA was completed in August 2020. In general, the waters surrounding Miloli`i Beach Park are being negatively 6 impacted by enterococcus. Samples near the entrance to the beach park and pavilion were found to have the highest enterococcus levels, which exceeded the limit for recreation waters. The shallow marine cove fronting the beach park was predicted to have the highest bacteria levels due to its proximity to the existing leach field. However, samples from this location were found to have the lowest enterococcus levels, well below the limits allowed for recreational waters. Additionally,a dye test was conducted and originated at the comfort station's septic tank and no dye was observed in the adjacent marine waters through the investigation period. The study concluded that the IWS appears to be adequate for low to normal usage periods, however it may be undersized for the estimated weekend use. The study further provided options to the Department of Parks and Recreation on other possible wastewater systems. Based on the water quality investigation, dye test and the IWS capacity for normal day-to-day flows, keeping the existing IWS was recommended. Additionally, further investigation was recommended during high usage periods and increasing the frequency of pumping was also recommended. Both will help to determine if the existing IWS is functioning properly during high usage periods and determine an approximate high usage population. At this time the Department of Parks and Recreation will provide a holding tank for toilet waste while continuing to use the existing IWS for sink water. Based on the preceding, the Planning Director is recommending a condition of approval requiring the applicant to more frequently routinely pump the existing septic system (once every three months to once a month during high usage periods) and provide a holding tank for toilet waste while continuing to use the existing IWS for sink water. There were no professional surveys conducted of the floral or faunal resources for the subject property, however the applicant does not believe that any rare or endangered floral or faunal resources are likely to be found within the subject property due to the long- developed use of the subject property for park activities. According to the State Department of Land and Natural Resources, Division of Forestry and Wildlife (DOFAW) there are several state-listed species that could occur at or in the vicinity of the subject property including the Hawaiian Hoary Bat(`Ope`ape`a), Hawaiian Duck(Koloa Maoli), Hawaiian Coot (`Alae ke`oke`o), Hawaiian Goose (Nene), Hawaiian Sea Turtle (Honu), Hawaiian Monk Seal (Ilio holo i ka), Hawaiian Hawk (`Io), Blackburn's Sphinx Moth, Hawksbill 7 Sea Turtle,Hawaiian yellow-faced bee,Anchialine pool shrimp,Hawaiian Damselflies and other seabirds. DOFAW provided recommendations to mitigate impacts on these species and conditions of approval have been added to protect endangered, threatened, and indigenous species. Beach Protection: The subject property is adjacent to an existing public shoreline that allows public use of three bays in the project area, including Ho`opuloa Bay, Miloli`i Bay, and Omoka`a Bay. Shoreline features within the three bays include a black sand beach at Ho`opuloa Bay; the broad, gently sloping lava flows extending into the sea between Ho`opuloa Bay and Miloli`i Bay; and the shallow and exposed lava platform reefs extending from Miloli`i Bay to Omoka`a Bay. In 2019 the Board of Land an Natural Resources certified the shoreline for the subject property as delineated along the makai edge of the existing seawalls that surround the subject property. The applicant is proposing to remove structural elements from the minimum 40-foot shoreline setback and locate the new structures further inland while still being located partially within the minimum 40-foot shoreline setback. Since the proposed project will be located mauka of the existing seawalls, the proposed improvements will not interfere with the natural shoreline process in the area and will not negatively impact erosion. Coastal Hazards: The subject property is designated as Zone X, Zone VE and Zone AE on the Flood Insurance Rate Maps (FIRM). Most of the project will occur within Flood Zone X, an area determined by FEMA to be outside the 500-year flood plain. According to the University of Hawaii Sea Level Rise exposure area mapping program SLR-Xa, the exposure area for 3.2 feet of sea level rise or 3.2 feet of passive flooding is located along the shoreline. The entire parcel is located within the Tsunami Evacuation Zone. There is a Civil Defense siren located on the subject property. The facility upgrades and ADA improvements will be subject to the requirements of Chapter 27 —Flood Control, of the Hawai`i County Code in order to minimize the effects of coastal hazards. In addition, all structures will be developed in conformance with Uniform Building Code specifications. Based on the preceding, the project area is not likely to be impacted by coastal hazards. Based on the above information, the proposed development is consistent with the objectives and policies of Chapter 205A, HRS. 8 The proposed development is consistent with the County General Plan, Kona Community Development Plan (CDP), Zoning Code, and other applicable ordinances. The County of Hawai`i's General Plan Land Use Pattern Allocation Guide (LUPAG) Map designation for the subject property is designated Open (ope)by the General Plan LUPAG map. The Open LUPAG designation allows conservation lands, forest and water reserves, natural and scientific preserves, and potential natural hazard areas. The proposed project will also compliment the Historic Sites, Natural Beauty, Natural Resources and Shoreline, Recreation and Economy goals and policies of the General Plan. Additionally, the proposed project also conforms with the Zoning Code as the zoning for the property is designated as Open, which allows for public parks as a permitted use. Lastly, the Kona Community Development Plan (KCDP) was adopted by the Hawaii County Council by Ordinance No. 08-131 on September 25,2008. The project site is located outside outside of the Kona Urban Area but within the area governed by the Plan. The proposed recreational improvements are being developed in accordance with the existing zoning. However, an SMA permit is required for this project. In reviewing SMA permits, Kona CDP Public Safety Policies PUB-7.2c(ii) specifically states that park facilities in remote areas such as Miloli`i shall be upgraded and maintained. Based on the preceding, the proposed development is consistent with the General Plan, KCDP, and Zoning Code. The development will to the extent feasible, reasonably protect native Hawaiian rights if they are found to exist. In view of the Hawaii State Supreme Court's"PASH" and"Ka Pa'akai O Ka'Aina" decisions, the issue relative to native Hawaiian rights, such as gathering and fishing rights, must be addressed in terms of the cultural, historical, and natural resources and the associated traditional and customary practices of the site. Investigation of valued resources: An Archaeological Inventory Survey of the subject property was completed by Haun & Associates in August 2022. A Cultural Impact Analysis for the proposed facility upgrades and ADA improvements to the Miloli`i Beach Park was not completed. The Applicant did however include in the 9 application, a September 2006 Cultural Impact Assessment for the South Kona Watershed Irrigation System Project and a February 2012 Cultural Impact Assessment for the Miloli`i Community Enrichment and Historical Center in. The valuable cultural, historical, and natural resources found in the area: The AIS identified three (3) sites within the subject area. A request for review of the application was sent to the State Historic Preservation Division (SHPD) as a part of this application process. By letter dated July 15, 2022, the State Historic Preservation Division did not recommend preservation of the three identified sites. No professional flora or faunal surveys were conducted on the site as the property has historically been used for recreational activities and it is unlikely that there are any valued cultural, historical, and natural resources to be found in the subject area. According to the State Department of Land and Natural Resources, Division of Forestry and Wildlife (DOFAW)there are several state-listed species that could occur at or in the vicinity of the subject property including the Hawaiian Hoary Bat(Ope`ape`a), Hawaiian Duck(Koloa Maoli), Hawaiian Coot(Alae ke`oke`o), Hawaiian Goose (Nene), Hawaiian Sea Turtle (Honu), Hawaiian Monk Seal (Ilio holo i ka), Hawaiian Hawk(Io), Blackburn's Sphinx Moth, Hawksbill Sea Turtle, Hawaiian yellow-faced bee, Anchialine pool shrimp, Hawaiian Damselflies and other seabirds. Possible adverse effects or impairment of valued resources: While the proposed project may have some effect on valued resources in the area, the proposed conditions of approval of this permit should minimize impacts to natural and cultural resources and protect native Hawaiian rights. Feasible actions to protect native Hawaiian rights: As there is no evidence of any valued cultural, historical, and/or natural resources found on the site, there is no action to be taken. Conditions of approval have been added to protect endangered, threatened and indigenous Hawaiian Hoary Bat(`Ope`ape`a), Hawaiian Goose (Nene), Hawaiian Hawk (`Io) , Hawaiian Sea Turtle (Honu), Hawaiian Monk Seal (Ilio holo i ka), Blackburn's Sphinx Moth, Hawksbill Sea Turtle, and other seabirds. A condition of approval will be added for the protection of inadvertent finds should any remains of historic sites, such as rock walls, terraces,platforms, marine shell concentrations or human burials be encountered. The applicants will be required to cease work in the immediate area and 10 contact SHPD. Subsequent work may proceed upon an archaeological clearance from SHPD when it finds that sufficient mitigation measures have been taken. Lastly, this recommendation for approval is made with the understanding that the applicant remains responsible for complying with all other applicable government requirements in connection with the approved use,prior to its commencement or establishment upon the subject property. Additional governmental requirements may include the issuance of building permits, the installation of approved wastewater disposal systems, compliance with Fire Code, installation of improvements required by the American with Disabilities Act(ADA), among many others. Compliance with all applicable governmental requirements is a condition of this approval; failure to comply with such requirements will be considered a violation that may result in enforcement action by the Planning Department and/or the affected agencies. Based on the above findings, the proposed development will not have substantial adverse impacts on the environment, nor will its approval be contrary to the objectives and policies of Chapter 205A,HRS, relating to Coastal Zone Management and Rule No. 9 of the Planning Commission relating to the Special Management Area. Approval of this request is subject to the following conditions: 1) The applicant(s), its successor(s), or assign(s) ("Applicant") shall be responsible for complying with all stated conditions of approval. 2) The overall development shall conform substantially to the plans submitted and the representations made by the Applicant and as described in the multi-permit application dated January 25, 2023, any supplemental information, and any representations made to the Leeward Planning Commission. 3) The applicant shall secure all necessary approvals and permits from other affected Federal, State,and County agencies as necessary to comply with all applicable laws and regulations. 4) Construction of the proposed facility improvements shall be completed within five (5) years from the effective date of this permit. Prior to commencing construction, Final Plan Approval for the proposed development, as represented in the plans submitted with the application, shall be secured from the Planning Department. Plans shall identify existing and proposed structures, paved driveway access, lighting, parking, and public access associated with the proposed use. 11 5) The applicant shall implement the August 2020 IWS Assessment and Feasibility Study for Miloli`i Beach Park recommendations for the routine pumping of the existing wastewater system and providing a holding tank for the toilet waste and continued use of the individual wastewater system for the sink water as shown in Appendix D of the Final Environmental Assessment dated December 2022. The Applicant shall ensure that the existing wastewater system be routinely pumped once every three months and additional monthly routine pumping during high usage periods. 6) The Planning Department may require a shoreline survey certified by the Chair of the Board of Land and Natural Resources for any future construction or activity. 7) The applicant shall comply with the Mitigation Measures and Regulatory Requirements and Summary of Mitigation Measures and Project Commitments to Minimize Potential Impacts of the Project located within the Final Environmental Assessment dated December 2022. 8) Artificial light from exterior lighting fixtures, including, but not necessarily limited to floodlights, up-lights or spotlights used for decorative or aesthetic purposes shall be prohibited if the light directly illuminates, or is directed to project across property boundaries toward, the shoreline and ocean waters, except as may otherwise be permitted pursuant to Section 205A-71(b), Hawaii Revised Statutes. 9) All development shall comply with Chapter 27,Flood Control of the Hawai`i County Code. 10) All earthwork and grading shall conform to Chapter 10,Erosion and Sedimentation Control of the Hawaii County Code. 11) All development generated runoff shall be disposed of onsite and shall not be directed toward any adjacent properties. A drainage study shall be prepared by a professional civil engineer licensed in the State of Hawaii and submitted to the Department of Public Works prior to issuance of Final Plan Approval. Any recommended drainage improvements, if required, shall be constructed meeting with the approval of the Department of Public Works prior to receipt of a Certificate of Occupancy for any portion of the development. 12) During construction,measures shall be taken to minimize the potential of both fugitive dust and runoff sedimentation. Such measures shall be in compliance with construction industry standards and practices utilized during construction projects of the State of Hawaii. 12 13) The applicant shall comply with Chapter 11-55, Water Pollution Control, Hawaii Administrative Rules, Department of Health, which requires an NPDES permit for certain construction activities. 14) Should any drywells be installed, the applicant shall implement the best management practices contained in the State Office of Planning's Low Impact Development-A Practitioner's Guide, for storm water management to minimize the impact of the proposed development on the existing area's hydrology while maintain on-site infiltration and preventing polluted runoff from storm events. 15) In the event that surface or subsurface historic resources,including human skeletal remains, structural remains(e.g.,rock walls,terraces,platforms, etc.), cultural deposits,marine shell concentrations, sand deposits, or sink holes are identified during the demolition and/or construction work, the Applicant shall cease work in the immediate vicinity of the find, protect the find from additional disturbance and contact the State Historic Preservation Division (SHPD) at (808) 933-7651. Subsequent work shall proceed upon an archaeological clearance from SHPD when it finds that sufficient mitigation measures have been taken. 16) The State endangered Hawaiian Monk Seal (Ilio holo i ka) could potentially occur or haul out onshore within the vicinity of the proposed project site.If this species is detected within 100 feet of the project area all nearby construction operations should cease and not continue until the monk seal has departed the area on its own accord. 17) To protect the endangered Blackburn's sphinx moth, the Applicant shall prevent infestations of tree tobacco by removing the plants under three(3)feet tall. Where removal of taller tree tobacco is necessary, the Applicant shall provide a faunal survey of the area, conducted by a qualified biologist for review and approval to the U.S. Fish and Wildlife Service prior to cutting or removal of vegetation from the property. 18) To protect any seabirds (Hawaiian petrels, Newell's shearwaters and band-rumped storm petrel) in the vicinity of the property, any lighting shall be fully shielded so that the bulb can only be seen from below bulb height. The lights shall be turned off when human activity is not occurring in the lighted area. 19) An initial extension of time for the performance of conditions within this permit may be granted by the Planning Director upon the following circumstances: 13 A. The non-performance is the result of conditions that could not have been foreseen or are beyond the control of the Applicant and that are not the result of their fault or negligence. B. Granting of the time extension would not be contrary to the General Plan or Zoning Code. C. Granting of the time extension would not be contrary to the original reasons for the granting of this permit. D. The time extension granted shall be for a period not to exceed the period originally granted for performance (i.e., a condition to be performed within one year may be extended for up to one additional year). If the Applicant should require an additional extension of time, the Planning Department shall submit the Applicant's request to the Planning Commission for appropriate action. 20) Should any of the foregoing conditions not be met or substantially complied with in a timely fashion, the Planning Director may initiate procedures to revoke the permit. 14