CollectionGardens of Noor Cemetery Collection

Gardens of Noor Cemetery Collection

CEQA Review

The supplied Initial Study and Conditions of Approval are explicitly work-in-progress drafts. This page identifies factual conflicts and unresolved analysis questions without treating draft wording as a final County determination.

Draft inconsistency

“No proposed change in use”

The WIP Initial Study contains statements that there is no proposed change in use, no proposed physical changes, and no proposed development—even though the use permit would authorize cemetery operations, grave excavation, roads/parking, restrooms, fencing, drainage work, and related improvements.

Template language

Parcel-map / subdivider references

The draft refers to a parcel map, division of land, a “subdivider,” and conditions before recordation of a final map, although the project before the County is a use permit.

Project description

1.2 acres versus 1.7 acres

The draft Conditions of Approval place 1,832 graves on the northern 1.2 acres, while the current applicant narrative says the burial sections occupy approximately 1.7 acres.

Transportation

Qualitative VMT conclusion

The draft says cemetery use is not particularly significant for VMT because individuals visit infrequently. It does not appear to quantify the applicant’s expressly regional service area, trip lengths, vehicle occupancy, or 60-funerals-per-month operating estimate.

Biology

Survey deferred until later

BIO-1 requires a Biological Resource Analysis before ground disturbance, after which the site plan may be modified. This sequencing deserves close review given CDFW’s earlier species and oak-woodland comments.

Water / utilities

Different water-source descriptions

The draft utility language does not neatly align with AWA project correspondence and the current application’s description of AWA service plus a planned well.

Draft status matters

These errors and contradictions are evidence that the work-in-progress document needs correction and support before final environmental action; they are not being presented here as defects in a final adopted CEQA document.