Planning Fees, CEQA Billing and Accounting Records

Related tracker: October 23 CPRA request and the November 2–3 agency response history.

Executive summary

Newly supplied County receipts show Gardens of Noor related fee payments, while an October 2026 request and the Planning Department's response raise a narrower question: how do the assessed fees and documented deposits compare with the actual staff, technical, and legal costs of reviewing this project? We can identify multiple payments but cannot calculate full cost recovery because project-specific labor/time records, a consolidated bill history, and any relevant agreements from an earlier production are not included in this set.

1. What the original application payments show

2. Applicable fee schedules and the minimum-deposit issue

The 2005 consultant study recommended a $65.60 fully burdened hourly rate; a 2017 staff memo explored partial versus full recovery options. These historical recommendations are background, not the project’s operative 2022 fee bill. On March 27, 2018, Board Resolution 18-028 adopted the revised fee schedule based on a $110 hourly figure and phased increases.

More directly relevant, the furnished FY 2021–22 Planning fee schedule lists a minor use permit at $1,069 and a CEQA initial study for a use permit at $710. Both exactly match the February 2022 Planning receipt. The schedule calls these amounts minimum deposits and specifies time-and-materials billing. A deposit matching the schedule is not itself proof that the County later performed a final reconciliation of actual staff time.

The FY 2022–23 schedule lists a $118 Planning hourly rate. The 2026 rate and any amendments governing the September appeal or October review need to be verified separately, rather than extrapolated from an older schedule.

3. Notices and the applicant’s appeal

The newspaper correspondence quotes $103.64 for the Gardens of Noor Planning Commission notice scheduled for August 28, 2026, and $90.92 for a Board-related notice scheduled for October 30, 2026. These are vendor charges/quotes to the County; neither communication by itself shows reimbursement by the applicant or payment by the County.

The applicant submitted a written appeal after the September 8 Planning Commission denial. In the September 9 letter, the applicant disputed the evidentiary basis and asserted concerns about the fairness of the hearing, including alleged religiously biased comments. These are assertions in the applicant’s appeal, not findings adopted by this archive. The appeal receipt confirms the fee paid to process the appeal, not the merits of the arguments.

4. What the agencies said they could and could not locate

The October 23 joint public-records request asked Planning and the Auditor's Office for project-specific ledgers, receipts, staff-time records, fee/reimbursement agreements, cost calculations and signed indemnification records. On November 2, the Planning Director said the office coordinated with Environmental Health and Public Works, attached responsive records, and furnished a spreadsheet distinguishing produced items from those not located. The third-party forward supplied to this archive did not include attachments, but those materials have now been provided separately and reviewed.

The supplied Planning records-status spreadsheet states that “there are no such records” in response to item 2, which sought project-specific CEQA staff labor, staff-time entries and related expenditure records. It also lists several billing and waiver-related categories as “no responsive records located.” Those are reported search outcomes—not proof that staff performed no work, nor proof of deliberate non-recovery.

The matrix states that indemnification materials sought in items 5a and 5b were previously provided in a July 20, 2026 records production. That earlier production is not part of the new set reviewed here, so the report cannot conclude that no indemnity agreement exists or assess its terms. Other indemnification-related categories were marked not found.

On November 3, the Auditor's Office reported finding no records in its accounting software from searches on project names and parcel identifiers. That is narrower than a search by the actual receipt numbers, account codes, Treasurer deposit references, and Public Works fund/account numbers now disclosed in these receipts. The departmental receipts are affirmative records of payment; the unanswered issue is how their transactions appear in the County's central accounting system.

5. Financial reconciliation: what remains open

• Actual-cost review: How many planning, CEQA, Public Works and Environmental Health staff hours were spent from 2022 through 2026, including resubmittals and appeal work? If no project time logs were created, how were actual time-and-materials costs determined?
• Account linkage: Can the Auditor or Treasurer match Planning receipt 93857, the $500 Public Works deposit, the September $1,255 Board appeal receipt, and the listed account codes to the County’s ledger?
• Post-2022 charges: Were further deposits, true-up invoices, waivers, refunds or write-offs assessed? No consolidated running account reconciliation is included in the material reviewed.
• Environmental Health: Was the $480 assessment paid, billed later, or still pending? What County records show its disposition?
• Publication: Were the $103.64 and $90.92 notice charges paid by Planning, passed through to the applicant or handled another way?
• Indemnity: Obtain and evaluate the July 20, 2026 production referenced by the status matrix before claiming an agreement is present or absent, and examine its actual scope.

Publication standards and privacy

The materials were supplied to the archive by a third party. County receipts and schedules are identified by the agencies shown on their faces; they have not all been independently reobtained from original custodians. Private requester identities, personal contact data and spreadsheet metadata were excluded. Check imagery and non-public addresses have been masked in released PDF copies; originals are kept out of the public bundle. Names of County officials acting in their official capacities and the identified project applicant may appear where necessary to understand the public permitting record. The request and spreadsheet transcriptions are clearly designated as derivative redacted sources.