Save Open Space - Variance, permit and legal Documents
Obtained by Public Records Request
The Residential lot was dedicated to Open Space in 1979
On August 5, 2022, a plan was submitted to the Woodside Planning Department to bulldoze the Open Space and build an additional 35 parking places. This would allow a massive expansion of the Bakery and cause more traffic and congestion in our country town. The Town is the owner of the Open Space easement and has not approved sacrificing it yet. Details of the plan to bulldoze the Open Space are on the this page:
Bulldoze Plan
Below is an index to all the documents filed for this application and short summary
. They are in reverse chronological order, with most recent first.
The important documents are highlighted in red
Click on the link to open the document .
The Town should not abandon the Open Space Easement
The following is in the text of the Open Space Easement document that George Roberts signed in 1979. The easement was assigned to the Town in perpetuity. The Town must obey the California Code regarding abandoning an Open Space Easement as per the code mentioned below..
The below findings must be approved by the Town Council in order to abandon the Open Space Easement .
It is our belief that they can not be legally found, and it is up to the applicant to prove them.
Below is an index to all the documents filed for this application and short summary
. They are in reverse chronological order, with most recent first.
The important documents are highlighted in red
Click on the link to open the document .
Feb 13, 2024 Great Letter from R.Van Duzer attorney for the neighbors, regarding the damage the bulldozing will cause and opposing the project.
2024-02-13 Letter from R. Van Duzer to S. Schaan re Response to Town of Woodside.pdf
Dec 23, 2023 - Updated CUP application letter from applicant's new attorney, filled with distortions, rationalizations and mistakes.
ASRB2022-0022 - Updated CUP Application Letter - 12-12-23.pdf
Dec 23, 2023 - Updated Variance application letter from applicant's new attorney, filled with distortions, rationalizations and mistakes.
ASRB2022-0022 - Updated Variance Application Letter - 12-12-23.pdf
Sept 7, 2023 - Questions from staff regarding details on the plans, construction, parking, tree removal
ASRB2022-0022 - Incomplete Letter - 09-07-23 with attachments - no plans.pdf
Aug 23, 2023 - Attempt to justify the five findings required for a Variance Application and amend Conditional Use Permit
ASRB2022-0022 - Variance Letter from applicant received 08-23-23.pdf
1-Fox Rothschild new attorney Why did they switch from Jorgenson, Siegel ?
2-A bunch of rationalization and excuses regarding the five findings required of a Variance application should be granted.
July 17, 2023 - Notes on Parking Lot layout
Bechtel & Associates Response Letter - 07-17-23.pdf
July 26, 2023 - Reply to several details on Bechtel plans, Arborists Reports and plans.
Dave Tanner - Updated Submittal Letter - 07-26-23.pdf
July 3, 2023 Parking Lot Tree Report
Parking Lot Tree Report - Monarch Consulting Arborist - 07-03-23.pdf
1-Plan to remove 66 Significant trees and 41not significant trees.
Dec 2, 2022 Response from Town to neighbors attorney (FBM), regarding application, GP consistency, reports , maps and easements
2.1 Town Response to 11-10-22 FBM Letter - 12-02-22 with attachments.pdf
1-Attached a copy of the application and the Towns' initial review letter.
2-The Town will provide the analysis of the application, copies of the reports and access to the copies of the old site plans
Nov 10, 2022 From attorney for the neighbors (FBM) to the Town. Follow up with questions regarding application, GP consistency, reports , maps and easements
2. R. Van Duzer Letter received 11-10-22.pdf
1-Request to send the Town's analysis of the Open Space Easement
2-Is the construction of 35 new parking spaces consistent with the General Plan.
3-Send copies of assessment and analysis reports when completed.
Nov 6, 2022 - Response to the Attorney for the neighbors. Complaint regarding the parking lot and abandoning the Open Space easement
Town Response to 10-21-22 FBM Letter - 11-06-22.pdf
1-Initial application has been deemed incomplete
2-After technical studies are done and application completed, the Town will determine CEQA
Oct 21, 2022 - The attorney for the neighbors filed a complaint regarding the parking lot and abandoning the Open Space easement.
1. R. Van Duzer Letter received 10-21-22.pdf
1-The Town can not abandon the Open space Easement
2-CEQA review should be required
3-Inconsistent with the Genera Plan
Sept 2, 2022
ASRB2022-0022 - Incomplete Letter - 09-02-22 with all attachments signed
This is a list of all the incomplete issues to be updated in the parking plan. Mostly building plan issues.
Aug 5, 2022.
Received Aug 5, 2022. Dave Tanner is the applicant. This is the formal application with references answers provided by Jorgenson, Siegel, and McClure & Flegel Attorneys document noted above.
Aug 5, 2022.
This is the standard variance application with references to the answers provided by Jorgenson, Siegel, McClure & Flegel Attorneys CUP Amendment document noted below
Aug 5, 2022.
This is a response to a few questions on the submitted plans. Discussion and details of sizes of parking spaces.
Aug 4, 2022
This is the formal application to ASRB and Planning Commission for a public hearing for CUP and zoning changes. Dave Tanner is the applicant
Aug 2, 2022
Canada Corners CUP Amendment lrt
By Jorgenson, Siegel, McClure & Flegel Attorneys. This is the most significant document, which is copied in the Use Permit Application and the Variance Application below. This is a twisted rational and excuses on how the increased parking is in compliance with the Town General Plan. This is the one that is most important
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