Title
PLN250295 - PRASAD NARAIN & AMRITA B TRS (AT&T MOBILITY)
Public hearing to consider the demolition of an existing “Union 76” circular pylon sign and the construction of a 70-foot 4 inch tall, 256 square foot dual sided square “Eco Gas & Mart” freestanding pylon sign; the installation of 12 new antennas and five string batteries on the freestanding sign, and associated site improvements.
Project Location: 11400 Merritt St, Castroville, CA 95012
Proposed CEQA action: Find that denial of the project is Statutorily Exempt pursuant to CEQA Guidelines sections 15061(b)(4) and 15270(b).
Body
RECOMMENDATIONS
It is recommended that the Planning Commission adopt a resolution to:
1) Find that denial of the project is Statutorily Exempt pursuant to CEQA Guidelines sections 15061(b)(4) and 15270; and
2) Deny a Combined Development Permit consisting of:
a. A Use Permit and Design Approval to allow demolition of an existing pylon sign and allow for the development and construction of a 70-foot 4 inch tall “Eco Gas & Mart” freestanding pylon sign; and
b. A Use Permit and Design Approval to allow for the installation of twelve (12) new antennas and five (5) string batteries on the freestanding sign, and associated site improvements.
The attached draft resolution includes findings and evidence for consideration (Exhibit A). Staff recommends denial of the proposed project.
PROJECT INFORMATION
Agent: Greg Davis with Centerline Communications LLC on behalf of AT&T Mobility
Property Owner: Narain Prasad & Amrita B. Prasad Trs
APN: 030-281-023-000
Parcel Size: 0.53 acres
Zoning: Mixed Use and Design Control overlay “MU-C-D”
Plan Area: Castroville Community Plan (North County Area Plan)
Flagged and Staked: No
Project Planner: Jade Mason, Assistant Planner
masonj@countyofmonterey.gov, (831) 755-3759
Brendon Coye, Senior Planner
coyeb@countyofmonterey.gov, (831) 784-5731
SUMMARY/DISCUSSION
The project site is located at 11400 Merritt Street, Castroville, within the Castroville Community Plan. The proposed project includes the demolition of an existing 70 foot 4 inch “Union 76” pylon sign and its existing wireless communication facilities (antennas), and the construction of a 70-foot 4 inch tall, 256 square foot dual sided square “Eco Gas & Mart” freestanding pylon sign, the installation of 12 new antennas and five string batteries on the freestanding sign, and associated site improvements. The replacement sign and wireless communication facility would be located 35 feet southeast of the existing sign. The proposed height (70’ 4”) and sign area (256 square feet, dual sided [512 square feet in the aggregate]) exceed allowable development standards applicable to this site. Accordingly, a Variance is needed to consider each of these exceedances. However, the Applicant/Owner has not applied for a Variance. The proposed development would be visible from a major common public viewing area due to location.
Based on staff’s analysis, the proposed project is inconsistent with the policies and regulations pertaining to zoning uses and any other applicable provisions of the 2010 Monterey County General Plan (General Plan), North County Area Plan (NCAP), Castroville Community Plan (CCP), and applicable sections of the Monterey County Inland zoning ordinance (Title 21).
Site Location
The subject property is in a Mixed-Use zoning district with a Design Control overlay established in the Castroville Community Plan or “MU-C”. All parcels within the Castroville Community Plan are subject to a Design review as outlined in Appendix A: Design Guidelines of the Castroville Community Plan. The site is located at the intersection of State Route 183 (Merritt Street) and Haro Street. The proposed sign and wireless communication facility would be located on the rear western portion of the 0.53-acre parcel that is currently developed with a gas station, corner gas price sign, and a freestanding sign with a wireless communication facility.
Development Standards
Development of freestanding signs and wireless communication facilities are allowed uses in the MU-C zoning district subject to the issuance of a Use Permit, in each case. A Design Approval is required pursuant to the Castroville Community Plan as required by the aforementioned Monterey County Code sections and applicable North County Area Plan policies. Therefore, the project is an allowed land use for the proposed site.
Projects within the Castroville Community Plan and in the MU-C zoning district are subject to the development standards of Appendix B of the Castroville Community Plan. Pursuant to Table B-6, development of structures in the MU-C zoning district shall not exceed a height of 42 feet. Pursuant to Chapter 21.60 (Sign Regulations), any new commercial sign that requires Design Approval is limited to 35 square feet in the aggregate. The existing 76 Union sign (70 feet 4 inches tall, dual sided, circular design, approximately 250-310 square feet) was constructed in approximately 1971 and thus predated the establishment of these standards. Therefore, the sign is considered legal non-conforming as to height and sign size.
Monterey County Code (MCC) Title 21 Chapter 21.60 establishes the regulations, standards, and circumstances for the procedures to allow the continued use, maintenance and repair of nonconforming historic signs that preserve locally recognized values of community appearance or that reflect unique characteristics of development. Title 21 section 21.60.160.A (Legal Non-Conforming Sign Regulations) requires that the “enlargement, extension, reconstruction or structural alteration of a nonconforming sign may be allowed if the enlargement, extension, reconstruction or structural alteration conforms to all the regulations of the district in which it is located.” Accordingly, the existing sign may only be structurally altered if such modifications conform to the required height of 42 feet and size of 35 square feet. Ordinary maintenance and repair (non-structural) may be made without requiring the structure to conform to height requirements. Alternatively, a Use Permit may be obtained to allow additional maintenance and repair.
The Applicant/Owner claims that the condition of the sign is deteriorating and cannot be repaired to meet project objectives. Photos of the existing sign’s condition are attached at Exhibit C. HCD-Planning staff asked the Applicant to elaborate this claim and provide evidence from a structural engineer justifying their desire to replace the structure (rather than repair it). No evidence was provided by a structural engineer, but the Applicant claims that the “corrosion is so bad that the flange plate has detached and sunk into the larger pole, essentially creating a telescoping effect where the smaller columns at multiple locations are beginning to nest into the adjacent larger pole. This is an unrepairable condition which already presents a hazard on the property. AT&T’s proposed replacement of the sign structure and sign thereby not only addresses the hazard, but also significantly upgrades the aesthetics of the sign from the adjacent highway and streets”. (October 29, 2026 correspondence with the Applicant)
Here, demolition of the sign abandons the legal non-conforming height and sign size and does not justify construction of a replacement sign elsewhere on the property. This is further supported by Title 21 section 21.60.160.C, which states “No legal nonconforming sign shall be moved in whole or in part to any other location unless every portion of such sign which is moved is made to conform to all the regulations of the district in which it is located.”
Staff has repeatedly informed the applicant that the current scope of work is inconsistent with Title 21 requirements, and has given the applicant multiple alternatives to move forward with staff support. These include:
1. The existing sign may be structurally modified (but not demolished), provided that any changes do not exceed the sign area of the existing sign and that the overall height remains unchanged, and that the modified sign better complies with Castroville Community Plan sign design standards. Under this option, the sign may include either a logo only, or gas prices; however, if gas prices are included on the proposed sign, the applicant shall demonstrate that such design better complies with Castroville Community Plan sign design standards and that no other signs on the parcel displays gas prices (i.e. the smaller gas price sign on the corner). These modifications would be processed through a Use Permit for a legal nonconforming structure modification.
2. Upgrades/additions to the existing monopole/antenna panels may proceed without any modifications to the existing sign or height. This option would be processed as an Amendment to the previous discretionary permit that allows for construction of the existing wireless communications facility; or
3. Comply with Monterey County Code sign regulations that require a 35-square-foot sign area (provided that the area permitted may be divided into not more than three single-faced or double-faced signs) and a height that does not exceed 42 feet in height. Such design shall also comply with Castroville Community Plan sign design standards.
4. Apply for a Variance to exceed height and sign size regulations. However, staff noted concerns about whether the required findings could be made to support such Variances.
The Applicant requested that staff proceed with processing the project as currently proposed, which includes the 70’ 4” freestanding sign with an aggregate sign face of 512 square feet, and 12 antennas. The Applicant/Owner has not applied for Variances to consider such exceedances.
Even if a Variance was applied for, staff has concerns whether the required findings to grant such modifications could be made. The findings to grant a Variance include:
1. That based on circumstances specific to the property, the strict requirements of Title 21 deprive the property of privileges enjoyed by other properties in the vicinity and zoning district;
2. That such a variance is not a grant of special privileges inconsistent with the limitations upon other properties in the vicinity and zoning district; and
3. That a variance not be granted for use or activity which is not otherwise expressly authorized by the applicable zone governing the parcel of property.
The applicant has been informed that they may repair and maintain the existing legally nonconforming pylon sign to achieve their project goals while retaining its existing status and thereby maintain existing visual impacts. Further, the property currently has canopy signage and a 35-square-foot corner sign, which provide adequate on-site advertising and meet applicable state (Business and Professions Code sections 13531 and 13532) for displaying gas prices and brand identification. The existing Union 76 sign no longer has its vinyl logo, but the structure itself still exists. The existing operational on-site signage (gas station canopy and corner signage) are consistent with gas station signs in nearby MU-C zoned properties along Merrit. Photos of other commercial signs along the Merritt Street corridor, as well as the existing sign, are attached as Exhibit D. A third, non-human scale sign at this location would be inconsistent with the privileges enjoyed by other properties in the vicinity and zoning district, which are required to comply with the development standards established by the Castroville Community Plan. Simply, the proposed sign would introduce a third form of signage on the property, exceed the applicable MU-C zoning standards, and create additional visual impacts along adjacent scenic corridors. Based on these considerations, staff concludes that the applicant has not provided sufficient evidence to support granting a variance.
Design Standards & Visual Resources
According to Figure 15 “Scenic Highways Corridors and Visual Sensitivity North County Area” of the North County Area Plan, the subject site is in a designated Visually Sensitive area, and a 1.5 mile segment of Highway 156 is designated as a scenic highway. Pursuant to Policy NC-1.1 of the North County Area Plan, “new commercial development, or intensification of existing commercial development may be permitted subject to a discretionary permit. Proposed commercial development shall be designed to minimize traffic, noise, visual, and/or other impacts on the surrounding area to the greatest extent feasible.” Pursuant to section 7.6.2 of the Castroville Community Plan, freestanding signs should be small in scale and incorporated into the planned landscape for the site located in landscaped areas. Further, CCP section 7.6.2 states “signs should be creative and emphasize artistic expression, especially when located in the Merritt Street Corridor”. Relocation of the proposed freestanding sign would vacate the legal nonconforming status, requiring the design and placement of the proposed sign to complement the neighborhood character including architectural style and landscaping pursuant to Section 7.6.2, Appendix A: Design Guidelines of the Castroville Community Area Plan.
The Applicant provided visual simulations (Exhibit E). Staff conducted site visits, using the current 70’ 4” sign to determine proposed visual impacts of the proposed similar sign. The proposed sign would not comply with the design standard to be small in scale, nor provide a creative, artistic design. The proposed sign face is 221 square feet larger than what is allowed. The square shape of the proposed freestanding sign, as well as the size of the sign face and height, visually detracts from, and conflicts with, the surrounding architecture styles and character of the neighborhood and the Merrit Street corridor. Specifically, the digital display, at its height, would draw a distinct contrast from the style and lighting of the existing freestanding sign and many of those signs along the Merrit Street corridor which meet the height, size and siting requirements of the Castroville Community Plan. See Exhibit D.
The existing sign is visible 1.5 miles south and 0.5 miles north of the project site, when viewed along Highway 156. The project is also visible for the entire length of the segment of Highway 156 that is designated a scenic highway under the Area Plan. The round shape of the existing freestanding sign compliments the contours of surrounding environment including the rolling shape of the Gabilan Mountains and Santa Lucia Mountain Range. Additionally, the existing sign is a commonly familiar structure which doesn’t automatically detract from the natural landscape. The square shape of the proposed freestanding sign, on the other hand, is stark in contrast. The square edges do not complement the contours of the surrounding environment, and the proposed digital price display would provide significant visual distraction all hours of the day and night along Highway 156. Accordingly, staff believes that the proposed replacement of the freestanding sign location would worsen existing visual impacts to Highway 156, thereby conflicting with visual resources policies of the General Plan, including OS-1.2 and OS-1.12.
Wireless Communication Facility Regulations
Title 21 section 21.64.310 establishes the regulations, standards and circumstances for the siting, design, construction and maintenance of wireless communication facilities (WCF) in the unincorporated area of the County of Monterey. This Section assures, by regulation of siting WCFs, that the integrity and nature of residential, rural, commercial, and industrial areas are protected from the indiscriminate and inappropriate proliferation of WCFs, while complying with the Federal Telecommunication Act of 1996, General Order 159A of the Public Utilities Commission of the state of California and the policies of County of Monterey.
WCFs are allowed on any lot or parcel in any zoning district, subject to a discretionary permit, and subject to the following regulations:
1. Wireless communication facilities shall comply with all applicable goals, objectives and policies of the general plan, area plans, zoning regulations and development standards.
2. Wireless communication facilities shall comply with all FCC rules, regulations, and standards.
3. Wireless communication facilities shall comply with all applicable criteria from the Monterey County Airport Land Use Commission (ALUC) and the Federal Aviation Administration (FAA).
4. Wireless communication facilities shall be sited in the least visually obtrusive location possible. Appropriate mitigation measures shall be applied in instances where the facility is visible from a public viewing area.
5. A visual simulation of the wireless communication facility shall be provided. Visual simulation can consist of either a physical mock-up of the facility, balloon simulation, computer simulation or other means. In instances where the wireless communication facility is located near or in a residential area, photos shall be submitted of the proposed wireless communication facility from the nearest residential neighbors. In instances where the wireless communication facility is located along a scenic corridor, or within a Historic Resource Area or District, a detailed visual analysis of the facility shall be submitted.
6. Where the wireless communication facility is proposed to be located within a designated historic resource site or district, the applicant shall comply with the regulations for historic resources pursuant to Chapter 21.54 and Chapters 18.25 and 18.26.
7. Where a wireless communication facility exists on the proposed site location, co-location shall be pursued to the maximum extent feasible. If a co-location agreement cannot be met, documentation of the effort and the reasons why co-location was not possible shall be submitted and reviewed by the Director of Planning.
8. Other regulations enacted pursuant to the General Plan and Area Plan, may be applied to the proposed wireless communication facility, depending on the location and type of facility.
The project complies with all WCF regulations, except for providing a co-location feasibility analysis and for those regulations pertaining to preserving the public viewshed. WCF’s proposed in visually sensitive areas and along scenic corridors shall be sited below the ridge line or designed to minimize their visual impact (Title 21 section 21.64.310.H.1.d). In conflict with requirement, the proposed height of the sign and WCF sits 28 feet above the maximum height limit for the zoning district (42 feet) and does not have surrounding vegetation or buildings at such a height, and thus detracts from the scenic value of the area. Further, Title 21.64.310.H.1.b states that co-location is encouraged when it decreases visual impacts as a measure to preserve the visual character and aesthetic values of the surrounding area. No alternative site analysis was prepared for this proposal for co-location opportunities. Finally, the proposed project places the antennas directly on the two support poles exposing the wireless telecommunications equipment rather than sufficiently screening the equipment behind the sign. This design does not comply with the screening requirements of Section 21.64.310.E. Together with the above discussion regarding the project’s impact on the public viewshed, staff has determined the project is inconsistent with the required findings and regulations outlined in Title 21 pertaining to Wireless Communication Facilities.
Violations
On March 25, 2025, HCD issued an administrative citation, 25CE00053, citing the property for two unpermitted Conex containers being used as office and storage. As of the date of this hearing, the violation has not been resolved and continues to remain active with a status of “citation issued.” Title 21 prohibits the issuance of any permit where there is an outstanding violation. The processing of the application is constrained by strict FCC timelines. Therefore, rather than deeming the application incomplete in accordance with Title 21 section 21.84.120, the project was scheduled for consideration by the Planning Commission prior to lapse of the FCC shot clock (December 18, 2026).
CEQA
California Environmental Quality Act (CEQA) Guidelines sections 15061(b)(4) and 15270 statutorily exempts a project that is rejected or disapproved by a public agency which a public agency rejects or disapproves. The County is a public agency disapproving of the project. Statutory exemptions from CEQA are not qualified by the exceptions applicable to categorical exemptions in CEQA Guidelines section 15300.2.
LUAC:
The proposed project was reviewed by the Castroville Land Use Advisory Committee on November 16, 2026. The LUACs recommendation was not available at the time of distributing this staff report. HCD-Planning will provide a verbal update at the November 18, 2026 Planning Commission hearing.
OTHER AGENCY INVOLVEMENT
The following agencies have reviewed the project, have comments, and/or have recommended conditions:
HCD-Engineering Services
Environmental Health Bureau
HCD-Environmental Services
North County Fire Protection District
Prepared by: Jade Mason, Assistant Planner and Brendon Coye, Senior Planner
Reviewed by: Fionna Jensen, Principal Planner
Approved by: Melanie Beretti, AICP, Chief of Planning
The following attachments are on file with HCD:
Exhibit A - Draft Resolution including:
• Site Plans
Exhibit B - Vicinity Map
Exhibit C - Existing Sign Conditions
Exhibit D - Merritt Street Corridor Signs
Exhibit E - Visual Simulations
cc: Front Counter Copy; Monterey County Regional Fire Protection District; HCD-Environmental Services; HCD-Engineering Services; Environmental Health Bureau; Jade Mason, Planner; Brendon Coye, Planner; Fionna Jensen, Principal Planner; Narain Prasad & Amrita B. Prasad Trs, Property Owner; Greg Davis & Chase Otis, Agent; The Open Monterey Project (Molly Erickson); Landwatch: Planning File PLN250295.