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HomeMy WebLinkAbout08-166p.,, ~~ ••' ,r• • ~: ~ •ap i • ~O~ • 4'' • f % *~ ^ r S (/~ i ~ • ~ * ~• • ~ ' ' 'y' • ~ • iii~iiiti* BtJARD COUNTY OF QF UPERVI~CIRS BUTTE, STATE OF CALIFORNIA Resal~tion IVY. og--1~6 RESOLUTION OF THE BOARD OF SUPERVISORS OF THE COUNTY OF BUTTE ADOPTING AGRICULTURALIRESIDENTIAL BUFFER IMPLEMENTATION GUIDELINES, PURSUANT TO SECTION 24- 2$6(C)(2) OF THE BUTTE COUNTY CODE. WHEREAS, the Board of Supervisors of the County of Butte, State of California, in 1995 adopted the General Plan Agricultural Element including Program 2.2, which requires a 300' foot buffer between residential uses and agricultural land; and WHEREAS, an February 13, 2007 the Board of Supervisors approved Ordinance 3953, which is codified as Section 24-286 of the Butte County Code. Section 24-286 requires a 300' foot buffer between residential uses and agricultural land within the OFC (Orchard and Field Crop) and GOL (Grazing and Open Lands) land use designations and areas abutting those two land use designations, and along the interior three hundred feet of community boundaries and spheres of influence lines; and WHEREAS, General Plan Agricultural Element program 2.2 directs that guidelines be developed "illustrating buffer requirements for various situations"; and WHEREAS, buffer implementation guidelines illustrating buffer requirements for various situations will help implement the 300' buffer required by Butte County Code Section 24-286 and will provide guidance relative to requests for determination of unusual circumstances pursuant to Butte County Code Section 24-286{c) and {d); and WHEREAS, the Butte County Planning Commission, after reviewing a staff report and public testimony at their regular meeting of November 13, 2008 has recommended that the Board of Supervisors adopt such AgriculturallResidential Buffer Implementation Guidelines; and WHEREAS, the Board of Supervisors, accepted public testimony and reviewed a staff report and the recommendations of the Planning Commission. NOW, THEREFORE, BE IT RESOLVED that the Board of Supervisars does hereby find it to be in the public interest to adopt and establish the AgriculturallResidential Buffer Implementation Guidelines in the unincorporated area of the County of Butte, pursuant to Butte Caunty Code Section 24-286(c}{2}, as set forth in Exhibit "A" attached hereto and by this reference made a part thereof. PASSED AND ADOPTED by the Butte County Board of Supervisors this 16th day of December 2008 by the following vote: AYES: Supervisors Connelly, Dolan, Kirk Chair Josiassen and Yamaguchi NOES: None ABSENT: None NOT VOTING: None ~ %~ t Curt~Jgsiassen, CHAIR Butte County Board of Supervisors ATTEST: C. BRIAN HAD~iX Administfa ivy Offi4 and Cierk ~~. I ,~,,,~/ {// ~ 'f l Chief ~` _{ f ,~ ; ,; L 1! Exhibit A Table of Contents AgriculturallResidential Buffer Implementation Guidelines, pursuant to Section 24-28fi{c)(2} Buffer Guidelines of the Butte County Code. Section Page # A. Intent of Buffer Guidelines: 1 1 }Purpose. 1 2} Why a Buffer is Required? 1 3} Case by Case Guidance. 2 B. General AssumptionslOverview {1-3). 2 C. Applicability of Buffer Guidelines {1-5}. 3 Differentiating Commercial Agriculture from Nobby/Gardening Activities 4 D. Process for Determination of "Unusual Circumstances". 4 1}Unusual Circumstances Determination Process for Qiscretionary Entitlement Project Applications. 4 2} Unusual Circumstances Determination Process for Administrative/ 5 Building Permits on Existing Parcels. E. Factors Applicable to Both Administrative Permits and Discretionary Projects regarding "Unusual Circumstances" and Modifying the 3Q0' Buffer. 6 1 } "Unusual Circumstances" General Approach & Noticing Procedures 7 2} Five Factors {a. through e.} that May Support Buffer Modification. 7 3} "Substantially Affected" Agricultural Land {a-d). 10 4} Three {1-3} Factors that May Make Agricultural Land Unavailable 11 for Norma{ Operations. F. Conditions of Approval {1-6} upon Determining Unusual Circumstances and Other Considerations. 13 G. Definitions. 14 Agriculture 14 Agricultural Maintenance Plan 14 Agricultural Permits 14 Administrative Permits 15 Discretionary Project 15 Exhibit .l, Resolution Adopting Agricultnral:Residcntial Buffer Implementation Guidelines (12-1b-R8} 4 Exhibit A List of figures Description Page # Figure 1. illustration of the general concept of an agricultural-residential buffer. 1 Figure 2. Illustration of the general concept of features which may or may not be 2 considered in making a recommendation of Unusual Circumstances in modifying the 300' buffer. Figure 3. Location of new homesites near existing homesites and roads. 3 Figure 4. Flow chart of the process for making a determination of "unusual 4 circumstances" for discretionary project applications. Figure 5. Flow chart of the process for making a determination of "unusual 6 circumstances" for administrative {building} permits on existing parcels. Figure 6. Existing natura# features may help support recommendations of unusual 8 circumstances. Figure 7. Diagrammatic example of potential constructed barriers and landscape 9 features which may or may not support recommendations of unusual circumstances. Figure 8. Intervening features may help support recommendations of unusual 10 circumstances_ Figure 9. Agricultural land may be substantially affected by surrounding 11 smal{-parcel residentiak uses. Figure 10. Agriculture) land may be substantially affected when residential use 12 impacts overlap at least 25°f° of the agricultural parcel. Figure 11. Agricultural land may be substantially affected when a de-facto 13 buffer has been created. ExF~fbit A, Recolutiun Adopting A~ricutti:ral.-Rcsidentiat Suffer Im~rlerncntation Guidelines (]Z-IG-0~3) Exhibit A AgriculturaltResidential Buffer Implementation Guidelines, pursuant to Section 24- 286{c) {2} Buffer Guidelines of the Butte County Cade {BCC): A. Intent of Buffer Guidelines 1) Purpose These agricultural buffer guidelines are intended to help implement the 300-foot (300'} buffer required by Butte County Code (BCC) Section 24-286 and to provide guidance relative to requests for determination of unusual circumstances pursuant to BCC Section 24-286(c) and (d). If approved, requests far determination of unusual circumstances allow modification of the 300' agricultural buffer requirement. 2) Why a Buffer is Required Conflicts potentially exist between agricultural and non-agricultural uses. Agricultural land users commonly have concerns about potential conflicts including: restrictions on farming operations, restrictions an pesticide usage, increased risk of theft and vandalism, complaints, theft, introduction of pests, litter, and pets Pram residential uses. Residential land users commonly have concerns about potential conflicts related to: pesticide use. noise, odors, insects, dust. smoke, animal containment, extended hours of operation, and visual impacts (See Figure 1 below). A buffer physically separates agricultural and non-agricultural uses and helps minimize potential conflicts. The required residential-agricultural buffer separation is 300'. If the County makes a determination of "Unusual Circumstances' (See Sections d & E below) a buffer may take other farms or be of a lesser distance {See Figure 2 below}. 3D0' Agricultural-Residential Buffer Common Properky Trespass, Litter, Pests Line 4 ~~~~~~~~~~.~~~~~~~~~~~~~a~~~~~~• Pets, Vandalism, Complaints .4 ................................ ~* ~. S ra Drift Noise ,~'' :,~~!` °~~l~~~,'~ Smoke. Qdors. Dust .... ,.~ Buffer Area ,,t ___ _ ~ 300' separation ~~ Figure 1. Illustration of the general concept of an agricultural-residential buffer- F:~hibit .l Rrsolutia^ fear ldoptinn z~i'_A~,!riculturaVRcsidcn~i;il 13uE~t'cr Irnplcmcatation t:uidcliucs Unusual Circumstances Reduced Buffer Camman Property ~` . Line ~" - Buffer Area Figure 2. Illustration of the general concept of features which may or may not be considered in making a recommendation of Unusual Circumstances in modifying the 300' buffer. 3} Case toy Case Guidance These guidelines are meant to guide and direct landowners, County staff; project applicants. Planning Commissioners, and Board members in deciding if projects have adequately met the objectives of General Plan Agricultural Element Program 2.2. as implemented by BCC Section 24-286. These are meant to be °guidelines". not one-size-fits-all "regulations or rules". Each project application will be studied. assessed and considered an a case-by-case basis. The intent of these guidelines is to facilitate predictability and uniformity in land use planning and decision making. It is anticipated that these guidelines may be amended with more detail as the County gains experience in the implementation of buffers. B. General AssumptiansJQverview 1} In general, these agricultural buffer guidelines make no distinction between Grazing and Open Land (GOL} and Orchard and Field Grops {OFG} land with regard to the application of unusual circumstances. 2} In order to achieve the objectives of the 300' buffer to preserve and protect agricultural resources; land located within the 300' buffer which is at unincorporated community boundaries or at the outer boundaries of spheres of influence shall not be recommended for development. Spheres of influence around cities {as amended over time} define the primary area within which urban development is to be encouraged. Spheres of influence are essential planning tools to combat urban sprawl, provide well planned. efficient urban development patterns,. and preserve prime agricultural land. 3} When agricultural land is proposed far residential development, new homesites should be located near existing homesites and roads to minimize impacts on agriculture, segmentation of valuable agricultural land, and to preserve the agricultural land resources of the Gounty (See Figure 3 below). h:~hibit ~ Nccolutiu^ Iirr adoption nf:~;,riculhn• d,'Rccidenti it Buffo Im~lcntcntnlio~ Gttidclinc~ Agricultural ' Land ? - ' i ~, • ~ ~~' ' I ~ Z ~ S ' I ` i ........... .......... .....: ~~~ I aYl-~ aip~ ~ ~~ Grape Vine Ave. Land Key to Symbols .............. ', I Agricultural Land '• ~ :Proposed Homesite i Proposed for Development ~ t iGenerally Approved :..`::::Y::. t~ Existing HomelParcel ~~ .generally Not AIlotved Figure 3. Location of new homesites near existing homesites and roads. C. Applicability of Buffer Guidelines 1} The 304' buffer referred to in these guidelines is as established in BCC Section 2) The applicability of the 300' buffer is as described in BCC Section 24-286{b). 3} These guidelines address situations where a determination of unusual circumstances has been requested to adjust the 300' buffer. 4) These guidelines are applicable to development entitlement and building permit applications deemed complete on and after March 14, 2007 (effective date of BCC Section 24-286). 5) Buffers apply to °commercial agricultural" operationslactivities only, not to residential gardening and hobby activities. These two categories are differentiated by the Agricultural Commissioner by considering factors that include but are not limited to any of the size and permitting criteria listed below: I~ahibit 1 F2c~olutinn for Adoption oC \~ricultur;itlKcsidcntial F3uffcr lurplrmcnta~tion t;uidclines g Differentiating Commercial Agriculture from Hobby/Gardening Activities Commercial Agriculture Criteria: a} Parcel size one {1) acre or greater. b} Issuance of Agricultura! Permits as defined in Section G. c} Production of an agricultural commodity for sale. d} Issuance of export {phyfosar~ilary) certification. e} Approved agricultural Maintenance Plan as defined in Section G. f} Agriculturally-related business license. Nan-commercial Residential Gardening /Hobby Agriculture Criteria: a) Parcels less than 1 acre. b} Not substantially meeting any of b) through f} above. D. Process for Determination of "Unusual Circumstances". The process used for determining if a project has an unusual circumstance that supports modification of the 300' buffer differs depending an whether the project requires °discretionary" or "administrative" approval. The definitions of "discretionary" and "administrative" are found in Section G. For example, project applications far parcel map and subdivision map entitlements are subject to "discretionary" review and approval by the Planning Commission {See figure 4 below}. However, building~ermit applications for existing developable parcels are reviewed "administratively" for approval (See Figure 5 below} Project designs which generate the need far a determination of unusual circumstances should be avoided. 1) Unusual Circumstances Determination Process for Discretionary Entitlement Project Applications: A determination of unusual circumstances for a discretionary entitlement project results when the Planning Commission, and in some cases the Board of Supervisors, considers the recommendation of the Director of Development Services as a factor in approving or denying a project, as outlined in Figure 4 below. ---- , _ - ------ Concept ~ Project i 'Revise ~~ Planning __ _ ~ ~ Application , ~ Project Commission _ ___ i -- PRED ! ~ Cansuglt ton & I' ~ Public l ! Appeal ---- _ , ~ I Notice ~ ~ - _ ~ Recommendaton ~ ~___ __- Figure 4. Flaw chart of the process far making a determination of "unusual circumstances° for discretionary project applications. Fahibit l Revolutirui fur tclu~tti+>~~ of ~~ricultural/Kc.~identi:~l Buffer Ln~lemrntati~,n Guidelines t~ Concept: Land development proponent (applicant} informally discusses with Planning Division of the Department of Development Services {DDS} The Planner explains the requirements of the 300' buffer. PRED: Pre-Development Conference with applicable departments of the County. including Agricultural Commissioner and Planning Division. Project Application: Proponent submits an application for a discretionary project (e.g. Tentative Parcel Map, Subdivision Map, or Use Permi#) with a request for Determination of Unusual Circumstances. DDS/Agricultural Commissioner Consultation: The Director of Development Services consults with the Agricultural Commissioner to formulate a recommendation to the Planning Commission. The details of the Director's recommendation are discussed with the applicant. Revise Project: Proponent has the opportunity to revise the project based on recommendations from the Agricultural Commissioner and Director of Development Services. Public Notice: The general public and surrounding property owners are notified of the Planning Commission hearing for the project. The project description. including any buffer and environmental review are made available to the public. Planning Commission: The Planning Commission holds a public hearing, receives testimony and either approves the project with conditions or denies the project. The Commission has the authority to accept. deny. or modify the recommendation of the DDS Director regarding Unusual Circumstances which may allow modification of the buffer. Board of Supervisors: Per Butte County Cade, some project applications can only be approved by the Board of Supervisors. These include: General Plan Amendments, Rezones, Planned Unit Developments, Development Agreements, and projects involving contracts or contract amendments.. etc. Actions of the Board are not appealable. Right of Appeal: Discretionary project approvals and denials by the Planning Commission can be appealed to the Board of Supervisors. A project approval can be appealed by any interested person. 2) Unusual Circumstances Determination Process for Administrative) Building Permits on Existing Parcels. A determination of unusual circumstances for an administrative {building} permit application on an existing parcel is made by the Director of Development Services after consultation with the Agricultural Commissioner. as outlined in Figure 5 below: F:~hifaill Itc~olution for ~doptiun oC.1~~riculturaURcsidcntixl Aul~fcr Implemculation (:uidclincs ~~ Building Possible Permit Concept Permit Revised Issued or Application j Site Plan Denied ,: / _ __ J __ ,/~ Informal - - --, Consultation , ~ DDSIAg-Comm. ppS i with Planner Consultation .Determination Figure 5. Flow chart of the process for making a determination of `unusual circumstances' for administrative {building) permits an existing parcels. Concept: Landowner informally discusses their residential site plan with the Planning Division of the Department of Development Services {DDS). The Planner explains the requirements of the 300' buffer. Building Permit Application: The owner submits a building permit application for processing, with a request for Determination of Unusual Circumstances if the proposal does not comply with the 300' buffer. DDSIAgricultural Commissioner Consultation: The Planning Division and Rgricultural Commissioner review the proposed residential site plan far conformance with the 300' buffer requirement and assess whether a determination of Unusual Circumstances should be made. The Director of Development Services informs the landowner of the determination. Possible Revised Project: If the proposed site plan does not conform to the 300' buffer and does not qualify fora Determination of Unusual Circumstances, the owner has the opportunity to revise the site plan. DDS Determination: In consultation with the Agricultural Commissioner. the Director of Development Services decides if a Determination of Unusual Circumstances should be made. Permit Issued or Denied: If the final site plan conforms to the 300' buffer or if the Director of Development Services makes a Determination of Unusual Circumstances the permit is approved; if not, the permit is denied. E. Factors Applicable to Both Administrative Permits and Discretionary Projects, regarding "Unusual Circumstances" and Modifying the 300' Buffer For both discretionary project applications and building permit applications, the applicant may petition the Director of Development Services (Director}, in writing, to make a recommendation of `unusual circumstances" {per Section 24-286{d)} for modifying the 300 buffer. It is the responsibility of the applicant to provide detailed supporting information., rationale and justification, based an the five criteria below {as listed in Section 24-286{d}}: F:ahibit .~ Etc,olutinn rnr .~dnption riCAgrictdtnr~tll3dcsidcntia] (3u1'1'cr Imptcauntntian Guidcliiec~ ~ 1 ~ Parcel size and shape Z location of residence(s). 3. Infrastructure and other existing uses. 4 Natural physical features and topography. 5 Uther circumstances not specified above. A Pre-Development Conference {PRED) application {a fee service} may be used to petition for a recommendation of "unusual circumstances" in advance of a discretionary land use entitlement application. The Director and the Agricultural Commissioner will assess and consider the following four factors regarding "unusual circumstances" in support of modifying the add' buffer' 1} "Unusual Circumstances" General Approach and Noticing Procedures: a. The 300' buffer applies to habitable residential structures. b. Non-habitable structures or infrastructure features may be approved within the 300' buffer area. c. The 300' buffer area is always applied an the proposed "residential-use" land and is measured from the agricultural property boundary to the proposed residential structure. d. Per the standard procedure for public noticing of hearings before the Planning Commission and Board of Supervisors (does not apply to administrative building permits): all property owners within 300' of proposed development will be notified of scheduled hearings. Any proposed reduction of the 300' buffer will be included in the project description of such noticing. 2} Five Factors {a. through e.} that May Support Buffer Modification: a. After consultation with the Agricultural Commissioner (per Section 24- 286(f}} the Director of Development Services may make a recommendation for modification of the 300' buffer. As part of such a recommendation, the Agricultural Commissioner may determine if any of the following factors or combinations thereof support buffer modification {~) A determination is made that existing land uses, development or structures have substantially affected {See Figure 9 below} the operationstactivities on the agricultural land. (2) R determination is made that the adjacent agriculturally- designated land normally protected by the buffer is unsuitable for agricul#ural use due to various factors including but not limited to: {a} Site is unlikely to host an agricultural operation. 1~:~hihit .~ Kc~olution Ifn~ adoption ~rf a;;ricultur~l;l2csidcntinl f3ul'ttr Implcment~itinn Guidctinc~ tb} No existing agriculture on site and no adjacent agriculture within 3flOft Otherwise viable fallow land shall be considered an agricultural use. (c} Absence of arable soil, ar inadequate soil characteristics (e g gravel. rocks. hard pan, tailings} that would preclude agricultural use. (d) Extreme topography that would preclude agricultural use. b. A determination is made that existing, significant natural features such as topography or vegetation help prevent negative influences on existing agricultural uses and provides adequate protection to residential uses from adjacent agricultural operations. The example below (Figure 6) is one of many variations and situations which would require case-by-case review. Incorporation of any such natural feature as part of a buffer may be considered, provided that no significant environmental impacts would result. To be an effective feature of a buffer.. a natural feature must be reasonably expected to remain intact far the foreseeable future. 2f C ca J .~ Q .~ -~ __ soa° ........ i di ~,~ ,a ,~ i'> .................. is ,~ ~. `. .~ ~~ ~ . ~ p'er', ac .d "~ ~ ,~„ ; y'ca T O V lad ~~~ .~ ~' P m ~~ ~, . ~~~. Agricultural Land Figure 6. Existing natural features may help support recommendations of unusual circumstances. c. R determination is made that constructed features such as solid walls, fences, andlor landscaping will provide some buffering between agricultural and residential uses and prevent impacts to the agricultural operation. Constructed barriers alone may not be adequate to support I~:zhibit ~ Resolution fer.Ac3optiou uf,iy;riculhirxlrKesidcillial fturfer Implementation Guidelines l~ reduction of the 300' buffer. but may be used effectively in combination with other factors to modify the need for the full 300' buffer (See Figure 7 below} Features must be designed to remain intact for the foreseeable future. Consideration of constructed barriers as part of a recommendation of unusual circumstances requires thorough consultation between the applicant, the Agricultural Commissioner, and the Department of Development Services. The use of design features to modify the buffer is considered on a site and case-specific basis, per BCC Section 24- 286(d}(S}, depending on factors including but not limited to: • Parcel Size • Type of Crop • Topography • Agricultural Chemicals and Farming Practices in Use Property Fine -Conifer- ry Evergreen '~`-.~~ Tree Row ~ '"~ ~ ~; ,~ rr. - Decidu©us ReSld@nUal ? Trey Raw _j i` _ __ I Land t; :,,.~ ~' •~ `~" ;r ;,;: 1 :~~ i _~~~~'' ~ BERM •v,~ _ _ Agricultura! Land s I ,~ 1 ~~ f~ y 9i b Figure 7. Diagrammatic example of potential constructed barriers and landscape features which may or may not support recarnmendations of unusual circumstances. d. A determination is made that combinations of natural features and constructedJlandscape barriers will support modification of the 300' buffer area. e. A determination is made that non-agricultural intervening features such as roads, railroads, and canals may provide physical separation andlor barriers and serve as part of the buffer area (See the Figure 8 below}. The Director may recommend that the buffer include these features. ICchit~it V 1{csuluti~m fr~r ldoptinn nr.l~rieu]tursiliKesidential Buffer Implemcotntion Guidelines ;(¢j'j \ 2oa° ~~ ,~ ~, ~~ ~; ~r-- "I o ~r• ~ ,~, Figure 8. Intervening features may help support recommendations of unusual circumstances. 3} "Substantially Affected" Agricultural Land: Agricultural operations) activities may be considered to be substantially affected when they are impacted or limited by the presence of existing adjacent residential and /or urban development so that normal and customary agricultural practices cari no longer be carried out. This assessment is to determine the relative degree of residential development impact, based on a composite of the criteria below. The Agricultural Commissioner and Director of Development Services will assess the qualitative effects of existing residential development on the sustainability of operations on the agricultural land to be protected by the 300' buffer. In the case of "administrativelbuilding permits" the Director then makes a determination of whether the land is "substantially affected by residential development" and if the situation may support modification of the 300' buffer requirement. In the case of "discretionary project applications", the Director makes a recommendation to the Planning Commission and/or Board {depending on project type} regarding whether or not land is "substantially affected by residential development". The criteria that will be assessed in determining if agricultural operations) activities are considered to be substantially affected, impacted or limited by the presence of existing adjacent residential and lar urban development inciude the following four factors: a. At least 55°lo of the parcels surrounding the GQL ar OFC agricultural land to be protected are less than 5 acres and in residential use (See Figure 9 below}. ,Q, (>! ~, , a Agricultural Land F:~hihit S {tesuh~ti+}n fur .ldu~tiun of \;;ricalturxVResidculial 13ufrer Iroplcmcnriliun Guidelines i _ ___ I Possible ........,. _ Reduced ~ ~: ~~: ;~ ` ... Buffer `~~~~~•~~ ~- --- - - era a vine.vve-`'-'^--~ i "Substantially Affected" Agricultural ,~.~ Non- Land "Substantially Affected" Agricultural ` Land ~ I ~~ Key to Symbols .............. ~ Agricr:Itural ~a~d i ~~ ti Proposed Homesite :............. Proposed for Development Exstina NornelParcel ', -~ Figure 9. Agricultural land may be substantially affected by surrounding small-parcel residential uses. b. There is significant existing urban infrastructure on at least two boundaries of the property to be protected by the buffer. c. The presence of pre-existing legal non-agricultural activitiesloperations on other parcels adjacent to the agricultural land normally protected by the 300' buffer. d. The presence of existing °sensitive residential receptors" may impose regulatory limits on some agricultural practices, rendering some portion of the agricultural land normally protected by the 300' buffer unavailable for normal agricultural operations when one of the following three conditions exist: 4) Three Factors (1-3 below) that May Make Agricultural Land Unavailable for Normal Operations: {1) Existing residential impact, as measured by a 300' radius from each existing residence, overlaps at least 25°t° of the agricultural parcel protected by the 300' buffer (See Figure 10 below). Echibit .A Rcsulutiujj ft~r Adoption of ~~riculh~rsif.~IZctiidcntial Baffcr Lnplemcnh~tiun Guirtclinc~ Agricultural Land 5-acre j "A-10" Parcel app= Y Q} V ~{ I ~1 ~~ __ Key to Symbols ___ __. AgE~cvih~ra ! and ~ ~~; Proposed ~iomesde '°ro~osed br De~elopcien~ Iasi s-sang Norn eiParra Figure 10. Agricultural land may be substantially affected when residential use impacts overlap at least 25°l0 of the agricultural parcel. (2) A de-facto buffer has been established. as delineated by a tangent line drawn across the agricultural side of existing residences and connecting those existing residences which are no more than 600 feet apart. The distance between that tangent line and the parallel property line of the agricultural parcel is the de-facto buffer (See Figure 11 below). I~:~hilait :A Rcsidutiun fur:~duption af.As~ricul~uryliNcsidcntial 13uCfcr lmplcmcnhuinn Guidclinc: 17