3. Defining "Revocability" and "Limited Use"
The most common criticism of GO 69-C was that the Commission's interpretation of the GO is too strict regarding the terms "revocability" and "limited use." Several Parties indicated that the seeming prohibition on construction and ground-disturbing activities currently associated with GO 69-C appears to be in conflict with the two examples of "limited" uses provided for in the GO: private roads, and agricultural activities. Several Parties agreed that construction should be allowed under GO 69-C if either no CEQA ("CEQA" refers to the California Environmental Quality Act) is required or it is performed at the local level. These Parties also concurred that the term "revocability" requires clarification: does the physical extent of any activity or facilities installed under GO 69-C reflect on their revocability; i.e., does the fact that facilities or structures may be removed or demolished allow that activity to still be considered "revocable?" Finally, Parties suggested that the definition of "limited uses" should be conformed to activities envisioned under PU Code § 767.5 and the "ROW Decision" (D.98-10-058).