Can a misrepresentation in a permit application be used as the basis for a claim for justifiable reliance?

In any event, the purported misrepresentations do not appear to be material and thus cannot serve as the basis for a claim for misrepresentation, regardless of the party to whom they were made. (Adkins v. Wycoff (1957) 152 Cal.App.2d 684, 689.) The element of justifiable reliance requires that any alleged misrepresentation be material. (See Lacher v. Superior Court (1991) 230 Cal.App.3d 1038, 1049.) Looking at the offending document in context -- an unsigned document entitled "Use Permit Application Information" which states that the "site itself is nestled among some trees," thereby making "the building and the lower half of the tower impossible to see from the public" and that the surrounding residences "probably cannot see the facility due to tree coverage" -- the alleged misrepresentation does not appear to be materially false. The document notes that the existing tower is 110 feet and that a new equipment building will replace the old service module. In that context, a statement that the "lower half of the tower" (emphasis added) is "impossible to see from the public" and that the surrounding residences "probably cannot see the facility due to tree coverage" cannot be reasonably interpreted to mean that the trees fully obscure a 110-foot (or higher) tower from anyone's vantage point.