HomeMy WebLinkAboutItem 09 - Tolling and 1yr Extension of all City Discretionary Approvals due to COVID-19Department Name: Community Development
Cost Center: 4001
For Agenda of: June 16, 2020
Placement: Consent
Estimated Time: NA
FROM: Derek Johnson, City Manager
Prepared By: Michael Codron, Director of Community Development
Brian Leveille, Senior Planner
SUBJECT: TOLLING AND ONE-YEAR EXTENSION OF ALL CITY DISCRETIONARY
APPROVALS DUE TO THE COVID-19 PANDEMIC EMERGENCY
RECOMMENDATION
Adopt a Resolution to accomplish the following actions deemed necessary to support economic
recovery:
1.Toll the expiration of any City entitlement set to expire on or after March 17, 2020, which
will retroactively extend approvals that expired after the City declared the pandemic
emergency.
2.Extend the term of all active City planning entitlements for one additional year following the
end of the Covid-19 pandemic emergency.
3.Extend the life of all commercial cannabis business operator permits by a fixed period of six
months from the original date of expiration.
4.Extend the life of all building permit applications by a fixed period of six months from the
original date of expiration.
DISCUSSION
Background
On June 2, 2020, the City Council adopted the 2020-21 Financial Plan supplement with a
singular, integrated Major City Goal – Economic Recovery. One of the near-term actions
identified to implement this goal is the extension of entitlements so that they do not expire,
forcing a project developer to restart the approval process and causing delays in the economic
recovery effort that could result in business closures and lost revenue opportunities for both
businesses and city operations. Staff is now recommending that the City Council adopt a
resolution authorizing extension of City discretionary approvals and building permit
applications.
City Discretionary Approvals
Staff’s recommendation is to extend all City discretionary approvals, issued under the Zoning
Regulations and active on the date of the emergency declaration on March 17, 2020, for one year
following the declared end of the state and local emergency. Specifically, for any discretionary
approval active on March 17, 2020, the one-year “life” of the permit will be extended by both the
term of the emergency plus one additional year.
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The term of the emergency is tied to the Governor’s declaration of a state of emergency, the
County Public Health Officer’s declaration of a public health emergency, and the City Council’s
local emergency declaration.
Chapter 17.104.070 of the City’s Municipal Code includes the following:
If building permits are not issued for site development authorized by a
discretionary permit within one year of the date of approval or such longer time
as may be stipulated as a condition of approval, the permit shall expire with the
building permit application. Upon written request received prior to expiration,
the director may grant renewals of an approval for successive periods of not more
than one year each, up to a total of three years. Requests beyond three years are
subject to review by the planning commission. Approvals of such renewals shall
be in writing and for a specific period. Renewals may be approved with new or
modified conditions upon a finding that the circumstances under which the permit
was originally approved have substantially changed. Renewal of a permit shall
not require public notice or hearing, unless the renewal is subject to new or
modified conditions. In order to approve a renewal, the director, or planning
commission as applicable, must make the findings required for initial
approval. (Ord. 1650 § 3 (Exh. B), 2018)
The recommendation before the City Council is to approve a generally applicable extension to
the term of any approval covered by this section of the Municipal Code by the term of the
pandemic emergency, plus one year. This extension would not impact the ability of any
individual applicant or project proponent to pursue additional extensions, not to exceed a
cumulative three years when combined with this general extension, as provided by this section.
Building Permit Applications
Building permit applications submitted before January 1, 2020 are subject to the 2016 California
Building Code (CBC). These applications are required by the code to be actively pursued and
issued within six months of the application date. The CBC does provide for the possibility of
successive 90-day extensions. The recommendation before the City Council is to grant a single,
six-month extension to all building permit applications submitted prior to January 1, 2020,
extending their potential life to June 30, 2021.
CBC Section 105.3.2 - An application for a permit for any proposed work shall be
deemed to have been abandoned 180 days after the date of filing, unless such
application has been pursued in good faith or a permit has been issued; except
that the building official is authorized to grant one or more extensions of time for
additional periods not exceeding 90 days each. The extension shall be requested
in writing and justifiable cause demonstrated.
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Commercial Cannabis Business Operator Permits
The City of San Luis Obispo has issued five commercial cannabis operator permits during the
past year. One of those permits has been activated and four have not met all of the requirements.
If a commercial cannabis operator permit is not fully activated (meaning the business is open and
continually operating) within one year of permit issuance, then current code provisions specify
that the operator permit expires. Commercial cannabis business operators have been impacted by
Covid-19 similar to other business types in the City. The process of activating a commercial
cannabis operator permit is extensive and requires approval of a Conditional Use Permit,
application for building permit, construction per the approved building permit, stocking
inventory and opening for business. Accomplishing all of this within one year is represents an
ambitious schedule during normal times and the current pandemic and other world events define
this time as anything but normal. In light of the generally applicable recommended entitlement
and building permit extensions discussed above, as well as the inextricable intertwined
relationship between such land use entitlements and building permits and the activation
requirements of a cannabis operator’s permit, staff is also recommending a six-month extension
on the activation of currently issued operator’s permits to align with building permit extensions,
due to the effects of the pandemic emergency. The relevant code section follows.
SLOMC 9.10.070.D. Duration and Activation of Permit. Each commercial
cannabis operator permit issued pursuant to this chapter shall expire twelve
months after the date of its activation. The permittee may apply for renewal prior
to expiration in accordance with this chapter. Each commercial cannabis
operator permit must be activated within twelve months of issuance. The permit is
activated by the issuance of a use permit for the commercial cannabis activity
pursuant to Section 17.86.080, together with all other applicable city permits and
state licenses, and the commercial cannabis operator thereafter opening and
continuously operating the commercial cannabis activity. Failure to timely
activate the permit shall be deemed abandonment of the permit and the permit
shall automatically lapse. (Ord. 1673 §§ 1, 2 (Exh. A), 2020; Ord. 1647 § 4 (Exh.
A (part)), 2018)
Policy Context
The proposed action is consistent with the City’s Major City Goal for economic recovery and
facilitates the City’s sub -goal for Housing Production. Further, the recommendation will help
avoid time and cost spent reviewing individual approval extension requests.
Public Engagement
This project has followed an “inform” level of public engagement. However, the City has
received specific requests for this action to help preserve the value of entitlements granted by
ensuring that they do not expire before they can be acted on.
CONCURRENCE
The City’s Assistant City Manager for Community Services and the Economic Development
Manager concur with this recommendation.
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ENVIRONMENTAL REVIEW
The California Environmental Quality Act does not apply to the recommended action in this
report, because the action does not constitute a “Project” under CEQA Guidelines Sec. 15378.
FISCAL IMPACT
Budgeted: No Budget Year: N/A
Funding Identified: No
Fiscal Analysis:
Funding Sources Current FY Cost
Annualized
On-going Cost
Total Project
Cost
General Fund N/A
State
Federal
Fees
Other:
Total
The recommendation will have no fiscal impact on the City. However, the extension of the life of
entitlements and building permit applications is expected to have a positive economic effect on
the community.
ALTERNATIVES
1. The City Council can extend discretionary approvals for a different time period. This
action is not recommended because together, the tolling of approvals and the one-year
extension, will provide a substantial increase in the life of all active entitlements. In the case
of building permit applications, six months is the longest term enabled by the California
Building Code.
2. The City Council can decide not to extend entitlements or building permit applications.
This action is not recommended because the City Council has adopted Economic Recovery
as a Major City Goal and this action is intended to be supportive of the goal.
Attachments:
a - Draft Resolution
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RESOLUTION NO. _____ (2020 SERIES)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA PROCLAIMING THE CONTINUING
EXISTENCE OF A LOCAL EMERGENCY REGARDING THE COVID-19
PANDEMIC AND EXTENDING THE LIFE OF DISCRETIONARY
APPROVALS, BUILDING PERMIT APPLICATIONS AND CANNABIS
OPERATOR PERMITS TO MITIGATE ECONOMIC IMPACTS AND AID
IN ECONOMIC RECOVERY
WHEREAS, section 2.24.060 of the Municipal Code empowers the Emergency Services
Director to request that the City Council proclaim a local emergency when the City of San Luis
Obispo is affected or likely to be affected by a public calamity and the City Council proclaimed a
local emergency at its regular meeting on March 17, 2020 regarding the COVID-19 pandemic and
has subsequently regularly reviewed said proclamation and proclaimed the continuation of local
emergency; and
WHEREAS, the Secretary of Health and Human Services Director issued a Determination
that a Public Health Emergency exists and has existed of January 27, 2020; and
WHEREAS, the President of the United States has declared a State of National
Emergency; the Governor of the State of California has proclaimed a State of Emergency for the
State of California and issued Executive Orders and direction regarding measures to mitigate the
spread of cases of COVID-19 within the State of California; the San Luis Obispo County
Emergency Services Director has proclaimed a local emergency; and the San Luis Obispo County
Public Health Director has declared a public health emergency related the spread of cases of
COVID-19 within the State of California and all recitals set forth therein, are included as though
fully set forth herein; and
WHEREAS, on March 19, 2020, the Governor issued Executive Order N-33-20, including
the Order of the State Public Health Officer mandating all individuals living in the State of
California to stay home or at their place of residence except as needed to maintain continuity of
operations of the federal critical infrastructure sectors and has issued subsequent orders permitting
phased re-opening and requiring continuing measures to mitigate the spread of COVID- 19; and
WHEREAS, the City of San Luis Obispo will be required to help enforce all restrictions
imposed by the State of California and by the County of San Luis Obispo acting as the heal th
agency; and
WHEREAS, the pandemic COVID-19 continues to spread worldwide and in the U.S.,
continuing to present an immediate and significant risk to public health and safety, and resulting
in serious illness or death to vulnerable populations, including the elderly and those with
underlying health conditions and is anticipated to continue to spread in response to phased re-
openings and significant heightened social interaction and group gatherings associated with recent
protest activity; and
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WHEREAS, heightened levels of public health and safety planning and preparedness have
been necessitated in preparation for and response to confirmed cases of COVID-19 in the County
of San Luis Obispo, and rapid response not lending itself to otherwise applicable notice and
approval timelines has been and will be necessary to respond to the rapidly evolving pandemic and
its related, and to mitigate against the spread or resurgence of COVID-19 and its resulting mental
and physical health, social, and economic impacts, compromising the public health and safety; and
WHEREAS, in the absence of such actions, an escalation of the spread remains an
imminent threat and County wide health services may become overwhelmed and unable to keep
up with medical demand for care and availability of hospital or care facility capacity; and
WHEREAS, the pandemic and necessary federal, state and local public health orders
requiring social distancing to prevent spread of COVID-19 have had and will continue to have
devastating economic impacts on the local community, including residents, businesses, employees
and City operations; and
WHEREAS, the City has instituted its Fiscal Health Contingency Plan in order to mitigate
against economic impacts of emergency response costs and significant revenue reductions and has
made drastic reductions to current and projected city costs through reductions in purchasing, limits
on hiring, capital improvement project deferrals, and furloughs of temporary and supplemental
staff; and
WHEREAS, Article 14, Section 8630, of the California Emergency Services Act requires
that the City Council review the need for continuing the Local Emergency at least every sixty (60)
days until such Local Emergency is terminated.
NOW, THEREFORE, BE IT PROCLAIMED AND RESOLVED by the City Council
of the City of San Luis Obispo that:
SECTION 1. All recitals set forth above, and all recitals included in support of Federal,
State and County actions referenced herein, are adopted as though fully set forth herein as findings
in support of this Resolution; and
SECTION 2. A local emergency continues to exist throughout the City resulting from the
condition of extreme peril related to the pandemic of COVID-19, which, absent continuation of
preventative measures, and in the absence of a vaccine, is still deemed to be beyond the control of
normal protective service, personnel, equipment, and facilities of and within the City; and
SECTION 3. Due to the severe economic impacts of COVID-19 and its economic impacts
on the community and the City organization and in order to prevent situations where developers
or contractors need to restart the discretionary review process or delay construction projects with
the need to reapply for permits or request individual extensions and to focus limited staff resources
on supporting the effective implementation of COVID-19 public health and safety compliance
measures for the protection of employees and customers of businesses within the City, and
enforcement of the highest priority provisions for the protection of the general health and safety
of the community, the Council deems it necessary to take the following actions related to the
continuing existence of a local emergency and in support of economic recovery therefrom:
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1. Toll the expiration of all discretionary approvals covered by Municipal Code Section
17.104.070 from the declaration of the pandemic emergency (beginning March 17,
2020).
2. Automatically extend the life of all discretionary approvals covered by Municipal Code
Section 17.104.070 by one year after the termination of the declared local emergency.
3. Automatically extend the life of all active building permits applications by six months,
as authorized by California Building Code Section 105.3.2.
4. Extend the life of all commercial cannabis business operator permits by a fixed period
of six months from the original expiration date. If any operator’s permit currently
issued from the existing application period is not activated and expires or is deemed
abandoned at the conclusion of the period specified herein, the City shall open a
subsequent application period for any retail storefront permits available during which
applications from any previously qualified or permitted applicant may follow the
normal process to submit a new application, along with the applications of any new
applicants.
SECTION 4. All existing orders of the San Luis Obispo County Emergency Services
Director as currently in effect and as subsequently clarified, amended, modified or superseded by
subsequent action or order of the County Emergency Services Director, the County Public Health
Officer, and/or the County Board of Supervisors, are hereby expressly acknowledged and declared
to be enforceable within the City of San Luis Obispo as if directly enacted by the City Council
pursuant to San Luis Obispo Municipal Code Chapter 2.24 and shall be enforceable under
Municipal Code 2.24.100 until such time as terminated by the issuing authority.
SECTION 5. The proclamation of local emergency shall be deemed to continue to exist
until it is terminated by the City Council of the City of San Luis Obispo pursuant to a resolution
adopted by the City Council of the City San Luis Obispo or its Emergency Services Director.
SECTION 6. The City has been undertaking, and will continue through cessation of this
emergency to undertake, necessary measures and incur necessary and extraordinary costs, which
are directly related to the prevention of the spread of the COVID-19 Virus and are taken in
furtherance of: the Secretary of Health and Human Services Secretary’s determination that a public
health emergency has existed since January 27, 2020; City Council’s Proclamation of Local
Emergency on March 17, 2020 and subsequent proclamations of continuing local emergency the
Governor’s Proclamation of a State of Emergency on March 4, 2020 ; the President of the United
States’ Declaration of a National Emergency on March 13, 2020; the County Emergency Services
Director’s Proclamation of Local Emergency and the County Public Health Director’s Declaration
of a Public Health Emergency on March 13, 2020, and related orders, regulations and directions.
SECTION 7. During the existence of said local emergency, the powers, functions, and
duties of the Emergency Services Director and the Emergency Organization of this City shall be
those prescribed by state law, ordinances, and resolutions of this City and by the City of San Luis
Obispo Emergency Operations Plan, notwithstanding otherwise applicable procedures, timelines
or methods of action and the Emergency Services Director is expressly authorized to take any and
all actions in furtherance of emergency powers to address the local emergency.
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SECTION 8. A copy of this Resolution shall be posted on all outside public access doors
of City Hall of the City of San Luis Obispo and in one public place within any area of the City
within which this Resolution applies and personnel of the City of San Luis Obispo shall endeavor
to make copies of this order and regulation available to the news media.
Upon motion of _______________________, seconded by _______________________,
and on the following roll call vote:
AYES:
NOES:
ABSENT:
The foregoing Resolution was approved this _____ day of _____________________ 2020.
____________________________________
Heidi Harmon
Mayor
ATTEST:
____________________________________
Teresa Purrington
City Clerk
APPROVED AS TO FORM:
_____________________________________
J. Christine Dietrick
City Attorney
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City
of San Luis Obispo, California, on _____________________.
____________________________________
Teresa Purrington
City Clerk
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