HomeMy WebLinkAbout10/15/2024 Item 6b, Tway, Hanh - Staff Agenda CorrespondenceCity of San Luis Obispo, Council Memorandum
City of San Luis Obispo
Council Agenda Correspondence
DATE: October 15, 2024
TO: Mayor and Council
FROM: Timmi Tway, Community Development Director
Hannah Hanh, Associate Planner
VIA: Whitney McDonald, City Manager
SUBJECT: ITEM # 6b – REVIEW OF AN APPEAL OF THE PLANNING
COMMISSION’S DECISION TO APPROVE A CONDITIONAL USE
PERMIT TO ESTABLISH A FRATERNITY (USE-0331-2023, APPL-0365-
2024)
This memorandum provides City staff’s responses, shown in italics, to questions and
issue areas raised from the City Council and members of the public related to Item #6b.
1) What is a Conditional Use Permit? Are fraternities and sororities required to
obtain Conditional Use Permit approval?
A Conditional Use Permit is required for reviewing land uses that may be
appropriate in the applicable zone, but whose effects on a site and its surroundings
cannot be determined without discretionary review and consideration of the site
context. A Conditional Use Permit allows flexibility in providing for, regulating, or
preventing particular uses so they will be compatible with existing or desired
conditions in their neighborhoods or zones. Approval of a Conditional Use Permit
is required for certain uses so that their potentially detrimental effects can be
reduced or avoided and potential conflicts in land use can be prevented.
Fraternities and sororities are only allowed in the Medium-High Density (R-3) and
High Density (R-4) residential zones with approval of a Conditional Use Permit.
2) How is the maximum number of people determined for routine gatherings
and meetings for fraternities/sororities?
Section 17.86.130(A) of the Zoning Regulations states that the maximum number
of persons allowed onsite for routine meetings and gatherings shall not exceed the
limit established by the applicable Conditional Use Permit. Prior approvals of
Conditional Use Permits to establish fraternities/sororities have limited the number
of people onsite for routine meetings and gatherings to 1.5 times the number of
average population density. This calculation takes into consideration the number
of residents, areas inside buildings, and number of parking spaces available in the
vicinity.
Item 6b. Review of Appeal (APPL-0365-2024) Page 2
Per Table 4 (Residential Population Assumptions) of the Land Use Element (LUE),
the High Density Residential (HDR) land use designation, which corresponds to
the R-4 zone where fraternities may be permitted, has an average population
density of 55 people per acre. The project site at E. Foothill Blvd. and Monte Vista
Pl. is approximately 0.58-acre in size, which results in an average of 32 people
(rounded up from 31.9) for the property. Based on this past practice, the maximum
number of people for routine meetings and gatherings for this fraternity would be
48 people (32 people x 1.5) (Condition No. 5).
3) The following statement is requested as an additional condition for all
Conditional Use Permit approvals for fraternities/sororities:
“Failure to comply with any of the above conditions or code requirements,
or the conduct of the use so as to constitute a violation of Federal, State, or
local law, or so as to constitute a public nuisance or so as to cause adverse
impacts on the health, safety, or welfare of persons in the vicinity of this use
is prohibited and may constitute grounds for the revocation of this permit.”
Would any conflict be introduced if this statement is added as a condition?
Condition No. 3 states the Conditional Use Permit shall be re-reviewed by the
Planning Commission if a complaint containing information and/or evidence to
support a conclusion that a violation of the conditions or City Ordinances or
regulations, which are intended to protect the health, safety, and welfare of the
general public, has occurred. Section 17.02.050 (General Relationship to Other
Regulations) also states that any uses authorized by Title 17 (Zoning Regulations)
must comply with all other applicable regulations and requirements imposed by the
State and relevant Federal agencies, including application of the more restrictive
provision if a conflict occurs between different provisions from different agencies.
While incorporation of Condition No. 3 and implementation of requirements in
Section 17.02.050 (General Relationship to Other Regulations) would address this
request, it is within the City Council’s purview to add this statement as a condition
to provide additional clarity on the grounds for re-review of a Conditional Use
Permit.
4) Are special events allowed to exceed exterior noise limits established in
Chapter 9.12 (Noise Control)?
Section 9.12.100 (Exceptions) of Chapter 9.12 (Noise Control) provides an
application process that allows applicants to request exceptions from the exterior
limits in the Noise Ordinance. Any requested exceptions would be reviewed as part
of a special event permit in accordance with Section 17.86.260(B)(5) (Other
Temporary or Intermittent Uses and Special Events) and Chapter 17.108
(Director’s Action). Please note that this is a separate application from the
Conditional Use Permit that allows staff to review special event requests and any
associated exceptions on a case-by-case basis.
Item 6b. Review of Appeal (APPL-0365-2024) Page 3
The noise control officer (e.g., Community Development Director) would review the
request and may only grant exceptions from the provisions of Chapter 9.12 (Noise
Control), if deemed appropriate. Approval of a special event permit with requested
noise exceptions is subject to requirements, outlined in Section 17.108.040
(Director’s Action – Required Findings) and Section 9.12.100(A) (Noise Control –
Special Exceptions), in order to provide for adequate consideration of, and
measures to address, any adverse impact on the public health, safety, and welfare
of those in the vicinity. If the Community Development Director determines that the
strict findings outlined in Section 9.12.100(A)(3) cannot be made, then the
application would be denied. It should be noted that staff cannot recall an instance
where an exception to the Noise Ordinance was granted by the Community
Development Director through a special event permit.
5) Can special event permits allow more than 48 people after 10:00 p.m.? As
proposed, does the Conditional Use Permit allow more than 48 people after
10:00 p.m.?
Condition No. 5 limits the number of people for routine meetings and gatherings to
48 people at all times. If the fraternity is requesting to host a special event involving
more than 48 people, then a separate special event permit is required to be
submitted for review and approval by the Community Development Director prior
to the event occurring.
6) Should code requirements in the Municipal Code be included as conditions
of approval in Conditional Use Permits for fraternities and sororities?
Several older permits have code requirements listed as conditions of
approval.
There are several reasons why including Municipal Code regulations as conditions
of approval is not considered best practice. First, Municipal Code regulations
change over time, and Conditional Use Permits can be in effect for decades. In the
interest of not creating a Conditional Use Permit that is in direct conflict with current
Municipal Code regulations, it is generally not best practice to reiterate code
standards in the Conditional Use Permit. Additionally, it can be confusing to future
parties if some, but not all, relevant code sections are reiterated in the Conditional
Use Permit. In general, conditions in Conditional Use Permits are meant to be
more restrictive than the existing Municipal Code regulations, and are generally
not used for reiteration of otherwise already applicable codes. If the City Council
wishes to incorporate existing Municipal Code regulations into the Conditional Use
Permit, staff recommends referencing the regulations/code sections in a separate
section, but not reiterating them as conditions in the permit.
Item 6b. Review of Appeal (APPL-0365-2024) Page 4
7) The Appellant is requesting a threshold be established to require re-review
by the Planning Commission, if a certain number of violations is received
within the specified timeframe. Please confirm whether Condition No. 3, as
proposed, allows staff to refer the Use Permit for re-review upon receipt of
one violation.
Yes – Condition No. 3 states the Conditional Use Permit shall be reviewed by the
Planning Commission if the City receives substantiated written complaints
supporting a conclusion that a violation of the Conditional Use Permit, City
ordinances and/or regulations, and/or Police resources has occurred.
8) Does the Conditional Use Permit run with the land or the applicant? What
happens to the Use Permit if property ownership changes over time?
Per Section 17.110.090 (Permit to Run with the Land), approval of a Conditional
Use Permit runs with the land (not the applicant). If there is a change in property
ownership, the Use Permit would only continue to be valid if the use is operated in
the same area, configuration, and manner as it was previously approved and has
not ceased operation for a continuous period of one year. In addition, Condition
No. 2 states the Community Development Director would determine whether the
use is in compliance with the conditions, as approved, or if a modification to the
Use Permit is required upon the change in ownership.
If a modification is determined to be required, then the Conditional Use Permit
would be brought back to the Planning Commission for re-review. At that time,
conditions of approval may be added, modified, and/or removed to accommodate
the updated project description of the use.
9) Comments were received expressing concern about the Director of
Community Development allowing exceptions to the noise ordinance
through the special event process.
The Municipal Code does allow the noise control officer to approve exceptions to
the Noise Ordinance (see staff’s response to question 4 above). The City Council
could amend the Conditional Use Permit, including Conditions No. 14 and 16, to
state that no exceptions to the Noise Ordinance shall be granted to this property
operating under the Conditional Use Permit.
Item 6b. Review of Appeal (APPL-0365-2024) Page 5
10) Several comments were received regarding the inclusion of a condition that
would establish an automatic threshold to trigger Planning Commission
review for multiple violations. Comments were received noting that staff has
not acted on a written complaint received for a fraternity that has violated
their Conditional Use Permit.
The Planning Commission approved Conditional Use Permit, as currently written,
addresses this concern. However, the City Council could amend Condition No. 3
to include a specific trigger for review. The current language attempts to balance
responsiveness to written complaints about verified violations with the available
resources to address all code enforcement issues that impact the community.
The assertions that no action has been taken on the Conditional Use Permit for
which a written complaint has been received is not true. Upon receipt of this written
complaint, staff worked to verify the complaints and began the code enforcement
process to gain compliance. In addition, staff reached out to the property owner,
manager, and fraternity in question to discuss the written complaint and explain
the process involved in taking the Conditional Use Permit to Planning Commission
for review. It is true that this process took several months to make contact with the
fraternity in question as members of the fraternity were out of town and not
available during the summer months. Staff required a meeting with the fraternity
leadership once they returned in September and the item will be heard by the
Planning Commission in November or early December of this year.
11) Several comments and questions were received related to the request to
change or amend various conditions of approval.
The City Council can add, remove, or amend any of the conditions of approval to
address concerns that the Council does not find to be adequately addressed in the
currently approved Conditional Use Permit or to strengthen the language of the
Conditional Use Permit for clarity. Staff continues to recommend against any
conditions that would restrict the type of persons (e.g., residents vs. non-residents)
on the site.