HomeMy WebLinkAbout05/03/1994, 1 - WATER ALLOCATION FOR ADDITIONAL PHASES OF COPELAND'S DOWNTOWN CENTER PROJECT (APPEAL OF STAFF'S CODE INTERPRETATION). MEETIN ATE:
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city of San IRIS OBISpo -
COUNCIL AGENDA REPORT NUMBER: /
FROM: Arnold B. Jonas, Community Development Director v
BY. Glen Matteson, Associate Planner !!!
SUBJECT: Water allocation for additional phases of Copeland's Downtown Center
project (appeal of staffs code interpretation).
CAO RECOMMENDATION:
By adoption of resolution"A" (attached), determine that the Copeland's Downtown Center
project is not an extension of the French Pavilion proposal and therefore, for purposes of
water allocation, is not eligible for building permits as a "pipeline" project.
DISCUSSION
Data Summary
Location: Approximately one-half block fronting on Higuera, Morro, and Marsh streets.
Applicant/owner: Copeland Enterprises
Representative: Randy Rea, APS
Environmental status: Request is categorically exempt as a minor change to land use
limitations.
Action deadline: None specified by State law.
Situation
The applicant has appealed staffs determination that the Copeland's project is not a
"pipeline"project Staffs determination requires that building permits for additional phases
of construction be issued on the basis of replacement of previous site uses, on-site supply,
or retrofitting (attached letters). Under the interpretation requested by the applicant,
additional phases would obtain building permits on the basis of water assigned to the French
Pavilion proposal.
Explanation
The Water Allocation Regulations, adopted in 1988, are intended to help the City achieve
and maintain balance between normal water use and reliable levels of supply (S.L.O.
Municipal Code, section 17.89.010). A 1989 amendment to these regulations stated
Council's intent to allow projects to proceed even if no water allocations were available, if
project applications had been received before the amendment date —so called "pipeline"
projects (section 17.89.060.H). Water allocations are assigned to specific projects (sections
17.89.040 and 17.89.060.G). If required water allocations are not available,which is now the
case, projects have the option of retrofitting (section 17.89.030).
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1111111141111 City of san Ls ompo
COUNCIL AGENDA REPORT
Initial applications for the French Pavilion project were received in 1987. The
environmental study concluded that the new buildings would use about 2.9 acre-feet more
water than the buildings removed from the site. Revised French Pavilion plans were
submitted in 1988. A building permit was processed and construction started in 1989, for
a four-level project having stores, offices, a food court, a bank, and an enclosed pedestrian
space.
After construction was suspended for some time,a new architectural application for basically
the same site was received in 1992: the Copeland's Downtown Center, a three-level project
with stores, offices, a restaurant, a theater, and an outdoor pedestrian space. Architectural
Review Commission approval was obtained, a building permit was processed, and
construction began in 1993. The initial phase, approved on the basis of using water credits
from buildings which had existed on the site, has been occupied. Additional phases are
proposed. Depending on the size and type of restaurants which may be included, the whole
project would use roughly seven acre-feet more water than the buildings removed from the
site.
Evaluation
Several times in administering the Water Allocation Regulations, staff has needed to
interpret what constitutes a new project, as opposed to changes to an original "pipeline"
project In each case the guiding principle has been whether the changes could be
accommodated by revised architectural-review and building-permit plans, or if new
applications were required. Changes in facade (materials, colors, doors and windows) or
roof style clearly are revisions, while changes to the site plan, uses, or structural systems
generally require new applications. Staff has tried to be liberal in allowing revisions without
jeopardizing"pipeline"status. Note that previous projects have been required to retrofit(or
not change) as a result of these decisions.
Staff believes the determination in the present case is consistent with earlier determinations.
The regulations do not indicate that the amount of water usage or the design merits of
projects can be considered in making these determinations.
The present request would not make a significant difference in the City's overall water
situation. Considering the direct effect, the roughly seven acre-feet additional water usage
for remaining phases represents about 1/10th percent of current water usage. Considering
this request as a precedent, nearly all "pipeline" projects have been built; about eight acre-
feet are committed to "pipeline" projects which have not applied for building permits.
No advisory bodies have been involved with this issue.
/r
!RIII city of San 1�6 OBISPO
COUNCIL AGENDA REPORT
ALTERNATIVES
The Council may adopt resolution "B" to determine that the Copeland's Downtown Center
is an extension of the French Pavilion proposal, and therefore may obtain building permits
based on a "pipeline" status. Council may continue action with direction to staff
FISCAL IIWPACTS
No significant fiscal impacts are expected from approving or denying the requested
interpretation.
ATTACHMENTS
Draft resolution "A" denying request
Draft resolution "B" approving request
Appeal letter
Staff letter
COP&WMCAR
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RESOLUTION NO. (1994 SERIES)
A RESOLUTION OF THE SAN LUIS OBISPO CITY COUNCIL.
DETERMINING THAT THE COPELAND'S DOWNTOWN CENTER IS
NOT AN EXTENSION OF THE FRENCH PAVILION PROJECT
FOR WATER ALLOCATION PURPOSES
The Council of the City of San Luis Obispo resolves as follows:
SECTION 1. Findings.
A. A public hearing has been held to consider the applicant's appeal of staffs
determination concerning the status of Copeland's Downtown Center under
the Water Allocation Regulations (S.L.O. Municipal Code Chapter 17.89).
B. Council has considered the report and recommendation of staff.
C. Staffs determination was consistent with the General Plan Water &
Wastewater Management Element and the intent of the Water Allocation
Regulations.
D. Complete planning applications for the Copeland's Downtown Center were
received after March 15, 1989; the Copeland's Downtown Center is not the
same project as the French Pavilion, since it has a different design and
contains different types of uses; the receipt of separate planning and
building applications constitutes separate projects within the meaning of
Water Allocation Regulations parts 17.89.040 and 17.89.060.G.
SECTION 2. Action.
Council hereby determines that, since it is not an extension of the French Pavilion
proposal, the Copeland's Downtown Center can qualify for building permits under the
Water Allocation Regulations only to the extent that it is a replacement for previous
development on the site, it obtains a water allocation, or it provides its own water supply
or offset (retrofit) credit.
On motion of . seconded by . and on the
following roll call vote:
AYES:
NOES:
ABSENT:
v
Resolution No; (1994'Series)
.Page 2
the foregoing resolution was passed and adopted this day of
1994: - - -- -- ---
ATTEST:
City Clerk
APPROVED:
�A_tto ey -
jmL•COPEWIRRE$
0
RESOLUTION NO. (1994 SERIES)
A RESOLUTION OF THE SAN LUIS OBISPO CTTY COUNCIL
DETERMINING THAT THE COPELAND'S DOWNTOWN CENTER IS
AN EXTENSION OF THE FRENCH PAVILION PROJECT
FOR WATER ALLOCATION PURPOSES
The Council of the City of San Luis Obispo resolves as follows:
SECTION 1. Findings.
A. A public hearing has been held to consider the applicant's appeal of staff's
determination concerning the status of Copeland's Downtown Center under
the Water Allocation Regulations (S.L.O. Municipal Code Chapter 17.89).
B. Council has considered the report and recommendation of staff.
C. The requested determination is consistent with the General Plan Water &
Wastewater Management Element and the intent of the Water Allocation
Regulations.
D. The determination will not make a significant difference in total water use
within the City.
E. The request is categorically exempt from environmental review as a minor
change to land use limitations (Environmental Guidelines Section 15303).
F. The French Pavilion project's complete planning applications were received
before March 15, 1989, so that project qualified for building permits
without being considered entirely a replacement for previous development
on the site, and without needing to wait for a water allocation or needing
to provide its own water supply or offset (retrofit) credit, as provided in
Water Allocation Regulations part 17.89.060.H.; the Copeland's Downtown
Center is substantially the same project as the French Pavilion, considering
that both proposals involved commercial developments on essentially the
same site; the receipt of separate planning and building applications does
not constitute separate projects within the meaning of Water Allocation
Regulations parts 17.89.040 and 17.89.060.G.
Resolution No. (1994 Series)
Page 2
SECTION 2. Action.
Council hereby determines that, as an extension of the French Pavilion proposal, the
Copeland's Downtown Center qualifies for building permits under Water Allocation
Regulations part 17.89.060.H, without being considered entirely a replacement for
previous development on the site, and without needing to wait for a water allocation or
needing to provide its own water supply or offset (retrofit) credit.
On motion of . seconded by . and on the
following roll call vote:
AYES:
NOES:
ABSENT:
the foregoing resolution was passed and adopted this day of
1994.
Mayor
ATTEST:
City Clerk
APPROVED:
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vnLCOP&WIRRES
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Cit Of s4n .lMS OBISPO .
990 Palm Street/Post Office Boz 8100•San LulaOblspo,,CA 93403-8100
APPEAL TO CITY COUNCIL
..... .... .
In accordance with the"appeals prooedure as authorized by Title I, Chapter 1.20 of the San Luis Obispo
MunicipalCode.the undersigned herebyappealsfromthedecislonof C mmuumf C1WSLOpwt6N7 DIROtTa
rendered onAQIRaL Co .144 , . which decision consisted of the following (Le. set forth factual
situation and the grounds for submitting this appeal. Use additional sheets as needed):
51:5 fs T TAL-1A W L6TTe1Q,�
The undersigned dMussed the.decision being appealed with:
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DATE&TIME APPEAL RF[;FIVFrn_ , AppciWt
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original to City Clerk
City Attorney
Calendared for. -G� _ Copy to AdministratIve Officer
- - Copy to the-following department(s):
ARCHITECTURAL
PRODUCTION
SERVICES
April 14, 1994
SLO City Council
990 Palm Street R E C E I V E L
San Luis Obispo, CA 93401
APR 1 41494
RE: Downtown Centre - Appeal to City Council CRY OF SAN LUISOBLSPO
COMMIM OEVELOPLTW
Dear Mayor Peg Pinard,
This letter is a request to appeal the Planning Department's
decision to not consider the Downtown Centre project as a "pipeline
project" or as a continuation of the original French Pavilion
application.
The "triggers" as stated by your department for the necessity to
submit a new application was due because construction had ceased,
and the project was inactive for a long period of time. The second
"trigger" was that the design was substantially different than the
previous submittal.
The current project is on the same site, with the same architect
and substantially the same character and intent as the previous
project which was submitted in 1.987 and subsequently received a
building permit in 1989. Construction started and proceeded into
late 1990. A permit for the temporary shoring for the basement was
issued in late 1991. Installation of the shoring took place in
early 1992. The revised ARC application was submitted in May 1992.
The construction was temporarily slowed while a new buyer
(Copeland) was negotiating the sale with the owner (French) .
Building permit application extensions may be granted by the
Building Department for two additional six months periods when
construction is halted. Unfortunately, no extensions were
requested.
Part of the perception of the project being delayed relies on the
time spent with the redesign going through Planning Department
approvals, the architect was preparing construction drawings and
plans were reviewed by the Building Department for permit.
APS ARCHITECTS , INC .
1068 Higuera Street,Suite 200 San Luis Obispo.CA 93401 Tel:(805)541.6294 Fax:(805)541.2739
Architects.Randolph L. Rea.AIA-Mark D. Rawson.AIA-Michael Peachev /�
The changes in design (which all have less impact than the original
design) are as follows:
a. previous approved design was for 135,000 SF; the present
design is approximately 88,000 SF
b. previous project was three stories in height; present
design as constructed is one story, with one building in
the next phase having two stories
C. previous project utilized materials consisting of stucco,
brick, aluminum storefront/glazing; existing project is
using the same palette of materials
d. previous project was totally enclosed without any
exterior open space; the present project provides
approximately 15,000 SF of exterior open public plazas
and walkways
We agree that the project was relatively inactive. We also agree
the design has changed, but for the betterment of the project and
the community. With the present project being a substantial asset
to the downtown area and the community, we feel this project should
continue on and under the original guidelines as required for the
French Pavilion. It should be considered as a "pipeline project"
and be exempt for the current Water Allocation Guidelines that
would require potentially retrofitting of three hundred fifty
toilets when the final phase is completed.
The new owner is being unfairly penalized (by a technicality) for
changing the design concept that we all agree has benefited
everyone.
sincerely,
Rando h L. Rea, AIA
APS Architects, Inc.
M91191.179
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990 Palm Street/Post Office Box 8100 • San Luis Obispo, CA 93403.8100
April 6, 1994
Mark Rosen
APS
1088 Higuera Street - Suite 200
San Luis Obispo, CA 93401
SUBJECT: Water allocation status of Copeland's Downtown Center
Dear Mr. Rosen:
We have been asked about retrofitting requirements for this project. The situation is
described below, as Glen Matteson of this office has discussed with Randy Rea of your
office.
The French Pavilion project previously proposed for most of this site qualified for a
water allocation, since its planning applications had been submitted by March 15, 1989.
(The allocation was equal to the net increase in water usage expected from the new
development, considering the uses being removed from the site.) As provided in the
City's Water Allocation Regulations, and consistent with our determinations in other
cases, when the French Pavilion project expired and a new project was proposed, the
new project was not able to retain the water allocation (S.LO. Municipal Code parts
17.89.030.A, 17.89.030.B(3), 17.89.040, 17.89.060.F, G, and H).
Under the Water Allocation Regulations, the determination that your project is "new" is
not based on the expected water usage of the new project versus the previously proposed
project, but instead upon the degree of difference in design. Your project required new
architectural-review and building-permit applications, involved a somewhat larger site,
and contained different types of uses (theater instead of offices). The intent of the
regulations' "pipeline" provision was to allow completion of those projects undergoing
review at the time the regulations were adopted. (In contrast, once offset credits are
earned for a site, they remain available indefinitely.)
The Water Allocation Regulations do not provide for consideration of your project's
attractive design and generous outdoor public spaces in determining water allocation
status.
"Building 1," consisting of retail stores and the theater, was found to be a replacement
The City o1 San Luis Obispo is committed to include the disabled in all of its services, programs and activities.
v Telecommunications Device for the Deaf(805) 781-7410.
Page 2
Copeland's water status
for all buildings removed from the site. No additional credit from previous uses was
available for later phases. Details are presented in the. attached 1992 plan check
comments, which were staffs effort to bring theseissues to light and outline the.
applicant's options during review of Phase 1.
"Building 2" is now proposed as a..19,961-square-foot retail shell at the comer of Mono
and Marsh streets, and we recently received a separate application for a 1,240-square-
foot yogurt shop as a tenant improvement within this building. The water requirements
for these aspects are figured as follows (plan check comments of March 1 and April 1,
1994, attached).
Retail shell: (19,961 sq. ft.) X'(0.035 acre-foot/1000 sq. ft..for retail) = 0.70 acre-.
foot; X 2 = 1.4 acre-feet required offset.
Yogurt shop: (1,240 sq. ft.)X [(038 acre-foot/1000 sq. ft. for food service with
minimal on-site prep) X (0.8 for indoor usage only) 0.035 acre-
foot/1000 sq. ft. credit for shell building] = .033 acre-foot; X 2 =
0.66 required offset
No building permit application has been received for "Building 34for the area next to
the Riley's building. However;staff.recalls being asked about retrofit requirements for a
full-service restaurant of about 4;000 square feet. A full-service, 4;000-square-foot
restaurant (with minimal landscaping) would require:
(4;000 sq. ft.) X (1.65 acre-feet/1000 sq. ft.) X (0.9 indoor usage) 5.94 acre-feet;
X 2 = 11.88 acre-feet required offset
Assuming the offset is achieved by retrofitting one-bath dwellings (replacing 5-gallon
toilets with 1.5-gallon), the needed number of dwellings would be:
Building 7#2.retail shell: 1.4/0.06 = 24
Building 7,r2 yogurt shop: 0.66/0.06 = 11.
Building 7#3 rest aurant:. .11.88/0:06 = 198
Total 233.
Retrofitting dwellings with multiple bathrooms would reduce the required number of
dwellings,while retrofitting dwellings having 3.5-gallon,toilets would increase the
number. Other types of retrofits are eligible for credits. Assuming the current retrofit
N A
Copeland's water status Page 3
cost of about $200 dollars per one-bath dwelling, the cost of retrofitting 233 dwellings
would be $46,600. (There may be some consolation in that projects which retrofit pay
only about 13 percent of the water impact fee which otherwise would be charged by the
City.) The City's Water Conservation staff will help you locate places to retrofit.
Contact me or Glen Matteson, Associate Planner, (805 781-7165) if you have any
questions.
Si Gere ,
old Jonas
Community D elopment Director
copies: John Dunn, CAO; Tom Copeland
PLAYCHECK COMMENTS: COPELAND'S D0WNT0WN CENTER BPA #209:6
Water allocation status
by Glen Matteson,A sociate Planner 12-30-92 (SOS) 751-7165
Reference: Rater .Allocation Reg,-,!,tions (SLO 'iunicipal Code Chapter 17.S9)
L No water allocation has been reserved for this project, since it was not in the
planning review "pipeline" by March 15, 1989, and because it consists of new
applications rather than revisions to the "French Pavilion" project (which was in
the "pipeline").
2. A project is responsible only for the net increase in water usage over previous
development on a site. normally, that previous usage.is estimated by multiplying
the square footage of the previous buildings by the water-usage factors for the
t ees of uses which occupied them, rather than the actual metered usage.
However, accurate information on the previous buildings' floor area is not
available. Instead, we will use the metered usage for all the buildings on the site
for the period 1981 through 1956 (a pre-drought period on which our water usage
factors are based). This information was developed for the initial environmental
study on the French Pavilion (ER 40-87).
The averaee annual water usage was 7.6 acre-feet (.AF).
3. The water allocations required for the new development are as follows.
Building #]: none
Explanation: Retail spaces B, C, D-1 through D-5 have 22,084 sq. ft.
floor area X retail water usage factor = water allocation required
22,OS4 sq. ft. X 0.035 AF/1000 sq. ft. = 0.77 AF
Theater (space A): 1,:07 seats
number seats.X water usage factor/seat [from City of Santa Barbara study]
1,507 seats X 0.0047 AF/seat = 7.05 AF
0.77 T TOS = 7.55 AF.
Conclusion: 7.55 AF exceeds 7.6 AF by about three percent. However,
considering that all new toilets will have a maximum 1.5 gallons/flush, Building
#1 is determined to be a replacement for all previous development on the site.
Therefor, this permit can be issued without a water allocation or retrofitting. This
determination assumes that tenants are dry-goods retailers, not uses such as
restaurants or fitness centers, which would require higher allocations.
Building T2: 0.76 AF
Explanarion: Retail spaces F and G have 21,600 sq. ft.
floor area X Nater usage factor = water allocation required
21,600 sq. ft. X 0.036 .kF/1000 sq. ft. = 0.76 AF
Conclusion: Before a permit is issued for Building AZ a water allocation must be
obtained or twice the required allocation must be offset by retrofitting existing
facilities in the city. Water allocations will not be available until the City obtains
a major supplemental source of water (probably July 1995 to December 2000).
Details on the offset option are available from the Planning Division (contact
me).
Building#3: 3.22 AF to 3.91 AF
Explanarion: Space E has 6,000 sq. ft.
floor area X water usage factor = water allocation required
6,000 sq. ft. X 1.65 AF/1000 sq. ft. for full service restaurant X 0.9 fraction
of total water use indoors = 5.91 AF
or
6,000 sq. ft. X 0.67 AF/1000 sq. ft. for fast-food restaurant X O.S fraction of
total water use indoors = 3.22 AF.
Conclusion: Before a permit is issued for Building =2, a -water allocation must be
obtained or twice the required allocation must be offset by retrofitting existing
facilities in the city.
4. The amount of a required water allocation can be reduced by:
A- Using a City-approved source of water other than City supply. The City
Council has established a policy that individual wells cannot be used to
make a project exempt from needing an allocation, but private well water
can be credited to nonessential uses, such a landscape irrigation, thereby
reducing the amount of the required allocation (or the amount of offset).
I think drainage from the basement area has been pumped almost
continuously since the foundation was excavated, and run into the storm
drain system. if so, I would urge an evaluation of using this water on-site,
for toilet gushing or other nonpotable uses that would not require
treatment. As an example, supplying all toilet and urinal flushing from
basement drainage would reduce the entire project's use of City water by
about one-half. The resulting water usage for the entire project, 7 to 3 AF,
could allow the entire project to be considered a replacement for previous
development on the site. (Approval of this approach would require
documentation of the reliability of flow for the long term, and adequate
storage capacity to meet peak demands.)
B. Demonstrating eater usage factors lower than the City's standard factors.
The City's factors are based on meter readings of a sample of recent
developments, by type, for a „multiyear period prior to the drought. Sirnailar
documentation, possibly for developments using state-of-the-art water
conservation and recyclinz, could be a basis for lower usage factors.
S. The applicant has the option of retrofitting for Building l`1 before the permit is
issued, and crediting previous site usage to later phases.
Plan check comments: 898 Marsh Street
water allocation
"Cooeland's Downtown Center - Phase 2"
by Glen Matteson(81-7165) 3/1/94
(19,961 sq. ft. retain X (0.035 acre-foot/1000 sq. ft. retail) = 0.70 acre-foot;
X 2 = 1.4 acre-feet required offset
This amount could be achieved by retrofitting 24 one-bath dwellings or motel units,
replacing 5-gallon toilets with 1.5-gallon toilets. (See the Offset Program guidelines for
details).
[Council proposes to change the offset ratio to 1:1, which would mean an offset of 0.70
acre-foot; action is scheduled for 3/15/94, with ordinance changes to take effect about
May 5. Applicant can start retrofitting, and stop when sufficient amount is obtained under
any new ratio, before permit is issued.]
This offset is for retail shell building only. Food service businesses would, and other
types of businesses may, require additional offset prior to tenant improvement permits.
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_,4uilding Permit Applin-*ion ALL UNSHADED" C`ACES
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address: S 9 C) " ?—R S�r—} treeUBo:8100•San LuisObispo,CA 93403.8100•(805)781.7180
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City/State
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Allocation Given Phone Number�310�
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Sprinklers: ES M NO - Flood Zone: VVES ❑ NO
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Deck/Porch ��� Accessory Bldg, Swimming Pool Surface Area
BLDG.HEIGHT V STORIES NO.OF BEDROOMS /} DWELLING UNITS (V
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#OF PLANS: Application Num 227
eOF STRUCT.CALCS: Application 0ate!S_Ji57
APPLICANT(Sign Name) #OF ENERGY CALCS: Plan Ck.Fee �/r 01
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#OF SOILS REPORTS: Permit Fee
APPLICANT(Print Name) ?+•ne Valuation
BUSINESS IMPROV RSSOC TE[ - 805-781-2647 Rpr 2.9 94 . 13 :59 No . 003 P .01
I TING AGENDA
WE -5-3-94 ITEM #=
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[1.'�naciiS: L RED
MEMORANDUM
TO: Mayor Peg Pinard
Council members Rappa, Roalman, Romero. and Settle
FROM: Lynn Block, Administrator
DATE: April 29, 1994
RE: Downtown Centre
The Business Improvement Association Board of Directors
would like to ask the City Council to facilitate the rapid .
build out of . the Downtown Centre project. The BIA Board of
Directors strongly supports this project due to. the
tremendously positive impact it has already had on the
downtown.
The BIA would ask that the City Council evaluate the
construction as one project. The buildings are being
completed on a phased in schedule due to the relationship
with each tenant.
The City Council is simply reviewing the same project which
has already received City approval and the Mayor' s Award for.
Excellence.
Please give your support to this project. Please feel free ` '.
to contact me at 541-0286 should you have any .questions.
Post-It"brand fax transmittal memo 7671 *of Pages N.
AV/rr ID
Dept.
fTR 2 9 1994
Fax e r
F
CITY COUNCIL
S.AN LUIS QB1Sp_0i CA
P.C.Alar 1402•Sen Iain Obvp•CR•99406.805/54)-0266
MEMORANDUM
May 2, 1994
TO: City Council MEETING AGENDA
DATE 2 -qV ITEM #
FROM: John Dunn, City Administrative Officer
Bill Statler, Director of Finance
SUBJECT: REQUEST FROM COUNCIL MEMBER ROMERO FOR
THEATER WATER USE INFORMATION
In reference to the agenda item being considered by the Council on May 3 regarding the
Downtown Centre project's retrofit requirements, Council Member Romero asked if we had any
information on water usage by motion picture theaters on a per seat basis in comparison with
the "standard planning" ratios developed by the City of Santa Barbara (.0047 acre feet per year
per seat).
We have separate meters upon which to develop this information for 3 of the 4 movie theaters in
town:
• Palm Theater 220 seats
• Fremont Theater 1025 seats
• Mission Cinemas 620 seats
We looked at three years of bimonthly consumption for these theaters and compared it with the
number of seats at each theater (see above)as reported to us by the Fire Department.
In reviewing this information, our"average"use for movie theaters is approximately .0017 acre
feet per year per seat compared with the Santa Barbara planning standard of.0047 acre feet per
year. This reflects an adjustment for the Fremont Theater based on its very large seating
capacity;without this adjustment, the per seat usage average would be even lower.
The detail information upon which this average was developed is available for your review in the
Finance Department. If you have any questions concerning this information, please do not
hestitate to contact us.
cc Arnold Jonas
John Moss
fOUNCII ]FIRECHIEF
R
El AO
CAO IEF YI%Y 199r:
ATTORNEY Q'CLER JMG CHF❑ MGMT TEAM❑ C REQ FILE RIR
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