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HomeMy WebLinkAboutAPPL-0665-2025_Council Agenda Report for Appeal of USE-0332-2025_10.21.25_Final Item Click or tap here to enter text. Department: Community Development Cost Center: 4006 For Agenda of: 10/21/2025 Placement: Public Hearing Estimated Time: 90 minutes FROM: Timmi Tway, Community Development Director Prepared By: Mallory Patino, Assistant Planner SUBJECT: REVIEW OF AN APPEAL OF THE PLANNING COMMISSION’S DECISION TO REVOKE A USE PERMIT FOR OPERATION OF A FRATERNITY ORGANIZATION AT 1236 MONTE VISTA PLACE (USE- 0332-2025, APPL-0665-2025) RECOMMENDATION Adopt a Draft Resolution entitled, “Resolution of the City Council of the City of San Luis Obispo, California, denying an appeal and upholding the Planning Commission’s decision to revoke the use permit for a fraternity located at 1236 Monte Vista Place. The project is exempt from environmental review under Section 15301 (Existing Facilities) of the California Environmental Quality Act (CEQA) Guidelines as represented in the council agenda report and attachments dated October 21, 2025 (USE-0332-2025, APPL-0665- 2025).”( Attachment A) REPORT-IN-BRIEF On August 12, 1998, the Planning Commission approved a Use Permit (U106-98) (Attachment B - PC Resolution No. 5230-98) to allow a fraternity (Kappa Sigma) at the multifamily apartment complex at 1236 Monte Vista Place. Delta Chi (Appellant) has continued the use as a fraternity organization under the approved Use Permit since moving into the complex in 2012. In 2025, the Community Development Director (Director) referred the existing Use Permit to the Planning Commission for re-review based on several recent violations of the permit conditions. On May 28, 2025, the Planning Commission conducted a public hearing for the re-review of the Use Permit for the continuation of the fraternity. The Planning Commission voted 5-0 to revoke the Use Permit because they could not make the required findings enumerated in San Luis Obispo Municipal Code (SLOMC) §17.110.070. Specifically, the Planning Commission found that the design, location, size, and operating characteristics of the use was not compatible with residential uses in the vicinity (§17.110.070(A)(3)), Item Click or tap here to enter text. and that continued use of the property as a fraternity under the Use Permit was not appropriate for the subject location, was incompatible with the neighborhood, and would be detrimental to the health, safety, and welfare of persons living or working at the site or in the vicinity (§17.110.070(A)(5)). The Planning Commission was not satisfied that any set of conditions would secure these purposes. On June 11, 2025 Resolution No. PC- 1102-2025 was ratified with the final Planning Commission decision. This decision does not prevent the Appellant from re-applying for a new use permit if they choose. On June 20, 2025, the Delta Chi Fraternity filed a timely appeal of the Planning Commission’s decision to revoke the Use Permit (APPL-0665-2025) (Attachments C and D – Appeal Form and Supplemental Statements). As described in the Appeal Form and statements, the Appellant does not concur with the findings that form the basis of the Planning Commission’s decision. The Appellant requests that City Council uphold the appeal, reverse the Planning Commission’s decision to revoke the Use Permit, direct City staff to collaborate with the fraternity and community to draft clear and enforceable Conditions of Approval that ensure compliance and alignment with City regulations, and adopt a modified Conditional Use Permit with said drafted conditions. POLICY CONTEXT General Plan Within the General Plan, Land Use Element (LUE) Policy 2.2.6 (Neighborhood Characteristics) directs the City to promote livability, quiet enjoyment, and safety for all residents, and highlights that one characteristic of a quality neighborhood includes a sense of personal safety. LUE Policy 2.2.1 (Neighborhood Identity) encourages the City to work with residents to address neighborhood specific issues. Additionally, Goal 7 of the Housing Element (Neighborhood Quality) is to maintain, preserve, and enhance the quality and livability of neighborhoods. Major City Goals One of the 2025-2027 Major City Goals is “Housing and Neighborhood Livability – Healthy, Safe, and Affordable,” which specifically includes a focus on fostering diverse, connected, and safe neighborhoods that are livable for all. Zoning Regulations (SLOMC Chapter 17) Per Table 2-1 of SLOMC (Uses Allowed by Zone), the establishment of a fraternity in the R-4 zone requires approval of a Conditional Use Permit. Approval of a Conditional Use Permit for a fraternity is subject to the requirements, listed below, to ensure its consistency with the General Plan and Zoning Regulations and its compatibility with existing and future land uses in the vicinity: • Section 17.110.060 (Minor Use Permits and Conditional Use Permits – Criteria for Approval) • Section 17.110.070 (Minor Use Permits and Conditional Use Permits – Required Findings) Item Click or tap here to enter text. • Section 17.86.130(B) (Fraternities and Sororities – Required Findings) Per SLOMC §17.102.020(C)(7), revocation of a Conditional Use Permit is a quasi-judicial process providing for the review of potential violations of conditions of approval for an authorized use, and for the revocation of such approval based upon findings set forth in Chapter 17.110. DISCUSSION Site Data Appellant Delta Chi General Plan Land Use Designation High Density Residential (HDR) Zone High-Density Residential (R-4) Site Area Approximately 0.66 acre Environmental Determination Categorically exempt from environmental review under CEQA Guidelines Section 15301 (Existing Facilities) BACKGROUND On August 12, 1998, the Planning Commission approved a Use Permit, U106-98 (PC Resolution No. 5230-98) (Attachment B) to allow a fraternity (Kappa Sigma) at the multifamily apartment complex at 1236 Monte Vista Place (Property). The fraternity organization Delta Chi began residing at 1236 Monte Vista Place in 2012, continuing the use of the site under the existing Use Permit. The Police Department issued one (1) citation for a noise violation and one (1) citation for an unruly gathering to the Property between September 2024 and March 2025. The noise violation citation (issued on March 3, 2025) was successfully appealed resulting in the citation being dismissed. The unruly gathering citation was issued March 15, 2025, the Saturday ahead of St. Patrick’s Day (locally referred to as “St. Fratty’s Day” weekend). The notes from the Police response visit to the site at 4 AM on March 15 cite that approximately 100 people were visible in the courtyard, music could be heard from over 200 feet from the property line, and alcohol was present on site. Despite efforts from Code Enforcement and the Police Department to encourage safe celebrations and deter unruly gatherings ahead of St. Patrick’s Day, an event still took place at 1236 Monte Vista Place that resulted in the citation. On March 9, 2025, a complaint was made to the Police relating to loud music at the Property, though no citation was issued. Item Click or tap here to enter text. On March 19, 2025, Code Enforcement issued a Notice to Correct Code Violation(s) / Notice of Violation relating to the multiple, confirmed administrative citations, noise violations, and Use Permit violations. The Notice of Violation stated that due to the active and continued violations by the fraternity, Code Enforcement staff would be recommending review of the Use Permit to the Director of Community Development. The Director then referred the Use Permit to the Planning Commission for re-review in accordance with Condition No. 111 of Use Permit U106-98. On April 18, 2025, after the fraternity had been notified that the Use Permit would be re- reviewed by Planning Commission, the Police Department issued another citation for a noise violation to the Property related to a large gathering of approximately 50 visible people with alcohol present. Planning Commission Action On May 28, 2025, the Planning Commission conducted a public hearing for the re-review of the Use Permit, U106-98, to consider the continuation of the fraternity at 1236 Monte Vista Place. Staff evaluated the fraternity and its recent violations against current City standards and regulations, including the updated findings and criteria for approval as well as code requirements. Staff additionally took previous, recent Council and Advisory Body actions2 into consideration for consistency across all fraternity and sorority use permits. Staff recommended the Planning Commission allow continuation of the fraternity subject to a modified Use Permit. The proposed modified conditions reflected updated language for consistency with current Municipal Code requirements per Section 17.86.130(A) and recent actions related to fraternities and sororities. The proposed conditions included thresholds for future re-reviews, limits on routine gatherings and meetings, standards for Cal Poly affiliation, site maintenance requirements, restrictions on amplified noise, and an updated process for special events. The proposed modified conditions can be viewed in total in the draft resolution that was provided to the Planning Commission (May 28, 2025 Planning Commission Agenda Report). In evaluating whether to revoke the Use Permit or to approve a modified Use Permit based on the conditions recommended by staff, the Planning Commission considered the 1Condition 11 of U106-98: Use permit shall be reviewed if any reasonable written citizen or Police or Fire Department complaints are received by the city. In review of the use permit, the Planning Commission may add, delete or modify conditions of approval, or revoke the use permit. The Planning Commission may consider adding a condition requiring fraternity officers to perform a community service project in the neighborhood. 2Resolution No. PC-1085-2024 (USE-0331-2023) approving a Conditional Use Permit to establish a fraternity at 1264 and 1264 ½ E. Foothill and 1241, 1243, 1249 and 1251 Monte Vista Place; Resolution R-11529 (2024 Series) (USE-0331-2023, APPL-0365-2024) denying an appeal and upholding Planning Commission’s decision to approval a Conditional Use Permit to establish a fraternity at 1264 and 1264 ½ E. Foothill and 1241, 1243, 1249 and 1251 Monte Vista Place; and Resolution No. PC-1092-2024 (USE-0625-2024) approving modifications to Conditional Use Permit to allow continuation of the fraternity at 280 California Boulevard. Item Click or tap here to enter text. findings outlined in SLOMC §17.110.070.A, which are required to approve a Use Permit and read as follows: 1. The proposed use is consistent with the general plan and any applicable specific plan; 2. The proposed use is allowed or conditionally allowed within the applicable zone and complies with all other applicable provisions of these zoning regulations and the municipal code; 3. The design, location, size, and operating characteristics of the proposed activity will be compatible with the existing and future land uses in the vicinity; 4. The site is physically suitable in terms of: a. Its design, location, shape, size, and operating characteristics of the proposed use; b. Traffic generation and the provision of public and emergency vehicle (e.g., fire and medical) access; c. Public protection services (e.g., fire protection, police protection, etc.); and d. The provision of utilities (e.g., potable water, schools, solid waste collection and disposal, storm drainage, wastewater collection, treatment, and disposal, etc.). 5. The establishment and subsequent operation or conduct of the use will not, because of the circumstances and conditions applied in the particular case, be detrimental to the health, safety or welfare of the general public or persons residing or working in the neighborhood of the use, or be detrimental or injurious to property or improvements in the vicinity of the use. After considering all evidence, including the staff’s evaluation and recommendation, the applicant’s testimony, and public testimony, the Planning Commission determined the design, location, size, and operating characteristics of the site as a fraternity were not compatible with residential uses in the vicinity. The Planning Commission also found that continued use as a fraternity was not appropriate for the subject location, incompatible with the neighborhood, and detrimental to the health, safety, and welfare of persons living or working at the site or in the vicinity. As such, the required findings enumerated in SLOMC §17.110.070(A)(3) and §17.110.070(A)(5) could not be made by the Planning Commission. The Planning Commission voted 5-0 to revoke the Use Permit, based on the findings specified in Resolution No. PC-1102-2025. This decision does not prevent the Appellant from re-applying for a new use permit if they choose. APPEAL On June 20, 2025, Delta Chi Cal Poly Chapter filed a timely appeal of the Planning Commission’s decision to revoke Use Permit U106-98 (APPL-0665-2025) (Attachments C and D – Appeal Form and Supplemental Statements). As described in the Appeal Form Item Click or tap here to enter text. and supplemental materials, Delta Chi asserts that the revocation was premature and that issues cited can be effectively addressed through collaboration with City staff and other stakeholders. The Appellant requests that the City Council uphold the appeal, reverse the Planning Commission’s decision to revoke the Use Permit, and direct staff to work in good faith with Delta Chi to amend the existing permit to ensure compliance and alignment with community expectations to avoid a costly and time-consuming reapplication process. The Appeal Form and supplemental statements can be distilled into two (2) issues, which are summarized and discussed in the following analysis. Appeal Issue No. 1 – Good-Faith Reliance, Cooperative History, and Severe and Disproportionate Penalty The Appellant asserts that they have worked systematically to reduce incidents that result in citations or use permit violations in recent years, reflecting their commitment to improvements. They cite their efforts to work with City staff over the years to comply with permit conditions, to address neighborhood concerns in good faith, and to respond to feedback and implement operational improvements. The Appellant notes they have invested time and resources in mitigation measures and adjusted management practices and have consistently sought to be a constructive member of the community. The Appellant states that after years of interaction and reliance on City feedback, revocation imposes a severe and disproportionate penalty, which leaves them to face significant hardship due to a sudden change in course, especially considering Staff’s recommendation to modify the use permit during the Planning Commission hearing. Staff Response The Community Development Department and Planning Commission acted in accordance with and did not exercise any discretion outside of that which is provided for in SLOMC §17.102.020(C)(7). Due to active violations by the fraternity, the Director referred the Use Permit to the Planning Commission for re-review in accordance with Condition of Approval No. 11 of Use Permit, U106-98, which states the following: 11. Use permit shall be reviewed if any reasonable written citizen or Police or Fire Department complaints are received by the city. In review of the use permit, the Planning Commission may add, delete or modify conditions of approval, or revoke the use permit. The Planning Commission may consider adding a condition requiring fraternity officers to perform a community service project in the neighborhood. As described in Condition No. 11, revocation of the use permit is one possible outcome of a review instigated from a complaint. Several complaints and violations contributed to the Director’s decision to refer the Use Permit to the Planning Commission for re-review. Item Click or tap here to enter text. One complaint that resulted in the Police issuing a noise violation citation to the Property on March 3, 2025 contributed to the Director’s referral of the Use Permit to Planning Commission. Though this violation was successfully appealed resulting in the citation being dismissed, the appeal process did not conclude until April 15, 2025, after such referral was made. Another complaint that contributed to the Director’s referral was made to the Police on March 9, 2025 relating to loud music at the Property, though no citation was issued. Another complaint that further contributed to the referral related to the event held on March 15, 2025 at 4 AM, which resulted in a citation for an unruly gathering. Police notes indicated the large party had over 100 people visible in the courtyard, people shouting, and a live DJ playing music that could be heard from over 200 feet from the property line. As defined in SLOMC §9.13.020(E), unruly gatherings are gatherings of twenty or more persons on private property with conduct that causes a substantial disturbance of the quiet enjoyment in a significant segment of an immediate neighborhood or presents a threat to the health, welfare and safety of those in attendance, responding enforcement personnel, or nearby residents or properties. Per SLOMC §9.13, unruly gatherings are prohibited, as they are detrimental to the public health, welfare and safety, and are contrary to the public interest. This event was also in direct violation of Conditions #4, #5, #7 and #12 of Use Permit U106-98, listed below for reference, as well as in opposition to the extensive outreach that was conducted by Cal Poly and the City regarding events during the days around St. Patrick’s Day. 4. The maximum number of persons allowed on the site for routine meetings and gatherings is 53, except as specifically approved by the Community Development Director for special events. For such special events, the applicant shall also submit a parking and transportation plan. 5. No meetings, parties, or other types of similar activities involving persons other than residents are allowed between the hours of 10 p.m. and 9 a.m., except as approved by the Community Development Director. 7. Events, including meetings or parties, on site, shall be limited to those listed on a meeting and activities schedule, submitted to an approved by the Community Development Director in the fall of each year. Exceptions to this schedule must be approved by the Community Development Director. If the Director determines the change is significant and may have an adverse impact on the neighborhood, then it will be referred to the Planning Commission for consideration. 12. Failure to comply with the above conditions or code requirements, or the conduct of the use so as to constitute a violation of Federal, State, or local l, 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 revocation of this permit. Code Enforcement issued a Notice of Violation to the Property on March 19, 2025, which stated that the administrative citations, noise violations, and police contacts between Item Click or tap here to enter text. January to March 2025 constituted violations of the Municipal Code and the Use Permit Conditions of Approval. The notice stated that immediate compliance was required to correct the violations, and that the violations constituted a public nuisance that must be abated. A few weeks later, the Police responded to a complaint on April 18, 2025, around 9:30 PM, which resulted in another citation for a noise violation. Police notes indicated the large gathering had approximately 50 visible people and alcohol present. This event was in direct violation of Conditions #7 and #12 of Use Permit U106-98 and the Notice of Violation sent to the fraternity on March 19, 2025. Collectively, these actions of the organization have constituted a public nuisance and caused a substantial disturbance of the quiet enjoyment of private property in the immediate neighborhood. Therefore, the Planning Commission’s decision to revoke the Use Permit would not be considered a severe or disproportionate penalty. During the May 28, 2025 Planning Commission hearing, the fraternity representative presented information concerning their reduction in complaints in recent years. The representative also noted the fraternity’s history of cooperation with the City and organizational mitigation measures and adjusted management practices. The Planning Commission considered this information, as well as the information relating to the multiple confirmed use permit violations, including the March 15th and April 18th incidents, and public input from community members. Based on all the evidence discussed, the Planning Commission was unable to make the required findings to grant continuation of Use Permit U106-98, as required under SLOMC §17.110 and revoked the Use Permit per Condition No. 11. It should be noted that the multi-family residential complex located at 1236 Monte Vista Place may continue to be used for residential uses, regardless of holding a use permit. Revocation of the Use Permit means that the site cannot be used as a fraternity or sorority house, which is defined as residences for college or university students who are members of a social or educational association that is affiliated and in good standing with the California Polytechnic State University and where such an association also holds meetings or gatherings (SLOMC §17.156.014). While fraternity members may continue to live at 1236 Monte Vista Place, the change requires regular fraternity operations, such as chapter meetings and special events, to cease on site. Those meetings and gatherings may continue at off-site locations, including Cal Poly’s campus or other private venues suitable for the intended land uses. Additional Noise Violation Citation Since the Appellant filed an appeal, the Police issued another citation to the Property on October 4, 2025, for a noise violation. Police responded around 2:30 AM to a complaint relating to loud noise. The responding Officer confirmed music and voices could be heard from beyond the property line. The responding Officer noted that people were running into the apartments from the courtyard with Police’s arrival, and approximately 10 people were visible in the courtyard with alcohol present. Item Click or tap here to enter text. Appeal Issue No. 2 – Collaborative Process for Constructive Resolution The Appellant requests that the City Council uphold the appeal and direct staff to collaborate with Delta Chi, neighbors and university partners to modify the conditions of use permit so that they are clear, achievable, enforceable, and ensure accountability. The Appellant has provided feedback and draft modifications to conditions of approval for the use permit (Attachments C and D – Appeal Form and Supplemental Statements) based on the draft conditions of approval that were presented in the May 28, 2025 draft resolution and the comments made by Planning Commission (see Planning Commission Agenda Report). The Appellant argues that their drafted modifications address concerns raised by the Planning Commission and, if adopted, would allow fraternity operations to satisfy the required findings in SLOMC §17.110.070(A). Staff Response Revocation of the permit by the Planning Commission was based on the findings that the continued use of a fraternity would be incompatible with residential uses in the vicinity, and would be detrimental to the health, safety, and welfare of persons living or working at the site or in the vicinity. In the supplemental material provided, the Appellant has not provided evidence that the fraternity would be able to satisfy the Planning Commission concerns and meet the required findings in SLOMC §17.110.070(A). Staff has analyzed the proposed alterations and additions to the conditions that the fraternity has submitted, and this analysis is provided in Attachment E. Many of the proposed changes and provided reasoning from the Second Supplemental Statement (Attachment D) have the possibility for beneficial outcomes, but they are still conceptual ideas and would be difficult to enforce. Information is lacking regarding how the proposed changes might be implemented, and how implementation would effectively change the operations and behavior of the fraternity. There remains insufficient evidence to address the concerns raised by the Planning Commission that operation of a fraternity is appropriate for the subject location, compatible with the neighborhood, and will not be detrimental to the health, safety, and welfare of people living or working at the site or in the vicinity. The Appeal process, as outlined in SLOMC §17.126, does not provide an effective avenue to support a collaborative conversation or the time necessary to modify the existing Use Permit. If City Council directs staff to undertake the effort requested by the Appellant, the appeal would need to be continued to either a date certain in the future or off-calendar to provide time for staff, the Appellant, and the community to discuss the proposed conditions and then return for consideration of a revised Use Permit and proposed findings. However, the Appellant has the ability to re-apply, at any time, for a new use permit if they choose. If the Appellant applied for a new use permit, staff would be able to collaborate with the applicant and other stakeholders on their application proposal. Item Click or tap here to enter text. City Council Consideration Per SLOMC §17.126.040(B), decisions of the Planning Commission shall be appealed to City Council. Delta Chi Cal Poly Chapter filed a timely appeal of the Planning Commission’s decision to revoke Use Permit U106-98 resulting in this review (Application No. APPL-0665-2025) being brought before City Council. Actions on appeals are “de novo” review per SLOMC §17.126.050(A). De novo review means that the City Council must exercise its independent judgment to determine if the Applicant/Appellant’s Use Permit should be modified, revoked, or remain in effect as it was prior to the Planning Commission’s revocation. The City Council is not bound by the Planning Commission’s findings or conclusions. The decision made by City Council shall be made based on the required findings in SLOMC §17.110.070 and listed above under the “Planning Commission Action” section of this report. Because this is a “de novo” hearing, the City Council can take any of the actions outlined in the alternatives section below or staff’s recommendation. Public Engagement The project has been noticed in compliance with the City’s notification requirements for Development Projects for each public hearing associated with the project. Newspaper legal advertisements were posted in the New Times ten (10) days prior to the Planning Commission and City Council hearings. Additionally, postcards were sent to both owners and occupants of properties, located within 300 feet of the project site, ten (10) days prior to each hearing. CONCURRENCE The Council Agenda Report was reviewed by the Planning Division, and the City Attorney’s Office for concurrence. ENVIRONMENTAL REVIEW The project is exempt from environmental review under Section 15061(b)(3) (Common Sense Exemption) of the CEQA Guidelines because it can be seen with certainty that there is no possibility that the revocation of the Conditional Use Permit may have a significant effect on the environment. Additionally, CEQA does not apply to projects which a public agency rejects or disapproves. (CEQA Guidelines Section 15270.). FISCAL IMPACT Budgeted: N/A Budget Year: 2025-26 Funding Identified: No Item Click or tap here to enter text. Fiscal Analysis: Funding Sources Total Budget Available Current Funding Request Remaining Balance Annual Ongoing Cost General Fund $ N/A $0 $0 $0 State Federal Fees Other: Total $ N/A $0 $0 $0 Consideration by the City Council of an appeal of a decision made by the Planning Commission does not directly result in expenditure of funds and thus has no fiscal impact to the City. The appeal fee, which covers a portion of the staff time required to bring this item forward, per City policy, was paid by the Appellant, and there is no upfront cost resulting from the revocation of the Use Permit. If Council adopts the Resolution to deny the appeal, subsequent review of a new use permit application, should the Appellant reapply, would be subject to the appropriate permitting application fee, which is paid by the applicant. ALTERNATIVES 1. Continue review of the appeal. The City Council may continue the review of the appeal with direction to staff regarding additional information or analysis required to make a decision. Under this alternative, the hearing would be continued to a date certain or, if amenable to the Appellant, continued off-calendar and then re-noticed as a new hearing in the future. 2. Uphold the appeal and modify the Use Permit. The City Council may uphold the appeal and modify the findings and/ or conditions of approval based on consistency with the General Plan, Zoning Regulations, or other policy documents. The City Council may consider and incorporate any of the Appellant’s submitted modified conditions, which are listed and analyzed in Attachment E – Staff Analysis of APPL- 0665-2025 Appellant Submittal. Under this alternative, a revised Resolution would need to be prepared to provide findings to uphold the appeal and allow the Use Permit to continue, as well as to adopt the revised conditions of approval; therefore, it would be recommended that the hearing on the appeal be continued to a date certain to allow for the preparation and consideration of a revised Resolution. 3. Uphold the appeal and retain the existing Use Permit as is. The City Council may uphold the appeal and retain the Use Permit with the existing findings and conditions of approval. Under this alternative, a revised Resolution would need to be prepared to provide findings to uphold the appeal and allow the Use Permit to continue; therefore, it would be recommended that the hearing on the appeal be continued to a date certain to allow for the preparation and consideration of a revised Resolution. Item Click or tap here to enter text. ATTACHMENTS A - Draft Resolution denying the appeal and uphold the Planning Commission’s decision to revoke the Use Permit U106-98 (USE-0332-2025, APPL-0665-2025) B - PC Resolution No. 5230-98 (Approval of the Original Use Permit, U106-98) C - Appeal Form and Supplemental Statements from Appellant (APPL-0665-2025, 06.20.2025, 07.11.2025) D - Second Supplemental Statement from Appellant (APPL-0665-2025, 09.22.2025) E - Staff Analysis of APPL-0665-2025 Appellant Submittal for Modifications and Additions to Draft Conditions of Approval