HomeMy WebLinkAboutE - Staff Analysis of APPL-0665-2025 Appellant Submitted Modifications and Additions to Draft Conditions of Approval_FinalATTACHMENT E - STAFF ANALYSIS OF APPL-0665-2025 APPELLANT SUBMITTED MODIFICATIONS AND
ADDITIONS TO DRAFT CONDITIONS OF APPROVAL
At the May 28, 2025 Planning Commission hearing, staff recommended the Planning Commission allow continuation of the
fraternity subject to a modified Use Permit. With staff’s recommendation, draft Conditions of Approval were included in the
draft Resolution attached to the May 28, 2025 Planning Commission Agenda Report (PCAR). The Planning Commission
rejected staff’s recommendation and revoked the Use Permit.
In the Second Supplemental Statement, submitted on September 22, 2025, the Appellant proposed draft Conditions of
Approval based on the May 28, 2025 PCAR draft Conditions. The Appellant stated if their proposed draft Conditions of Approval
were adopted, the fraternity would meet the required findings for modification of the Use Permit and continuance of use as a
fraternity. Staff evaluated the differences between staff’s recommended draft Conditions and the Appellant’s draft Conditions
in the table below. Staff’s draft conditions from the May 28, 2025 PCAR are in left hand column, the Appellant proposed
amendments and additions to the draft Conditions are in the middle column, and staff’s associated response and
recommendations are in the right hand column.
With Planning Commission’s revocation of the Use Permit and the fraternity’s subsequent appeal, Use Permit U106-98 is
currently still in effect, and the active Conditions of Approval of U106-98 can be reviewed in Attachment B.
Staff’s Draft Conditions from
5/28/25 PCAR Recommendation
Proposed Changes from Appellant
(Additions italicized and underlined)
Staff Response and Recommendation
1 The Conditional Use Permit shall
be reviewed by the Community
Development Director for
compliance with the conditions of
approval, or to determine whether
a modification of the Conditional
Use Permit is necessary upon
significant change to the project as
represented in the Staff Report
dated May 28, 2025, or in the event
of a change in ownership which
may result in deviation from the
project description or approved
plans.
No change N/A
2 The Conditional Use Permit shall The Conditional Use Permit shall be This proposed revision indicates that a
Attachment E of APPL-0665-2025 Page 2
Staff’s Draft Conditions from
5/28/25 PCAR Recommendation
Proposed Changes from Appellant
(Additions italicized and underlined)
Staff Response and Recommendation
be reviewed by the Planning
Commission as soon as practical if
conduct on the permitted premises
results in three (3) citations within
any 12-month period for a violation
of law or permit condition that (a)
are not contested or are upheld on
appeal, and (b) the conduct for
which the citations were issued
resulted in adverse impacts to, or
complaints from, residents or
occupants of the surrounding
neighborhood. At the time of the
Conditional Use Permit review, to
ensure ongoing compatibility with
nearby uses, conditions of
approval may be added, modified,
and/or removed, or the Conditional
Use Permit may be revoked. The
City shall notify Cal Poly if the Use
Permit is revoked. A re-review by
the Planning Commission shall be
accompanied by the appropriate
fee.
reviewed by the Planning Commission
as soon as practical if conduct on the
permitted premises results in three (3)
citations within any 12-month period for
a violation of law or permit condition that
(a) are not contested or are upheld on
appeal, and (b) the conduct for which the
citations were issued resulted in
adverse impacts to, or complaints from,
residents or occupants of the
surrounding neighborhood. If there are
two (2) citations within any 12-month
period for a violation of law or permit
condition that meet conditions (a) and
(b) above, the fraternity shall submit a
plan on how they will prevent future an
additional violation of law or permit
condition that meet conditions (a) and
(b). At the time of the Conditional Use
Permit review, to ensure ongoing
compatibility with nearby uses,
conditions of approval may be added,
modified, and/or removed, or the
Conditional Use Permit may be revoked.
The City shall notify Cal Poly if the Use
Permit is revoked. A re review by the
Planning Commission shall be
accompanied by the appropriate fee.
plan describing how the fraternity would
prevent future violations upon receipt of
two (2) citations. It is unclear how the
review, processing, implementation, and
enforcement of the plan would be
accomplished without significant City
staff time and resources that are not
accounted for in the Use Permit
application process and associated fees.
Implementation of such a plan should be
applied as a regular best practice so that
the fraternity does not receive any
citations.
Staff does not recommend amending
this condition of approval because it is
unclear how the review, processing,
implementation, and enforcement of
the plan would be accomplished.
3 The fraternity shall be limited to a
maximum of 35 residents for the
property. The property owner shall
allow the City to verify the
maximum occupancy by allowing
The fraternity shall be limited to a
maximum of 35 residents for the
property, averaging 370 sq ft per
resident above the 60 sqft minimum in
17.86.130. The property owner shall
This proposed amendment provides the
square footage calculation per resident.
This is a minor amendment to the
condition of approval that is not
necessary, however could be added if
Attachment E of APPL-0665-2025 Page 3
Staff’s Draft Conditions from
5/28/25 PCAR Recommendation
Proposed Changes from Appellant
(Additions italicized and underlined)
Staff Response and Recommendation
an inspection of records or visual
inspection of the premises. Any
inspection shall be scheduled at a
reasonable time with at least 24-
hour notice to the residents.
allow the City to verify the maximum
occupancy by allowing an inspection of
records or visual inspection of the
premises. Any inspection shall be
scheduled at a reasonable time with at
least 24-hour notice to the residents.
determined to be helpful.
4 Routine meetings and gatherings
for the fraternity shall be limited to
a maximum of 54 people (rounded
down from 54.45 = 36.3 people x
1.5), except as otherwise approved
by the Community Development
Director for special events. If the
fraternity hosts special events
involving more than 54 people, a
transportation management plan to
reduce impacts to the surrounding
neighborhood shall be submitted to
the Community Development
Department, at least 30 days prior
to the event taking place, for review
and approval. No exception from
the Noise Ordinance shall be
approved by the Director as part of
the special event. Presence of
more than 54 people at the
property without valid approval
from the Community Development
Director shall be considered a
violation of this Conditional Use
Permit.
Routine meetings and gatherings for the
fraternity shall be limited to a maximum
of 1 guest per 90 square feet of living
space, 1.5 times the minimum
occupancy requirements of 60 square
feet per resident outlined in 17.86.130
except as otherwise approved by the
Community Development Director for
special events submitted to the
Community Development Director as
part of their annual event plan. The
annual event plan shall include planned
events on the property beyond routine
meetings and gatherings which would
cover social, philanthropy, alumni,
parents and recruitment events. The
plan shall be reviewed, approved or
denied within 30 days. After approving
the plan, the fraternity shall provide any
changes and updates to the plan as
soon as practicable. As part of that
annual event plan, the fraternity shall
provide a transportation management
plan for events beyond routine meetings
and gatherings to reduce impacts to the
The method used by staff to calculate
maximum capacity for routine meetings
and gatherings is based on current
practices and recent fraternity and
sorority use permit approvals. The
number of people allowed onsite for
routine meetings and gatherings is 1.5
times the average population density (=
36 person population for this site). This
calculation takes into consideration the
residential population assumptions set
forth in the General Plan Land Use
Element based on the land use
designation and zone and the site/lot
area and constraints. The proposed
amendment identifies that there would be
1 guest per 90 s.f of living space. The
total residential square footage on the
subject Property is approximately 13,764
s.f and as proposed 152 total people
would be allowed at the site compared to
the 54 total people allowed on the site in
the original condition.
Staff does not recommend this
proposed amendment because the
Attachment E of APPL-0665-2025 Page 4
Staff’s Draft Conditions from
5/28/25 PCAR Recommendation
Proposed Changes from Appellant
(Additions italicized and underlined)
Staff Response and Recommendation
surrounding neighborhood shall be
submitted to the Community
Development Department for review
and approval. No exception from the
Noise Ordinance shall be approved by
the Director as Part of the special event.
Presence of more than 1 guest per 90
sqft of living space at the property
without valid approval from the
Community Development Director shall
be considered a violation of this
Conditional Use Permit.
maximum capacity is not consistent
with the Land Use Element or site
considerations and constraints.
The proposed amendment would require
the Community Development Director to
review fraternity events outside the
standards and procedures of the Zoning
Regulations (which are in place to ensure
that such uses are compatible with their
surroundings and the intent of the
regulations).
Staff does not recommend adopting
the proposed amendment because it
is inconsistent with Zoning
Regulation’s Processes and
Procedures. The original condition of
approval allows the fraternity to apply
for a temporary and intermittent use
permits (SLOMC §17.113) for special
events that surpass the maximum
gathering limit as allowed within an
approved CUP.
5 The fraternity shall remain affiliated
and in good standing with the
Interfraternity Council of Student
Life and Leadership at California
Polytechnic University, San Luis
Obispo. If the fraternity becomes
unaffiliated or is no longer in good
standing, the Conditional Use
No change N/A
Attachment E of APPL-0665-2025 Page 5
Staff’s Draft Conditions from
5/28/25 PCAR Recommendation
Proposed Changes from Appellant
(Additions italicized and underlined)
Staff Response and Recommendation
Permit shall be automatically
revoked.
6 The fraternity shall provide the
name and contact information (i.e.,
phone number and email address)
of all responsible parties to the
Community Development
Department and Neighborhood
Services Manager of the Police
Department on an annual basis. If
there is a change to the name
and/or contact information of any
responsible parties, the
Community Development
Department and Neighborhood
Services Manager shall be notified
immediately. The “responsible
parties” are those that cause,
maintain, allow, or are otherwise
responsible for actions regulated
by this Use Permit, or those that
have an ownership interest in the
real property.
The fraternity shall provide the name
and contact information (i.e., phone
number and email address) of all
responsible parties to the Community
Development Department and
Neighborhood Services Manager of the
Police Department on an annual basis.
The fraternity shall provide the name
and contact information (i.e., phone
number and email address) of the
President of the Alumni board of
Trustees and the President of the
Housing Corporation to the Community
Development Department and
Neighborhood Services Manager of the
Police Department on an annual basis if
there is a change to the name and/or
contact information of any responsible
parties, the Community Development
Department and Neighborhood Services
Manager shall be notified immediately.
The “responsible parties” are those that
cause, maintain, allow, or are otherwise
responsible for actions regulated by this
Use Permit, or those that have an
ownership interest in the real property.
Providing additional contacts for the
fraternity organization to the Community
Development and Police Departments
could be beneficial.
Staff recommends considering this
amendment because it could be
beneficial in boosting education and
communication opportunities
between the City and the fraternity.
7 The property shall be maintained in
a clean and orderly manner and in
compliance with the Municipal
No change N/A
Attachment E of APPL-0665-2025 Page 6
Staff’s Draft Conditions from
5/28/25 PCAR Recommendation
Proposed Changes from Appellant
(Additions italicized and underlined)
Staff Response and Recommendation
Code. All landscaping shall be
replaced as necessary and
maintained ( e.g., trimmed, pruned,
etc.) to the satisfaction of the
Community Development Director.
8 A minimum of 32 parking spaces
shall be provided and maintained
at all times. These spaces shall
remain available to residents of the
fraternity and not designated for
any individuals not residing on the
property.
No change N/A
9 Within 60 days of the re-review
hearing with the Planning
Commission on May 28, 2025, the
fraternity shall install a minimum of
35 bicycle spaces (one for each
resident) and contact the City for a
follow-up inspection to verify that
all required bicycle spaces have
been installed.
At the beginning of every academic year
due the property’s proximity adjacent to
campus, the fraternity shall offer bicycle
parking to every resident, up to 35
bicycle spaces (one for each resident)
and contact the City for a follow-up
inspection to verify that all required
bicycle spaces have been installed.
Per SLOMC §17.72.070(B) (Bicycle
parking standards; Table 3-6) the site is
required to have 35 bicycle parking
spaces (one bicycle space per bed) at all
times and does not allow changes in the
number of spaces based on the number
of residents that do or do not have
bicycles.
Staff does not recommend amending
the condition because it is
inconsistent with Zoning Regulation’s
current requirements.
10 The fraternity use shall comply with
Table 1 (Exterior Noise Limits) of
Section 9.12.060 (Exterior Noise
Limits) of the San Luis Obispo
Municipal Code between the
extended hours of 10:00 p.m. and
9:00 a.m.
No change N/A
Attachment E of APPL-0665-2025 Page 7
Staff’s Draft Conditions from
5/28/25 PCAR Recommendation
Proposed Changes from Appellant
(Additions italicized and underlined)
Staff Response and Recommendation
11 Prior to a special event approved
by the Community Development
Director pursuant to Condition No.
4, the fraternity shall provide
written notification of the event to
all occupants residing within 300
feet of the site. The written
notification shall include the date,
hours, and contact information for
the responsible party for the
special event. No exception from
the Noise Ordinance shall be
approved by the Director as part of
the special event.
No change N/A
12 Live entertainment, bands, and/or
amplified sounds are prohibited,
unless otherwise approved through
a special event by the Community
Development Department. No
exception from the Noise
Ordinance shall be approved by
the Director as part of the special
event.
No change N/A
13 Unless otherwise approved by the
Community Development Director,
the building permits to resolve the
open code enforcement case
regarding unpermitted conversion
of non-habitable space (e.g.,
balconies, decks, and sunrooms)
to sleeping areas shall be finaled
Noted that corrections have been
completed.
Code Enforcement case (CODE-000610-
2021) related to unpermitted
conversation of non-habitable space has
been resolved and the site is now
compliant with no active, open Code
Enforcement cases.
Staff would recommend removing this
condition.
Attachment E of APPL-0665-2025 Page 8
Staff’s Draft Conditions from
5/28/25 PCAR Recommendation
Proposed Changes from Appellant
(Additions italicized and underlined)
Staff Response and Recommendation
within six (6) months following the
May 28, 2025 Planning
Commission re-review hearing or
prior to leasing the affected
residential units to new tenants for
the next academic year, whichever
occurs first. Failure to complete the
required work to resolve the open
code enforcement case within the
preceding timeframe shall result in
the automatic revocation of this
Conditional Use Permit.
14 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 considered a
violation of this Conditional Use
Permit and may constitute grounds
for the revocation of this permit.
No change. N/A
N/A The Fraternity shall have an annual
education program for the fraternity
about the existence and requirements of
the Conditional Use Permit.
An annual education program regarding
Conditional Use Permit requirements
could be beneficial to both the fraternity
and the City. However, it is unclear how
implementation of the program would be
accomplished, and if included as a
Attachment E of APPL-0665-2025 Page 9
Staff’s Draft Conditions from
5/28/25 PCAR Recommendation
Proposed Changes from Appellant
(Additions italicized and underlined)
Staff Response and Recommendation
condition, it is unclear how staff would
verify condition compliance
Staff recommends considering this
amendment because it could be
beneficial, however, it is unclear how
implementation of the program would
be accomplished and how staff would
verify condition compliance.
N/A The fraternity shall create a good
neighbor management plan to reduce
impacts to the surrounding
neighborhood shall be submitted to the
Community Development Department,
at least 30 days before the commencing
of the fall academic period.
A good neighbor management plan could
be beneficial to both the fraternity and the
City. However, it is unclear how review,
processing, implementation, and
enforcement of the plan would be
accomplished without significant City
staff time and resources that are not
accounted for in the Use Permit
application process and associated fees.
Note: Draft Condition No. 11 includes
requirements for neighborhood outreach
for special events that are approved by
the Community Development
Department.
Staff recommends considering this
amendment because it could be
beneficial, however, it is unclear how
review, processing, implementation,
and enforcement of the plan would be
accomplished.
N/A The Fraternity shall have a community
service program with no less than three
A community service program could be
beneficial to both the fraternity and the
Attachment E of APPL-0665-2025 Page 10
Staff’s Draft Conditions from
5/28/25 PCAR Recommendation
Proposed Changes from Appellant
(Additions italicized and underlined)
Staff Response and Recommendation
community service events a year
benefiting the community of San Luis
Obispo.
City. However, there is no land use nexus
for requiring such a condition, but with the
appellant volunteering the addition of the
program, express consent should be
made clear in the condition language. It is
also unclear how such a program would
be implemented and how staff would
verify condition compliance .
Staff recommends adding this
condition of approval because it could
be beneficial, however there is no land
use nexus for requiring such a
condition, and if this specific applicant
is volunteering it, then their express
consent should be made clear in the
condition language. Additionally, it is
unclear how implementation and
enforcement of the program would be
accomplished.