HomeMy WebLinkAbout03-19-2013 B1 Lyons 2Mullen Henzell L.L.P
ATTORNEYS AT LAW
RECEIVED
MAR 2 0 2013
SLO CITY CLERK
March 18, 2013
e -mail: glyons @mullenlaw.com
with the Council's response to their concerns and assumed staff would bring forward a
revised Plan at the next meeting. Unfortunately, staff did not revise the Plan and
instead has brought forward a resolution that does not reflect the direction you
provided at your last meeting.
Despite Council's direction to staff that the Plan needed to be revised, staff is bringing
back the same Plan for your approval. The proposed resolution would include the
Plan, without any of the revisions requested by the Council, as part of the growth
alternative in the LUCE update.
112 East Victoria Street Post Office Drawer 789
Santa Barbara, California 93102 -0789
(805) 966 -1501
FAX (805) 966 -9204
Honorable Mayor and Council Members
J ROBERT ANDREWS
City of San Luis Obispo
JAY L BECKERMAN
990 Palm Street
JOSEPH F GREEN
MACK S STATON
San Luis Obispo, CA 93401
GREGORY F. FAULKNER
WILLIAM E DEGEN
Re: March 19, 2013 City Council Agenda Item B.1— Continued Discussion of
CHRISTINE P. ROBERTS
South Broad Street Area Plan
MICHAEL E. CAGE
LORI A. LEWIS
Dear Hon. Mayor and Council Members:
PAUL K. WILCOX
JARED M KATZ
DEBORAH K BOSWELL
This office represents property owners, business owners, landlords and tenants
RAMON R. GUPTA
affected by the proposed South Broad Street Area Plan (the "Plan"). We would like to
GRAHAM M. LYONS
thank you for your thoughtful consideration of the Plan at the last City Council
RAFAEL GoIVZALEz
meeting. We believe the more than two dozen affected citizens who spoke at your
DANA S. JOHNSON
meeting effectively articulated the concerns created by the Plan. Simply put, the Plan
LINDSAY G. SHINN
ROBERT D DOMINGUEZ
discourages successful business owners from continuing to operate in the Plan area
JENNIFER ADKINS TOMLIN
and in many instances would force these businesses to eventually shut down or
JARED A. GREEN
relocate out of the area. We believe you heard these concerns and appropriately
directed City staff to come back with a revised resolution. Specifically, a majority of
Council Members wanted to see the following revisions to the Plan: (a) remove
DENNIS W. REILLY
McMillan Avenue and Duncan Lane from the proposed rezoning plan; (b) a special
CHARLES S BARGIEL
KIRK R. WILSON
zoning overlay for the South Broad M -zone, which would allow existing
Or COUNSEL
manufacturing uses to remain "conforming ", with a "Right to Manufacture" disclosure
requirement informing residents that manufacturing operations exist nearby; and (c)
THOMAS M. MULLEN
1915 -1991
extending the 6 -month window for "grandfathered" non - conforming uses created by
ARTHUR A HENZELL
RETIRED
changes in the underlying zoning of certain properties. Our clients were very pleased
with the Council's response to their concerns and assumed staff would bring forward a
revised Plan at the next meeting. Unfortunately, staff did not revise the Plan and
instead has brought forward a resolution that does not reflect the direction you
provided at your last meeting.
Despite Council's direction to staff that the Plan needed to be revised, staff is bringing
back the same Plan for your approval. The proposed resolution would include the
Plan, without any of the revisions requested by the Council, as part of the growth
alternative in the LUCE update.
112 East Victoria Street Post Office Drawer 789
Santa Barbara, California 93102 -0789
(805) 966 -1501
FAX (805) 966 -9204
Honorable Mayor and Council Members
March 18, 2013
Page 2
The Council Agenda Report acknowledges revisions to the Plan are necessary but
recommends such changes be addressed as part of the LUCE update. We fail to see
the logic behind this recommendation. Why approve an admittedly defective plan and
forward it to the LUCE update process where the Council will be forced to revisit the
same issues it already considered and already directed staff to resolve? It is much
more efficient to correct the Plan now so the LUCE update process includes a plan for
South Broad that Council supports. Bringing an admittedly flawed plan to the LUCE
update process will only further confuse what is bound to be a long and complex
review of the City -wide Land Use and Circulation Elements. The City would be better
served if the Council fixed the Plan now and brought forward the right Plan to the
LUCE update.
The Council has the authority to revise the Plan now. Revisions made by the Council
do not need to go back to the Planning Commission, since the Planning Commission
acts only as an advisory body in this instance. Therefore, fixing the Plan will not
delay the LUCE update process, which appears to be a concern of staff. In fact,
revising the Plan now will speed up the LUCE update process as the Council will not
have to revisit the Plan's faulty provisions.
The simple question before the Council is: Why approve a plan you have already
found to be flawed? The majority of Council members agreed on three specific
revisions to the Plan and directed staff to make those changes. Staff did not make the
requested changes and is asking Council to approve a Plan the Council has already
found to be flawed.
Our clients and their neighbors hoped to come to the Council's March 19th meeting
and support staff's revisions to the Plan. Instead, they will be coming back to once
again demand that the Plan be revised before it is approved by Council and moved
forward to the LUCE update process.
We would ask that the Council not approve the proposed Resolution and instead direct
staff to revise the Plan to: (a) remove McMillan Avenue and Duncan Lane from the
proposed rezoning plan; (b) prepare a special zoning overlay for the South Broad M-
zone allowing existing manufacturing uses to remain "conforming" with the
underlying zoning, with a "Right to Manufacture" disclosure requirement informing
residents that manufacturing operations exist nearby; and (c) extend the 6 -month
window for "grandfathered" non - conforming uses that may be created by changes in
Honorable Mayor and Council Members
March 18, 2013
Page 3
the underlying zoning of certain properties. Once the Plan has been revised, staff can
return to Council for approval of the Plan with the full support of our clients.
Very truly yours,
r
Graham M. Lyons of
Mullen & Henzell L.L.P.
GML:rpl
G:\20046\0001\DOCS\GH9912.DOCX