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Home My WebLink About12-05-2016 ARC Correspondence - Public Hearing 1 (Racouillat)Richard Racouillat 5 11 Serrano Drive San Luis Obispo, CA 93405 December 1, 2016 Greg Wynn, Chair, and Members Architectural Review Commission City of San Luis Obispo 990 Palm Street San Luis Obispo, CA 93401 Re: Architectural Review Commission 12/5/16 Regular Hearing Project: 22 Chorro Street ARCH -2794-2016 Dear Chairman Wynn and other Commission Members: CEIVLD DEC 01 2.016 1__SILO CITY CLERIC Hand Delivered Meeting: ELL 1� - I W ltern:_Z�L I, The original application for the 22 Chorro project called for 18 density units, 55 parking spaces and a 1,600 square foot commercial/retail space. By designating 2 density units for very - low -income households, the Applicant maneuvered through a dizzying array of development regulations and now requests approval for a four-story mixed-use building with 27 residential apartments, a mechanical parking lift system restricted to residents only, a vehicle parking space reduction of 22 spaces from 55 spaces to 33 spaces, and 1,600 square feet of commercial/retail space. But for the addition of affordable housing, the concessions sought by the Applicant would likely have faced certain denial. The Project before you, therefore, strains at the limits of statutory interpretation and deserves careful scrutiny. The City Council approved the Applicant's requests including the reduction of required vehicle parking spaces from 55 spaces to 33 spaces. The question is whether the 22 parking space reduction is legally permissible. It is not. The Project does not qualify for a 22 parking space reduction. Under applicable law, the maximum allowed parking reduction for this Project is 12 spaces. The mixed use parking reduction has been miscalculated. Parking Deduction Request and Allocation The proposed Project requires 55 vehicle parking spaces (50 spaces for 27 residential units and 5 spaces for 1,600 square feet of commercial space). The Applicant is requesting a 40% parking reduction to 33 parking spaces based on the combination of three separate Code provisions: • Shared Parking Reduction. Maximum 10% reduction per SLOMC 17.16.060.B • Mixed -Use Parking Reduction. Maximum 20% reduction per SLOMC 17.16.060.0 • Bicycle Parking Reduction, Maximum 10% reduction per SLOMC 17.16.060.G Of the 33 parking spaces requested, 27 spaces are enclosed inside a Klaus TrendVario 4100 mechanical lift system and are assigned exclusively to residents. The remaining 6 parking spaces are allocated: (a) 2 handicap spaces; and (b) 4 spaces for a common parking area serving residents without lift parking privileges, staff, employees, guests, customers and commercial vehicles. Four spaces for common use! Since; there is no cin-s(reet parking of any kind next to the Project oir either Chcrro or Foothill this severe Varkinglirnitation is astonishin ► considerin (but tiler Proiect accommodates more than 100 individuals. Mix -Use Parking, Redurtianti up to 341%) SLOMC 17.16.060.13 states that "where two or more uses share qo� i>rton aiking,ar•eas, the total number of parking spaces required may be reduced by up to 10%, with approval of an administrative use permit." SLOMC 17.16.060.0 further states that "by approving an administrative use permit, the Director may reduce the parking requirement for projects sharing parking by up to 20%, in addition to the shared parking reduction, for a total maximum parking reduction of 30%, upon finding that the times of maximum parking demand from various uses will not coincide." In this case, the Applicant divided the 55 required parking spaces into two separate parking areas: (a) a common parking area; and (b) a separate mechanical lift parking facility assigned exclusively to residents. The mechanical lift system is not a common parking area. Rather, access and use of the lift is limited residents using a secure key system. The 22 mixed-use/shared parking reduction granted to the Applicant has been applied incorrectly against the full 55 parking space requirement rather than against the shared common parking required by Code. The shared parking area consists of only 28 parking spaces. The other 27 parking slots are ass�i ,neeexclusively to residents (one for each apartment) in the mechanical lift system, which is not part of the shared common parking area whatsoever. SLOMC 17.16.060.x.3: "Where there has been a reduction in required parking, all resulting spaces must be available for common use and not exclusive!y assigned to cit? individual use. In mixed use projects, required residential parking maybe reserved, but commercial parking must be made available for guests or overflow from residences. " Accordingly, the correct 30% mixed-use/shared parking reduction is 9 spaces (28 spaces x 30% = 8.4 rounded up per statute). In addition, the Applicant is entitled to a maximum 10% parking space reduction for motorcycle/bicycle parking spaces provided in the Project. SLOMC 17.16.060,G. Accordingly, the correct 10% bicycle parking reduction is 3 sipaces (28 shared spaces x 10% = 2.8 rounded up per statute). When the bicycle parking reduction is combined with the mixed-use shared parking reduction, the Applicant is entitled to deduct only 12 parking spaces from the 55 parking space requirement, not the 22 space reduction approved by the City Council. The Corrected Maximum Parking Reduction Calculation for the Proiect Parkin Rei Yired: 2 Bedrooms 4 Studios Rental Space Permissible Reductions: Shares Parking Reduction Mixed Use Reduction Bicycle Reductions Proiect Parkiy. Reauireenent 46 (23 apartments x 2 spaces each) 4 (1 space per studio) 5 100sf x l s ace/ 300st 55 Vehicle Spaces Required -3 (10% x 28 spaces — round up per statute) -6 (20% x 28 spaces — round up per statute) -3 C 10% x 28 s acc -- round un per statute) -12 Parking Reduction 43 16 shared common parking spaces 27 assigned residential spaces Rectuired Coronion Parking Spaces for the Proiect: The Applicant needs to provide as least 1[6 shared cmunton parking spaces, rather than the 6 shared spaces proposed for the Project. Recommendation Based on the foregoing, the Commission should consider and make one of two alternative findings: 1,1 n d i n g 1. The 22 vehicle parking space reduction approved for the Project exceeds the permissible limits set forth in SLOW 17.16.060.B, 17.16.060.0 and 17.16.060.G. Accordingly, the Project is denied. Finding 2. The parking space reduction formulas set forth in SLOW 17.16.060.B, 17.16.060.0 and 17.16.060.G shall be applied against total required parking requirements for a project, including both (i) common parking areas, and (ii) any separate parking areas assigned exclusively to individual uses, contrary to SLOW 17.16.060.K.3 prohibiting exclusive assignments. Alternatively, the Commission could forward the Project back to the City Council to determine whether Finding I or Finding 2 is applicable to the Project. Chorro Street Crosswalk €stand Uesiyn Issues The Applicant intends to widen the existing right turn lane on Chorro to accommodate vehicles/bicycles turning East onto Foothill. The right -turn lane is uncontrolled and has a crosswalk leading to a small island in the middle of Chorro Street. The refuge island has three crosswalks: one leading to the Project, one leading to Ferrini Square, and one leading across Foothill to the University Square Shopping Center. Since more than 100 new pedestrians and bicyclists introduced by the Project will reach these commercial areas through this intersection, the small refuge island poses serious safety risks to pedestrians in wheelchairs or individuals managing walkers, strollers, shopping carts, or bicycles. These risks are compounded by the addition of a bike box to the exceptionally small standing space on the island. The intersection and the refuge island should be redesigned, controlled and enlarged for safety reasons. Inconsistencies With other'kpplicable Laws In addition to the miscalculation of the permissible parking space reductions and the safety risks mentioned above, the Project is inconsistent with a number of applicable laws and regulations: ✓ Land Use Element 2.3.9.E (building height exceeds 35' height limit) ✓ Zoning Regulation 17.08.072.A.3 (Failure to minimize impacts to adjacent properties) ✓ Zoning Regulation 17.08.072.A.6 (the Project's scale is incompatible with adjacent neighborhood. There is no smooth height transition with adjoining structures. The abrupt height differential and large massing is incompatible with, and wholly inconsistent with, neighboring commercial and residential uses.) ✓ Zoning Regulation 17.08.072.F.2.a (the mixed-use Project is inconsistent with general plan and is incompatible with the surroundings.) ✓ Community Design Guidelines 3.1.13.2 (the Project is incompatible with the immediate neighborhood in scale, setbacks and massing.) ✓ Community Design Guidelines 5.3.A.1 (the Project has a negative impact on adjacent buildings and neighborhood for an infill development.) ✓ Community Design Guidelines 3.2.D.3a (Facade articulation. Facades longer than 100 feet should incorporate recesses or projections at least 20 feet deep along at least 30% of the length of the facade, and accommodate shops and functions within the project.) Design Solutions — Minimize Conflicts • Eliminate the shared -use parking concession, or alternatively, require an additional 10 common parking spaces to meet the 16 shared space minimum. • Eliminate the 4th Floor. Relocate the bonus units on the 4th floor to the 2nd and 3`d floors. Design horizontally rather than vertically. The Applicant should forfeit some bonus density units, offer 1 -bedroom apartments for working couples in place of some 2 -bedroom units, and reduce massing. « Consider whether the Klaus Parking Lift System poses serious safety issues. If the lift system is approved, consider whether the Applicant should: (1) provide handicap parking in each lift; (2) design each lift for larger or longer vehicles; and (3) post a substantial bond to assure the safety, continual operation and maintenance of the lifts, and to address parking spill-over into adjacent commercial and residential neighborhoods. • Eliminate the added right -turn lane from Chorro onto Foothill Street, and install vehicle controls to protect pedestrians and bicyclists crossing Chorro. The refuge island in the middle of Chorro Street is particularly dangerous and should be enlarged. • Establish Rent Controls and/or subsidies for low-income households along the Foothill corridor and avoid this assault on adjoining commercial and residential neighborhoods. Cooiclusion: The Project is over -built, severely under -parked, and dangerous to pedestrians bicyclists attempting,to cross Chorro or Foothill Boulevard, and should be rejected. The approved Project is inconsistent with the Community Design Guidelines and the Mixed Use project design standards (Zoning Regulations §17.08.072) for the reasons stated above. ( "lotiiing Thank you for your courtesy and consideration in addressing the very troubling design features of the 22 Chorro project proposed for the Foothill corridor. Respectfully submitted, Richard Racouillat