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HomeMy WebLinkAbout10/10/2018, Item 2, Grant 3765 S. Higuera St., Ste. 102 • San Luis Obispo, CA 93401 p: (805) 543-1794 • f: (805) 543-4609 www.rrmdesign.com a California corporation  Lenny Grant, Architect C26973  Jerry Michael, PE 36895, LS 6276  Jeff Ferber, LA 2844 September 21, 2018 Doug Davidson, AICP, Deputy Director Community Development City of San Luis Obispo 919 Palm Street San Luis Obispo, CA 93401 RE: Final Adoption of Revised Zoning Regulations Dear Doug, Recently members of RRM staff attended two different information sessions where City of SLO Planners presented an overview of the upcoming changes to the City’s Zoning Regulations. The update is a comprehensive revision to the regulations and its intent is to have a better organized document, get rid of archaic requirements, and respond to current trends. While admittedly the bulk of the changes to the regulations is welcome and was thoughtfully drafted, some changes seem to have occurred under the radar and have negative implications to creating housing for both lower income groups and senior citizens. The specific issue highlighted in this letter is the unintended consequence that parking for affordable housing projects will increase rather than decrease with the latest draft of the Zoning Regulations. The changes at issue relate to the relocation of “J” and elimination of “K” which are the following two requirements that have been in the City’s Parking Section 17.16.060 of the Zoning Regulations for several decades: J. Elderly housing parking. Housing occupied exclusively by persons aged 62 or older may provide one-half space per dwelling unit or one space per four occupants of a group quarters. K. Low-income housing parking. Housing occupied exclusively by very low or low-income households, as defined by the State, may provide one car and one bicycle space per dwelling unit. These types of projects include lower parking requirements since it can be documented through numerous industry standards and academic research that they have lower parking demand than market-rate or non-age restricted multi-family housing developments. Final Adoption of Revised Zoning Regulations City of San Luis Obispo September 21, 2018 Page 2 of 5 Low Income Housing Like elderly housing, affordable housing developments have lower parking demands than market- rate projects. The existing requirement of one space per unit is now proposed to be replaced with the “Affordable Housing Incentives” which come from State Housing Law. Currently, both the City and State requirements are in the current Zoning Regulations and allow for some flexibility in application depending of the project’s specific programming for unit types and target population. This change is understandable to make City requirements consistent with State law, but the change has the effect of increasing, probably unintentionally, parking requirements. Here is the language of the proposed requirements: K. Parking Requirements. 1. Upon the request of the developer, parking ratios of a development meeting the criteria of this section, inclusive of handicapped and guest parking, shall be as follows: a. Studio to one bedroom: one onsite parking space. b. Two to three bedrooms: two onsite parking spaces. c. Four or more bedrooms: two and one-half parking spaces. d. Senior Housing: 0.5 spaces per bedroom. 2. If the total number of parking spaces required for a development is other than a whole number, the number shall be rounded up to the next whole number. 3. For purposes of this section, a development may provide onsite parking through tandem or uncovered parking, but not through on street parking. 4. An applicant may request additional parking incentives or concessions beyond those provided in this section, subject to section 17.90.060. Parking Calculations Examples To illustrate how the change to the regulations would affect parking calculations, here’s an example for a 30-unit multi-family apartment project with 15 one-bedroom units and 15 two- bedroom units: Current Requirement 30 x 1.0 = 30 spaces Proposed Requirement 15 x 1.0 = 15 spaces; 15 x 2.0 = 30 spaces - total of 45 spaces Final Adoption of Revised Zoning Regulations City of San Luis Obispo September 21, 2018 Page 3 of 5 This is a huge difference, resulting in 50% more parking spaces than would currently be required, and has been the requirement for decades. This seems to contradict City efforts to reduce, rather than intensify parking requirements, especially for special needs housing categories. Affordable projects built to the current standards of one space per unit have not resulted in parking issues, such as cars spilling over into adjacent neighborhoods or insufficient on-site parking. In addition, the new affordable parking requirements could even require more parking then a non-affordable project depending on the unit mix. Per the updated parking standards for a non- affordable project, the unit mix example above of 15 one-bedroom units and 15 two-bedroom units would require 43.5 spaces as detailed in the calculations below: Non-Affordable Requirement One-bedroom units: 15 x 1.0 = 15 spaces Two-bedroom units: .75 x 2.0 = 1.5 x 15 = 22.5 spaces Guest Parking 1/5 units; 30/5 = 6 spaces Total parking required: 43.5 spaces Another observation with the revised regulations is that senior housing is listed above in the affordable housing section with a requirement of 0.5 spaces per bedroom. This is in keeping with the general elderly housing standard that has existed in the code for decades (the cited Section “J” on the previous page) except that it is per bedroom, rather than unit, which is an important distinction. Senior housing in general will have a similar parking demand, whether it is affordable or not since fewer seniors in these types of developments drive. The requirement in the Affordable Housing Section should be updated to be 0.5 spaces per unit for consistency purposes. Multi-Unit Residential The new parking requirement for multi-unit residential is: For multi-unit projects, the requirement is 0.75 space per bedroom (no less than 1 space per dwelling unit), plus 1 guest parking space per 5 units. Housing occupied exclusively by persons aged 62 or older may provide one-half space per dwelling unit. The first half of the requirement formerly labeled “J” has now been added here, which provides a reasonable standard for senior housing preserving the established standard of one-half space per dwelling unit that has been in the Zoning Regulations for decades. The notation above Final Adoption of Revised Zoning Regulations City of San Luis Obispo September 21, 2018 Page 4 of 5 should also clarify that the reduced senior parking requirement does not include a separate guest parking requirement. However, with the new Continuing Care Community discussed in the next section, this lower parking requirement for seniors is not specifically referenced. Continuing Care Community The land use category of Continuing Care Community has been added to the updated Zoning Regulations. It refers to dwelling type, which is either single unit dwellings, detached, or multi- unit residential, and includes a requirement for 1 space for every two employees providing on- site services to residents. However, a reference needs to be added that the “housing occupied exclusively by persons aged 62 or older may provide 0.5 space per dwelling unit” which is listed under the multi-unit residential category applies to this type of development. The overall parking requirement for a Continuing Care Community is lower like other senior housing development since so many residents likely will not have individual cars. Also, the definition for a Continuing Care Community later in the document does not note that these communities have a minimum resident age requirement of 60 years old. Perhaps, the code could use 60 rather than 62 as the minimum age in both locations of the code to be consistent. Summary It is well documented that the State of California is in a housing crisis. The City of San Luis Obispo is especially hard hit with its extraordinarily high property values and rental costs. The ongoing effort to provide affordable housing projects is important to City goals to provide quality housing to all citizens. Parking is an important component of all projects including affordable housing developments. However, parking beyond the documented needs of a development wastes land area, adds costs to development, and does not follow sustainable practices. Planning trends are to lower rather than raise parking requirements given lifestyle preferences and technological changes. Fewer people are opting to purchase vehicles given the range of options available to get rides on demand and to share vehicles. The main point with this letter related to the update to the City’s Zoning Regulations is that parking requirements for affordable housing projects should not be increased over existing standards. The parking requirements have been in the code for decades and have proven effective in meeting the parking demand of residents in these developments. Please keep the existing standards the way they are. It makes sense since they have been proven to meet the needs of many projects developed to these standards over several decades. Final Adoption of Revised Zoning Regulations City of San Luis Obispo September 21, 2018 Page 5 of 5 Then you for the opportunity to comment on this important issue. Sincerely, RRM DESIGN GROUP Leonard Grant Principal CA License No. C26973 Attached: Current Regulations – 17.16.060 J & K Proposed Regulations - Residential Parking Standards ecmN:\0801\0879-01-RS17-487-Leff-St-Mixed-Use-Dev\Planning\2018 City of SLO Zoning Regs Update\Final Version of Parking Comments\Zoning-Regs-Update- Parkingv4-9-21-18.docx CC: HASLO PSHH (John Fowler) Jerry Rioux City of San Luis Obispo March 2015 Zoning Regulations Page 69 TABLE 6.5 BICYCLE PARKING SPACE REQUIREMENTS a Zone Number of bicycle spaces as a percentage of required auto spaces b Minimum short-term c bicycle spaces Minimum long- term d/e bicycle spaces R-2, R-3, R-4 5% 100% -- C-C, C-R, C-N, C-D 15% 50% 40% O, BP 15% 10% 80% C-T 5% 10% 80% C-S, M 15% 10% 80% PF (schools, junior high to college) 1 space per 3 students Park & ride lots 10% - - 100% a. All parking shall be provided on site. b. Requirements apply to uses that require 10 or more vehicle parking spaces. When less than ½ space is calculated, one space is required. c. “Short-Term” bicycle parking is used by visitors to multi-family housing and by patrons of commercial and institutional uses. Bicycle racks are used to satisfy this need. d. “Long-Term” bicycle parking is used by employees of commercial and institutional uses and by residents. Fully enclosed lockers are used to satisfy this need. Lockable rooms reserved for bicycle storage and secured parking areas managed by attendants are other acceptable forms. Bicycles shall be parked vertically or horizontally with at least the rear tire resting at floor level. e. In addition to short- and long-term parking required for commercial uses, residential uses in all zones, including the Downtown Commercial (C-D) zone, shall provide bicycle lockers or interior space within each dwelling or accessory structure (e.g. garages) for the storage of at least two bicycles per unit regardless of the number of automobile parking spaces provided. J. Elderly housing parking. Housing occupied exclusively by persons aged 62 or older may provide one -half space per dwelling unit or one space per four occupants of a group quarters. K. Low-income housing parking. Housing occupied exclusively by very low or low-income households, as defined by the State, may provide one car and one bicycle space per dwelling unit. L. Additions and changes in use for existing uses or structures which do not meet current parking standards. 1. Minor additions. Minor additions to existing legal structures or uses, which are non-conforming because they do not meet current parking standards, may be permitted if they meet the following requirements: Article 3: Regulations Applicable to All Zones 3-48 September 2018 Table 3-4: Parking Requirements by Use Type of Land Use Number of Off-Street Parking Spaces Required Hotels and Motels 1 space per room, plus any spaces required for conference/meeting facilities and restaurants open to the public RV Parks As provided in approved use permit PUBLIC AND ASSEMBLY USES Cultural Institutions Live Theater: 1 space per 100 sf; all other uses 1 space per 400 sf of public assembly area Hospitals and Clinics Clinic 1 space per 200 sf Hospital 1 space per bed Park and Recreation Facilities 4 spaces per acre of park space and 1 space per 200 sf indoor recreational facilities Public Assembly Facilities 1 space per 100 sf Religious Assembly Facilities 1 space per 100 sf Schools - Colleges 2 spaces per classroom plus 1 space per 300 sf of assembly or common area Schools - Primary and Middle 2 spaces per classroom plus 1 space per 300 sf of assembly or common area Schools - Secondary, High School 5 spaces per classroom plus 1 space per 300 sf of assembly or common area Schools - Trade Schools 2 spaces per classroom plus 1 space per 300 sf of assembly or common area Sports and Entertainment Assembly Facility As provided in approved use permit RESIDENTIAL USES General Residential Housing Types Single-Unit Dwellings, Detached 0.75 space per bedroom (no requirement for Accessory Dwelling Units), plus 1 guest parking space per 5 units in a tract development Multi-Unit Residential 0.75 space per bedroom (no less than 1 space per dwelling unit), plus 1 guest parking space per 5 units Housing occupied exclusively by persons aged 62 or older may provide 0.5 space per dwelling unit Boarding House 1 space per 1.5 occupants or 1.5 spaces per bedroom, whichever is greater Caretaker quarters Two spaces per dwelling Continuing Care Community Same as dwelling type, plus 1 space for every two employees providing on-site services to residents Elderly and Long-Term Care 2 spaces for the owner-manager plus 1 for every 5 beds and 1 for each nonresident employee. Family Day Care - Small None in addition to what is required for the residential use. Family Day Care - Large Same as dwelling type, plus 1 space for every two employees providing day care services Fraternities and Sororities 1 space per 1.5 occupants or 1.5 spaces per bedroom, whichever is greater CITY OF SAN LUIS OBISPO Title 17 – ZONING REGULATIONS 8-15 September 2018 J. An applicant may elect to accept a lesser percentage of density bonus. K. Parking Requirements. 1. Upon the request of the developer, parking ratios of a development meeting the criteria of this Section, inclusive of handicapped and guest parking, shall be as follows: a. Studio to one bedroom: one onsite parking space per unit. b. Two to three bedrooms: two onsite parking spaces per unit. c. Four or more bedrooms: two and one-half parking spaces per unit. d. Senior housing: 0.5 spaces per bedroom 2. If the total number of parking spaces required for a development is other than a whole number, the number shall be rounded up to the next whole number. 3. For purposes of this Section, a development may provide onsite parking through tandem or uncovered parking, but not through on-street parking. 4. An applicant may request additional parking incentives or concessions beyond those provided in this Section. 17.140.050 – Standard Incentives for Mixed Use Projects When an applicant for a commercial development partners with a housing developer proposing to provide affordable housing, the City shall grant to the commercial developer a development bonus pursuant to Government Code Section 65915.7 (Commercial development incentives for affordable housing.) 17.140.060 – Standard Incentives for Conversion of Apartments to Condominium Projects A. For the purposes of this Section, “other incentives of equivalent financial value” shall not be construed to require the City to provide cash transfer payments or other monetary compensations but may include the reduction or waiver of requirements which the City might otherwise apply as conditions of conversion approval. B. For purposes of this Section, “density bonus” means an increase in units of 25 percent over the number of apartments to be provided within the existing structure or structures proposed for conversion. C. When an applicant for approval to convert apartments to condominium units agrees to provide at least 33 percent of the total units of the proposed condominium project to persons and families of low or moderate income, or 15 percent of the total units of the proposed condominium project to lower income households, and agrees to pay for the reasonable, necessary administrative costs incurred by the City pursuant to this Section, the Director shall grant a density bonus or provide other incentives of equivalent financial value as it finds appropriate. D. Nothing in this Section shall be construed to require the City to approve a proposal to convert apartments to condominiums. E. An applicant shall not be eligible for a density bonus under this Section if the apartments proposed for conversion constitute a housing development for which a density bonus or other incentives were provided under Sections 17.140.040, 17.140.050, or 17.140.070.