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HomeMy WebLinkAbout10/10/2018, Item 2, CooperTo: SLO Planning Commission Re: Zoning Regulations Amendments; Amendments To The Recently Approved Zoning Regulations Comprehensive Update (Introduced By City Council On August 21, 2018 And Adopted By Council On September 18, 2018) To Address Council Direction From The August 21, 2018 Hearing And Other Miscellaneous Clean -Up Items. From: Allan Cooper, Secretary Save Our Downtown Date: October 6, 2018 Honorable Chair Fowler and Planning Commissioners - Save Our Downtown believes that the addition of moveable tiny houses onto existing lots should require additional parking. In the past, you have described the policy of imposing City-wide parking reductions, while increasing housing densities, as "draconian" and we agree. Under Section 23. Section 17.140.070 (Alternative or Additional Incentives) we are concerned that you, rather than the Council, will be approving any alternative incentive or concession and the requisite number of incentives or concessions for affordable housing projects. We believe that these important discretionary decisions be the purview of elected, not appointed, city officials. We are concerned with the provision that the accessory dwelling unit (ADUs) owner occupancy requirement might be excluded in the R-3 Zone. The R-3 neighborhoods within or near the Downtown District are predominantly comprised of single family detached houses, many of which are owner -occupied. These neighborhoods include the Railroad Square Neighborhood, the Dana and Palm Street Neighborhoods and the Pismo Street or Old Town Neighborhood. Exempting owner occupancy for ADU's is compounded by the fact that substandard (i.e., 50 ft. x 100 ft.) lots are commonly found within these older neighborhoods. Although we embrace the new requirement that development agreements be required for any project proposing increased height within the Downtown Overlay Zone, we remain concerned that LUE Policy No. 3.13 "Zoning Update for Visitor Services Uses" is being used to justify expanding the C -D Zone into upper Monterey. This proposed change did not originate with the LUCE nor is it consistent with the LUCE EIR. We were told that it originated with you. Continuing the downtown development standards to Upper Monterey would be a problem for the adjoining residential neighborhoods which flank upper Palm and Higuera Streets. No enhanced requirement for step backs could possibly make a 75 foot tall building compatible with a single story residence. If you insist on moving forward with this proposal, then you should state more specifically what maximum heights must be incorporated into these development agreements (we recommend far less than 75 feet) and what the minimum percentage of very -low and low income housing would be (we recommend much greater than 5%). Because the LUCE EIR did not address the potential impacts associated with the possible level of housing production associated with this policy change, we concur with staff that there be a more in-depth policy and CEQA analysis before any action can occur. As you have determined for the variable residential densities proposal, we believe that extending downtown development standards into Upper Monterey should involve a traffic study including some build -out scenarios. We would also like to point out several errors and omissions contained within the Addendum to the Negative Declaration of Environmental Impact. Under Aesthetics, we believe that the following wording is incorrect: "The proposed overlay zone for Upper Monterey (from C-R to C -R -D) would allow additional building height along this corridor, resulting in an expected increase of 5 feet, with provisions for an additional 30 feet based on incorporation of specific incentives identified in the Zoning Regulations Update. This would not be inconsistent with the analysis and conclusions presented in the LUCE EIR because allowable density would not change, the potential impacts associated with potential future structural development in compliance with the proposed regulations would not result in any new significant impacts beyond what is identified in the LUCE EIR as identified in LUCE EIR Section 4.1 Aesthetics, Impact AES -1)..." We believe that the proposed overlay zone is inconsistent with the analysis presenting the LUCE EIR and that there could be significant impacts beyond what is identified in the LUCE EIR. Moreover, this proposal is inconsistent with the SLO Downtown Concept Plan as this plan clearly does not recommend buildings in excess of 4 stories for blocks 15, 23, 35, 16, 24, 17 or 25, all of which fall within this proposed zone change. Under Air Quality, we disagree that "there would be no new air quality impacts that have not been previously disclosed and addressed in LUCE EIR Section 4.3 Air Quality". These new air quality impacts would result from the proposed increased housing density related to the development occurring within the Upper Monterey Overlay zone. Under Greenhouse Gas Emissions, we believe that given Council's recent decision to attain carbon neutrality by 2035 (ten years faster than the rest of California), the following statement should be revamped: "the CAP includes a community wide GHG emissions reduction target of 15 percent below 2005 levels by 2020. This target can also be expressed as a 22 percent reduction below the projected BAU forecast by 2020..." With this goal in mind, the following new strategies in the updated Zoning Regulations may have to change from "incentives" to "requirements": "As an incentive for increased height in the C -D zone and a community benefit for a PD overlay, having a developer provide net -zero energy construction features. As an incentive for increased height in the C -D zone and a community benefit for a PD overlay, requiring a Transportation Demand Management (TDM) program that achieves measurable 20 percent mode shift and that is covenanted for long-term implementation." Under Hazards and Hazardous Materials, once appropriate CEQA review has been completed, it may be determined that the significant increase in housing densities resulting from variable densities could "impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan". Under Hydrology And Water Quality, a significant increase in housing densities could expose more people or structures to significant risk of loss, injury or death involving flooding. As we all know the Downtown Core is located within a flood zone. Finally under Transportation/Traffic And Congestion Management, downtown variable densities combined with the proposed future development within the Upper Monterey Downtown Overlay Zone would result in significant impacts related to operations of City roadways and key intersections as identified in the LUCE EIR. Thank you! 1) Tiny Homes - Reduce the maximum size from 450 sq. ft. to possibly 300 sq. ft. without counting the loft) and require a Director's Action for design review. 2) Accessory Dwelling Units (ADUs) Owner Occupancy Requirement - Consider excluding the owner occupancy requirement for ADUs in the R-3 and R-4 zones 3) Accessory Dwelling Unit (ADU) Lot Coverage Requirement - Consider reducing the lot coverage exemption for an ADU from 450 sq. ft. to 300 sq. ft. (consistent with the size of a Tiny Home). 4) Climate Action Plan (CAP) Electric Vehicle (EV) Parking - Further implement the (CAP) by requiring installation of EV capable parking spaces in new developments or significant remodels/additions. 5) Downtown Overlay Zone - Revise to require a Development Agreement (DA) for any project proposing to take advantage of increased height (above 45 feet). The Council's motion included the provision that additional workforce and affordable housing opportunities in the project be incorporated into the DA.