HomeMy WebLinkAbout10/1/2019 Item 08, Cooper
Wilbanks, Megan
From:Allan Cooper <
To:Codron, Michael; Bell, Kyle; E-mail Council Website
Subject:REVIEW OF APPEALS FILED REGARDING PROPERTY LOCATED AT 1121 MONTALBAN
Attachments:009_27_19...montalbanletter.pdf
Dear Michael & Kyle -
Would you kindly forward the letter attached below to the
City Council? This letter pertains to next Tuesday's Public
Hearing Item #8. Thanks!
- Allan
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To: San Luis Obispo City Council, Michael Codron, Community Development Director, Kyle
Bell, Associate Planner
Re: Review Of Appeals Filed By Damien Mavis, Applicant, And David Joy, Appellant,
Concerning The Planning Commission’s Decision Regarding Property Located At 1121
Montalban
From: Allan Cooper, San Luis Obispo
Date: September 27, 2019
Honorable Mayor and Council Members -
I am writing this letter in opposition to Mr. Damien Mavis’ appeal of both the ARC’s and PC’s
condition to limit bedroom access to a single door (in lieu of the proposed double doors).
Deflection
Associate Planner Kyle Bell is misrepresenting the intent behind the decision made by these
Commissions as there was never any discussion during their deliberations about “maximum
occupancy”. Dragging the case of Briseno v. City of Santa Ana into this discussion appears to
be a deliberate attempt to deflect our attention away from the real issue at stake here which is
parking. What we are protesting is that the City is allowing the applicant to provide only 19
parking spaces (and this based on the new city-wide parking reductions included in the Zoning
Reg Update) when twice that number will be required once these demising walls are made
permanent. This shortfall of on-site parking will end up on the city’s streets. Moreover, inserting
mention of the Density Bonus Law (DBL) and the Housing Accountability Act (HAA) has no
bearing on this discussion. This 15-unit project is not being denied any benefits from either the
DBL or HAA as it is receiving a 97% density bonus in exchange for providing only two deed-
restricted housing units.
Citing Non-Existent Codes
Mr. Bell stated “The proposed partitions do not qualify as additional bedrooms under the
California Building Code, or the City’s Zoning Regulations.” Five months ago, I defied Mr. Bell
to actually find the citations within either the California Building Code, or the City’s Zoning
Regulations that will provide you with the precise definition of a “bedroom”. He has failed to do
this. In good faith, I have looked everywhere in these two documents and these definitions
cannot be found. You should place the burden on staff to provide you with these specific
citations before you determine that this issue is settled.
Nevertheless, I can tell you how the National Building Code defines a “bedroom”. “A room
must have a window for direct egress to the exterior with an opening of no less than 6 square
feet and a door on it so that the room can be closed.” Each of these partitioned off spaces are
provided with both a window and a door such that the room can be closed. There should be no
debate that the partition, once installed, will result in meeting the definition of a “closed room”.
More specifically, the California Building Code states that a bedroom must have a minimum of
70 square feet, a minimum dimension of 7 feet, in any direction, 2 means of egress,
temperature controls between a specific range and a smoke detector.
Mr. Bell further states that “partitions that are used as privacy screens in the proposed project
do not constitute walls that create additional bedrooms in the project”. Again, I have defied
Mr. Bell to find the citations within either the California Building Code, or the City’s
Zoning Regulations that define a “wall”. The closest I can come to the definition of a “wall”
is in the International Building Code. The 2018 IBC Code defines a wall as “a vertical element…
used to enclose space.” I believe these partitions fit that description .
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In Summary
In summary, it is not a coincidence that each of these double-doored bedrooms include a
demising wall separating the two doors. It is clear that these should be counted as multiple
bedrooms for the purpose of determining the project’s parking requirements. Nevertheless,
both of your advisory bodies determined that there was a simpler way of approaching this
problem. Simply replace the double doors with one door.
Please consider that this is not the first project which has come before the City that had
double-doored bedrooms with demising walls. Previous projects (not incidentally designed by
the same architect, Thom Jess) include 71 Palomar, 22 Chorro and 790 East Foothill. Is it not
telling that the 2 and 3 bedroom units at both the Academy Chorro and the Academy Palomar
are currently being advertised as 4- and 5-bedroom units? Please do not set a worrisome
precedent by ignoring the wise counsel of your advisory bodies. Thank you!
(see https://codes.iccsafe.org/content/IBC2018/chapter-2-definitions)
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Chapter 2 Definitions First Printing August 2017:
“Wall (for Chapter 21). A vertical element with a horizontal length-to-thickness ratio greater than three,
used to enclose space.”