HomeMy WebLinkAboutAGENDA REPORT 2018 0919 CCSA REG ITEM 08A CORRESPONDENCE ,Jackson Tidus
A LAWCORPORATION
•
September 13, 2018 Darect Dias: 805.418.1914
Ernail: msellers@jacksontidus.law
Reply to:
Foie No: 9686.126296
VIA PERSONAL HAND DELIVERY
City Council
Care of The City Clerk for City of Moorpark
City Hall
799 Moorpark Ave.
Moorpark, CA 93021
Re: September 19, 2018 City Council Meeting; Tentative Parcel Map No. 2018-
01; Applicant's Request Condition 1 Be Deleted and Condition 4 Be
Modified.
Dear Honorable City Council:
We represent the land owner and the Applicant, Robert in't Hout, who has filed for
Tentative Parcel Map No. 2018-01 that is before you at your September 19, 2018 City Council
Meeting. We oppose two conditions that staff has proposed for this parcel map approval and
request that Condition 1 be deleted and Condition 4 be modified.
A. Condition No. i - Remainder Parcel Needed
The parcel map contains 4 new parcels and a "remainder" area. Frequently, a large
area with the most engineering and development challenges is designated a "remainder" or
"not a part of' the map, which portion of the land is not created or divided for the purpose of
"sale, lease, or financing" at that time. The designated remainder on Parcel Map No. 2018-01
is the largest of the parcels created along Wicks Road (at 20,444 sq. ft.), and that portion of
the property has the most challenges for designing, engineering and solving drainage, for the
installation of street improvements on Wicks Road and for grading of that area. This map's
designated remainder area is not left for the purpose of the Applicant's sale, leasing, or
financing at this time, but was created simply to allow more time for the Applicant to explore
and resolve drainage complications (i.e., storm water flows from the street and then
eventually offsite to the south of the property and work may needed to be done at the inlet of
drain off-site), to defer street improvements until installation can be sensibly made, and to
have grading issues resolved. There is an existing house on the western most parcel and the
development of the 3 new parcels, also to the west of the remainder, could move forward
while that drainage and grading issues are worked on by the City, the Applicant and the
impacted property owners. The Applicant, who is very experienced in development, grading
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Irvine,California 92614 Westlake Village,California 91361
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City Council
September 13,2018
Page 2
and civil engineering', has a preliminary design for this area, but needs to discuss and possibly
have an agreement with his neighbors on such work.
Staff had mentioned a concern that the remainder might never be developed and
could be foreclosed on due to the non-payment of taxes. However, with very high Moorpark
housing prices for view properties like all of these 5 sites there are certainly many financial
reasons and a genuine motivation for Applicant to find ways to resolve these drainage and
grading issues as soon as possible. The Applicant, as an experienced contractor, is well aware
of the costs to install the drainage facilities and grade the remainder and such costs are
justified for a view lot. The Applicant has too much invested in this property to allow it to be
foreclosed on for non-payment of taxes. This remainder makes sense in this unique situation
and is needed.
California Government Code §66424.6 (Map Act) clearly says "when a subdivision, as
defined in Section 66424, is of a portion of any unit or units of improved or unimproved land,
the subdivider may designate as a remainder that portion which is not divided for the
purpose of sale, lease, or financing." The power to decide if a parcel map will have a
remainder is held solely by land owner subdivider.
The City has cited no supportable reason or authority for imposing condition i
deleting the identified remainder. We agree that the City can impose a condition on this
parcel map that the designated remainder may only be subsequently sold, leased or
transferred if the City issues a Conditional Certificate of Compliance for that area. The City
will then be informed of final grading plan, house location and timing on the installation of
the Wick Road street and sidewalk improvements along the frontage of that area and for the
off-site portion of that work to the east. A deed restriction to that affect can be recorded
against the remainder
The staff report also states without any supportive evidence or explanation that the
Map Act findings cannot be made if the remainder stays. We disagree. This map does not
meet any of the situations or requirements of Government Code §66474 for disapproval:
• This project is consistent with the Moorpark general plan;
• The site is physically suitable for this small type of 5 unit SFD residential
development that is like those in the immediate neighborhood, and the
remainder can be graded and made level and compatible with the adjoining
parcels;
• There is no evidence that the density is an issue as the zoning has a 6,000 sq.
ft. minimum lot size and each of these parcels exceed that size;
` A licensed general contractor in California for 24 years.
City Council
September 13,2018
Page 3
• There is no evidence as to inadequate water, sewage or other public facilities
to serve the site;
• The design of this small subdivision or the proposed improvements along an
existing City street are not likely to cause substantial environmental damage
or substantially and avoidably injure fish or wildlife or their habitat; and
• The design and layout of the 4 parcels and type of residential improvements
thereon is not likely to cause any serious public health problems. This project
is similar to other residential properties in the area and no serious public
health problem has been identified that is caused by these 4 parcels or houses
or this parcel map. Wicks Road has been its present condition for many years,
and the residents in these 4 houses do not need to use Wicks Road going to or
coming from the east. Wicks Road dead ends a short distance to the east.
The required findings must be supported by substantial evidence in the record before
the hearing body. The record lacks any substantial evidence that the parcel map's layout or
design, for the 4 parcels it creates, causes any public health problem. There is no difficulty in
making the normal Map Act approval findings.
The proposed condition number i requiring the removal of the land owner's
designated remainder should be deleted.
B. Condition No. 4 Should Be Modified to Deleted Installation For Frontage Along
the Remainder and Off-Site, or Have A Condition That the Applicant Install Remainder and Off-
Site Street Improvements at a Logical Time.
If an owner is not allowed to sell, grade and build on a parcel, there may not be the
necessary funds generated for installing the public facilities associated with that parcel.
Therefore, under the Map Act normally the fulfillment of construction of the street and
sidewalk improvements is not required for area along a designated remainder (which is not
now divided for the purpose of sale, lease, or financing) until a City grants a permit or other
City approval for development of the remainder (like issuing a conditional certificate of
compliance). Government Code §664ii.i(b). Presently, there is no home pad designed and
located and no grading plan prepared for the remainder to have such coordinated with the
installation of the street improvements.
Condition 4 for installing street and sidewalk improvements off-site on the property to
the east of the applicant's property was never brought up in the pre-hearing process and the
Applicant was surprised to see this condition when he received the Planning Commission
agenda report just two business days before the Planning Commission hearing. Basically, the
remainder is now a large hole or ravine that also includes part of the adjacent lot to the east.
It will be very difficult and costly to design and install any street and sidewalk improvements
City Council
September 13,2018
Page 4
until a development plan has been created and approved for the remainder area, along with a
grading agreement reached with the neighbor to the east who is burdened with this same
ravine.
If the drainage improvements could be installed first, the improvement of Wicks Road
could be done in a way that would fit both the remainder and neighborhood better. As
conditioned, Wicks Road would be improved but the drainage issue would not be solved, and
that timing defeats the coordination of that solution with the design Wicks Road
improvements and that could be more costly for the City or benefiting properties.
Access on Wicks Road to and from the Applicant's 4 legal and transferable parcels
would be from the west, and not from the east. There is little development to the east being
only one vacant lot and five lots with houses. Other than the City Ventures Tract, there are
no pending plans to develop anymore properties east of the Applicant's project on Wicks. As
mentioned above, Wicks Road dead ends a short distance to the east. Installing such off-site
improvements to the east is not needed for the present and 3 future new residents in this
project. Orderly development means requiring street improvements along and for a logical
series of newly created adjoining usable lots.
There should be a reasonable relationship to the impacts of this 4 parcel project to any
City imposed condition, like the installation of street and sidewalk improvements along the
remainder and off-site to the east. We do not see any reasonable degree of connection to the
impacts of this proposed small development of 4 parcels with 3 new homes and any
mitigating need to install the street and sidewalk improvements along the vacant remainder
and off-site to the east, street portions that do not benefit or serve this project.
For some unknown reason, the off-site portion where the Applicant is asked to install
street improvements was developed in the early 1990's, yet street improvements were done
for only about half of that adjacent parcel's frontage. Also, since Wicks Road is to provide
access to the City Ventures' no lot development approved the north of Applicant' project, that
development was conditioned to improve this same section of Wicks Road we are concerned
about. With the housing market being very active and little new housing being approved in
Ventura County, we expect that City Ventures' project to move ahead soon. Shifting the cost
burden for installing these remainder and off-site street and sidewalk improvements onto this
very small project, with no reimbursement from the benefiting adjoining lot owner who
escaped that obligation, is not fair. Condition 4 should be modified to require installing
street and sidewalk improvements on along only the frontage of the 4 western parcels created
by this map.
As an option, we suggest a condition deferring Applicant's construction of these
street/sidewalk improvements. The Applicant will commit to installing the Wick Road
improvements within 5 years if those improvements have not been installed by City Ventures'
development, or when the drainage design has been finalized over and to the south of the
City Council
September 13,2018
Page 5
remainder and a grading plan has been approved by the City for the remainder, or within 12
months of when the City grants a Conditional Certificate of Compliance for the remainder.
Very truly yours,
I4.4A--V. Of.a.4./..--__
M rk G. Sellers
Robert in't Hout
1419444.2