HomeMy WebLinkAboutAGENDA REPORT 2004 0602 CC REG ITEM 09AITEM q • A.
MOORPARK CITY COUNCIL
AGENDA REPORT
TO: Honorable City Council
FROM: Barry K. Hogan, Community Development Director��
DATE: May 21, 2004 (CC Meeting of 6/02/04)
SUBJECT: Consider Whether Appliance Sales, Distribution and
Warehousing are Commercial Uses in Compliance With the
Existing SDI Development Agreement for the Land
Located on the East Side of SR 23, Immediately North
and South of New Los Angeles Avenue (Lots 1 and 2 of
Tract 5004)
BACKGROUND /DISCUSSION
This matter was originally scheduled for the City Council of May
19, 2004. At the request of the property owner, Selleck
Development Group, Inc., the item was continued to the meeting
of June 2, 2004, so they could provide additional information to
the City Council. Attached is a May 20, 2004 letter from Daniel
F. Selleck. The May 19, 2004 Agenda Report is also attached.
The Affordable Housing /Community Development Committee (Mayor
Hunter and Councilmember Mikos) reviewed this and forwarded it
to the City Council to look at the usage of the property for
Warehouse Appliance Center for a quick "read" on the use and its
compliance with the existing Development Agreement. Since that
time additional information continues to come in as shown in the
attached letter. This is no longer a quick "read" and should
therefore follow the process set forth in the Development
Agreement Section 13. Section 13 Administration of Agreement,
states as follows:
All decisions by City staff concerning the
interpretation and administration of this Agreement
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Honorable City Council
June 2, 2004
Page 2
and development of the Property in accordance herewith
are appealable by Developer to the City Council,
provided that any such appeal shall be filed with the
City Clerk of the City within ten (10) days after
Developer is notified of the staff decision. The City
Council shall render its decision to affirm, reverse
or modify the staff decision within thirty (30) days
after the appeal was filed. Developer shall not seek
judicial review of any staff decision without first
having exhausted its remedies pursuant to this
section.
The Developer should request a decision on the use with all
information on the use presented to the Director, pay the
required fees for the Director's determination, and if the
Developer does not agree with the Director's determination, then
appeal the determination within the prescribed time period
outlined in section 13 of the Development Agreement. The
developer could also file a Commercial Planned Development
application.
STAFF RECO10MNDATION
Remove from calendar and request Selleck Development Group, Inc.
to follow the process provided for in the Development Agreement
and other applicable City procedures.
Attachments:
1. May 20, 2004 letter from Selleck Development Group, Inc.
2. May 19, 2004 City Council Agenda Report
000116
SELLECK DEVELOPMENT GROUP, INC.
May 20, 2004
Barry Hogan
Community Development Director
City of Moorpark
799 Moorpark Ave
Moorpark CA 93021
(copy via email bhogan @ci.moorpark.ca.us)
RE: Response to Staff Report
Proposed Warehouse Discount Center
Dear Barry:
Below, I have responded to the staff report I received on Monday. Please send a copy of
this response to the City Council for the hearing on June 2, 2004.
The Proposed Use of the Property is Not Industrial as Inferred in the Staff Report
The staff report suggests that the Applicant's proposed retail furniture, appliances
furniture and fixtures business is industrial in nature, not commercial, and on the basis of
this finding, staff is recommending that the proposed use is inconsistent with the
Development Agreement land uses specified in Section 6.K.
The logic of staff's analysis appears to be that "distribution" is both the dominant and
primary use proposed by the applicant, which is not the case. The staff report further
recites that because the inventory area of the building exceeds the showroom space,
product storage makes the building into an industrial use. We believe that this conclusion
misrepresents the proposal before the Council for several reasons as stated below.
First, the nature of this use and its customer attraction is retail, not industrial. The
customer base is drawn from individual purchase oriented retail sales by use of a well
stocked showroom with ample backup inventory on site. This retail outlet also serves
contractors, who purchase appliances and other big ticket items for their clients. As with
any retail multi -store operation, there are additional retail locations, which spread product
2660 Townsgate Road Suite 250, Westlake Village, CA 91361
805/495 -5400; Fax 805/495 -5300; email selleckinc @aol.com
CC ATTACHMENT 1
00011'7
inventory throughout the region, with such products being available to satisfy customer
preferences with short delivery times. For example, one can shop at Saks Fifth Avenue
in Pasadena, be unable to find a certain item in that store and have Saks personnel call to
Saks in Santa Barbara to determine stocking and intra -store shipping. What is proposed
in this case is very similar, but the scale of the products are march larger (ranges,
refrigerators, etc.).
Second, the square footages of showroom, office and inventory recited in the staff report
are incorrect which is probably due to a lack of clarity on our part as applicants. The
project includes two retail structures: a stand -alone retail building that is approximately
25,500 square feet and a warehouse retail /office facility of approximately 115,000 square
feet. The 25,500 square foot stand alone building is designed to help create attraction to
and synergy with the larger retail /warehouse center. In the larger warehouse retail
building to be owned and occupied by Warehouse Discount Center, about 15,000 square
feet will be devoted to general sales /showroom and another 15,000 square feet of
mezzanine area will be devoted to contractor sales and corporate offices. There are two
major keys to the success of this type of warehouse retail business: (1) having on hand a
very large variety of brands and styles of appliances and other items for sale and (2)
ensuring the ready availability of merchandise for purchase off of the showroom floor
suitable for next day delivery. With time and changing circumstances, the area dedicated
to retail showroom in the main building is likely to increase as customer base expands.
The total area devoted to warehouse supporting retail sales is 85,000 square feet which is
approximately a 3:1 ratio of inventory storage to sales space. For uses such as
automobile dealers, an uncontestable retail use, retail sales related to storage /service
space approach a ratio of nearly 10:1. In some E- business uses, a 3:1 ratio is certainly
not uncommon. Therefore, the conclusion that a large inventory area within a retail
facility implies an "industrial" use misrepresents the realities of current trends in
"Warehouse" retail business models.
Third, there is simply no manufacturing, construction, or synthesis of product proposed
by the applicant. The staff report suggests that the "distribution" functions identified as
one of three components of this project somehow render the project entirely inconsistent
with the Development Agreement use designations, and thus negate further consideration
of the purposeful site use, which is clearly retail. It is likely that the applicant's
consultant has contributed unknowingly to staff's misinterpretation of "distribution" by
the schematics and language used in the submitted exhibits describing the project and site
plan. If given an opportunity before Council, we believe it will be possible to clarify the
retail model that applies to this project. What is occurring in this case is delivery of retail
products sold, not distribution.
The rear building area of the larger of the two proposed retail structures is devoted
entirely to the orderly storage of inventory for rapid deployment to customer interest. It
also facilitates a normal retail function for preparation for and dispatch delivery to
customers. As with its other branch locations in nearby communities, there will be inter
and intra action by way appliance and furnishing exchanges and transfers. This
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000118
capability enables the applicant to better serve the desire of Moorpark, Simi Valley and
Camarillo residents for maximum access to a variety of merchandise, a variety of brands
and a full mix of sizes and dimensions not usually available in a City of the size of
Moorpark.
Fourth, it is important to keep in mind that nearly all major retailers of house, housing
construction and repair and furnishings, which are similar to this operation, e.g., Costco,
Ikea, Home Depot, Target, Bed Bath and Beyond, etc. function in facilities no different in
type and size as the one proposed by this applicant. They are organized and managed for
inventory accessibility and storage with such basic functions as off - loading, receiving,
stacking and stocking, operating cashiers stations and delivery. The organization of
stock in all these retail stores is no different that what is proposed in this case.
In the current retail environment, the distinction between warehouse and retail space
continues to be minimized and in many cases the distinction has simply been erased. The
proposed retail uses in this case are most comparable to stores such as Ikea and Costco,
but differ only in execution due to the size and weight of the warehouse retail objects
being sold which require truck delivery.
These last two conclusions related to distinctions between the size of the objects sold and
their transportation off -site is important. In most retail settings, e.g. Bed Bath & Beyond,
the objects purchased are small, or at least small enough that the majority of customers
can load the items purchased into their own cars. In this case, the merchandise often
weighs hundreds of pounds, is bulky and large requiring mechanical loading and
unloading, and can easily be damaged unless professionally transported and installed;
they are not "home pick up" type items.
Finally, to infer that the "use" in this case is industrial does not render a fit with any of
the definitions in Code Section 17.08.010. Nor do the purposes and uses called out in the
Industrial Zone sections of the ordinance (Section 17.16.060) conform in anyway to the
retail uses and supporting warehouse and delivery functions proposed in this case.
Clearly Section 17.16.060 contemplates industrial, technical research, business office
complexes, light manufacturing, fabrication, and related activities. Storage of business
products sold as retail products to customers and a business model which facilitates
exchange and transfer of merchandise just does not fit the definition of an industrial use.
This project conforms with the intent and purpose of the CPD zone. The exchange and
transfer functions of the applicant's businesses in no way subverts or subordinates the
primary business function of retail sales or uses permitted in a CPD zone. Nor does this
application set any new precedents for such uses. As a practical matter, this applicant
would be far better off economically to find less expensive M -1 zoned property for
warehousing if it were not for the integrated business model of showroom and inventory
storage which has marked its business success. It is that success which the applicant
wishes to bring to the City of Moorpark. Further, the design and materials aesthetics
which the applicant proposes for this retail facility far exceeds what would be applied to
an industrial building.
0►00119
What About General Plan Consistency?
The General Plan text states (emphasis added) "This designation [C -2] encourages the
grouping of commercial outlets into consolidated centers with direct access to major
roads, arterials and /or freeways. The proposed use and location is totally consistent with
this definition by explicitly grouping and consolidating retail sales in Moorpark,
whether by closing other potentially competing showrooms in the other nearby cities by
the way it addresses the needs of both builders and owner /remodelers. The placement of
such a facility at a location immediately adjacent to a major interchange which will
preclude or minimize any through truck traffic on City streets is one of the significant
business and City attractions associated with this location. Similarly valuable to the City
and this area is the fact that this retail use is akin to retail furniture, which are both light
generators of traffic and parking needs.
Are Warehouse Uses Predominant?
The staff report suggests that the presence of a substantial warehouse means that the
warehouse use is predominant. One must ask how warehousing in this case relates to the
business model. This is where there may be some confusion on point and possibly some
of the confusion has been introduced unintentionally by the applicant so we need to clear
the air on this point. The dominant use of this site is local /regional retail; the warehouse
use supports the sales income stream but does not determine it.
Nor is the warehouse a place where goods are being held for time - market related
appreciation nor is the warehouse area designed to represent a separate business operation
unrelated to the retail activities. The only possible source of the logic that the warehouse
is a distribution center is that this proposed headquarters facility will serve smaller
satellite retail outlets in Oxnard, Agoura Hills, Santa Barbara, Northridge and Santa
Clarita.
Of course it will be necessary to deliver supplies to these smaller showroom floors or
deliver products directly to customers buying furniture or fixtures at these showrooms.
But this is a simple "hub and spokes' business model where a larger central facility
supports a smaller remote location.
The brief analysis on Page 3 of the staff report, paragraph 3, does not accurately reflect
the consolidation of retail uses proposed with the closure of the existing Simi Valley and
Camarillo outlets. The suggested revenues don't include projections for local growth in
sales as the region surrounding Moorpark build out. The revenues also do not reflect the
potential for further consolidation. All contractor sales will occur through the office at
the new proposed Moorpark location and retail sales for all of the Simi, Little Simi,
Tierra Rejada, Santa Rosa Valleys and Camarillo will be concentrated at this location.
4
000120
Consistency with Adjacent Commercial Land Uses
The staff report makes the argument that the proposed project would not be consistent
with the Moorpark Marketplace, Towne Center or Mission Bell Plaza. Actually, this
project is clearly an extension of the "big box" and "warehouse outlet" retail uses which
exist directly across the freeway in the Moorpark Marketplace. The proximity of this
"warehouse retail" to other warehouse retail across the freeway was intentional and
planned; this synergy is an important part of succeeding in retail markets. Adjacencies
are critical. The Mission Bell Plaza and Towne Center, while also located in CPD zones,
are completely different types of retail centers and are not comparable to a center such as
the Marketplace which is intended to be a destination retail center for warehouse based
retail sales. This project has been situated in the best location relative to adjacencies and
compatibility with proximal businesses.
This is a Difficult Site to Develop
This site is difficult to develop for three reasons. Staff and the City Council need to
understand why this is a difficult site to develop and why the proposed use may be one of
the only types of retail uses that is likely to be attracted (other than major automobile
service centers and fast food destinations which are permitted by the development
agreement but are not thought by the owner or the City to be a preferred use).
First, the existence of the grades on upper New Los Angeles Avenue preclude the type of
circulation pattern preferred by major retailers typical of businesses that occupy the
Moorpark Towne Center or the Mission Bell Plaza. The applicant has designed the
project to be sensitive to cross - valley residential areas by reducing the visibility of the
parking field in front of the stores and to eliminate the visibility of the loading and
unloading functions related to deliveries. Both mixed use commercial centers (containing
office support, retail, restaurant, and professional services uses) and the conventional
warehouse commercial centers, such as the adjacent one downslope across the freeway,
nearly always require visible, large parking fields in front of all major buildings to obtain
major corporations to commit to long term leases. This relationship is not possible on the
proposed project site due to visibility problems, difficult grades at the entrance, and lack
of suitable solutions for dual primary retail access.
So, this site is not what one would characterize as a friendly pedestrian environment with
supportive adjacencies for uses such as a hotel, motel, or convention center. There are
some perception obstacles and management issues to be overcome with Lots 1 and 2 that
are really quite difficult.
Third, the landowner has investigated thoroughly whether there is any interest in this site
on the part of quality hoteliers, mid - quality and business traveler hotels and suites, and
potential convention center developers uses. After this extensive search for interest, the
owner has determined that these uses, if the City wants to see them pursued, would best
be accommodated on the smaller of the two lots comprising this site. However, it is
000121
important to be frank that at best, it is likely the only interested parties for this type of use
would be mid- to- lower -range business hotel developers with room rates in the $80 to
$100 range (such as a Hampton Inn, La Quinta or perhaps Hilton Garden Inn).
The site is certainly less than ideal for a resort, destination or even convention center
given its relative isolation from the rest of the City, the proximity of the freeway
immediately adjacent, and other constraints.
Summary
The applicant and landowner understand the City's interest in a "signature" use and
building at this location. However, the site configuration, relatively poor visibility of the
parking field, proximity to the freeway, absence of compatible proximate uses and
pedestrian friendly environment and limited ability to draw on synergy and adjacencies to
support ambitious uses such as a convention center all mitigate against the probability
that, even if the City were to deny the consistency of the uses proposed with the
development agreement, that the site would ever attract uses other than those similar to
the proposals presented by the applicant.
Also, the Development Agreement permits what are clearly not very desirable uses such
as a gas station and mini mart complex which are clearly not the "message" that the City
wants to send to the traveler, businessperson, or citizen entering the Los Angeles Avenue
corridor. Other clearly "legal" solutions exist that will not necessarily produce a good
planning result. We believe that all parties want to avoid this from occurring.
We respectfully submit that the use proposed is consistent with the Development
Agreement and the owner will make a significant effort to secure a hotel use on the
smaller adjacent lot out of respect for the City's direction that this would be desirable use
and be as well of financial assistance to the City. However, the City's vision and the
hotel development community's vision for this site are not consistent and even with best
efforts, it may be very difficult to secure this use.
A better emphasis for this project would be to work the site plan, architecture, and
landscaping to make the proposed project a unique and attractive asset for the City while
recognizing the difficulties that both this site and the general location pose for both the
landowner and applicant.
Respectfully,
Daniel F. Selleck
Cc: Tom Schlender, Warehouse Discount Center
0
000122
MOORPARK CITY COUNCIL
AGENDA REPORT
TO: Honorable City Council
FROM: Barry K. Hogan, Community Development Directo
DATE: April 23, 2004 (CC Meeting of 5/19/04)
SUBJECT: Consider Whether Appliance Sales, Distribution and
Warehousing are Commercial Uses in Compliance With the
Existing SDI Development Agreement for the Land
Located on the East Side of SR 23, Immediately North
and South of New Los Angeles Avenue (Lots 1 and 2 of
Tract 5004)
SUMMARY
At the April 21, 2004 Affordable Housing /Community Development
Committee (Mayor Hunter and Councilmember Mikos) meeting, Mr.
Selleck asked the Committee to consider whether or not the
corporate offices (8,000 square feet), a showroom (8,000 square
feet) and appliance distribution warehousing facilities (115,000
square feet) were within the commercial uses of the adopted
Development Agreement. Specifically, the owners of Warehouse
Discount Appliance would like to construct a single building
with these uses on Mr. Selleck's 8.1 acre site. The Committee
recommended that the item be referred to the Council for
consideration without specifying a course of action.
BACKGROUND /DISCUSSION
On August 28, 1996, the City Council adopted Ordinance 220
approving a Development Agreement with Special Devices, Inc.
(SDI). The Development Agreement described a number of items
which were to be accomplished by SDI, as well as setting forth
the permitted uses for Lots 1, 2, and 3. Lot 3 has been
developed with the SDI facility while Lots 1 and 2 have been
graded, but remain undeveloped. With respect to the allowable
uses for Lots 1 and 2, Section 6.k. of the Development Agreement
states:
CC ATTACHMENT 2
S: \Community Development \DEV PMTS \C P D \Selleck- warehouse Appliance \cc agenda report.doc 000123
Honorable City Council
May 19, 2004
Page 2
Developer agrees that the maximum building square
footage for Lot 1 of VTTM No. 5004 shall not exceed
132,183 and for Lot 2 of VTTM No. 5004 shall not
exceed 37,200, and further agrees that the permitted
and conditionally permitted uses of Lots 1 and 2 shall
be limited to: (i) shopping centers; (ii) hotels and
motels; (iii) bars, taverns and night clubs but only
in conjunction with a hotel or motel use; (iv)
conference centers and convention centers; (v)
hospitals;_ (vi) retail pharmacies fog prescription
pharmaceutical only; (vii) restaurants, cafes and
cafeterias; (viii) retail trades, only within a
building; and (ix) motor vehicle, mobile home,
recreation vehicle and boat dealers and for Lot 2
only, automobile service station including a mini
mart.
Subsequently, SDI sold Lots 1 and 2. Dan Selleck is the current
owner. The Development Agreement will expire in 2006 at which
time, unless the Development Agreement is extended or modified,
the CPD zoning would govern the allowable land uses on Lots 1 `
and 2.
ANALYSIS
The question before the Council is whether the uses proposed by
Warehouse Discount Center fit within the parameters of Section
6.k. of the Development Agreement, are consistent with the
General Commercial land use and consistent with the CPD zoning.
The Moorpark General Plan Land Use Map shows the sites as
General Commercial. General Commercial is defined in the
General Plan as follows:
C -2 General Commercial (.25 FAR)
This designation provides fro commercial areas with a wide
range of retail and service activities (6 -20 acres).
Intended uses include community shopping centers, department
stores, restaurants, automotive uses, office and
professional services, and business support services. This
designation encourages the grouping of commercial outlets
into consolidated centers with direct access to major roads,
arterials and /or freeways.
000124
Honorable City Council
May 19, 2004
Page 3
The zoning for the site is Commercial Planned Development (CPD)
which is defined as follows:
The purpose of this zone is to encour�
coordinated, innovative and efficient
to provide areas for a wide range
business uses, including stores, shops
commodities or performing services
community.
age the development of
commercial sites and
of commercial retail
and offices supplying
for the surrounding
It is clear to staff that the distribution portion of the
proposed use is not within the parameters of the Development
Agreement due to the industrial nature of the distribution use
and the fact that the distribution portion of the use is the
predominant or primary use. Warehouse Discount Center is
proposing to centralize its appliance distribution, establish
its corporate headquarters and create a showroom at this site.
They would acquire the entire 8.1 acre site and place a 115,000
square foot building on the site, devoting approximately 8,000
square feet to office and 8,000 square feet to showroom as well
as a companion 25,500 square foot retail building for furniture
and /or associated uses. The warehousing use is typical of what
one would find in a light industrial area. The primary use is
distribution of appliances while sales and office use are
secondary. The applicant has indicated that the company
produces annual earnings of $56 million from all of its stores
in other communities. The annual retail sales from the proposed
showroom in Moorpark is estimated by Warehouse Discount Center
to be $8.5 million. Another way to look at the use issue is to
ask if this use would be acceptable in other CPD area such as
the Moorpark Marketplace, Moorpark Towne Center, Mission Bell
Plaza or any other of the many CPD zones in the City?
Development of the site with such a use would also be
architecturally challenging having to deal with the monolithic
nature of the warehouse building as well as the visibility of
the site. Loading docks would need to be screened; the mass of
the building disguised and the aesthetics of the site and
building would need to be of the highest quality due to its
prominent location above the freeway.
However, should it be the Council's desire to allow such a use
it would require an amendment to the Development Agreement, an
000125
Honorable City Council
May 19, 2004
Page 4
amendment to the General Plan text language for General
Commercial and /or an amendment in the Land Use Plan Map, and
possibly an amendment in the zoning for the site.
STAFF RECObMMWATION
Find that the distribution use is not within the uses of Section
6.k. of the Development Agreement and that the distribution use
is inconsistent with the General Commercial land use and the CPD
zone.
Attachments:
1. Proposed Front Elevation of Warehouse
2. Proposed Site Plan with Retail
3. Proposed Site Plan with Retail and Restaurant
4. Affordable /Housing Community Development Agenda Report
000126
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AFFORDABLE HOUSING
COMMUNITY DEVELOPMENT COMMITTEE
AGENDA REPORT
TO: Affordable Housing /Community Development Committee
FROM: Barry K. Hogan, Community Development Director
DATE: April 14, 2004 (AH /CDC Meeting of 4/21/04)
SUBJECT: Consider and Discuss Development Potential for the
Property Located on the North and South Sides of White
Sage Road, East of SR 23, Dan Selleck, owner.
BACKGROUND
On August 28, 1996, the City Council adopted Ordinance 220
approving a Development Agreement with Special Devices, Inc.
(SDI). The Development Agreement described a number of items
which were to be accomplished by SDI, as well as, setting forth
the permitted uses for Lots 1, 2, and 3. Lot 3 has been
developed with SDI facility while Lots 1 and 2 have been graded,
but remain undeveloped. With respect to the allowable uses for
Lots 1 and 2, Section 6.k. of the Development Agreement states:
Developer agrees that the maximum building square
footage for Lot 1 of VTTM No. 5004 shall not exceed
132,183 and for Lot 2 of VTTM No. 5004 shall not
exceed 37,200, and further agrees that the permitted
and conditionally permitted uses of Lots 1 and 2 shall
be limited to: (i) shopping centers; (ii) hotels and
motels; (iii) bars, taverns and night clubs but only
in conjunction with a hotel or motel use; (iv)
conference centers and convention centers; (v)
hospitals; (vi) retail pharmacies for prescription
pharmaceutical only; (vii) restaurants, cafes and
cafeterias; (viii) retail trades, only within a
building; and (ix) motor vehicle, mobile home,
recreation vehicle and boat dealers and for Lot 2
S: \Community Development \DEV PMTS \C P D\Selleck- Warehouse Appliance \Att 4.doc
000130
Affordable Housing /Community Development Committee
April 21, 2004
Page 2
only, automobile service station including a mini
mart.
Subsequently, SDI sold Lots 1 and 2. Dan Selleck is the current
owner. The Development Agreement will expire in 2006 at which
time, unless the Development Agreement is extended or modified,
the CPD zoning would govern the allowable land uses on Lots 1
and 2.
DISCUSSION
Existing Site Conditions:
Lot 1 is approximately 8.1 acres, topographically at
approximately the same level as SR 23 and has excellent
visibility from SR 23. It is also prominently visible from a
great portion of the City. Lot 2 is approximately 2.4 acres and
is adjacent to the New Los Angeles Avenue off ramp and has
limited visibility from SR 23. Both sites have been previously
graded.
GENERAL PLAN /ZONING
Direction
General Plan
Zoning
Land Use
Commercial
Site
General Commercial
Planned
Graded and
Development
undeveloped
-- ._.... ----- ............. - - -
__.__..._--__ _..._._......_..--- .___..._.._. .._.
(CPD)
North
Open Space
Open Space
Arroyo Simi
(OS)
--._
Open Space
...._._..... ...... ----- ....__..
Open Space and
(OS) and
Open Space and
South
Manufacturing
Limited
Special Devices,
Industrial
Inc.
(M -2)
Open Space
Arroyo Simi and
East
Open Space
(OS)
open space
Open Space and
_
Open Space
_ _
Open space and —
West
(OS) and
Freeway
SR 23
Freeway
Any change to the land use would require an amendment to the
Development Agreement, potential amendment to the zoning,
potential amendment to the General Plan and environmental
documentation.
000131.
Affordable Housing /Community Development Committee
April 21, 2004
Page 3
STAFF RECOIMNDATION
Direct staff as appropriate.
Attachments:
1. Aerial Photo
000132