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HomeMy WebLinkAboutAGENDA REPORT 2020 0715 CCSA REG ITEM 08CCITY OF MOORPARK, 
CALIFORNIA City Council Meeting of July 15, 2020 ACTION Approved Staff Recommendation, Including Adoption of Resolution No. 2020- 3936. (Roll Call Vote: Unanimous) BY B.Garza. C. Consider a Resolution for Amendment No. 3 to SP 1995-01 (Downtown Specific Plan) for Text Amendments pertaining to Mixed-Use Regulations within the Specific Plan – Downtown Overlay Zone. Staff Recommendation: 1) Open the public hearing, accept public testimony and close the public hearing; and 2) Adopt Resolution No. 2020-3936 Amending SP 1995-01 (Downtown Specific Plan). (ROLL CALL VOTE REQUIRED) (Staff: Karen Vaughn) Item: 8.C. MOORPARK CITY COUNCIL AGENDA REPORT TO: Honorable City Council FROM: Karen Vaughn, Community Development Director DATE: 07/15/2020 Regular Meeting SUBJECT: Consider a Resolution for Amendment No. 3 to SP 1995-01 (Downtown Specific Plan) for Text Amendments pertaining to Mixed- Use Regulations within the Specific Plan – Downtown Overlay Zone SUMMARY In 1998, the City Council adopted Ordinance No. 247 establishing the Specific Plan - Downtown (SP-D) Overlay Zone (Zoning Code Chapter 17.72) and Resolution No. 1998-1515 establishing the Downtown Specific Plan (DTSP). The DTSP sets forth a vision for the downtown area which identifies certain commercial corridors, residential areas, and mixed-uses along High Street. Section 2.2.5 Old Town Commercial (C-OT) of the DTSP includes uses and development standards relating to mixed-use development within this district. On May 15, 2019, the City Council held a workshop to provide feedback on a downtown mixed-use development proposal (High Street Station – The Daly Group) and also to provide general policy guidance for downtown mixed-uses. At that meeting, the City Council affirmed the following policy statements:  Design flexibility is appropriate for mixed-use projects.  Higher residential densities are appropriate when located within transit-oriented development (TOD) hubs.  Flexible parking standards for mixed-use projects located within TOD hubs are appropriate.  Mixed-Use Overlay Zone is the best tool to implement the vision. In the time since the May 15 workshop, the City has elected to move forward with a comprehensive update to the General Plan, which will look at land uses, economic development and redevelopment of underperforming commercial properties throughout Item: 8.C. 148 Honorable City Council 07/15/2020 Regular Meeting Page 2 the city. Preparation of mixed-use tools, including mixed-use overlay zones that can be adapted citywide will roll into that effort. On June 3, 2020, the City Council adopted Resolution No. 2020-3915 to initiate amendments to the DTSP and directing the Planning Commission to hold a public hearing to consider and provide a recommendation on such amendments. On June 23, 2020, the Planning Commission held a public hearing and voted unanimously (3-0, Haverstock absent, DiCecco recused) to forward a recommendation to the City Council to approve the proposed text amendments. BACKGROUND Chapter 17.72 of the City’s zoning code establishes the SP-D Overlay Zone. Section 17.72.020 General Provisions states that “All provisions of the downtown specific plan shall apply to the development and use of the properties within the downtown specific plan overlay zone. Those provisions shall be supplemental to the regulations of the underlying zone. In such cases where the specific plan development standards and the standards for the underlying zone conflict, the specific plan development standards shall apply.” Thus, the DTSP serves to supplement and add to the regulations of the underlying zone. The DTSP contains goals and a core vision for the revitalization of downtown to make it an attractive and thriving place for the enjoyment and benefit of everyone. Within Section 1.1 it states, “Revitalization and image building of Old Town Moorpark will contribute to a memorable City identity, welcoming residents and visitors to downtown Moorpark.” In conjunction with the development of the DTSP, the City performed an analysis to determine whether mixed uses (commercial plus residential) would be appropriate in downtown. The study consisted of a survey of City/Statewide programs to determine how mixed-use projects succeed or fail in downtown settings. The results, outlined in DTSP Section 1.4.7 (Table 3), determined that mixed-use development would be appropriate in the Commercial Old Town zone along the High Street corridor. The analysis further found that “Increasing residential and office activities in downtown can foster a healthy, diverse environment.” Based on this study and determination, mixed- use development and associated regulations were built into Section 2 of the DTSP. Since its inception, the DTSP has set the vision, pathway and regulations for mixed-use development in downtown. Section 2.2.5 Old Town Commercial (C-OT) sets forth the various development regulations for that district, and in particular for the development of mixed-uses along High Street. The DTSP is the regulatory document that allows and enables mixed-uses within downtown. By providing for the uses themselves and the specific development-related 149 Honorable City Council 07/15/2020 Regular Meeting Page 3 regulations, the DTSP creates the framework for both new mixed-use development as well as rehabilitation and redevelopment involving existing structures. The purpose of the following proposed text amendments is to augment the existing mixed-use regulations within the DTSP with the City Council’s 2019 policy guidance. DISCUSSION Section 2.2.5.A outlines the site development standards for development within the C-OT district. These include: 1. Land uses and permitted uses; 2. Development requirements; 3. Parking and signage; 4. Building maintenance and renovation; and 5. Mixed use development. It is this section that is the subject of the proposed text amendments. (The complete text of the proposed amendments is included in legislative format within Attachment A.) As noted above, the DTSP was originally written in the late 1990’s. While planning development theories have changed in the intervening two decades, the City had the foresight to allow for mixed-uses within downtown in order to attract new businesses, downtown living opportunities, and create a vibrant street life. Twenty years later, while the vision holds true, some of the development regulations need updating in order to accommodate current-day building standards, laws, environmental policies, and financial markets. On May 15, 2019, the City Council held a study session and affirmed several policy statements pertaining to mixed-use development in downtown. Those statements are:  Design flexibility is appropriate for mixed-use projects.  Higher residential densities are appropriate when located within transit-oriented development (TOD) hubs.  Flexible parking standards for mixed-use projects located within TOD hubs are appropriate. The analysis provided below outlines the reasoning for the proposed text amendments pertaining to mixed-use design, density and parking. ANALYSIS The proposed DTSP text amendments serve to clarify and update the regulations pertaining to mixed-use development in downtown. The amendments do not introduce any new uses nor design regulations that would alter the intent of the original DTSP 150 Honorable City Council 07/15/2020 Regular Meeting Page 4 vision. The amendments augment the existing regulations with updated policy guidance as provided by the City Council in May 2019 related to mixed-use design, density and parking. Design The DTSP development standards for mixed-use projects, as outlined in Section 2.2.5.5, require that the primary use be commercial and the residential use be secondary to the commercial use. The development standards further require that mixed uses be developed within the same building and that the entire ground floor be used exclusively for retail/commercial uses. This does not allow for any part of a residential dwelling unit to be located on the ground floor. The general idea of ensuring that the ground floor looks, acts, and feels like commercial space from the public vantage point is correct from an urban planning perspective. Public life occurs at the ground level; therefore, the ground floor of a mixed-use building should provide interest and an active interface with the public realm. It should entice people to explore and engage, and should reinforce a sense of place within downtown. There are, however, practical reasons to allow ground floor residential uses within a mixed-use building. The goal is to design them in a way that they are inconspicuous and do not interrupt the cadence of the commercial storefronts along the corridor. In terms of primary vs. secondary uses, there is no standard ratio for mixed-use development. The commercial and residential uses both act as primary uses. The percentage of one use to the other is generally determined by the number of floors within the building. The ground floor acts as the activity center and the upper floors are purely residential. The key is to ensure that the project is designed in a way that the ground floor commercial uses are more prominent than the residential uses. At the pedestrian level, the building should appear to be a commercial building. Second, the residential portions of mixed-use projects generally subsidize the commercial components. Residential development is a lower risk investment as housing is always in demand and financing is readily available. Also, residential vacancy periods tend to be shorter and there are far more units to cover the occasional vacancies. Commercial development, on the other hand, is a higher risk investment because it is market-driven and vacancies can be much longer in duration. Thus, allowing for a higher percentage of floor area to be dedicated to residential uses while maintaining the active commercial uses along the pedestrian frontage makes sense. Third, ground floor residential units can be adapted to be accessible units. Having ground floor residential units removes the building code requirement for elevators within the building. This reduces construction and operating costs for the project. It also helps from a design standpoint as no elevator shafts would project above the roofline of the building. 151 Honorable City Council 07/15/2020 Regular Meeting Page 5 Section 2.2.5.5 of the DTSP states, “The intent of allowing for mixed-use projects in the old Town Commercial District is to provide continuous frontage of retail shops and commercial business establishments at the street level, while providing opportunities for downtown residential living.” The intent can be achieved through good design, such as tucking ground floor residential units behind commercial liner shops that front onto High Street. This would preserve the pattern of ground floor active establishments as viewed and experienced from the public realm. The vision of an active mixed-use corridor along High Street can be achieved while providing flexibility in design. As noted above, the key is to take a thoughtful approach toward the placement of active commercial uses along the public frontage. On May 15, 2019, the City Council affirmed that design flexibility is appropriate for mixed-use projects. Based on the Council policy direction, the following text amendments pertaining to design flexibility are proposed: 2.2.5.A.5. A mixed commercial-residential use project is a project in which commercial uses will occupy all or a portion of the entire street level of a building or group of buildings, and residential uses will primarily occupy portions or all of the upper floors of that the same building(s). Residential uses may be allowed on the street level of a mixed-use building so long as they are designed in a way to be tucked behind commercial uses or otherwise hidden from the street frontage. The intent of allowing for mixed-use projects in the Old Town Commercial District is to provide for a continuous and activated public/private interface frontage of retail shops and commercial business establishments at the street level, while providing opportunities for downtown residential living behind or above the commercial uses. The following requirements shall apply to these mixed-use projects: a. The primary use of the street level of a mixed-use building shall be commercial. and the Residential uses on the street level of a mixed-use building shall be secondary to and located behind the commercial use. b. The street-facing frontage level of the commercial structure a mixed-use building shall be utilized for commercial uses and not for parking. c. The entire street-facing portion of the ground floor or street level, with the exception of circulation access, shall be used exclusively for retail and other active commercial uses 1. and no Residential dwellings or portions thereof may shall be permitted to be located in whole or in part on the ground floor so long as they are located behind commercial storefronts or otherwise designed to be inconspicuous from the street frontage. 1 Active commercial uses are generally open to the public, generate a high volume of customer foot traffic, provide window displays to promote views into the business, and seek goods that are typically consumed onsite, carried away by customers or provide services of a person or business nature. 152 Honorable City Council 07/15/2020 Regular Meeting Page 6 Residential Density The need for housing in the region and the state has hit a crisis level. With the passage of SB330, the state declared a Statewide Housing Emergency through January 1, 2025. As with all jurisdictions in California, the City of Moorpark has a regional housing needs allocation (RHNA) set by the state. Moorpark’s RHNA for the current cycle (2014-2021) is 1,164 housing units spread across various affordability levels. The upcoming cycle (2021-2029) will see an additional allocation of 1,288 housing units for Moorpark. Removing barriers to the construction of new housing units is key to fulfilling our requirements. As noted above, a City-initiated analysis determined that mixed-use development would be appropriate in the Commercial Old Town zone, and the DTSP was written to allow mixed-use development. This allowance aligns with current state and regional initiatives to place high-density residential uses near services and transit. Transit- oriented development (TOD) designations are intended to focus residential development near public transportation in order to reduce traffic congestion and help achieve greenhouse gas (GHG) emissions targets. The Moorpark Metrolink Station is defined as a High Quality Transit Area (HQTA) by the Southern California Association of Governments (SCAG) for purposes of regional transportation planning as well as RHNA housing unit allocations. Generally, from an urban planning perspective, the highest residential densities should occur in the city core and near transit. These are areas that tend to provide the best access to services including shopping, dining, entertainment, and public transportation. Allowing higher densities within a downtown setting also helps to reduce development pressure in residential areas away from the city center. Given the proximity of High Street to the Metrolink Station, the area can support transit-oriented development which would create compact, walkable, pedestrian-oriented development centered on high quality public transportation. On May 15, 2019, the City Council affirmed that higher residential densities can be supported within mixed-use projects located within TOD hubs. Based on the Council policy direction, the following language pertaining to density is proposed to be added to Section 2.2.5.A.5 Mixed-Use Development: Given the close proximity to public transit and local services, residential densities associated with mixed-use projects in downtown may be higher than in other parts of the City. Parking Parking standards are contained in both the DTSP and the zoning ordinance. In reference to mixed-use development, Section 2.2.5.A.5.d of the DTSP states, “All of the parking spaces required by the residential use shall be provided on-site to serve the 153 Honorable City Council 07/15/2020 Regular Meeting Page 7 residential units and shall be specifically designated and reserved for the exclusive use of the residents.” The DTSP and the zoning ordinance provide several parking incentives for High Street, including a 50% reduction in required commercial parking, the reduction of parking requirements for eating and drinking establishments, and the allowance of counting on-street parking spaces toward the commercial parking requirements. Because residential parking tends to be more long-term (overnight and weekends), staff agrees with the DTSP requirement to accommodate all residential parking on-site and that it be designated and reserved for residents. No amendments are proposed with regards to residential tenant parking requirements. Guest and commercial parking tend to be short-term and transient. These types of short-term parking needs can appropriately occur in the public realm if there is ample public parking options in the vicinity. In late 2019, the City contracted with Walker Consultants to conduct a Downtown Parking Study. On January 15, 2020, the Council received the report which detailed the existing inventory of downtown public parking spaces, the peak utilization and capacity, and recommendations on how best to leverage these assets. The downtown parking study acts as a baseline measurement to which future utilization can be measured. In general, the report found: • There are a total of 914 public parking spaces located downtown (798 excluding the street parking spaces on Charles Street.); • Peak downtown parking utilization occurs on weekdays, at which time 40% of downtown public parking spaces are used; • Utilization of downtown parking spaces during a theater event peaked at 29% usage (Sunday matinee); • The majority (77%) of cars parked downtown stayed for one to two hours (short- term usage); • Industry standard target utilization rate is 85%; • There is an abundance of available public parking within downtown; • Available downtown parking is significantly underutilized. As noted above, the DTSP and zoning code already contain parking incentives for commercial uses in downtown. There is, however, no specific text regarding guest parking requirements for mixed-use development. Based on the City Council policy direction for flexible parking standards within TOD hubs and the results of the downtown parking study, the following text amendment pertaining to guest parking is proposed: 2.2.5.A.5.d. All off-street parking spaces required by the residential use shall be provided on-site to serve the residential units and shall be specifically designated and reserved for the exclusive use of the residents. Residential guest parking requirements may be modified or waived when adequate public parking capacity is found to exist in the vicinity of the project site. 154 Honorable City Council 07/15/2020 Regular Meeting Page 8 GENERAL PLAN CONSISTENCY The General Plan Land Use Designation for downtown is “Downtown Specific Plan (SP- D)”. This designation is intended to create a viable central business core, and establishes a variety of uses that address community needs including commercial, civic, visitor and residential uses. The proposed DTSP text amendments augment existing development standards pertaining to mixed-use development, and do not introduce any new uses or design standards that would be inconsistent with the policies or provisions of the General Plan. The proposed text amendments are consistent with and would serve to implement the following General Plan goals and policies: Land Use Goal 6: Encourage the use of Specific Plans in the undeveloped areas of the community. Policy 6.1: Specific Plans shall be utilized as a tool for implementation of General Plan policies and priorities for larger land areas. The intent of each Specific Plan is to achieve a long-term cohesive development program which is responsive to the physical and economic opportunities and constraints of each individual Specific Plan area. Land Use Goal 9: Promote the revitalization of the downtown commercial core (Moorpark Avenue area, Walnut Street, Bard Street, Magnolia Avenue, and High Street). Policy 9.1: The visual character of the downtown commercial core shall be strengthened in order to attract a variety of commercial uses and to promote the economic viability of downtown Moorpark. Land Use Goal 13: Achieve a well-balanced and diversified economy within the City which provides a variety of economic and employment opportunities. Policy 13.3: The City shall encourage the coordinated revitalization of obsolete or declining commercial areas, particularly focusing on the downtown area. Housing Goal 2: Provide residential sites through land use, zoning and specific plan designations to provide a range of housing opportunities commensurate with the City’s needs. Policy 2.4: Promote and encourage mixed-use residential and commercial uses where appropriate as a means to facilitate development. Housing Goal 4: Where appropriate, mitigate unnecessary governmental constraints to the maintenance, improvement, and development of housing. 155 Honorable City Council 07/15/2020 Regular Meeting Page 9 Policy 4.4: Support infill development at suitable locations and provide, where appropriate, incentives to facilitate such development. ENVIRONMENTAL DETERMINATION In accordance with the City’s environmental review procedures adopted by resolution, the Community Development Director determines the level of review necessary for a project to comply with the California Environmental Quality Act (CEQA). Some projects may be exempt from review based upon a specific category listed in CEQA. Other projects may be exempt under a general rule that environmental review is not necessary where it can be determined that there would be no possibility of significant effect upon the environment. A project which does not qualify for an exemption requires the preparation of an Initial Study to assess the level of potential environmental impacts. Pursuant to the California Environmental Quality Act (CEQA), the Community Development Director has determined this project to be exempt in accordance with Section 15061(b)(3) of the California Code of Regulations (CEQA Guidelines). The proposed text amendments to the Downtown Specific Plan do not in and of themselves have the potential for causing significant effects to the environment. NOTICING Public hearing notices for the proposed DTSP text amendments were mailed to all property owners and tenants within the C-OT zoning district as well as a 1,000-foot radius. A newspaper ad was published in the Ventura County Star 10 days in advance of the public hearing. Notice of the public hearing was also published on the City’s website. FISCAL IMPACT None. COUNCIL GOAL COMPLIANCE This action would help to implement City Council Strategy 1, Goal 1.3 “Evaluate and deploy tools for adaptive reuse of vacant and existing underutilized sites with property owners.” 156 Honorable City Council 07/15/2020 Regular Meeting Page 10 STAFF RECOMMENDATION (ROLL CALL VOTE REQUIRED) 1. Open the public hearing, accept public testimony and close the public hearing; and 2. Adopt Resolution No. 2020-____ Amending SP 1995-01 (Downtown Specific Plan) Attachment 1: Draft Resolution No. 2020-____ with Exhibit A Attachment 2: Planning Commission Resolution No. 2020-652 Attachment 3: Comment Letter, dated June 22, 2020 157 RESOLUTION NO. 2020-____ A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF MOORPARK, CALIFORNIA, APPROVING AMENDMENT NO. 3 TO SPECIFIC PLAN NO. 1995-01 FOR TEXT AMENDMENTS PERTAINING TO MIXED-USE DEVELOPMENT WITHIN THE DOWNTOWN SPECIFIC PLAN OVERLAY ZONE WHEREAS, on October 7, 1998, the City Council adopted Resolution No. 1998- 1515, approving Specific Plan No. 1995-01 (Downtown Specific Plan); and WHEREAS, on October 21, 1998, the City Council adopted Ordinance No. 247, establishing the Specific Plan – Downtown Overlay (SP-D) Zone; and WHEREAS, on November 1, 2006, the City Council adopted Resolution No. 2006-2535, approving Amendment No. 1 to Specific Plan No. 1995-01 pertaining to development and architectural styles; and WHEREAS, on September 4, 2013, the City Council adopted Resolution No. 2013-3213, approving Amendment No. 2 to SP No. 1995-01 pertaining to parcels located at the corner of Everett Street and Moorpark Avenue; and WHEREAS, on May 15, 2019, the City Council held a study session and provided policy guidance to staff regarding the design, density and parking regulations for mixed-use development in downtown; and WHEREAS, on June 3, 2020, the City Council adopted Resolution No. 2020- 3915 to initiate amendments to the Downtown Specific Plan and directing the Planning Commission to hold a public hearing to consider and provide a recommendation on text amendments pertaining to mixed-use regulations; and WHEREAS, on June 23, 2020, the Planning Commission held a duly noticed public hearing to consider Amendment No. 3 to Specific Plan No. 1995-01 for text amendments pertaining to mixed-use development within the SP-D Overlay Zone; and WHEREAS, at its meeting of June 23, 2020, the Planning Commission considered the agenda report and any supplements thereto and written public comments; opened the public hearing and took and considered public testimony both for and against the proposal; and reached a decision on this matter upon a 3-0 vote (Haverstock absent, DiCecco recused) to forward a recommendation of approval to the City Council; and WHEREAS, on July 15, 2020, the City Council held a duly notice public hearing to consider Amendment No. 3 to Specific Plan No. 1995-01 for text amendments pertaining to mixed-use development within the SP-D Overlay Zone; and ATTACHMENT 1 158 Resolution No. 2020-____ Page 2 WHEREAS, at its meeting of July 15, 2020, the City Council considered the agenda report and any supplements thereto and written public comments; opened the public hearing and took and considered public testimony both for and against the proposal; and WHEREAS, the Community Development Director has determined that this project is exempt from the provisions of the California Environmental Quality Act (CEQA) by the general rule that CEQA only applies to projects that may have a significant effect on the environment. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF MOORPARK DOES HEREBY RESOLVE AS FOLLOWS: SECTION 1. The City Council concurs with the Community Development Director’s determination that this project is exempt from the provisions of CEQA by the general rule that CEQA only applies to projects that may have a significant effect on the environment. SECTION 2. The City Council finds that Amendment No. 3 to Specific Plan No. 1995-01 is consistent with the City of Moorpark General Plan. SECTION 3. The City Council approves Amendment No. 3 to Specific Plan No. 1995-01 in order to augment the regulations pertaining to mixed-use development, as recommended by staff and shown in attached Exhibit A. SECTION 4. This resolution shall become effective upon adoption. SECTION 5. The City Clerk shall certify to the adoption of this resolution and shall cause a certified resolution to be filed in the book of original resolutions. PASSED AND ADOPTED this 15th day of July, 2020. Janice S. Parvin, Mayor Ky Spangler, City Clerk Attachment: Exhibit A – Amendment No. 3 to Specific Plan No. 1995-01 (Downtown Specific Plan) 159 Exhibit A 2.2.5 Old Town Commercial (C-OT) A. Site Development Standards The table below is to be used as a reference tool. For more specific requirements please refer to the particular subsections below. 1. Land Use and Permitted Uses Uses in the Old Town Commercial designation shall meet the requirements for the C-OT designation as shown in Chapter 17.20 of the Moorpark Municipal Code along with the uses identified in Subsection 5 of this chapter below. 2. Development Requirements Development in the Old Town Commercial designation shall meet the requirements for the C-OT designation as shown in Chapter 17.24 and Chapter 17.36 of the Moorpark Municipal Code with the exception of building height which shall be 35 feet, maximum. Architectural elements such as towers, chimneys, and parapet walls may have a maximum height of forty (40) feet. Parapets used as architectural accents may exceed the maximum height when approved by the Community Development Director. Additional requirements pertaining to Mixed-Use development are included in Subsection 5 of this chapter below. 3. Parking and Signage Parking and signage shall meet the requirements of Chapter 17.32 and Chapter 17.40, respectively, of the Moorpark Municipal Code, unless otherwise modified by this chapter. 4. Building Maintenance and Renovation Quality maintenance of existing buildings and parcels combined with progress in meeting design goals for this land use designation are encouraged. To this end, the maintenance guidelines and incentives Site Development Standard Zoning Ordinance Reference Land Use and Permitted Uses See Chapter 17.20 Development Requirements See Chapter 17.24 and 17.36 Fences and Walls See Chapter 17.24 Parking and Signage See Chapter 17.32 and 17.40 160 outlined in Section 2.3.1 to 2.3.3 of this Specific Plan apply to the Old Town Commercial designation. 5. Mixed -Use Development A mixed commercial-residential use project is a project in which commercial uses will occupy all or a portion of the entire street level of a building or group of buildings, and residential uses will primarily occupy portions or all of the upper floors of that the same building(s). Residential uses may be allowed on the street level of a mixed-use building so long as they are designed in a way to be tucked behind commercial uses or otherwise hidden from the street frontage. The intent of allowing for mixed mixed-use projects in the Old Town Commercial District is to provide for a continuous and activated public/private interfacefrontage of retail shops and commercial business establishments at the street level, while providing opportunities for downtown residential living behind or above the commercial uses. Given the close proximity to public transit and local services, residential densities associated with mixed-use projects in downtown may be higher than in other parts of the City. The following requirements shall apply to these mixed -use projects: a. The primary use of the street level of a mixed-use building shall be commercial. and the residential Residential uses on the street level of a mixed-use building shall be secondary to and located behind the commercial use of the property. b. The street-facing frontage level of a the commercial structuremixed-use building shall be utilized for commercial uses and not for parking. c. The entire street-facing portion of the ground floor or street level, with the exception of circulation access, shall be used exclusively for retail and other active commercial uses1. and no dResidential dwellings or portions thereof shall may be permitted to be located in whole or in part on the ground floor or street levelso long as they are located behind commercial storefronts or otherwise designed to be inconspicuous from the street frontage. d. All off-street parking spaces required by the residential use shall be provided on-site to serve the residential units and shall be specifically designated and reserved for the exclusive use of the residents. Residential guest parking requirements may be modified or 1 Active commercial uses are generally open to the public, generate a high volume of customer foot traffic, provide window displays to promote views into the business, and sell goods that are typically consumed onsite, carried away by customers or provide services of a personal or business nature. 161 waived when adequate public parking capacity is found to exist in the vicinity of the project site. e. Where a project consists of more than ten (10) units, the project shall be clustered in two or more buildings to reduce building mass and create architectural interest. f. Wall planes for buildings shall have design articulation consistent with the design standards set for all buildings in the Old Town Commercial district. g. Direct access for parking areas and driveways is discouraged along High Street. Access for parking and driveways shall be taken from adjoining alleys or alternative streets when available. If a parking area or driveway cannot be designed to avoid access from High Street the driveway and parking area shall not occupy more than 40% of the lot frontage, leaving the majority of the lot width for commercial store front development. h. Driveway access to parking shall be taken as close to a side lot line as is feasible, rather than from the middle of the lot frontage. Driveway alignment with existing intersections is encouraged, where feasible. i. Additions to existing buildings shall be designed to be integrated with the existing building when the Community Development Director has determined that the existing design is in conformance with the Downtown Specific Plan. The new addition should match the original in terms of scale, architectural details, window and door styles and openings, roofline, materials, color and other aspects of design. j. Where a large addition to an existing structure is developed, the entire building should be renovated to achieve a single, coordinated appearance. 162 ATTACHMENT 2 163 164 165 166 167 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 dw@aenv.org June 22, 2020 Karen Vaughn, Community Development Director City of Moorpark 799 Moorpark Ave. Moorpark, CA 93021 Via U.S. Mail and email to KVaughn@MoorparkCA.gov re: Amendment No. 3 to SP 1995-01, to be considered at June 23, 2020 Planning Committee meeting Dear Ms. Vaughn: I write to comment on the City of Moorpark’s proposal to amend the Downtown Specific Plan, as outlined in your Moorpark Planning Commission Agenda Report (Staff Report) for that meeting. I comment on behalf of our client, the Committee to Preserve Historic High Street. The Specific Plan, as amended, does not comply with Gov. Code § 65451(a). Gov. Code § 65451(a) requires a specific plan to include text and diagrams specifying, in detail, “the distribution, location, and extent of uses of land, including open space, within the area covered by the plan.” The Downtown Specific Plan, as amended (DTSP), comes closest to satisfying this requirement via the table in section 2.2.5.A, which directs the reader to “See Chapter 17.20” for “Land Use and Permitted Uses.” But Moorpark Municipal Code (MMC) § 17.20 contains no information on land uses permitted in the Downtown Specific Plan Overlay Zone (SP-D). Neither does LAMC Chapter 17.72, which is devoted to the SP-D. And the information on permitted uses is not to be found in the General Plan Land Use Element section on the Downtown Specific Plan. In short, the Specific Plan, as amended, violates Gov. Code § 65451(a), because it does not specify allowed land uses in the area covered by the plan. The proposed density provision is so vague that it violates the law. A land use ordinance cannot be so vague or uncertain that a person of common intelligence and understanding must guess at its meaning. (See Zubarau v. City of Palmdale (2011) 192 Cal.App.4th 289, 311.) The City’s proposed addition to DTSP § 2.2.5.A.5, states that “…residential densities associated with mixed-use projects in downtown may be Advocates for the Environment A non-profit public-interest law firm and environmental advocacy organization ATTACHMENT 3 168 City of Moorpark Page 2 Proposed amendments to Downtown Specific Plan June 22, 2020 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 dw@aenv.org higher than in other part of the City.” This provision gives unlimited discretion to the City to increase densities in the DTSP area, and violates the law through its vagueness, because a reasonable person cannot use it to determine the maximum allowable density. The CEQA common-sense exemption does not apply to the SP amendments. The Staff Report states, on page 9, that the Community Development Director has determined this [DTSP amendment] project to be exempt in in accordance with Section 15061(b)(3) of the CEQA Guidelines. That Guidelines section contains the “common sense exemption,” which applies to projects “where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment.” That is not the case here. The density provision that the City proposes to add to DTSP § 2.2.5.A.5 allows effectively unlimited density in the DTSP area. Projects with extremely high densities would have significant environmental impacts, which would need to be analyzed in an Environmental Impact Report before the City approves them. The common-sense exemption does not apply to the proposed DTSP amendments; they are subject to CEQA. The City must do an initial study, followed by a Mitigated Negative Declaration or EIR before approving the amendments. Conclusion To comply with the law, the City should revise the proposed amendments to the Downtown Specific Plan to, and perhaps revise the zoning for that area, to correct the defects cited above. The City must also perform an environmental review before adopting the proposed amendments. Sincerely, Dean Wallraff, Attorney at Law 169