HomeMy WebLinkAboutAGENDA REPORT 1986 0218 CC REG ITEM 10A2 LAW OFFICES
BuxKE, WILLIAMS & SOBENSEN
ONE WILSHIRE BUILDING
MARTIN J. BURKE' CHERYL J. KANE 524 SOUTH GRAND AVENUE, )ITN FLOOR TELEPHONE: (213) 623-1900
GEORGE W TACKABURY' RAYMOND J. FUENTES LOSS ANGELES, CALIFORNIA 90017 TELECOPIER: (213) 623-8297
JAMES T. BRADSHAW,JR.- RONALD E. LEVINE
MARK C. ALLEN,JR.- VIRGINIA R. PESOLA TELEX: 671-1271
RICHARD R. TERZIAN' S. PAUL SRUGUERA
CABLE ADDRESS
MARTIN L. BURKE' MICHELE R. VADON BWSLA UW
CARL K. NEWTON' B. DEREK STRAATSMA
J. ROBERT FLANDRICK' NEIL C. EVANS
EDWARD M. FOX SCOTT F FIELD
DENNIS P. BURKE' CRISTINA L. SIERRA January 27 , 1986
LELAND C. DOLLEY' JOHN W. BELSHER
COLIN LENNARD' BENJAMIN S. KAUFMAN HARRY 12 C. WILLIAMS
(1912-1967)
BRIAN J. .EERY* MICHAEL J. LONG Reissued February 3/ 1986
THOMAS J. FEELEV' ELLEN M. BENDER ROYAL M. SORENSEN
NEIL F. YEAGER* GREGORY A. DOCIMO (1914-1983)
BRIAN A. PIERIK' CYNTHIA D. GOENA
KATHERINE E. STONE' KEVIN S. MILLS
CHARLES M. CALDEROW DEBORAH J. FOX
THOMAS H. DOWNEY CAROL A. SCHWAB OF COUNSEL
PETER M. THORSON MARC G. PENSO DWIGHT A. NEWELL
HAROLD A. BRIDGES LISA E. KRANITZ GEORGE W. WAKEFIELD
'PROFESSIONAL CORPORATION
The Honorable James Weak and Members
of the City Council
City of Moorpark
799 Moorpark Avenue
Moorpark, California 93021
RE: Response To Questions Relative To General Plan
Amendments and Zone Changes
Dear Mr. Mayor and Council Members :
At your meeting of January 20, 1986, you requested
that I respond to a list of fourteen ( 14) questions
submitted by John Galloway, a resident of Moorpark . The
questions and my responses are set forth below. The
responses are made without reference to any specific request
relative to amending the General Plan for , or changing the
zone of, Gisler Field. Any change in the residential or
commercial designation must stand independent of the other ;
that is, each must be reasonable under the circumstances .
Question 1A.
Can the city change Gisler Field G.P. Land Use and
Zoning in response to residents ' petition and findings at a
public hearing?
Response
No. State law requires that before a city council
can take action on a general plan amendment or zone change,
the matter must be referred to the planning commission for a
public hearing and recommendation, which recommendation is
then considered by the city council at a public hearing .
(Gov' t Code § 65350, et sec. . and § 65853, et seq. ) Since
general plan amendments and zone changes are projects under
The Honorable James Weak and Members
of the City Council
January 27, 1986
Page 2
CEQA, the environmental review process must accompany this
planning process.
Question 1B.
What findings would be required?
Response
General plan amendments and zone changes are
legislative acts; as such, no findings are required under
state planning law. However , general plan amendments must
be reasonable and internally consistent with all other
provisions of the general plan and zone changes must be
consistent with the general plan.
Question 2.
Is the City Council legally required to take direct
action for or against the public hearing request? ( In what
time-frame?)
Response
No. Under state law, the initiation of general
plan amendments and zone changes is at the discretion of the
City. The City may permit interested persons to make
application for an amendment or change. (Gov' t Code
§ 65357 . ) A request for a public hearing by citizens at
large does not come within the procedures that have been
adopted by the City.
Question 3.
Might it be impeachable for the City Council to
ignore the request with no action?
Response
No. Impeachment is for misconduct in office. As
stated above in answer to question 2, the City Council has
no legal obligation to hold the requested public hearing.
Furthermore, in California, impeachment is reserved for
removal of state officers and judges . (Calif . Con. Art . IV,
§ 18. )
Question 4.
True or false: "The city has discretionary powers to
adjust the General Plan and Zoning on parcels within city
limits toward higher or lower valued uses. "
Response
True. However , the exercise of discretion must be
reasonable in objective and not arbitrary or confiscatory
The Honorable James Weak and Members
of the City Council
January 27, 1986
Page 3
in operation; nor may the exercise of discretion deprive a
property owner of substantially all reasonable use of his
property.
Question 5.
If it can be shown that residents ' request balances
over the entire parcel to result in NO NET LOSS to the
property owner, would any other consideration preclude the
city from making such a change at this time?
Response
Yes they could. What those considerations might be
would depend, among other things, upon the information
uncovered by staff in the preparation of its analysis and
report and the evidence that was presented through the
public hearing process . See also the response to questions
8 and 10 below.
Question 6.
What would the answer to #5 be if there were some
diminution of value?
Response
The same. Diminution of value by itself does not
make a change of zone unreasonable. However, the courts may
invalidate the change on other grounds. See for example
Arnel Development Co. v. City of Costa Mesa discussed in
response to question 10 below.
Question 7 .
What magnitude of lower value would define the
threshold of legally acceptable changes in property values?
Response
The courts do not proclaim objective criteria
( i .e. , a 60% reduction in value is acceptable while a 61%
reduction in value is unacceptable) . Each case turns on its
own facts .
Question 8.
Is the timing of General Plan and Zone change
requests critical, or is the primary issue the change in
values regardless of timing?
Response
The timing of a general plan amendment or zone
change request is of no particular importance. What is
critical is that the correct procedures are followed and the
The Honorable James Weak and Members
of the City Council
January 27 , 1986
Page 4
actions are reasonable and not arbitrary or discrimina-
tory. In that regard, the timing of the amendment or change
may have a bearing upon the reasonableness of the action.
See for example Arnel Development Co. v. City of Costa Mesa
discussed in response to question 10 below.
Question 9A.
What role does motive play in determining validity
of such changes?
Response
The purpose or motive of officials in enacting a
general plan amendment or zone change is generally
irrelevant to any inquiry concerning the reasonableness of
the action. However , were the facts establish that the
amendment or change was enacted to discriminate against a
particular parcel of land, the court may consider or give
weight to evidence of the motives of the City Council . ( 66
Cal. Jur . 3d, Zoning and Other Land Controls, § 57)
Question 9B.
Does the law recognize a distinction between changes
proposed as response to a specific plan proposal and changes
proposed regardless of plan details?
Response
The question is ambiguous. "Specific plan" is a
term of art under state planning law--a specific plan is for
the "systematic implementation of the general plan" . (Gov' t
Code § 65450) If what is meant is a specific development
plan for the property, the answer is no. A general plan
amendment or zone change must stand on its own merits
without regard to any specific development proposal .
Question 10.
Please outline any forseeable existing basis on
which a court would reverse the action by the city to change
from VHD to MEDIUM DENSITY under circumstances where effort
was made to eliminate great loss in property value?
Response
The answer depends upon the facts as they exist at
the time of the general plan amendment or a zone change.
An example of a situation in which a court invalidated a
rezoning where diminution of value was not at issue is Arnel
Development Co. v. City of Costa Mesa ( 1981) 126 Cal . App. 3d
330. There plaintiff ' s property was rezoned to single
family residential within sixteen ( 16) months after having
The Honorable James Weak and Members
of the City Council
January 27, 1986
Page 5
been zoned for the express purpose of permitting moderate-
income, multi-family housing. The court held that the
rezoning was arbitrary, capricious and discriminatory,
because there had been no significant change in
circumstances or consideration of appropriate planning
criteria and because the sole purpose was to defeat the
proposed multi-family development . The court also held that
by completely precluding multi-family housing in the area,
the rezoning was not rationally related to the public
welfare, but was only related to the interest of adjoining
property owners and residents.
Question 11 .
As a general rule: In cases where zoning and G.P.
Land Uses are contested in the courts and the landowner
prevails, is not the prior zoning simply restored and no
award of damages occurs unless it was a clear-cut case of
abuse of power and intent?
Response
Under existing law, the general rule is
invalidation of the challenged general plan amendment or
zone change. However, this rule is presently under
reconsideration by the U.S. Supreme Court in a case arising
from a zoning action taken by the City of Davis,
California. Furthermore, even under current California law,
a landowner is entitled to monetary damages when the general
plan amendment or zone change is a prelude to public
acquisition or evades the requirement that land used by, or
for the benefit of, the public must be acquired by eminent
domain.
Question 12.
If McLeod, for instance, had purchased the land
when the northern portion was zoned for single family homes
and had themselves requested the VHD GPA from the county,
would that dillute any claim for financial loss by McLeod
for financial loss (sic) if the city chose to reverse the
designation? Does subsequent change in ownership
(hypothetical) restrict the city' s options?
Response
The history of the ownership of property or the
value of the property when originally purchased is of no
consequence. The test is whether the general plan amendment
or zone change is reasonable in light of the facts as they
exist at the time of the challenged action.
The Honorable James Weak and Members
of the City Council
January 27 , 1986
Page 6
Question 13 .
Would changes in surrounding ( impacting) Land Use
designations be valid factors in determining that the city
should initiate changes to de-intensify Land Use on parcels
nearby?
Response
Such changes could be, provided that they were
reflected in the general plan and zone designations of the
surrounding properties, those designations were reasonable
and, finally, those designations were part of a
comprehensive planning scheme which could not logically be
carried out without amending the general plan designation
and changing the zone of the subject property.
Question 14 .
What would be the legal interpretation of the
current status : DO WE OR DO WE NOT HAVE A PROJECT PROPOSAL
UNDER SUBMISSION AT THIS TIME?
Response
As I understand the facts, on August 13, 1984, a
planned development permit application, known as PD-1014,
was filed by Keith Macloud, as owner of the property, for a
316 unit apartment project . A draft EIR, parcel map and
development permit for the project were scheduled for a
Planning Commission hearing on November 14 , 1985. Prior to
the meeting, the optionee of the property and developer of
the proposed project told staff that it no longer had any
interest in the property or the project . At the meeting, an
attorney for Dan Palmer stated that his client was now the
developer and that the project plans were being revised. In
light of this new information, the proceedings relative to
PD-1014 were "taken off calendar" . At this time, I
understand that Palmer is in escrow to buy the property and
that its architect has represented to staff that a new and
entirely different plan for the project is being prepared.
Under the City ' s zoning regulations, the
application for a development permit is to be filed by the
owner of the property. (Codified Ordinances of Ventura
County § 8163-4 . 11) That was done by Keith Macloud, who
remains the owner of the property. A change in prospective
owner or developer does not invalidate the application.
Until escrow closes there has been no change of ownership;
and typically, the closing of escrow is contingent upon the
prospective buyer receiving all of the necessary planning
The Honorable James Weak and Members
of the City Council
January 27 , 1986
Page 7
approvals for the project it proposes to develop on the
property.
The City ' s zoning regulations are silent with
respect to the circumstances under which a new application
is required to be filed. However , it would not be
unreasonable to interpret the regulations to require that a
new application be filed if the applicant makes substantial
changes to the project after the application has been
accepted as complete. Obviously, such changes make it
necessary to begin the planning and environmental review
process anew.
Based upon the architect ' s representations, it
might reasonably be construed that the applicant has
abandoned the application that was filed in 1984. However ,
a court could find that this fact alone is not
determinative, and so would weight it along with all of the
other facts relative to a General Plan amendment and zone
change of the property in determining the reasonableness of
those actions .
Very truly yours,
2CHeL . KA NE
City Attorney, MOORPARK; and
BURKE, WILLIAMS AND SORENSEN