HomeMy WebLinkAbout9/4/2013 - STAFF REPORTS - 1.B. Judy Deertrack
1333 South Belardo Road,Apt 510
Palm Springs, CA 92264
Home Phone: 760 325 4290
Email: judyftudydeertrack.00m
Wednesday, September 4 2013
To the City Council
Palm Springs, California
Re: Agenda Item 1 B
Case 5.1301 GPA
Eliminating Closed Ranges/Retaining Density Caps
City Council Hearing September 4, 2013
To the Honorable City Council:
Thank you for the opportunity to comment, and as always, thank you for your work on behalf of the City of Palm Springs. I
have made earlier commentary on the pending Dakota Project, Agenda Item 2F for Adoption of Ordinance No. 1827
(PDO), on today's agenda. I assume that the general plan amendment being processed today is related to that action,
since it was initiated simultaneously to public commentary letters on the very issue of minimum thresholds and the
housing impacts initiated therefrom.
I would like to reinforce my recommendation to the City Council that it is not in the best interest of either the City in
general or the goal of diversified housing to senior citizens, low income workers, labor and the service population to
eliminate the baseline requirements for high density housing. Eliminating the requirement in the general plan designation
of high-density housing (HDR) allows the city to approve projects in multi-family and other sensitive areas without
accountability to the minimum requirement that there be at least fifteen units per acre, which allows for lower rents or
housing costs. Most of the rental units for service workers, labor, elders and low-income senior citizens are created within
this designation, and by eliminating density requirements, the groups are adversely affected.
Further, the City has used the minimum threshold of fifteen units per acre within the high-density classification used to
meet its fair share housing requirements with the State of California. In its calculations with Housing and Community
Development (HCD), the City was credited with affordable housing numbers because it used these classifications to
ensure that an average housing density of 22 units per acre would result in building out high density residential using the
spread of 15 — 30 units per acre. To change the calculation at this point would be to undermine or change the
representation that enough housing has been set aside for lower income people to satisfy State requirements and the
needs of a growing population.
Agenda Item 1C on today's agenda references the relocation of seven separate parcels to multi-family residential and
high density residential classifications. It appears that this transfer may be a response to the choice to eliminate minimum
thresholds. It is critical, for purposes of public information, that the staff report and findings reference the reasons and
impacts of these transfers, and how it relates to meeting the State requirements of low-cost and diversified housing for all
members of the community.
Thank you for allowing me to comment.
Wdh gard,
fy
Juci< fee ck
l/�
Lgw Offices ofBabak Naficy
F! 2: 4;
; . September 3, 2013
F
Via US Mail and Email
City of Palm Springs, c/o City Clerk
City Council of Palm Springs
3200 E. Tahquitz Canyon Way
Palm Springs, California 92262
cityclerk@palmsprings-ca.gov
Steve.Pougnet(a nalmsprings-ca.gov
Chris.Millsapalmsprines-ca.gov
Ginny.FoatCa,,nalmsprines-ca.gov
Rick.Hutcheson(&,Valmsprings-ca.gov
Paul.Lewin@palmspringsca.gov
1504 Marsh Street
San Luis Obispo RE: September 4, 2013 Agenda Item I.B, proposal to eliminate minimum
California 93401 density requirements in land use designations.
ph:805-593-0926
fax:805-593-0946 Honorable City Councilmembers,
babaknaficy®sbcg lobal.net I write to you on behalf of People for Proper Planning ("PFPP") in connection with the
above-referenced agenda item. As I understand it, the City intends to eliminate the
minimum density requirements for all residential land use designations, including High-
density Residential ("HDR") designation, which is intended to accommodate multi-
family housing. PFPP is opposed to this General Plan Amendment("GPA") because it
is contrary to state law and could have the unintended consequence of discouraging low
income housing.
The proposed GPA makes a mockery of California planning law by making it possible
for the City to approve any residential project on any land designated for high density
residential. For example, under the proposed GPA, the City could approve a single
mansion on land designated as high density, regardless of the density cap. This policy
would therefore prevent the City from ensuring the housing stock would include high-
density, multifamily and low-income residential developments.
State law requires the City to maintain an adequate stock of appropriately designated
land to foster the development of adequate housing, including low-and medium-income
housing. Cal Gov. Code § 65863. The legislature intends that all cities and counties
"should undertake all necessary actions to encourage, promote, and facilitate the
development of housing to accommodate the entire regional housing need." Cal Gov.
Code § 65584. To this end, the regional housing allocation plan is intended to increase
housing supply and promote affordability. Ibid.
pd ii ovw l Ma* -i
11 .�3.
9lylZ3
City of Palm Springs
Palm Springs City Council
September 3, 2013
Page 2 of 4
Further, Government Code Section 65863 provides that:
No city, county, or city and county shall, by administrative, quasi-judicial,
legislative, or other action, reduce, or require or permit the reduction of,the
residential density for any parcel to, or allow development of any parcel at, a lower
residential density, as defined in paragraphs (1) and (2) of subdivision (g), unless the
city, county, or city and county makes written findings supported by substantial
evidence of both of the following:
(1) The reduction is consistent with the adopted general plan, including the
housing element.
(2) The remaining sites identified in the housing element are adequate to
accommodate the jurisdiction's share of the regional housing need pursuant to
Section 65584.
The proposed GPA effectively amounts to a reduction of the residential density within the meaning
of the statute for all affected parcels. As the City has already approved residential development at
densities lower than those designated by the General Plan land use element, the City has already
violated Gov. Code sec. 65863. This does not mean, however, that the City can adopt the GPA
(i.e. "eliminate closed ranges,"as the staff has described the proposed action) without making the
findings required by Gov. Code Section 65863.
The Staff Report makes no attempt to explain whyproposed GPA is needed or whether it is
consistent with the General Plan or State law.
The Staff Report for this item is unique in its brevity and lack of analysis. It makes no attempt to
explain why the proposed elimination of the "closed range", or minimum density requirements is
necessary, desirable from a policy perspective, or whether it would be consistent with the goals and
policies of the General Plan. In this regard,the Staff Report merely opines that it would be
"equally appropriate"to have an open lower range of densities across all residential land use
designations and zones. There is no discussion, for example, of the City's responsibility to
accommodate its share of the regional housing needs, or what effect, if any, the elimination of the
minimum zoning densities may have on the City's stock of multifamily or other typically higher
density, more affordable housing.
The proposed action could very well thwart the development of multifamily residential
developments in the City. This is exactly what happened when the City approved the Crescendo
project. That project was originally proposed as a high-density condominium project, but was
subsequently approved as a residential sub-division pursuant to the proposed policy of eliminating
the minimum density requirement. The City has made no attempt to consider whether this trend
could continue under the proposed GPA.
City of Palm Springs
Palm Springs City Council
September 3,2013
Page 3 of 4
The City has also made no attempt to analyze what effect, if any,the proposed GPA would have on
land values and the corresponding effect on the development of low-income housing in the City.
The proposed GPA could also have the unintended consequence of driving up the cost of raw land
if it turns out that land that can be developed without minimum density requirements is more
valuable to developers. Obviously, higher land values can negatively affect the future development
of low-income housing in the City.
The Project is not exempt under CEOA.
The City apparently intends to approve the proposed GPA without any environmental review under
CEQA. This is a mistake, because the proposed action does not qualify as a "minor alteration to
land use limitations" as the term is defined in CEQA Guideline §15305. Moreover, the GPA is
capable of adversely affecting the environment within the meaning of CEQA.
CEQA Guideline §15305 explains that:
Class 5 consists of minor alterations in land use limitations in areas with an average
slope of less than 20%, which do not result in any changes in land use or density,
including but not limited to:
(a) Minor lot line adjustments, side yard, and set back variances not resulting in the
creation of any new parcel;
(b) Issuance of minor encroachment permits;
(c) Reversion to acreage in accordance with the Subdivision Map Act.
The proposed action does not qualify as a Class 5 exemption because it will result in a change in
density by eliminating all minimum densities. Accordingly,the City may not approve the proposed
GPA without conducting adequate environmental review under CEQA.
The proposed GPA is not exempt from CEQA also because it is capable of causing adverse
environmental impacts. For example, as explained above, the proposed action may retard the
future development of low-income housing by driving up the cost of developing low-income
housing. If the City's stock of work-force housing does not grow at the same rate as the City's
hospitality and other industries, the City's labor force would increasingly be forced to find housing
in the surrounding communities. This would have a negative impact on the environment by
increasing the number of vehicle miles travelled (VMTs), which would in turn degrade air quality
by causing higher tailpipe emissions (e.g., PM, NOx, ROG, CO).
City of Palm Springs
Palm Springs City Council
September 3, 2013
Page 4 of 4
Conclusion
The City Council has a solemn duty to abide by state law, and serve all residents of Palm Springs,
regardless of their income or political clout. Eliminating the minimum density requirements may
serve the business interest of a few, but it would be against State law and will not benefit the City's
laborers,the elderly or others with low or fixed income. On its face,the proposed GPA is
inconsistent with the General Plan which recognizes that "[a]s the City continues to grow, it will be
important to ensure a variety of future residential development is available to the senior population,
first-time homebuyers, and the City's labor force." For all of the foregoing reasons, I urge you not
to approve the proposed GPA.
Sincerely,
Babak Naficy,
Counsel for People for Proper Planning
CC. Lisa Bates,
Deputy Director
Dept. of Housing and Comm. Dev.
Division of Housing Policy Development
{o 9ALMSb
iy
O
V N
t
• yc 4
Oq�F4p RN�p'
CITY COUNCIL STAFF REPORT
DATE: September 4, 2013 Public Hearing
SUBJECT: APPLICATION BY THE CITY OF PALM SPRINGS FOR A GENERAL
PLAN AMENDMENT IN LAND USE CATEGORIES ELIMINATING
CLOSED RANGES AND RETAINING DENSITY CAPS
(CASE 5.1301 GPA).
FROM: David H. Ready, City Manager
BY: Planning Services Department
SUMMARY
The General Plan Land Use Element delineates the types of land uses allowed in the
various categories. There are five residential categories. The density of development
allowed in each category is discussed with the primary emphasis being on the upper
limit.
RECOMMENDATION:
1. Open the public hearing and receive public testimony.
2. Adopt Resolution No. , "A RESOLUTION OF THE CITY COUNCIL OF THE
CITY OF PALM SPRINGS, CALIFORNIA, APPROVING AN AMENDMENT TO
THE 2007 PALM SPRINGS GENERAL PLAN ADOPTED BY RESOLUTION NO.
22077 REVISING RESIDENTIAL LAND USE CATEGORIES BY ELIMINATING
CLOSED RANGES."
STAFF ANALYSIS:
Currently the language in the General Plan sets both the upper and lower limits for
residential land use categories. An equally appropriate option is to allow an open lower
range, still maintaining an upper density maximum. The specific changes showing
language to be removed and added are shown in Exhibit "A" attached.
The Planning Commission unanimously recommended approval of the subject
amendment.
ITEM NO. ,�
City Council Staff Report
September 4, 2013-- Page 2
Case 5.1301 GPA— Land Use Categories
FISCAL IMPACT:
None.
ENVIRONMENT ASSESSMENT:
Staff has determined this action to allow lower densities within existing land use
categories to be a Class 5 Categorical Exemption Minor Alterations in Land Use
Limitations under the California Environmental Quality Act as the proposed change
reflects past and current practice and retains existing density maximum standards.
M. Margo Wheeler, A P
Director of Planning Services
David H. Ready, City r
Attachment:
1. Draft Resolution
02
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PALM
SPRINGS, CALIFORNIA, APPROVING AN AMENDMENT TO THE 2007
PALM SPRINGS GENERAL PLAN ADOPTED BY RESOLUTION NO.
22077 REVISING RESIDENTIAL LAND USE CATEGORIES BY
ELIMINATING CLOSED RANGES.
WHEREAS, the current General Plan of the City provides for closed ranges of
development density allowed in each residential land use category in the City. These ranges
include both a minimum as well as maximum density allowed in each land use category.
WHEREAS, the past and current practice of the City, including without limitation, the
City Council, the City Council, and the Director of Planning, is to consider only the maximum
density allowed within each land category and consider and approve lower density project.
WHEREAS, the City Council has approved several projects that have been less than
the minimum provided in the General Plan for each residential land use category.
WHEREAS, it is the desire of the City Council that the General Plan of the City be
amended that the minimum density requirements for each residential land use designation be
removed.
WHEREAS, Palm Springs is a charter city organized under the laws of the State of
California and zoning regulations of the City are not required to be consistent with the General
Plan, however, it is the desire of the Planning Commission that the General Plan ensure
consistent and fair administration of the City's land use policies and programs.
WHEREAS, that the said action is a Class 5 Categorical Exemption Minor Alterations in
Land Use Limitations under the California Environmental Quality Act (CEQA).
THE CITY COUNCIL OF THE CITY OF PALM SPRINGS DOES HEREBY RESOLVE
that, based upon the foregoing, to amend the General Plan of the City of Palm Springs revising
residential land use categories by eliminating closed ranges as shown in Exhibit "A".
ADOPTED THIS 4TH DAY OF SEPTEMBER 2013.
David H. Ready, City Manager
ATTEST:
James Thompson, City Clerk
03
City Council Resolution No.
Case 5.1301 GPA— Land Use Element
Page 2
CERTIFICATION
STATE OF CALIFORNIA )
COUNTY OF RIVERSIDE ) ss.
CITY OF PALM SPRINGS )
I, JAMES THOMPSON, City Clerk of the City of Palm Springs, hereby certify that
Resolution No. is a full, true and correct copy, and was duly adopted at a regular meeting
of the City Council of the City of Palm Springs on September 4, 2013, by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
James Thompson, City Clerk
City of Palm Springs, California
04
City Council Resolution
September 4,2013
Case 5.1301 GPA—Land Use Categories
EXHIBIT "A"
LAND USE ELEMENT
Zoning RESIDENTIAL LAND USES
GR5 Estate Residential (0 - 2.0 dwelling units per acre). The Estate Residential
designatien pFevides f9F the development of IaFge let, single fam"'y FesidenGes that
aFe Gusten; in design. This designation is predominantly located in areas adjacent
to the City's hillsides, reflecting the natural and environmental constraints that must
be addressed there.
minim- rn Int n of A 000 n e feet n est r nnh u nit '
R-1 AH Very Low Density Residential (2:4 up to - 4.0 dwelling units per acre). The
R-1A Very Low Density residential is the most prevalent land use designation is the most
R-1 B prevalent land use designation within the City, representing typical single-family
detached residential development I nt n this land use designation general!
feet. and other uses allowed by code.
R r1 Low Density Residential (4.4 Up to - 6.0 dwelling units per acre). Similar to the
R-1D Very Low Density Residential designation, the Low Density Residential designation
also represents "typical" single-family detached residential development T#is
feet- and other uses allowed by code.
RGA(6) Medium Density Residential (6:4 Up to - 15.0 dwelling units per acre). This
RGA(8) residential land use category accommodates a range of residential housing types,
R-2 including single-family attached, single-family detached, common interest
RMPH subdivisions, patio homes, duplexes, townhomes, multiple-family, and mobile home
projects and other uses as allowed by code.
High Density Residential (44.4 up to 30 dwelling units per acre). Typical
R-3 development in this category would include duplexes, townhomes, and apartments.
R-4
R4VIP net Wted en Indian I aF;d) as Inns as they ar4e GOR60steRt with the
einniCn^nt design, rkin OF trekie nth to the SUFFOUn.din si dent'..I
aeighber+ieed and other uses as allowed by code.
05
CITY OF PALM SPRINGS
PUBLIC HEARING NOTIFICATION
go
Date: September 4, 2013
Subject: Case 5.1301 — GPA—Amend Land Use Categories
AFFIDAVIT OF PUBLICATION
I, Kathie Hart, Chief Deputy City Clerk, of the City of Palm Springs, California, do hereby
certify that a copy of the attached Notice of Public Hearing was published in the Desert Sun
on September 24, 2013.
1d''e``clare under penalty of perjury that the foregoing is true and correct.
1
Kathie Hart, CMC
Chief Deputy City Clerk
AFFIDAVIT OF POSTING
I, Kathie Hart, Chief Deputy City Clerk, of the City of Palm Springs, California, do hereby
certify that a copy of the attached Notice of Public Hearing was posted at City Hall, 3200 E.
Tahquitz Canyon Drive, on the exterior legal notice posting board, and in the Office of the
City Clerk and on August 22, 2013.
1 declare under penalty of perjury that the foregoing is true and correct.
Kathie , CMC
Chief Deputy City Clerk
AFFIDAVIT OF MAILING
I, Kathie Hart, Chief Deputy City Clerk, of the City of Palm Springs, California, do hereby
certify that a copy of the attached Notice of Public Hearing was mailed to each and every
person on the attached list on August 22, 2013, in a sealed envelope, with postage prepaid,
and depositing same in the U.S. Mail at Palm Springs, California. (6 notices)
I declare under penalty of perjury that the foregoing is true and correct.
Kathie Hart, CMC
Chief Deputy City Clerk
06
The Desert Sun
750 N Gene Autry Trail Certificate of Publication
Palm Springs, CA 92262
760-7784578/Fax 760-7784731
2013 A,UG 27 Arl 9, 23
State Of California ss:
County of Riverside
NOTICE OF PUBLIC HEARING
CITY COUNCIL
Advertiser: CITY OF PALM SPRINGS
CASE 5.1301 GPA
CITY OF PALM SPRINGS/LEGALS APPLICATION BY THE CITY OF PALM SPRINGS
PO BOX 2743 FOR A GENERAL PLAN AMENDMENT
PALM SPRINGS CA 922632 IN LAND USE CATEGORIES
NOTICE IS HEREBY GIVEN that the City Council of the
City of Palm Springs,California,will hold a public hearing
2000376965 at its meeting of September 4, 2013. The City Council
•meeting begins at 6:00 p.m. in the Council Chamber at
City Hall,3200 East Tahquitz Canyon Way,Palm,Springs.
The purpose of the hearing is to consider an application by
the City of Palm Springs to amend the City's General Plan
I am over the age of 18 years old, a citizen of the United Land Use Element to modify certain land use categories.
States and not a party to, or have interest in this matter. I
hereby certify that the attached advertisement appeared ENVIRONMENTAL DETERMINATION: The City of
in said newspaper (set in type not smaller than non panel) Palm Springs, in its capacity as the Lead Agency,
in each and entire issue of said newspaper and not in any - under the California Environmental Quality Act (CEQA)
supplement thereof on the following dales,to wit: has determined that the proposed General Plan text
amendment is Categorically Exempt under Section
Newspaper: .The Desert Sun 15305 of the State CEQA Guidelines. The proposed
amendments would provide for a minor alteration of the
land use limitations in the City's land use regulations,but
8/24/2013 would not increase land use densities or intensities.
REVIEW OF INFORMATION:The staff report and other
supporting documents regarding this item are available
for public review at City Hall between the hours of 8:00
a.m. and 6:00 p.m., Monday through Thursday. Please
contact the Office of the City Clerk(760)323-8204 if you
I acknowledge that I am a principal clerk of the printer of would like toschedule an appointment to review these
The Desert Sun, printed and published weekly in the City documents.
of Palm Springs, County of Riverside, State of California. COMMENTS: Response to this notice may be made
The Desert Sun was adjudicated a newspaper of general
circulation on March 24, 1988 by the Superior Court of the verbally at the Public Hearing and/or in writing before
County of Riverside, State of California Case No. the hearing.Written comments may be made to the City
191236. Council by letter(for mail or hand delivery)to:
James Thompson,City Clerk
I declare under penally of perjury that the foregoing is true 3200 E.Tahquitz Canyon Way
and correct. Executed on-tk� 24th day of August, 2013 in Palm Springs,CA 92262
Palm Springs,Catifomia./!/J Any challenge of the proposed project in court may
be limited to raising only those issues raised at the
public hearing described in this notice, or in written
correspondence delivered to the City Clerk at,or prior to,
the public hearing. (Government Code Section 65009[b]
[2]).
pi�clara Signatur An opportunity will be given at said hearing for all
interested persons to be heard. Questions regarding this
y1,1V,` case may be directed to M. Margo Wheeler, Director of
1 K Planning Services,at(760)323-8245.
Si necesita ayuda con esta carts, por favor Ilame a la
Ciudad de Palm Springs y puede hablar con Nadine
Fieger telefonc(760)323-8245.
James Thompson,City Clerk
6ZZT S6E 008 L slage1twoo'Wg'MMM
:sn jaeluoZ) :ai!sgaMmo ji.siA
nm REPS
MR PETE MORUZZI
G ' H SDTOR C COM AND
REP-0d-0 PALM SPRINGS MODERN COMMITTEE
x P.O. BOX 4738
PALM SPRINGS,CA 92263-4738
CITY OF PALM SPRINGS CASE 5.1301
PLANNING SERVICES DEPARTMENT MRS. JOANNE BRUGGEMANS
VERIFICATION NOTICE�-0-0 ATTN SECRETARY/5.1301 506 W.SANTA CATALINA ROAD
PO BOX 2743 PALM SPRINGS, CA 92262
PALM SPRINGS, CA 92263-2743
MS MARGARET PARK
AOUAIGALIgNTE BAND OF CAHUILLA AGUA CALIENTE BAND OF CAHUILLA
1NDIANS-b-9-0-0-0-0 INDIANS
5401 DINAH SHORE DRIVE
PALM SPRINGS, CA 92264
SOBOBA BAND OF LUISENO INDIANS LUEBBEN JOHNSON&BARNHOUSE,
ATTN:JOSEPH ONTIVEROS LLP
ATTN: RICHARD C.WADE, PARALEGAL
INTERESTED PARTIES-0-0-0 - CULTURAL RESOURCES MANAGER
P.O. BOX 487 7424 4 STREET NW
SAN JACINTO, CA 92581 LOS RANCHOS DE ALBUQUEROUE, NM
87107
SPONSORS -0-0-0-0-0
1`v
NOTICE OF PUBLIC HEARING
CITY COUNCIL
CITY OF PALM SPRINGS
CASE 5.1301 GPA
APPLICATION BY THE CITY OF PALM SPRINGS
FOR A GENERAL PLAN AMENDMENT IN LAND USE CATEGORIES
NOTICE IS HEREBY GIVEN that the City Council of the City of Palm Springs, California, will
hold a public hearing at its meeting of September 4, 2013. The City Council meeting begins at
6:000 p.m. in the Council Chamber at City Hall, 3200 East Tahquitz Canyon Way, Palm Springs.
The purpose of the hearing is to consider an application by the City of Palm Springs to amend
the City's General Plan Land Use Element to modify certain land use categories.
ENVIRONMENTAL DETERMINATION: The City of Palm Springs, in its capacity as the Lead
Agency, under the California Environmental Quality Act (CEQA) has determined that the
proposed General Plan text amendment is Categorically Exempt under Section 15305 of the
State CEQA Guidelines. The proposed amendments would provide for a minor alteration of the
land use limitations in the City's land use regulations, but would not increase land use densities
or intensities.
REVIEW OF INFORMATION: The staff report and other supporting documents regarding this
item are available for public review at City Hall between the hours of 8:00 a.m. and 6:00 p.m.,
Monday through Thursday. Please contact the Office of the City Clerk (760) 323-8204 if you
would like to schedule an appointment to review these documents.
COMMENTS: Response to this notice may be made verbally at the Public Hearing and/or in
writing before the hearing. Written comments may be made to the City Council by letter(for mail
or hand delivery) to:
James Thompson, City Clerk
3200 E. Tahquitz Canyon Way
Palm Springs, CA 92262
Any challenge of the proposed project in court may be limited to raising only those issues raised
at the public hearing described in this notice, or in written correspondence delivered to the City
Clerk at, or prior to, the public hearing. (Government Code Section 65009[b][2]).
An opportunity will be given at said hearing for all interested persons to be heard. Questions
regarding this case may be directed to M. Margo Wheeler, Director of Planning Services, at
(760) 323-8245.
Si necesita ayuda con esta carta, por favor Ilame a la Ciudad de Palm Springs y puede hablar
con Nadine Fieger telefono (760) 323-8245.
mes Thompso�Citylerk
07