Desk ItemMEETING DATE: 2/18/14
ITEM NO:
DESK ITEM
COUNCIL AGENDA REPORT
DATE: FEBRUARY 18, 2014
TO: MAYOR AND TOWN COUNCIL
FROM: GREG LARSON, TOWN MANAGER
SUBJECT: UPDATE ON CONDITIONAL USE PERMIT COMPLAINT PROCESS
REMARKS:
The Town has received public comments regarding this matter (Attachment 2). Following is a
response to some of the comments raised in the attachments.
Hillbrook School's code compliance — Some allegations were raised regarding Hillbrook
School's CUP. This matter was not agendized and therefore cannot be discussed.
Public suggested Conditions of Approval - Staff takes into account any suggestions made by
both the public and the applicant regarding conditions of approval and may incorporate all or a
portion of any suggestions as draft conditions of approval, which staff believes is appropriate for
the project. All public comments on a specific application are forwarded to the Planning
Commission for consideration, which would include suggested conditions of approval.
Status of allowing the public to set revocation hearings — At this time there has been no Town
Council direction to amend the Town Code to allow the public a process to set revocation
hearings. As noted in previous reports on this matter, currently any concerned citizen can go
before the Planning Commission and Town Council to voice their concerns about an existing
CUP and request that the CUP be considered for revocation or modification.
Proposal to set a defined amount of time to abate a CUP violation — At the Town Council
meeting of April 1, 2013, there was a Council member comment that the amount of time to abate
a CUP violation be equal for all CUP's. At the September 4, 2012 Town Council meeting,
Council consensus was that code enforcement complaints should have a maximum of 30 to 60
days, if tangible resolution of the issue is evident. However, abatement of planning and
permitting issues (i.e. CUP violations) would not be allowed without Council concurrence.
PREPARED BY: SANDY L. BAILY, {�l2
Director of Community Development
Reviewed by: hb Assistant Town Manager
Town Attorney Finance
N:ADEVATC REPORTS2014VCUPCOMPLAINTPROCESS.dsk.docx
PAGE 2
MAYOR AND TOWN COUNCIL
SUBJECT: Update on Conditional Use Permit Complaint Process
February 18, 2014
Enforceable Conditions of Approval — Recommended conditions of approval are typically
written to be enforceable. During the public hearing process, applicants may offer a condition in
an attempt to possibly further mitigate a potential impact. On occasion, these offered conditions
are not mandatory and therefore are not enforceable. An example is where an applicant will
provide a specific service, but there is no requirement that the public use this service. In
reviewing any application, the deciding body should take this into consideration when approving
an application.
Requiring CUPs to be renewed — This would require an amendment to the Town Code. The
same concerns noted in the report for tonight's meeting for periodic CUP reviews would apply
for this process.
Attachment 1 (previously received with staff report):
1. Excerpt from Town Code
Attachment 2 (received with this desk item):
2. Public correspondence, received February 18, 2014
February 18, 2014
Members of the Los Gatos Town Council
110 East Main Street
Los Gatos, CA 95030
Dear Council Members:
I am happy to see the Town moving forward on issues related to CUPs. I just want to raise a couple of
issues. First, I want to raise an enforcement issue that has been a major problem with code compliance
complaints I and others have made about Hillbrook School.
As I've mentioned to Council previously, we believe Hillbrook has intensified the use of its campus by
increasing its afternoon activity and sports schedule. The result has been a dramatic increase in afternoon
traffic. Hillbrook has also created a new program that generates more than 5 additional peak hour trips.
We have filed complaints about these matters. Responses have never referred to the Town Code or
explained why provisions of the Town Code do not apply.
Town Code Section 29.20.200-Conditional use modification refers to the following kinds of instances as
violations:
• Intensification of use in which a change results in five or more peak hour trips;
• Commencement of new activities with adverse impacts on the surrounding area; and
• Changes that depart substantially from plans that were the basis of the CUP approval.
I wonder if there is any way to clarify this policy so that the Town can easily recognize intensifications of
use and address them. Residents need to be protected from the negative impacts of the kinds of
intensifications we've seen with Hillbrook. We think it is only reasonable that either these provisions of
the Town Code be enforced or we be told why they should not be enforced.
My second issue relates to whether or not to open up an entire CUP for review. In the Hillbrook situation,
residents feel that the current CUP from 2001 has failed to adequately address the traffic situation. We
also feel that many conditions were put in place without adequate research or information. We hope to see
the entire CUP reevaluated and all conditions reconsidered so that we can finally get some serious
mitigation for traffic and safety problems. I am guessing that in other CUP situations, residents want the
CUP to be looked at as a whole as well. I encourage you to continue to use the existing de novo approach
when CUPs come up for amendment.
My third issue relates to how residents can see their own requests for conditions included in the version of
the CUP that Staff submits for approval. Again referencing the Hillbrook case, we have provided a list of
conditions that represent our interests and goals in creating a neighborhood without excessive traffic.
Staff has simply filed these requests without including them in any versions of a CUP it projects. Can you
include a provision in the CUP policy that residents' requests for new conditions should be included in
staff recommendations for CUPS?
And a fourth issue relates to earlier proposals that seem to have been lost. Originally, there was a proposal
that the public should be allowed to set revocation hearings. There was also a proposal to set a defined
ATTACHMENT 2
amount of time to abate a CUP violation. What has happened to these? Can they still be included in
revisions to CUP policy? There are certainly cases where a business or school violates its CUP in so
many ways that revocation should be threatened to make that entity recognize it needs to conform to CUP
conditions. And it would be good to know the amount of time within which CUP violations had to be
abated.
1 hope that you can address the issues I've raised. As always, thank you for your public service.
Sincerely,
Barbara Dodson
page 1
FEBRUARY 10, 2014
TOWN COUNCIL AGENDA ITEM 8
UPDATE ON CONDITIONAL USE PROCESS
From Lee Quintana
Dear Mayor Steve Leonardis and Council Members,
I would like to thank the Council for considering changes to the CUP's.
I may not be able to attend Tuesdays Council Meeting and would like to make the
following comments for your consideration.
I. The bottom of page 3 of the staff report states:
RECEIVED
' Eb 1 8 2014
TOWN OF LOS GATOS
^LANNING DIVISION
As noted in the previous report on this matter, the Town receives approximately 20 CUP a year.
The majority of these applications are consent items or applications noncontroversial and operate
without incident. Due to staff workload and the number of hearings already before the Planning
Commission, staff does not recommend requiring that all CUPS have a condition to be
reevaluated before the Planning Commission. In addition, CUP reevaluations could potentially
deter CUP applicants, especially applicants for small independent businesses, as this could
create an uncertainty with their business planning. (emphasis added)
There needs to be a balance between business interests and those of the town and its
residents who may be affected the CUR CUP reevaluations encourage compliance
which would reduce or eliminate uncertainty as well.
While I appreciate the staff's concern for any concerns CUP applicant, I believe the
Town's focus should be the interest of its citizens, rather than the concerns of the
applicant's business. If both interests can be protected with a CUP, fine, but monitoring
compliance over time is essential to a successful permit process. If, potential impacts to
residents cannot be addressed by mandatory, enforceable conditions don't issue a CUP.
The whole purpose of a CUP is to protect residents from uses that have potential
impacts.
II. I support the following Staff recommendations to place information on the Town's
website.
• Place information on the Town's Website
• De Novo review for subsequent evaluation/review or revocation of approved CUR
III. Please also consider the following comments and suggestions:
• Conditions of Approval:
Include only mandatory, enforceable conditions of approval. Voluntary conditions are not
mandatory, are not enforceable, and do not ensure that identified potential impacts are
mitigated.
page 2
• Group CUPs by type and develop appropriate findings for each group.
Projects requiring CUPs may not share the same potential impacts. For example,
potential impacts from schools, churches or sports clubs, are different from those of
restaurants or alcohol related uses or live music or mixed use commercial or a non-
residential use in a residential zone etc.
• Types of Hearings:
Distinguish between hearings to address noncompliance with existing conditions and/or
requests for revocation for already approved project and modifications after initial
approval required as part of the CUP process to address issues that were not
anticipated by the original approval, or are found to be inadequate to address the
impacts identified at the initial approval.
• After initial CUP approval - Initial approval for two years, subsequent renewal for 5
years.1 2
Renew CUP two years after the initial approval to addresses compliance with
conditions, identifies any issues not anticipated during the initial approval process or
that were foreseen but not adequately addressed by the original approval. Modify
conditions of approval as necessary.
Subsequent to the initial two year evaluation require CUP's to be sunset every five
years.The renewal of CUPS every 5 year would allow modification of conditions to
current circumstances. For example, if there were a change in business plan or new
owners with a different business plan the CUP could be modified to address current
conditions.The length of the initial permit and subsequent permit renewals could be
varied by type of CUP based on identification of types that typically may result in
unforeseen problems
If no problems have been identified with compliance and no new issues and no other
changes have occurred renew CUP renew permit for an additional 5 years as an
administrative action. If complaints are on file or staff has identified the need to modify
conditions schedule a PC hearing to consider modification to conditions.
Cost covered for review and application fees.
Thank you for your consideration
Lee Quintana
5 Palm Ave., Los Gatos Ca.
Two years may give a better idea of how the CUP is functioning over a longer period of time.
2 Different CUP categories might have different initial and subsequent renewal periods,
depending on the history of complains to the category.