SR-11-C (31)
C/ED:CPD:DKW:NRM:klc
COUNCIL MEETING: June 23, 1987
II<!
JUN 23 1981
:.tUN 3 0 1981
Santa Monica, California
TO: Mayor and city council
FROM: City Staff
SUBJECT: Recommendation to Establish Interpretation of Policy
4.3.1 of the Circulation Element of the General Plan
INTRODUCTION
This report recommends that the City Council review Policy 4.3.1
of the Circulation Element of the General Plan to clarify its
intent. Policy 4.3.1 describes Level of service objectives for
various classes of streets in Santa Monica.
BACKGROUND
At the March 24, 1987, meeting, the City Council passed a motion
directing the Planning Commission to develop a recommended amend-
ment of Policy 4.3.1 of the Circulation Element of the General
Plan.
The City council was responding to a March 2, 1987,
request by the Planning commission to authorize the Commissioners
to review and possibly revise the ambiguous language contained in
Pol icy 4. 3 . 1.
Circulation Element Policy 4.3.1 was developed and adopted by an
unanimous vote at the March 17, 1984, Planning commission meeting
which was part of the deliberations leading to the adoption of
the revised Land Use and Circulation Elements in October 1984.
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lJ.e. .
JUN 2 3 1987
!UN 3 0 \937
See Attachment A for a complete transcript of the Planning
commission's discussion of Policy 4.3.1 at the March 17, 1984,
meeting. The policy reads as follows:
t'Safe or acceptable levels of service on city streets
shall be a criterion for evaluation of new development
proposals. Level of Service shall be "C" for collect-
or, feeder, and local streets and nO" for arterials
(See Glossary) or better where possible."
Before adopting Policy 4.3.1, the Planning Commission discussed
the policy's meaning and intent. Chairwoman Susan Cloke wanted
Pol icy 4 . 3 . 1 to n set a standard to hopefully guide [future]
decision makingn and expressed the belief that Level of service
(LOS) nCfI for collector, feeder and local streets and LOS nOn for
arterials "should be the goal for the city standard." Other
Commissioners, including Ken Genser and Gloria OeNecochea
concurred. Acting Planning Director Paul Silvern, added that LOS
nDn for arterial streets was na reasonable objective to aim for
on a City-wide bas is " because there are a number of streets at
LOS fiE" or worse in the City.
Chairwoman Susan Cloke thought that "where possible" should be
included at the end of Policy 4.3.1 for clarification, since
there were several places in the City where the "c" and "D" LOS
standards were already not met. The Acting Planning Director
explained that there were two levels of traffic capacity to be
considered, peak hour and average daily capacity; LOS figures are
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determined by average daily capacity. Therefore, intersections
could have a LOS of "0" on an average daily basis but peak hour
traffic may be at the equivalent of level liE" or "F". Silvern
commented further that "where possible" was needed in the policy
text because LOS "C" and "Du could only be considered as
..targets" not "guarantees" against level "E" or "F" at certain
City intersections during peak traffic hours.
Clearly, Policy 4.3.l was developed in response to concerns about
traffic congestion on the part of the Planning Commission and the
City council, who approved the Land Use and Circulation Elements.
Their goal in approving this policy was to establish obj ective
measures of traffic conditions against which to evaluate new
development projects. However, the policy was not well-worded,
so part of its intent, as discussed in the previous paragraphs,
was unclear. In a memorandum dated April 16, 1987, the City
Attorney stated that the language of Policy 4.3.1 was ambiguous
and the Planning Commission and city staff were the correct
parties to interpret its meaning. (See Attachment B.)
TECHNICAL BACKGROUND
Level of service (LOS)
The Land Use and Circulation Elements' Glossary defines Level of
Service (LOS) as indicated below:
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"An indication of a road I s performance based on an
evaluation of driving conditions, with six performance
ranges as follows:
A. Free Flow
B. Stable Flow
C. Restricted Flow, Tolerable Delay
D. Approaching Unstable Flow, Substantial Delays
E. Capacity conditions, Long Delays
F. Forced Flow"
The Level of Service definitions in Figure 1, based upon the
Highway capacity Manual, are used as the basis for analysis in
this report.
In Figure 2, the definitions for street classifications in the
City of Santa Monica are taken from the 1984 Circulation Element
of the General Plan, pages 123-124.
Actual/Projected Traffic Conditions
Comprehensive City-wide data on current and projected levels of
service is not currently available. Such data is expected to be
developed as part of the city-wide circulation study. The LOS
data on actual and projected traffic conditions in the City,
Figures 3 and 4, is taken from information developed for the
Colorado Place Phase III EIR, and the EIR for the planned hotel
at 1723 4th street. As stated in Policy 4.3.1, LOS "C" is the
goal for collector, feeder and local streets while LOS "Oil is the
desired level of service for arterials in santa Monica.
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LEVEL
OF
SERVICE
A
B
c
D
E
FIGURE 1
LEVEL OF SERVICE INTERPRETATION
DESCRIPTION
Excellent operation. All approaches
to the intersection appear quite open,
turning movements are easily made, and
nearly all drivers find freedom of
operation.
Very good operation. Many drivers
begin to feel somewhat restricted
within platoons of vehicles. This
represents stable flow. An approach
to an intersection may occasionally
be fully utilized and traffic queues
start to form.
Good operation. occasionally, drivers
may have to wait more than 60 seconds
and back-ups may develop behind turning
vehicles. Most drivers feel somewhat
restricted.
Fair operation. Cars are sometimes
required to wait more than 60 seconds
during short peaks. There are no
long-standing traffic queues. This
level is typically associated with
design practice for peak periods.
Poor operation. Some longstanding
vehicular queues develop on critical
approaches to intersections. Delays
may be up to several minutes.
DELAY
RANGE
(sec per
vehicle)
o to 16
16 to 22
22 to 28
28 to 35
35 to 40
V!C
RATIO
o
to
.59
.60
to
.69
.70 to
.79
.80 to
.89
.90 to
1. 00
Forced flow. Represents jammed con-
ditions. Backups from locations down
stream or on the cross street may re-
strict or prevent movement of vehicles
out of the intersection approach lanes;
therefore, volumes carried are not pre-
dictable. Potential for stop-and-go
type traffic flow.
Note: Based on National Academy of Sciences, Highway Capacity
Manual, 1965 and the update of the manual.
F
40 or
more
Source: DKS Associates, Transportation Analysis 1986.
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over
1. 00
FIGURE 2
STREET CLASSIFICATIONS
l. Arterial streets are generally commercial thoroughfares and
carry the majority of vehicles entering and traveling in
Santa Monica. Recommended traffic volume on arterial
streets ranges from 34,000 to 6l,000 vehicles per day
depending on the number of traffic lanes and left turn
movements. Arterials in the city include San Vicente, Santa
Monica, wilshire and Pico Boulevards.
2. Collector Streets are intended to carry traffic between
residential neighborhoods and the arterial street network.
An average daily traffic volume of 15,000 vehicles is
recommended for collector streets. Designated collector
streets in the City of Santa Monica include Montana Avenue,
Broadway and Main street.
3. Feeder streets are similar to collector streets because
feeder streets also carry traffic between residential
neighborhoods and the arterial street network; however,
feeder streets are almost always residential in character.
Feeder streets are intended to carry lower volumes of
traffic than collectors, usually below 7,500 vehicles per
day. Feeder streets in Santa Monica include Barnard Way,
Pearl Street and Washington Avenue.
4. Local Streets are intended to carry a lower traffic volume
than the other street classifications in Santa Monica,
approximately 2,500 vehicles per day. Examples of local
streets include Ashland Avenue, Appian Way and pier Avenue.
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FIGURE 3
SELECTED INTERSECTIONS (AM)
AM Existing Plus Project Plus Cumulative Plus Project Peak Hour
Volume/capacity Ratios and Level of service
INTERSECTION
Wilshire & 20th
Wilshire & 26th
Santa Monica & 20th
Santa Monica & 26th
Colorado & 20th
Colorado & Cloverfield
Colorado & centinela
Olympic & 20th
Olympic & Cloverfield
olympic & 26th
Olympic & centinela
SM Freeway WB off &/
Cloverfield
8M Freeway EB off &/
Cloverfield
Pico & Cloverfield
Ocean Park & 23rd
EXISTING
V/C LOS
0.62
0.76
0.77
0.57
0.61
0.46
0.63
0.65
0.62
0.59
0.64
0.48
0.42
0.67
0.73
B
C
C
A
B
A
B
B
B
A
B
A
A
B
C
EXISTING +
PROJECT
EXISTING +
PROJECT +
CUMULATIVE
vIe LOS
0.73
0.95
0.90
0.71
0.92
0.59
0.89
0.81
0.88
0.76
0.76
0.51
0.50
0.78
0.92
v IC LOS
C
E
E
C
E
B
o
D
o
C
c
0.93
1.21
1.04
0.85
1.35
LOS
1.41
0.93
1.04
0.83
0.S2
E
F
F
o
F
F
F
E
F
o
D
A
B
F
F
Note: This table does not reflect any potential traffic mitiga-
tion measures that may reduce the traffic impacts on these
intersections.
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A
0.53
A
C
E
0.68
1.03
1.11
FIGURE 4
SELECTED INTERSECTIONS (PM)
PM Existing Plus Project Plus Cumulative Plus Project Peak Hour
Volume/Capacity Ratios and Level of Service
INTERSECTION
Wilshire & 20th
Wilshire & 26th
Santa Monica & 20th
Santa Monica & Cloverfield
Santa Monica & 26th
Broadway & 26th
Colorado & 20th
Colorado & Cloverfield
Colorado & 26th
Colorado & centinela
Olympic & 20th
Olympic & Cloverfield
Olympic & 26th
Olympic & Stewart
Olympic & Centinela
SM Freeway WB Off &
Cloverfield
SM Freeway EB On &
Cloverfield
pico & 23rd
Pico & Cloverfield
Ocean Park & Cloverfield
Ocean Park & 23rd
EXISTING
V/C LOS
0.70
0.92
0.84
0.63
0.63
0.55
0.79
0.60
0.49
0.62
0.62
0.74
0.68
0.62
0.65
0.63
0.46
0.63
0.70
0.49
0.80
EXISTING +
PROJECT
V/C LOS
C
E
D
B
B
A
C
B
A
B
B
C
B
B
B
0.93
1.14
1.00
0.78
0.87
0.66
1.03
0.78
0.76
0.87
0.84
1.01
0.76
0.73
0.84
E
F
F
e
o
B
F
C
C
D
D
F
C
C
D
C
A
o
D
A
F
EXISTING +
PROJECT +
CUMULATIVE
vie LOS
1.15
1. 36
1.10
0.82
1.02
0.74
1.43
1.23
1.31
1.00
0.86
1.l0
0.78
0.76
1.01
0.84
0.61
0.95
0.86
0.74
1. 96
F
F
F
o
F
C
F
F
F
F
D
F
C
C
F
D
B
E
D
C
F
Note: This table does not reflect any potential traffic mitiga-
tion measures that may reduce the traffic impacts on these
intersections.
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B
0.71
A
B
C
A
D
0.54
0.82
0.79
0.57
1.51
The information developed for the Colorado Place Phase III
development provides some useful information about projected
traffic conditions for the city of Santa Monica. This staff
report only utilizes traffic data for the Colorado Place Phase
III project as an indication of projected traffic conditions;
this staff report does not analyze the proposed development or
make any recommendations to the City council regarding the
proposed project.
The information from The Santa Monica civic Center Hotel and
Commercial Complex EIR, Figure 5, provides information about
evening peak hour existing and projected traffic conditions in
the Downtown and Ocean front area.
During the morning peak hour, three intersections, wilshire
Boulevard & 26th Street, Santa Monica Boulevard & 20th Street and
Ocean Park Boulevard & 23rd street, are currently operating at
LOS "C". None of the intersections studied are operating below
LOS "C" in the morning peak hour. Four intersections, Santa
Monica Boulevard & 20th street, Ocean Park Boulevard & 23rd
street, 4th Street & Pico Boulevard and the Santa Monica Freeway
Eastbound On-ramp at Lincoln Boulevard, are currently operating
at LOS "0" in the peak evening hour. The intersection of
Wilshire Boulevard & 26th Street is functioning at LOS "E" during
the evening peak hour. With these exceptions in the evening peak
hour, the major arterials and feeder, collector and local streets
are operating at their desired capacity rate.
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FIGURE 5
SELECTED INTERSECTIONS (PM)
Existing Plus Project Plus Cumulative Plus Project
PM Peak Hour Capacity Analysis
EXISTING +
EXISTING + PROJECT +
INTERSECTION EXISTING PROJECT CUMULATIVE
Average Average Average
Delay LOS Delay LOS Delay LOS
4th & Civic Center 8.07 A 12.96 A 12.27 A
4th & Colorado 20.07 B 21. 50 B 24.69 C
4th & pi co 28.04 D 28.41 D 29.58 D
SM Freeway WB Off &
4th 15.50 A 16.26 B 17.45 C
SM Freeway EB on &
Lincoln 30.23 0 32.71 D 15.10 A
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without mitigation measures, LOS will decline at several inter-
sections during the morning and evening peak hours. For
instance, in the morning peak hour, Santa Monica Boulevard & 26th
street will decline from LOS "A" to LOS "0" while Colorado Avenue
& 20th street will deteriorate from LOS liB" to LOS "F". In the
evening peak hour, the intersection of Colorado Avenue & 2 oth
Street will decline from LOS "C" to LOS "Ftt while Colorado Avenue
& Cloverfield Boulevard will deteriorate from LOS "BIt to LOS ItF".
The EIR for the proposed 4th Street Hotel indicates that with the
inclusion of the proposed Santa Monica Freeway on-ramp at 4th
street, LOS will improve from "D" to "A" at the intersection of
Lincoln Boulevard and the existing east bound freeway on-ramp
during the evening peak hour. Mitigation measures proposed for
Colorado Place Phase III and the 4th street Hotel development
would improve future traffic conditions in the areas surrounding
the proposed projects.
The LOS at intersections in the City is a result of developments
in Santa Monica and growth in surrounding cities. Major projects
approved in Santa Monica are routinely required to mitigate their
immediate impacts on the City'S infrastructure. Projects outside
the City'S jurisdiction may impact on the circulation system in
Santa Monica, but the City has no authority to require that these
traffic impacts be mitigated.
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June 1, 1987, Planning Commission Meeting
On June 1, 1987, the Planning commission held a public hearing to
consider an amendment to pOlicy 4.3.1 of the Circulation Element
of the General Plan. Several members of the publ ic spoke in
opposition to staff's proposed amendment and interpretation that
Policy 4.3.1 is a guideline to consider when decision-makers
review new development proposals in the city.
The Planning Commissioners discussed Policy 4.3.1 and its intent.
Commissioner Nelson stated that peak hour, not average daily
capacity, should be the evaluation criteria for Level of service
at city intersections. staff concurred with this interpretation
because LOS determined on an average daily basis could provide an
unrealistic analysis of traffic levels at several city intersec-
tions where LOS is exceeded in the peak hour. Commissioner
Nelson also commented that the City may need to "bite the bullet"
and lower the Floor Area Ratios (FARs) in various areas of the
City.
All the Commissioners said that they interpret Policy 4.3.1 as a
mandate and not a guideline. The commission believes that
amendment of the POlicy was not appropriate until completion of
the City-wide traffic study, which is expected to take at least
six months. By a unanimous vote, the Commission passed the
following motion: 1) Policy 4.3.1 is a mandate; 2) peak hour LOS
is the appropriate evaluation criteria; 3) Policy 4.3.1 is not to
be interpreted as the sole criteria in reviewing new development
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projects but one of the essential criteria~ and 4) an Environ-
mental Impact Report (EIR) and a statement of Overriding
considerations should be required for approval of any proposed
proj ect that exceeds LOS "C" on collector, feeder and local
streets and/or LOS "D" for arterials.
ANALYSIS
staff has interpreted Policy 4.3.1 as establishing standards
against which proposed development projects should be evaluated,
as well as describing LOS goals which the city of Santa Monica
should strive to attain. This interpretation, which staff
believes is consistent with the Planning commission's original
intent, considers that the LOS standards specified in pOlicy
4.3.1 are criteria against which to evaluate and review proposed
development proj ects ; either an official interpreta tion of the
policy should be established, or the policy should be modified to
clearly state the Planning Commission's original intent.
The impact on LOS is a critical factor which should be carefully
reviewed, especially given increasing congestion and heightened
concern in the community. In some cases, modification or denial
of development projects because of LOS impacts is appropriate.
Some persons have interpreted policy 4.3.1 as requiring the
automatic denial of development proj ects which either alone or
together with background traffic growth, cause the traffic level
to fall below the LOS standards of Policy 4.3.1. This pOlicy
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interpretation could necessitate the denial of all major devel-
opment projects proposed in areas where the LOS is already below
the acceptable standards. The policy could even be interpreted
to require denial of all projects in such areas since even small
new projects would worsen traffic conditions.
The overall goal of the adopted Land Use and Circulation Elements
(LUCE) was to promote balanced growth in the city of Santa Monica
as opposed to no growth or uncontrolled growth. The goals of the
LUCE were to assure that this I1balanced growth" provide adequate
revenue to the City, employment opportunities for all residents,
support for businesses, especially small business, protection,
maintenance and expansion of the city's housing stock, preserva-
tion and improvement of the natural environment and consideration
for the City's unemployed and underemployed residents. These
goals were considered equally important during the LUCE revision
and adoption process.
The Land Use Element establishes development controls including
height limits and floor area ratios for the various city land use
categories. If the LOS standards in Policy 4.3.1 are interpreted
to be absolutes and virtually no new significant development is
allowed by the City, many of the basic development standards in
the LUCE would be rendered meaningless and several proposed
proj ects in Santa Monica would have to be denied. A proj ect
could have a negative impact on several intersections, not just
the intersections directly surrounding the proposed project. For
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example, a small project at 26th street and Montana Avenue could
have a negative effect on the intersection of 26th street and
Wilshire Boulevard and conceivably would have to be denied.
Under this interpretation, both the Colorado Place Phase III and
Water Garden Office developments might have to be denied
outright, even though it was the LueE I s intent to develop the
Special Office District into large-scale commercial office use.
Likewise, theater projects on the Third street Mall, hotel
projects in the Ocean Front area, major projects in the downtown,
and the Airport residual land development and other areas of the
city could, together with traffic generated outside of the City,
cause streets to exceed the LOS standards in Policy 4.3.1 during
peak hours. staff believes that the wording of Policy 4.3.1
needs to be interpreted or clarified to indicate that the LOS
standards in Policy 4.3.1 are goals for the City; otherwise, many
of the LUCE development standards and land use designations may
need modification. Such modifications may be appropriate, but
should be considered carefully, and in a broader context than
interpretation of a single policy in one of the General Plan
elements.
Clearly, traffic congestion is a growing prOblem which is of sig-
nificant concern to the city and indeed to the entire Los Angeles
region. Policy 4.3.1 provides guidelines which should be used in
evaluation of development projects. The City-wide traffic study
is expected to provide a comprehensive examination of circulation
issues, and will contribute towards measures to mitigate traffic
impacts. Staff is also developing a Transportation Systems
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Management (TSM) Plan which will propose a package of programs
addressing these issues. A draft TSM plan will be issued in
several months. Regional action is also needed, and staff is
working with the Southern California Association of Governments
as it addresses circulation and transportation issues.
Staff anticipates that the comprehensive City-wide traffic study
may provide information which leads to a variety of General Plan
amendments, likely including amendment of policy 4.3.1. For
example, as a result of the study, it may be appropriate to
develop improved pOlicies and implementing regulations which
provide detailed rules and standards for action on development
projects. In the interim, a clear interpretation of Policy 4.3.1
is needed.
The staff has a number of concerns with the Planning commission's
proposed interpretation of Policy 4.3.1 including the necessity
of an ErR for all proposed development, even small projects,
located on streets where the desired LOS is already exceeded and
the determination that under this interpretation, Policy 4.3.1 is
at the same time considered to be a "mandate" but also only one
of several criteria to be used in evaluating development
projects. policy 4.3.1 is part of the City'S General Plan, and
as such, must be adhered to in city action on private development
projects. However, General Plan policies may express either
mandatory or desirable Objectives. staff is concerned that the
commission's proposed interpretation may continue the debate
about the meaning of Policy 4.3.1, leading to further
difficulties in city consideration of development projects.
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CEQA STATUS
Council action which simply established an interpretation of
Policy 4.3.1 and did not revise it would not be subject to CEQA.
CONCLUSION
An interpretation of Policy 4.3.1 should be established in order
to provide clear direction to decision-makers in reviewing
proposed projects in the city pending completion of the City-wide
traffic study, which may result in amendment of the policy.
RECOMMENDATION
staff respectfully recommends that the City Council discuss this
matter and adopt the following interpretation of Circulation
Element Policy 4.3.1:
1. Policy 4.3.1 establishes standards against which proposed
development projects must be evaluated. These standards
represent critical goals which the City should strive to
attain.
2. Peak hour Level of Service (LOS) is the appropriate evalu-
ation criteria.
3. An Environmental Impact Report (EIR) and a statement of
overriding Considerations should be required for approval of
any proposed development that significantly contributes to
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the deterioration of LOS at city intersections below the
levels set forth in Policy 4.3.1.
4. Maintenance of the city's quality of life and mitigation of
traffic congestion are high-priority objectives for the
city.
Revision of Policy 4.3.1 may be appropriate as a
result of the City-wide traffic study and other policy
changes to the General Plan related to regulation of
development.
Attachments A: Planning Commission Discussion of POlicy 3.3.1 on
March 17, 1984
B: City Attorney Memorandum Opinion Number 87-21
c: Communications
Prepared by:
D. Kenyon Webster, Senior Planner
Nancy Ross Madnick, Assistant Planner
w/ceccl
06/16/87
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1'i.J. J. fiL.r::iv~r..N J. 1;)
MEMORANDUM OPINION NUMBER 87-21
DATE:
April 16, 1987
Planning Commission
Robert M. Myers, City Attorney
Laurie Lieberman, Deputy City Attorney
Interpretation of Circulation Element Policy 4.3.1
TO:
. FROM:
SUBJECT:
At the Planning Commission meeting of April 6, 1987, the
Planning Division staff advised the Planning cOIllJllission that
Circulation Element Policy 4.3.1 (set forth below) should be
interpreted as a guideline or a goal rather than as a mandatory
standard, which if not met, requires denial of project approval
(or mitigation measures to ensure co~pliance). A legal opinion
was requested regarding the interpretation of this Circulation
Element policy. It is our conclusion that since the language of
this section is ambiquous, the intent of the drafters is best
interpreted by the Planning Commission and its staff.
,The language of the Circulation Element policy in question
is as follows:
Safe or acceptable levels of service on
City streets shall be a criterion for
evaluation of new development proposals.
Level of Service shall be "e" for
collector, feeder, and local streets and
"0" for arterials (see Glossary) or
better where possible.
The use of the word "shall" in the above-quoted policy lends
credence to the interpretation that this policy was intended to
be mandatory. However, the phrase "where possible" clearly can
be read in two different ways. It can be read to modify the
entire paragraph, in which case Planning staff's interpretation
of the policy as a quideline rather than as a rule ~akes the ~ost
sense. If, on the other hand, "where possible" is read to modify
the phrase "or better," then the mandatory interpretation is
required.
4.3.1
since the language of the policy in question is ambiguous,
the policy should be interpreted by those bodies that adopted it.
Accordingly, the Planning Commission and the City Council on
appeal are the bodies charged with the responsibility for
interpreting this policy.
LL211/hpc