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SR-402-002 (15) . . I ~2 :16 C/ED:PB:DKW:WW:ww PC/cccup46 Council Mtg: June 26, 1990 Ljo'Z--O()-Z- Santa Monica, California TO: Mayor and City Council FROM: city staff SUBJECT: city Council Reconsideration of Appeal of Conditional Use Permit 89-046 and Tentative Tract Map 48039 for the Development of a Five Unit, 9000 Square Foot, Three Story Condominium Subdivision on a 7500 square Foot Parcel Located in the R3 (Residential Medium Density Multiple Family) District. Applicants: Law Firm of Lawrence and Harding Representing Rose and Leo Chang. Appellant: Syd Jurin Representing Residents and Homeowners of 11th Street. INTRODUCTION This report recommends that the city Council deny the appeal and uphold the Planning Commission approval of CUP 89-046 and TTM 48039 for the construction of a three story, five unit condominium at 1253 11th Street. On May 22, 1990, the city Council voted unanimously to reconsider the previous denial of the project. BACKGROUND On August 2, 1989, the Planning commission voted 6-0 to approve the development of a three story, five unit, 9,000 square foot condominium on the 7,500 square foot project site. The site presently contains two detached residential structures. (See Exhibit A). On August 11, 1989, Syd Jurin representing residents and homeowners of 11th Street, appealed the Commission action. On November 14, 1989, the City council voted 4-3 to reverse the Planning Commission's unanimous approval of the project, and to - 1 - JUL 0 3 1990 12-A JUN 2 6 1990 . . .. deny the development of the five unit condominium project. (See Exhibits B, C). On April 10, 1990, the law firm of Lawrence and Harding, representing the applicants Rose and Leo Chang submitted a letter to the City Council contending the findings proposed by the City Attorney for project denial were insufficient and requested the Council to reconsider the project based upon it's merits. (See Exhibit D). The Council continued the consideration of the matter to May 22, 1990. On May 22, 1990, the Council voted to reconsider its denial action for the project and to reconsider the merits of the project. ANALYSIS The project, as approved by the Planning Commission, conforms to the uniform height, setback and density standards established for the R3 District. Under the R3 District development standards, the site could be developed with six residential units, eight foot side yard setbacks and a 3 story, 40 foot height limit. The developer has proposed to construct five units, with 8-12 foot side yard setbacks and a 3 story, 34 foot height limit and parking for 13 vehicles. The August 11, 1989, appeal letter states that the existing buildings and six other properties located in the vicinity of the project site were built in 1904 as part of the "original" City of Santa Monica and should be preserved as an historic district. On November 9, 1989, five days prior to the scheduled City Council hearing, the Landmarks Commission determined that the structures - 2 - . . referred to in the appeal did not merit formal designation as an historic district. The Landmarks Commission determined that the structures when viewed both individually and collectively do not qualify as outstanding landmarks. The Landmarks Commission determination is binding on the city for a period of five (5) years pursuant to SMMC section 9608N. Building and Safety Division records indicate many of the structures referred to in the appeal have been altered and have not retained the original design, materials, or workmanship. Many of the altered structures do not meet the criteria established for landmark designation (SMMC Section 9606) and therefore may not contribute to a sense of historical continuity. The project was deemed exempt from environmental review under the City of Santa Monica Guidelines for Implementation of the California Environmental Quality Act (Resolution No. 6694 (CCS)). The criteria used by the city to exempt projects from environmental review is consistent with criteria established in CEQA Section 15061, which provides: The activity is covered by the general rule that CEQA applies only to proj ects which have the potential for causing a significant effect on the environment. 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, the activity is not subject to CEQA. The Planning Commission as the authorized decision-making body determined there was no possibility that the residential housing activity proposed could have a significant effect on the environment. The Planning commission made the same determination - 3 - . . for several other condominium proj ects approved on August 2, 1989. state Zoning Law provides that the council should consider a challenge to an environmental exemption granted if substantial credible evidence of environmental impacts of a particular project is presented in the written appeal or during the appeal hearing. There was no evidence presented as part of the written appeal or during the November 14, 1989 city council hearing, and therefore this project cannot be subjected to environmental review under the California Environmental Quality ActA The proposed 34 foot height and massing of the structure will appear similar to many of the two story mUltiple family structures located along Eleventh street. The proposed five unit density is consistent with the density permitted for development in the R2 (Low Density) District. Under the R2 low density zoning standards, a two story building with a staircase enclosure, skylights or rooftop decks could maintain an overall 34 foot height. Rather than develop this site with a 40 foot high structure, the developer has proposed a low scale 34 foot building height that is more sensitive to adjacent two story structures. Much of the discussion during the November 14, 1989 hearing focused on whether the City could impose a two story height restriction for the R3 zoned parcel. Planning staff indicated during the hearing that the development of a two story, five unit condominium on this site would result in similar traffic - 4 - . . circulation, noise and shadow projections and that the property owners should not be singled out and thus unfairly restricted in the development of this particular site. The development of a three story, five unit condominium will not affect the public heal th, cultural or aesthetic values and the property owners should be allowed to develop the property under the uniform R3 development standards. The redevelopment of other R3 zoned parcels on Eleventh street should also be subject to the three storyj40 foot height limit. The floor plans show minor revisions that include: 1) orienting the unit entrances toward the south property to project a more low scale neighborhood friendly building design and 2) relocating a second level family room above the second floor to reduce building mass at the second level. Landscaping plans accompanying the site plans indicate landscaping in excess of the code requirement. The proposed five unit, three story condominium building is compatible with the policies and objectives of the Zoning Ordinance and General Plan, and will not result in environmental impacts that require consideration under CEQA. The tentative tract map conforms with the Subdivision Map Act. BUDGET/FINANCIAL IMPACT The recommendation presented in this report does not have any budget or fiscal impact. RECOMMENDATION - 5 - . . It is respectfully recommended that the Council in it's reconsideration of the project, deny the appeal and uphold the Planning commission's approval of CUP 89-046 and TTM 48039 based upon the following findings and conditions: TENTATIVE TRACT MAP FINDINGS 1. The proposed subdivision, together with its prov~s~on for its design and improvements, is consistent with applicable general and specific plans as adopted by the City of Santa Monica. 2. The site is physically suitable for the proposed type of development. 3. The site is physically suitable for the proposed density of development. 4. The design of the subdivision or the proposed improvements will not cause substantial environmental damage or sub- stantially and avoidably injure fish or wildlife or their habitat. 5. The design of the subdivision or the type of improvement will not cause serious public health problems. 6. The design of the subdivision or the type of improvements will not conflict with easements, acquired by the public at large, for access through, or use of, property within the proposed subdivision. CONDITIONAL USE PERMIT FINDINGS 1. The proposed use is one conditionally permitted within the Subject district and complies with all of the applicable provisions of the tlcity of Santa Monica Comprehensive Land Use and Zoning ordinance", in that the 34 foot height pro- posed does not exceed the 40 foot height limit established for the RJ District and in that the 8-12 foot side yard setbacks exceed the minimum 8 foot side yard setback re- quirement, and in that the 50% lot coverage complies with the R3 maximum lot coverage amount and in that the 5 unit density is less than the 6 unit density permitted by right in the RJ District and in that the 13 parking spaces ac- cessed from an adjacent 20 foot wide alley comply with parking requirements established by the Zoning Ordinance. 2. The proposed use would not impair the integrity and character of the district in which it is to be established or located, in that the surrounding neighborhood is characterized by a mixture of pre-1940 and post-1940 mul- tiple family residential structures that conta~n similar - 6 - e . building heights. The location of entranceways, building orientation, outdoor open space, patio areas and landscap- ing will provide an attractive low scale neighborhood sen- sitive development that wi 11 transitionally relate to both pre-1940 and post-1940 structures. The additional set- backs provided along side building walls will reduce the potential for solar access loss for adjacent residential units. The development of five units rather than six will reduce the number of vehicles using the adjacent alley for aces purposes and will reduce the potential for noise or other environmental concerns. Further, the Landmarks Com- mission and Planning Commission fully considered the need to designate the particular development site and surround- ing sites as historical landmarks and determined that the specific site and surrounding collective sites do not qualify for historical designationA There is no evidence at this time to support designating the site or surround- ing neighborhood as landmarks. 3. The subject parcel is physically suitable for the type of land use being proposed, in that the site is located in a developed urban residential area of the City. The topog- raphy of the site can sustain the development proposed. The existing use and proposed use of the site was residen- tial and do not involve the use of materials or substances that could affect the public health, safety or welfare. The three story/ 34 foot height, 5 unit density, 50% lot coverage and setbacks as specified on plans are consistent with the regulations established for the R3 District. The building style, articulation, window and door fenestra- tion, modulation and location of open space and landscap- ing areas are consistent with other developments located along Eleventh Street and in the R3 District. 4. The proposed use is compatible with any of the land uses presently on the subject parcel if the present land uses are to remain, in that the existing owner occupied multi- ple family units located on the site will be removed and replaced with multiple family structures. The residential character of the neighborhood will not be affected or al- tered by the development of the five units. The long term use of adj acent properties, ownership or permanancy of tenants, safety and moral well-being of residents will not be jeopardized by the condominium development. 5. The proposed use would be compatible with existing and permissible land uses within the district and the general area in which the proposed use is to be located, in that the R3 District standards permit a three story building, five unit density ratio and 50% parcel coverage. Proper- ties within a 1000 foot radius of the site have applied similar development standards. The building style, loca- tion of entranceways, location and sizes of patios and open space areas, landscaping, placement and configuration of the building are sensitive to adjacent pre-l940 build- ing uses. - 7 - . . 6. There are adequate prov~s~ons for water, sanitation, and public utilities and services to ensure that the proposed use would not be detrimental to public health and safety, in that the site is located in an urban area that is ser- viced by public utility companies. All utilities are available to the site. The five unit project will not result in a significant increase in the demand for water, sanitation and public utilities. 7. Public access to the proposed use will be adequate, in that the location and size of the parking garage and park- ing spaces have been approved by the Parking and Traffic Engineer and comply with the Zoning Code standards. Park- ing is accessed from the rear 20 foot wide alley and will not require the removal of the streetscape along Eleventh street and will not interfere with pedestrian or vehicle movement along Eleventh Street. The parking garage will be properly lighted and a guest parking space will be pro- vided on site. 8. The physical location or placement of the use on the site is compatible with and relates harmoniously to the sur- rounding neighborhood, in that the 34 foot height, loca- tion and orientation of unit entrances, location and sizes of open space areas and level of building articulation and modulation will provide an acceptable transition between the proposed development and adjacent pre-1940 structures. 9. The proposed and pol icies regulations coverage and use is consistent with the goals, objectives, of the General Plan, in that the R3 zoning permit the height, density, setback, lot type of development proposed. 10. The proposed use would not be detrimental to the public interest, health, safety, convenience, or general welfare, in that the style of development, building height, mass and level of articulation will integrate with surrounding residential development and will not result in visual, audio or traffic related impacts. The use of adj acent properties will not be negatively affected by the develop- ment. The perceived low scale residential sense of security and privacy will not be negatively affected by the development. The sense of neighborhood cohesiveness and compatibility will not be negatively affected by the development. An exemption under the City of Santa Monica Guidelines for Implementation of the California Environ- mental Quality Act was previously granted for the project based upon a determination that the project does not have the potential to cause negative environmental impacts. There is no evidence that suggests the project will cau- senegative impacts and will require environmental review under CEQA. 11. The proposed use conforms precisely to the applicable per- formance standards contained in Subchapter 6, section 9050 and special conditions outlined in Subchapter 7, section - 8 - . . 9055 of the City of Santa Monica Comprehensive Land Use and Zoning Ordinance, in that a performance standards per- mi t is not required for development of the units. The number and location of units proposed do not conflict with this section of the code. 12. The proposed use will not result in an overconcentration of such uses in the immediate vicinity, in that the R3 development standards and General Plan Land Use, Circula- tion and Housing Elements establish the parameters for development of residential units in this neighborhood. The five unit project is not discouraged by the Zoning Code or key General Plan Elements. The proposed develop- ment conforms to District specifications and is compatible with surrounding development. CONDITIONS Plans 1. This approval is for those plans dated 3/1/901 a copy of which shall be maintained in the files of the City Plan- ning Division. Project development shall be consistent with such plans, except as otherwise specified in these conditions of approval. 2. The Plans shall comply with all other provisions of Chap- ter 1, Article IX of the Municipal Code, (Zoning Or- dinance) and all other pertinent ordinances and General Plan policies of the City of Santa Monica. 3. Final parking lot layout and specifications shall be sub- ject to the review and approval of the Parking and Traffic Engineer. 4. Minor amendments to the plans shall be subject to approval by the Director of Planning. A significant change in the approved concept shall be subject to Planning Commission Review. construction shall be in conformance with the plans submitted or as modified by the Planning commission, Architectural Review Board or Director of Planning. Architectural Review Board 5. Prior to consideration of the project by the Architectural Review Board, the applicant shall review disabled access requirements with the Building and Safety Division and make any necessary changes in the project design to achieve compliance with such requirements. The Architec- tural Review Board, in its review, shall pay particular attention to the aesthetic, landscaping, and setback im- pacts of any ramps or other features necessitated by ac- cessibility requirements. - 9 - . . 6. Plans for final design, landscaping, screening, trash en- closures, and signage shall be subject to review and ap- proval by the Architectural Review Board. 7. The Architectural Review Board, in its review, shall pay particular attention to the project's pedestrian orienta- tion and amenities; scale and articulation of design ele- ments; exterior colors, textures and materials; window treatment; glazing; and landscaping. 8. Construction period signage shall be subject to the approval of the Architectural Review Board. 9. Landscaping plans shall comply with Subchapter 5B (Landscaping Standards) of the zoning ordinance including use of water-conserving landscaping materials, landscape maintenance and other standards contained in the Subchapter. 10. Refuse areas, storage areas and mechanical equipment shall screened in accordance with SMMC Section 9040.13-9040.15. Refuse areas shall be of a size adequate to meet on-site need, including recycling. The Architectural Review Board in its review shall pay particular attention to the screening of such areas and equipment. 11. No gas or electric meters shall be located within the re- quired front yard setback area. The Architectural Review Board in its review shall pay particular attention to the location and screening of such meters. Fees 12. The city is contemplating the adoption of a Transportation Management Plan which is intended to mitigate traffic and air quality impacts resulting from both new and existing development. The Plan will likely include an ordinance establishing mitigation requirements, including one-time payment of fees on certain types of new development, and annual fees to be paid by certain types of employers in the City. This ordinance may require that the owner of the proposed proj ect pay such new development fees, and that employers within the project pay such new annual em- ployer fees related to the City'S Transportation Manage- ment Plan. 13. A Park and Recreation Facilities Tax of $200.00 per residential unit shall be due and payable at the time of issuance of a building permit for the construction or placement of the residential unit(s) on the subject lot, per and subject to the provisions of Section 6670 et seq. of the Santa Monica Municipal Code. Demolition - 10 - . . 14. Until such time as the demolition is undertaken, and un- less the structure is currently in use, the existing structure shall be maintained and secured by boarding up all openings, erecting a security fence, and removing all debris, bushes and planting that inhibit the easy surveil- lance of the property to the satisfaction of the Building and Safety Officer and the Fire Department. Any landscap- ing material remaining shall be watered and maintained until demolition occurs. 15. Unless otherwise approved by the Recreation and Parks De- partment and the Planning Division, at the time of demoli- tion, any street trees shall be protected from damage, death, or removal per the requirements of Ordinance 1242 (CCS) . 16. Immediately after demolition (and during construction), a security fence, the height of which shall be the maximum permi tted by the Zoning Ordinance, shall be maintained around the perimeter of the lot. The lot shall be kept clear of all trash, weeds, etc. 17. Prior to issuance of a demolition permit, applicant shal1 prepare for Building Division approval a rodent and pest control plan to ensure that demolition and construction activities at the site do not create pest control impacts on the project neighborhood. 18. Prior to issuance of a certificate of occupancy for this project, the project shall comply with any ordinance adop- ted by the city council to implement Program 10 of the Housing Element. In the event that such an ordinance has not been adopted prior to the issuance of a certificate of occupancy for this development proj ect, this condition shall be of no further force and effect. Failure to adopt and implementing ordinance shall not excuse a developer from the obligation to comply with any other condition imposed in connection with Program 10 of the Housing Element. Construction 19. Unless otherwise approved by the Department of General Services, all sidewalks shall be kept clear and passable during the grading and construction phase of the project. 20. sidewalks, curbs, gutters, paving and driveways which need replacing or removal as a result of the project as deter- mined by the Department of General services shall be re- constructed to the satisfaction of the Department of General Services. Approval for this work shall be ob- tained from the Department of General services prior to issuance of the building permits. - 11 - . . 21. Vehicles hauling dirt or other construction debris from the site shall cover any open load with a tarpaulin or other secure covering to minimize dust emissions. 22. street trees shall be maintained, relocated or provided as required in a manner consistent with the City'S Tree Code (Ord. 1242 CCS), per the specifications of the Department of Recreation and Parks and the Department of General Ser- vices. No street tree shall be removed without the ap- proval of the Department of Recreation and Parks. 23. A construction period mitigation plan shall be prepared by the applicant for approval by the Department of General Services prior to issuance of a building permit. As ap- plicable, this plan shall 1) Specify the names, addresses, telephone numbers and business license numbers of all con- tractors and subcontractors as well as the developer and architect; 2) Describe how demolition of any existing structures is to be accomplished; 3) Indicate where any cranes are to be located for erection/construction; 4) Describe how much of the public street, alleyway, or side- walk is proposed to be used in conjunction with construc- tion; 5) Set forth the extent and nature of any pile- driving operations: 6) Describe the length and number of any tiebacks which must extend under the property of other persons; 7) Specify the nature and extent of any dewater- ing and its effect on any adjacent buildings; 8} Describe anticipated contruction-related truck routes, number of truck trips, hours of haUling and parking location: 9} Specify the nature and extent of any helicopter hauling; 10) state whether any construction activity beyond normal- ly permitted hours is proposed; 11) Describe any proposed construction noise mitigation measures; 12) Describe con- struction-period security measures including any fencing, lighting, and security personnel; 13) Provide a drainage plan; 14) Provide a construction-period parking plan which shall minimize use of public streets for parking; 15) List a designated on-site construction manager. 24. A sign shall be posted on the property in a manner consis- tent with the public hearing sign requirements which shall identify the address and phone number of the owner and/or applicant for the purposes of responding to questions and complaints during the construction period. Said sign shall also indicate the hours of permissible construction work. 25. A copy of these conditions shall be posted in an easily visible and accessible location at all times during con- struction at the project site. The pages shall be lami- nated or otherwise protected to ensure durability of the copy. Environmental Mitigation - 12 - . . 26. Ultra-low flow plumbing fixtures are required on all new development and remodeling where plumbing is to be added. (Maximum 1.6 gallon toilets and 1.0 gallon urinals and low flow shower head.) 27. Prior to issuance of a certificate of Occupancy, project owner shall present documentation to the General services Department certifying that existing Santa Monica occupan- cies with toilets installed prior to 1978 have been retro- fitted with ultra low-flow toilets (1.6 gallons per flush or less) such that development of the new project will not result in a net increase in wastewater flows. Flow from existing occupancies which will be removed as part of the new development may be deducted from flow at- tributable to the new development if such occupancies have been occupied wi thin one year prior to issuance of a Building Permit for the proposed project. Alternatively, proj ect owner may provide a payment to the General Ser- vices Department in an amount specified by General Ser- vices in lieu of the installation requirement, which funds shall be used by the City for the exclusive purpose of achieving compliance with this condition by retrofitting existing occupancies. Flow calculations for new develop- ment and existing occupancies shall be consistent with guidelines developed by the General Services Department. Misce11aneous CUP Conditions 28. The building address shall be painted on the roof of the building and shall measure four feet by eight feet (32 square feet). 29. If any archaeological remains are uncovered during excavation or construction, work in the affected area shall be suspended and a recognized specialist shall be contacted to conduct a survey of the affected area at project's owner's expense. A determination shall then be made by the Director of Planning to determine the sig- nificance of the survey findings and appr~priate actions and requirements, if any, to address such findings. 30. street and/or alley lighting shall be provided on public rights of way adjacent to the project if and as needed per the specifications and with the approval of the Department of General Services. 31. Any lofts or mezzanines shall not exceed 99 square feet unless appropriate required parking is supplied. Such areas shall also not exceed 33.3% of the room below unless compliance with the distric~'s limits on number of stories can be maintained. validity of Permits - 13 - . . 32. The conditional use permit shall be of no further force or effect if the Tentative Map expires prior to approval of a Final Map for said tract. 33. In the event permittee violates or fails to comply with any conditions of approval of this permit, no further per- mits, licenses, approvals or certificates of occupancy shall be issued until such violation has been fully remedied. 34. within ten days of Planning Division transmittal of the statement of Official Action, project applicant shall sign and return a copy of the statement of Official Action prepared by the planning Division, agreeing to the Condi- tions of approval and acknowledging that failure to comply with such conditions shall constitute grounds for poten- tial revocation of the permit approval. By signing same, applicant shall not thereby waive any legal rights appli- cant may possess regarding said conditions. The signed statement shall be returned to the Planning Division. Failure to comply with this condition shall constitute grounds for potential permit revocation. TENTATIVE TRACT MAP CONDITIONS 1. All off site improvements required by the City Engineer shall be installed. Plans and specifications for off site improvements shall be prepared by a registered civil en- gineer and approved by the City Engineer. 2. Before the City Engineer may approve the final map, a sub- division improvement agreement for all off site improve- ments required by the City Engineer shall be prepared and a performance bond posted through the City Attorney's office. 3. The tentative map shall expire 24 months after approval, except as provided in the provisions of California Govern- ment Code section 66452.6 and sections 9380-9382 of the Santa Monica Municipal Code. During this time period the final map shall be presented to the City of Santa Monica for approval. 4. The developer shall provide the Engineering Department of the City of Santa Monica with one Dizal Cloth print reproduction and microfilm of each sheet of the final map after recordation. 5. Prior to approval of the final map, Condominium Associa- tion By-Laws (if applicable) and a Declaration of CC & Rls shall be reviewed and approved by the City Attorney. The CC & R' s shall contain a non-discrimination clause as presented in section 9392 (SMMC) and in the case of con- dominiums, contain such provisions as are required by Sec- tion 9122E (SMMC). - 14 - . . 6. The developer shall provide for payment of a Condominium Tax of $1,000 per saleable residential unit per the provi- sions of Section 6651 et seg. of the Santa Monica Municipal Code. 7. The form, contents, accompanying data, and filing of the final subdivision map shall conform to the provisions of Sections 9330 through 9338 (SMMC) and the Subdivision Map Act. The required Final Map filing fee shall be paid prior to scheduling of the Final Map for City Council approval. 8. The final map shall be recorded with the Los Angeles Coun- ty Recorder prior to issuance of any building permit for a condominium proj ect pursuant to Government Code section 66499.30. 9. Pursuant to section 9366 (SMMC), if the subdivider or any interested person disagrees with any action by the Planning Commission with respect to the tentative map, an appeal or complaint may be filed in writing with the City Clerk. No appeal or complaint may be filed after a ten day periOd from the Commission's decision on the tentative map. INCLUSIONARY UNIT CONDITION 1. The developer shall covenant and agree with the City of Santa Monica to the specific terms, conditions and restrictions upon the possession, use and enjoyment of the subject property, which terms, conditions and restrictions shall be recorded with the Los Angeles County Recorder's Office as a part of the deed of the property to ensure that one affordable unites) is (are) provided and main- tained over time and through subsequent sales of the prop- erty. An affordable unit shall be defined as being af- fordable to households with incomes not exceeding lOOt of the (HUD) Los Angeles County median income, expending not over 30% of monthly income on housing costs, as specified by the Housing Division of the Department of community and Economic Development. This agreement shall be executed and recorded prior to approval of the Final Map. Such agreement shall specify 1) responsibilities of the developer for making the unites) available to eligible tenants and 2) responsibili- ties of the city of Santa Monica to prepare application forms for potential tenants, establish criteria for qualifications, and monitor compliance with the provisions of the agreement. Owner shall provide the City Planning Division with a conformed copy of the recorded agreement prior to approval of the Final Map. - l5 - . . This provision is intended to satisfy the inclusionary housing requirements of Program 12 of the Housing Element of the General Plan of the city of Santa Monica (nprogram 12 It) . Developer may satisfy the obligations created by this Agreement by demonstrating to the Director of Plan- ning compliance with Ordinance 1448 (CCS), which provides implementation standards for Program 12. Prepared by: Paul Berlant, Director of Planning D. Kenyon Webster, Principal Planner Wanda Williams, Associate Planner Planning Division Community and Economic Development Department ATTACHMENTS: Exhibit A- Planning Commission staff Report and Statement of Official Action Exhibit B- Appeal Application Exhibit C- November 14, 1989 Council staff Report and proposed findings for denial Exhibit D- April 10, 1990 Lawrence and Harding Letter WW:ww PC/cccup46 06/19/90 - 16 -