ITEM 7-A

Council Mtg:  June 16, 1992

TO:       Mayor and City Council

FROM:     City Staff

SUBJECT:  Appeal  of  Planning  Commission  Approval  of   Tenant
          Participating Conversion 183, 2110 Fourth Street

          Applicant: HR Capital-Rossmore
          Appellant:  D.  Longstreet, L. Auker, M. Hale, L. Gale,
                     L. Privo

INTRODUCTION

This report recommends that the City Council deny the  appeal  to
overturn  the  Planning Commission's approval of TPC 183 and VTTM
50638 for  a  27-unit  Tenant-Participating  Conversion  at  2110
Fourth Street.

BACKGROUND

On March 14, 1991, HR Capital-Rossmore filed Tenant Participating
Conversion  (TPC)  154  for the conversion of a 27-unit apartment
building into condominiums at 2110 Fourth Street.  On August  26,
1991,  TPC  154  was withdrawn by the applicant after claims were
raised regarding the actual tenancy of two co-signers,  Ron  Kane
and Sam Rondazzo, and after tenant Ludmilla Privortskaya (spelled
"Privo" in the appeal) withdrew her support for the project.  The
current  application  for  the same building, TPC 183 and Vesting
Tentative  Tract  Map  (VTTM)  50683,   was   submitted   by   HR
Capital-Rossmore  on  September  13  1991,  and  approved  by the
Planning Commission on May 13, 1992.

On May 22, 1992, an appeal was filed by  five  residents  of  the
subject  apartment building, D. Longstreet, L. Auker, M. Hale, L.
Gale and L. Privortskaya.    The appellants base their appeal  on
several   claims  which  were  also  made  at  the  the  Planning
Commission public hearing.  (Attachment A.)

The appellants question the validity of Ron Kane's  tenancy,  who
signed  Agreement  to  Conversion  ("Agreement")  and  Intent  to
Purchase ("Purchase") forms on July  30,  1992.   The  appellants
claim  that  Mr.  Kane did not begin residency until May of 1991,
less than the required six months before  signing  the  Agreement
and Purchase forms.  Furthermore, the appellants believe that Mr.
Kane has not paid rent for the apartment, which would  disqualify
him  as  a  "Participating  Tenant"  under  the provisions of the
Tenant Ownership Rights Charter Amendment (TORCA).  If Mr. Kane's
signature were found to be invalid, the number of tenants signing
the Purchase forms would fall below the minimum of  50%,  thereby
requiring denial of the application.

In response to questions about Mr. Kane's tenancy, the  applicant
has  provided  staff with a sworn affidavit by Mr. Kane, a letter
from a neighboring tenant, a lease agreement,  and  records  from
Southern  California  Edison  Company (SCE).  (Attachment D.)  In
the affidavit, Mr. Kane states that he "had possession of unit  #
23  for  six  months prior to signing" the Agreement and Purchase
forms.  A  neighboring  tenant,  Stephanie  Gordon,  affirms  Mr.
Kane's  affidavit by stating that she has "witnessed occupancy in
apartment   #23   since   the   beginning    of    1991."     The
applicant-provided  lease  agreement calls out a starting date of
January 15, 1991.

The SCE documentation provided by the applicant casts an  element
of  doubt  on  the  date  Mr. Kane began to reside at unit no. 23
because it indicates a service  start-up  date  of  February  14,
1991,  15  days  after  the earliest day Mr. Kane must have begun
residency for a valid signature, and almost a  full  month  after
the January 15, 1991, date of the lease agreement provided by the
applicant.  The applicant was also  unable  to  provide  canceled
check statements from Mr. Kane, stating that he had paid his rent
in cash which is a violation of the apartment management policies
stated  in  a September 5, 1990, letter included as an attachment
to the appeal statement.   Although  these  issues  raise  doubts
regarding  the  validity  of  Mr.  Kane's  tenancy,  the Planning
Commission concluded  that  the  applicant  has  provided  enough
evidence  to  find  that Mr. Kane resided in his unit the minimum
time required to be a cosigning Participating Tenant.

The appellants have also provided a withdrawal  of  support  from
Ludmilla  Privortskaya,  a  tenant  who  signed the Agreement and
Purchase forms.  Ms. Privortskaya stated she signed in  order  to
get  her  apartment  painted  and  carpeted,  and,  in  a further
explanation filed with the appeal, that she  did  not  understand
what  she  was  signing.  The City Attorney's office states that,
because unit improvements such  as  painting  and  carpeting  are
customary bargaining points when negotiating tenant approval, Ms.
Privortskaya has not  demonstrated  that  she  was  coerced  into
signing,  and  that  her  support at the time the application was
filed should therefore stand.  A subsequent change of heart  does
not invalidate the application.

Prior to the Planning  Commission  public  hearing,  two  of  the
appellants also brought to staff's attention a question regarding
the validity  of  a  statement  signed  by  Gary  Murakami.   Mr.
Murakami  initially  signed  the  Agreement  and  Purchase forms,
withdrew his support for the project on  October  10,  1991,  and
subsequently  reinstated  his  support for the project on January
22, 1992.  (Attachments C and D.)  The appellants informed  staff
that  Mr. Murakami's letter reinstating support was written after
he  had  vacated  his  unit.   However,  because   he   had   not
demonstrated coercion, misrepresentation or fraud by the owner in
his original  letter  of  withdrawal,  staff  believes  that  Mr.
Murakami's original support for the project should stand.

Finally, the appellants  claim  that  the  the  owner  threatened
tenants with eviction pursuant to the Ellis Act if they would not
support the conversion, which would be  in  violation  of  TORCA.
However,  this claim is contradicted in the correspondence of one
of the appellants, David Longstreet, who  states  that  "...Ellis
was  never  threatened  by  the  Applicants,  [although]  it  was
mentioned by the former owner and  in  meetings  for  the  former
owner if her efforts to dispose of the property to the Associates
failed."  (Attachment C, Correspondence dated October  10,  1990,
page 10.)  With the exception of the appellants, no other tenants
have reported the threat of Ellis eviction, and the applicant has
made a sworn declaration that the tenants were not so threatened.
A transcript provided by the appellant of a July 2, 1990  meeting
contains  no reference to the Ellis Act.  Staff believes there is
insufficient evidence to deny the application based on the  claim
that   signatures  were  obtained  based  upon  threat  of  Ellis
evictions.

In another sworn affidavit,  the  applicant  claims  that,  at  a
meeting   held   prior   to   the  Planning  Commission  hearing,
appellants attempted to make a "deal," offering their support for
the  project only if he would sell their units to them for prices
in the $30,000 to $50,000  range,  and  if  the  applicant  would
guarantee  permanent tenancy to Beverly Longstreet.  Furthermore,
the applicant stated that Mr. Hale said that "$200,000 would  buy
[the  applicant]  four votes."  If the applicant's statements are
true, they may have  a  bearing  on  the  Council's  decision  in
weighing  each  side  of the case.  TORCA provides an opportunity
for tenants to negotiate the price of units, improvements,  etc.,
before  the application is filed and Agreement and Purchase forms
are signed.  However, TORCA does not provide a mechanism for this
type of negotiation after an application has been filed.

Conclusion

The appellants have failed to  demonstrate  that  there  was  any
fraud,  misrepresentation  or  coercion on the part of the owner.
Furthermore, the applicant provided sufficient  evidence  of  Mr.
Kane's  tenancy.   Therefore,  staff  recommends  that  the  City
Council deny the appeal and uphold the Planning Commission's  5-1
vote to approve the TORCA conversion at 2110 Fourth Street.

Public Notification

Pursuant to Municipal Code Section 9131.5, notice of the Planning
Commission  and,  upon  appeal,  City Council public hearings was
mailed to all owners and residential and  commercial  tenants  of
property  located  within  a  (300 foot) radius of the project at
least ten consecutive calendar days prior to the hearing.  A copy
of the notice is contained in Attachment F.

BUDGET/FINANCIAL IMPACT

The recommendation presented in this report  does  not  have  any
budget or fiscal impact.

RECOMMENDATION

It is respectfully recommended that the Council review the  facts
and  hear the appellants' and applicant's testimony, and, barring
any evidence which may be presented  indicating  a  violation  of
TORCA  by the applicant, staff recommends that the Council uphold
Planning Commission's approval of TPC 183 and VTTM  50638  for  a
27-unit  Tenant-Participating  Conversion  at  2110 Fourth Street
based on the findings and conditions contained  in  the  Planning
Commission Statement of Official Action.  (Attachment G.)

Prepared by:  D. Kenyon Webster, Principal Planner
              Drummond Buckley, Assistant Planner
              Planning Division
              Land Use and Transportation Management Department

ATTACHMENTS

A.  Appeal Statement
B.  Planning Commission Staff Report
C.  Correspondence in Opposition to the Application
D.  Correspondence in Favor of the Application
E.  Staff Correspondence
F.  Public Notice
G.  Planning Commission Statement of Official Action