PCD:SF:AS:LBE:F:\PLAN\SHARE\COUNCIL\STRPT\2004\Auto
Dealerships Study Session.doc
Council Mtg:
September 28, 2004 Santa
Monica, California
TO: Mayor
and Councilmembers
FROM: City Staff
SUBJECT: Discussion and Public Hearing Regarding Proposed Policy Revisions Related to Auto Dealership Development Standards in Commercial, Industrial, Residential and Parking Overlay Zones and Discussion of Implementation Options.
INTRODUCTION
This report recommends that the Council review Planning Commission and
staff recommendations regarding changes to the Municipal Code regulations
pertaining to auto dealerships in commercial and industrial zones in the City,
as well as residential parcels and parcels with Parking Overlay (“A”) designations
at existing dealerships. The report recommends that the Council hold a public
hearing and direct staff to draft an interim ordinance for implementation of
revised standards that would apply to auto dealership development pending the
overall revision of the Zoning Ordinance.
Following Council discussion and direction, environmental review on the
proposed amendments will be conducted and the proposed interim ordinance and
associated environmental document will be presented for Council adoption.
Auto dealerships have a long history in the City of
Santa Monica, going back as early as the 1920s, with the establishment of
Claude Short Dodge and W.I. Simonson Mercedes.
By the 1950s and 1960s, a number of other brands were being sold with
dealerships concentrated along a stretch of Santa Monica Boulevard between 9th
Street and the City’s east boundary.
Several used car dealerships and other automotive uses are located in
the City, primarily along Lincoln Boulevard, where such uses also extend into the
City of Los Angeles. Some Santa Monica auto dealerships pre-date the
residential development that now surrounds them, while others pre-date the
intensity of that development. The
combination of higher density residential development and increasing pressure
on dealerships with relatively small land areas has fueled conflict over the
years between auto dealerships and the surrounding residents.
In February 2001, a group of auto dealers,
dissatisfied with the development potential for expansion in their existing
locations or in the nearby vicinity, presented the City with a study prepared
by the consulting firm Hamilton, Rabinovitz & Alschuler, Inc. (HR&A),
(Attachment E). The study outlined the
auto dealers’ concerns with the Zoning regulations and made specific
recommendations for amending the current standards. These recommendations also included proposals for imposing
operational requirements that would apply to existing dealerships. Recognizing
the economic importance for the City of retaining these businesses, the Council
directed the Planning Division to study the auto dealers’ concerns as well as
to analyze conflicts with neighboring residential uses. The consultant team of
Cotton/Bridges/Associates, Moore Iacofano Goltsman, Inc. (for community
participation facilitation) and Economics Research Associates (for economic
background and analysis), were hired to review the HR&A study,
independently evaluate the issues involved and recommend proposals for amending
the City’s policies regarding automobile dealership uses.
The twin goals in this process have been to find
workable, meaningful solutions that provide sufficient incentive for dealers to
invest in improved facilities, while increasing protection of neighboring
residential uses by requiring development and operational standards that
mitigate the adverse neighborhood impacts.
ANALYSIS
The report and recommendations prepared by
Cotton/Bridges/Associates (Attachment C) expand on the information gathered
over the last six months from auto dealers and neighboring residents through a
series of meetings and surveys. The
consultant team met individually with owners of new auto dealerships in May
2003 in order to understand automobile dealership operations more fully. Community meetings were conducted on June 3,
2003, and on October 21, 2003. The
first meeting was to obtain an understanding of neighboring residents’ concerns
and the second meeting was to discuss and obtain comments regarding potential
Zoning Ordinance amendments.
The issues defined through this community outreach
process are summarized in the April 21, 2004 Planning Commission report
(Attachment B).
While the HR&A
report included a comprehensive analysis of the demands placed on auto dealers
due to the economic situation of their industry, staff commissioned an
independent study (Attachment C), conducted by Economic Research Associates
(ERA) to examine the trends in auto dealerships, in order to make certain that the City’s
policy development would be based on an unbiased source (Attachment D). ERA confirmed much of HR&A’s data
regarding the contribution of auto dealerships to the City budget and found
that while Santa Monica dealerships have increased revenue over the last few
years, it has not increased at the rate experienced in larger auto mall
dealerships. The report points to a
pressing need for the City to revise its policies in some way in order to
retain these businesses and their tax contributions in the coming years.
The Planning Commission held two hearings (April 21 and June 2) at which they received staff reports and public input. Speakers at the meetings included both auto dealer representatives and City residents. The discussion was completed on June 16, 2004,with recommendations that are summarized below, presenting both the Commission’s and staff’s recommendations for the Council’s consideration. Additional background on each issue is included in the April 21, 2004 Planning Commission report.
The Commission noted strong opposition to the concept
of developing an auto mall in Santa Monica, and did not believe that the option
of dealership relocation would have great impact. However, they could foresee circumstances in which it would be
acceptable to allow automobile sales, in addition to the repair already
permitted, in these industrial zones and favored allowing but not strongly
encouraging the use. Therefore, they
recommended maintaining the CUP requirement in the LMSD zone and adding the
same entitlement in the M1 Zone.
Staff recommends allowing the automobile sales use in
the M1 District through a Performance Standards Permit (PSP) for projects less
than 7,500 square feet, and requiring a CUP for developments above this
threshold. Staff believes that the M1
zone is at least as appropriate for auto sales as the commercial zones, and
should have the same incentives as the commercial zones for auto dealers
interested in this possibility. Staff favors this approach as providing more
predictability for applicants based on requiring clear performance standards to
ensure compatible development.
Due to the uncertainty regarding the direction of the
LMSD Zone and recent discussions that have taken place on the zone’s character,
staff agrees with the Planning Commission that the CUP requirement should
remain in an Interim Ordinance.
Staff agrees with the Commission’s concerns regarding
auto mall development, which is not compatible with Santa Monica’s
character. Staff does not believe that
allowing some staff-level (PSP) threshold for approval of auto sales development
in the M1 Zone will result in the formation of an auto mall due to high land
costs and lack of available and suitable property in this zone.
The Commission agreed with staff’s recommendation to
remove subterranean uses from the FAR calculation as an incentive to develop
more subterranean space for auto storage and other dealership activities and to
provide flexibility to dealers in utilizing their space. The Commission also
agreed that an FAR of 1.5 was sufficient for auto uses. Although their discussion was not specific,
staff understands that this recommendation was to apply in the C4, C6, LMSD and
M1 zones. Staff recommends allowing a
1.5 FAR for automobile dealerships in all four zones.
Staff also recommends allowing a height bonus to permit one additional story for projects that include at least one substantial subterranean level. Height should be stepped up toward the main commercial street and away from residential uses to minimize impacts on residential neighbors. The Commission did not express concern in their discussion regarding this proposal.
Both staff and the Planning Commission recommend
allowing rooftop parking at all dealerships, exempting this use from
prohibitions against rooftop parking adjacent to residential uses in the C4 and
C6 zones, provided that the rooftop level is screened with a parapet of at
least eight feet in height to reduce noise impacts and protect residents’
privacy. The height of any rooftop
screening should comply with the prevailing Code sections limiting projections
above the height limit.
In regard to stacked parking systems with mechanical
lifts, it is recommended that language be adopted that specifically permits use
of these systems for storage, encouraging them in subterranean garages and
permitting them with screening and a minimum distance from residential uses if
located above ground.
Staff and Commission agreed that development of
parking structures on Parking Overlay “A” lots that are used in conjunction
with existing dealerships should be permitted.
It should be noted that this represents a policy shift in relation to
“A” lot use specifically to encourage retention of the City’s auto dealerships. While staff recommends allowing these
structures based on the height of the underlying zoning, as described below,
the Commission recommended allowing a maximum of 23 feet regardless of
underlying zoning, including screening if rooftop parking is included.
The Commission also recommended setbacks for parking
structures adjacent to residential uses of 10 feet from the side property line
and 20 feet from the rear property line, consistent with the Auto Dealers Task
Force recommendation. The Commission
specified that substantial landscaping should be provided along the side
setback on the residentially abutting side, with security fencing to prevent
access to the area.
The Commission agreed with staff’s recommendation to
permit flexibility to use the parking structures permitted through these
regulations for any vehicle storage or parking use. At the same time, the Commission expressed support for
prioritizing provision of employee parking.
Staff recommends allowing parking structures on “A”
lots to be utilized for either employee and customer parking or auto
storage. In order to encourage
subterranean development and more efficient “A”-lot use, staff continues to
propose allowing auto storage/parking structures subject to the underlying
zoning district height limit, in conjunction with development of at least one
subterranean floor. The underlying
zoning for these lots is either R-2 or R-3, which limit height for flat-roofed
structures to two stories and 23 feet, and three stories and 35 feet, respectively. Staff agrees with the Commission’s
recommendation to allow rooftop parking on these structures within the height
limit, screened with an eight-foot parapet that provides privacy to neighbors
on all sides of the building.
Staff recommends requiring that “A” lot parking
structures comply with the setbacks of the underlying zoning district, with a
maximum side setback of 7 feet and landscaping in the areas adjacent to
residential uses. As the A-lots are
generally 50 feet wide, staff believes that a 10-foot side setback and 20-foot
rear setback would impede provision of required vehicle maneuvering area, while
providing minimal incremental benefit vis-ŕ-vis the relationship between the
structure and the adjacent residential building. In addition, staff is
concerned about the security of the wider, open spaces that extended setbacks
would create. Staff proposes exempting parking dealership structures from
additional multi-family stepback provisions that would present a hardship for
parking structure design. Sides of the
property abutting commercially zoned properties would not require any setback.
5.
Residentially-zoned
“R” lots with existing automobile dealership uses
Citing a long-term historic use of
residentially-zoned lots within auto dealerships, the Planning Commission
recommended that these residential lots should be allowed to be further
developed for use as parking structures, in the same manner as recommended for
“A” lots. The intention would be that
these parking structures could only be used for the adjacent dealership and
would need to be demolished if the dealership use ceased. One suggestion was that dealers post a bond
at the time of construction to be used to finance the demolition. The maximum height to be allowed would be 23
feet, for either two stories or one story with a rooftop level and screening as
described above for “A” lots.
Although staff recognizes
that some individual dealers would benefit from more liberal use of their
residential lots, staff continues to believe that such entitlement is an
undesirable long-term policy, which will permanently erode potential for
neighborhood improvement. Furthermore,
development of auto sales uses on residential properties is contradictory to
the Land Use Element’s goals and policies for multi-family areas. In the context of an Interim Ordinance, the
Council would need to identify a threat to the public welfare that would
justify allowing this inconsistency with the General Plan.
Staff, therefore,
recommends requiring dealerships with both “A” lots and “R” lots to
release the “R” lot in exchange for receiving more development rights on the
“A” lot. However, if there are specific circumstances in which development of a
dealership’s “R” lot(s) would benefit the surrounding neighborhood, the parcels
involved could be considered through the Zoning Map Amendment process for
Parking Overlay “A” designation. If a
parcel is not found to be appropriate for an “A” overlay, it is likewise not
appropriate for long-term development of an auto dealership facility.
Staff also recommends that when any development is
proposed involving a dealership with a residential lot(s) not proposed for
removal, then screening, landscaping and other aesthetic improvements on the
residentially zoned lot should be required as an approval condition to
alleviate some of the noise, light, glare and aesthetic impacts on the
neighboring residential uses.
The Commission embraced the concept of requiring more
specific design standards and allowing development up to 7,500 square feet
based on a Performance Standards Permit in the C4 and C6 zones. Thereafter,
they recommend requiring a Development Review (DR). However, they recommend
that all parking structures on “A” and “R” lots be subject to a DR.
Staff also recommends allowing staff-level approval
through a Performance Standards Permit up to the current DR threshold of 7,500
square feet for the C4, C6 and M1 zones.
As explained above, staff does not recommend allowing construction of
parking structures in R zones, but in cases in which an “A” overlay-zoned
parcel is included within a larger project involving commercially zoned
structures, staff recommends the same threshold of 7,500 square feet for
staff-level approval.
All projects would continue to require Architectural
Review Board approval. The City’s Urban
Designer would review projects at all levels to achieve higher quality design
and improve each project’s compatibility with the neighborhood.
The Commission agreed with staff’s recommendation to adopt a process for issuing Temporary Use Permits (TUPs) for auto dealerships in conjunction with issuance of a building permit for redevelopment of an existing auto dealership. Temporary relocation of repair functions would be allowed only in the LMSD and M1 zones, not adjacent to residences, and the TUP would be valid for long enough to reasonably allow completion of construction, with an opportunity for one 6-month extension. This proposed term of validity is longer than the current Code’s allowance for other temporary uses in order to address the unique situation of auto dealerships, which can be temporarily accommodated on a vacant lot with minimal structure and no additional construction. It is recommended to include operational conditions similar to the performance standards established in the Code, and to require temporary sound barriers if the site is within 100 feet of a residential use.
Also recommended is a short-term TUP process which
would allow quick administrative approval for auto storage in the LMSD and M1
Zones for periods up to three months annually per dealer per location to
provide a legal means for the dealers to facilitate the cyclical needs for
inventory stock associated with auto dealerships.
IMPLEMENTATION
THROUGH AN INTERIM ORDINANCE
Automobile dealership
standards have been under discussion for well over a year and both auto dealers
and their neighbors have developed expectations that these issues would be
addressed in the immediate future. The
Council’s request that staff study the needs of auto dealerships and
neighborhood concerns associated with these uses predates the City’s plan for a
comprehensive review of land use and zoning policies. The General Plan Land Use Element and Zoning Ordinance update
process is now underway, and is anticipated to be a two-year project. In light of this situation, both staff and
the Planning Commission are recommending that the Council adopt an interim
ordinance to immediately revise some regulations, addressing current Code
language that has been discouraging long-term investment in this important
sector of the local economy for too long and thereby delaying enclosure of
operations that would protect surrounding residents. Interim policy would then be reevaluated and refined through the
zoning ordinance revision process.
BUDGET/FINANCIAL
IMPACT
The recommendation presented in this report does not have any budget or financial impact.
RECOMMENDATION
It is recommended that the Council hold a public
hearing and direct staff to conduct environmental analysis in compliance with
the California Environmental Quality Act (CEQA) and prepare an interim
ordinance to implement revised policy regarding automobile dealerships.
Prepared by: Suzanne
Frick, Director
Amanda Schachter, Planning
Manager
Elizabeth Bar-El, AICP, Associate
Planner
City Planning Division Planning and
Community Development Department
Attachments:
A.
Notice of Public
Hearing
B.
April 21, 2004 &
June 2, 2004 Planning Commission staff reports
C.
Policy Recommendation
Report, prepared by Cotton Bridges Associates
D.
Economic Background
Report, prepared by Economic Research Associates
E.
HR & A Report, 2001
ATTACHMENT A
NOTICE OF PUBLIC HEARING
NOTICE OF A PUBLIC HEARING
BEFORE THE SANTA MONICA CITY COUNCIL
SUBJECT: Public Hearing of Proposed Revised Auto
Dealership Standards
The
City Council will hold a Public Hearing on Proposed Policy Revisions Related to
Auto Dealership Development Standards in Commercial, Industrial, Residential
and Parking Overlay Zones and Discussion of Implementation Options.
DATE/TIME: TUESDAY, September 28, 2004, AT 6:45 p.m.
LOCATION: City Council Chambers, Second Floor,
Santa Monica City Hall
1685 Main Street, Santa
Monica, California
HOW TO COMMENT
The City of Santa Monica encourages public comment. You may
comment at the City Council public hearing, or by writing a letter. Written
information will be given to the City Council at the meeting.
Address
your letters to: City Clerk
Re:
Auto Dealership Standards
1685
Main Street, Room 102
Santa
Monica, CA 90401
MORE INFORMATION
If you want more information about this project or wish to
review the project file, please contact Elizabeth Bar-El, AICP, at (310)
458-8341, or by e-mail at elizabeth-bar-el@santa-monica.org. The Zoning
Ordinance is available at the Planning Counter during business hours and on the
City’s web site at www.santa-monica.org.
The meeting facility is wheelchair accessible. For
disability-related accommodations, please contact (310) 458-8341 or (310)
458-8696 TTY at least 72 hours in advance. All written materials are available
in alternate format upon request. Santa Monica Big Blue Bus Lines numbered 1,
2, 3, 5, 7, 8, 9, and 10 serve City Hall.
Pursuant to California Government Code Section 65009(b), if
this matter is subsequently challenged in Court, the challenge may be limited
to only those issues raised at the public hearing described in this notice, or
in written correspondence delivered to the City of Santa Monica at, or prior
to, the public hearing.
ESPAŃOL
Esto es una noticia de una audiencia pública para revisar
applicaciónes proponiendo desarrollo en Santa Monica. Si deseas más información, favor de llamar a Carmen Gutierrez en
la División de Planificación al número (310) 458-8341.
APPROVED AS TO FORM:
___________________________
AMANDA SCHACHTER
Planning Manager
F:\PLAN\SHARE\COUNCIL\NOTICES\2004\Auto
Dealers Study Session.doc
ATTACHMENT B
APRIL 21, 2004 & JUNE 2, 2004
PLANNING COMMISSION STAFF REPORTS
CP:AS:LBE:F:\PLAN\SHARE\PC\STRPT\04\Auto
Dealer Standards Study Session. doc
Planning Commission Mtg: April 21, 2004 Santa Monica,
California
TO: The
Honorable Planning Commission
FROM: Planning Staff
SUBJECT: Study Session to Review and Comment on Proposed Policy and Zoning Ordinance Revisions Related to Auto Dealership Development Standards in Commercial, Industrial, Residential and Parking Overlay Zones.
INTRODUCTION
This report
recommends that the Planning Commission conduct a study session to review and
comment on recommendations regarding changes to the Municipal Code regulations
pertaining to auto dealerships in commercial and industrial zones in the City,
as well as residential zones with Parking Overlay (“A”) designations. The
report recommends that the Commission review staff’s recommended policy changes
and provide comments for City Council consideration. Following Council discussion and direction, environmental review
on the proposed text amendments will be conducted. The proposed ordinance and associated environmental document will
then be presented for Commission consideration and Council adoption.
Auto dealerships have a long history in the City of
Santa Monica, going back as early as the 1920s, with the establishment of
Claude Short Dodge and W.I. Simonson Mercedes.
By the 1950s and 1960s, a number of other brands were being sold with
dealerships concentrated along a stretch of Santa Monica Boulevard between 9th
Street and the City’s east boundary.
Several used car dealerships and other automotive uses are located in
the City, primarily along Lincoln Boulevard, where such uses also extend into
the City of Los Angeles. Some Santa Monica auto dealerships pre-date the
residential development that now surrounds them, while others pre-date the
intensity of that development.
The higher density residential development and
increasing pressure on dealerships with relatively small land areas has
intensified the points of conflict between surrounding residents and the auto
dealerships. Over the years, the City
has received regular complaints regarding dealership operations specifically
with regard to the use of alleys, noise, lighting, glare, off-loading
inventory, test-driving, repair work and customer and employees parking on
residential streets. The overall
parking shortage in the vicinity of the auto dealerships has given rise to
conflicts over use of street parking, resulting in the creation of many
permit-parking zones in the residential streets adjacent to Santa Monica
Boulevard. City staff has also heard on
many occasions that neighbors are dissatisfied with the responses to their complaints
from City Police and Code Compliance.
Often, complaints are hard to document because the source of the
disturbance is no longer present when officers arrive.
The auto dealers have similarly been dissatisfied
with the development potential for expansion in their existing locations or in
the nearby vicinity. In February 2001,
a group of auto dealers presented the City with a study prepared by the
consulting firm Hamilton, Rabinovitz & Alschuler, Inc. (HR&A). The study outlined the auto dealers’ concerns
with the Zoning regulations and made specific recommendations for amending the
current standards. These
recommendations also included proposals for imposing operational requirements
that would apply to existing dealerships. Recognizing the economic importance
for the City of retaining these businesses, the Council directed the Planning
Division to study the auto dealers’ concerns as well as to analyze conflicts
with neighboring residential uses. The
consultant team of Cotton/Bridges/Associates, Moore Iacofano Goltsman, Inc.
(for community participation facilitation) and Economics Research Associates
(for economic background and analysis), were hired to review the HR&A
study, independently evaluate the issues involved and recommend proposals for
amending the City’s policies regarding automobile dealership uses.
The twin goals in this process have been to find
workable, meaningful solutions that provide sufficient incentive for dealers to
invest in improved facilities, while increasing protection of neighboring
residential uses by requiring development and operational standards that
mitigate the adverse neighborhood impacts.
ANALYSIS
The report and recommendations prepared by
Cotton/Bridges/Associates (Attachment B) expand on the information gathered
over the last six months from auto dealers and neighboring residents through a
series of meetings and surveys. The
consultant team met individually with owners of new auto dealerships in May
2003 in order to understand automobile dealership operations more fully. Community meetings were conducted on June 3,
2003, and on October 21, 2003. The
first meeting was to obtain an understanding of neighboring residents’ concerns
and the second meeting was to discuss and obtain comments regarding potential
Zoning Ordinance amendments.
Additionally, auto dealer focus group meetings were conducted on October
9, 2003 to discuss preliminary concepts for Zoning Ordinance amendments. Economic Research Associates (ERA) has
prepared an economic analysis (Attachment C) that examines the trends in auto
dealerships, comparing Santa Monica’s situation with other jurisdictions in
which dealerships are located. This
input has focused and refined the issues that staff’s policy recommendations
aim to address.
Neighborhood issues that were widely cited at the two
community meetings and in surveys and letters include:
o
Misuse of Alleys: Test-driving, deliveries,
unkempt trash, car repair and double-parking, and speeding.
o
Parking Conflicts: Inadequate on-site
customer and employee parking leading to use of residential street parking by
employees and customers. Some of this
has been alleviated through permit parking districts, but some districts have
not been approved and there are reports of employees obtaining guest parking
passes.
o
Noise Impacts: Car alarms, music, loud
speakers, mechanical equipment (particularly compressor-driven tools); lack of
adequate noise barriers between dealerships and residential areas; noise from
idling delivery trucks.
o
Impacts during vehicle
deliveries:
Delivery trucks left running while offloading vehicles; side streets
blocked/impeded by delivery trucks; unconcerned delivery staff; deliveries
during evenings and weekends.
o
Rude employee behavior: Employees undertaking disruptive
activities, speeding in alleys and exhibiting disrespect to protesting
neighbors; lack of follow-up from dealership management when informed.
o
Visual impacts/lighting: Nighttime glare into
residential units; some lighting impacts have been abated through removal of
lights, but conflicts remain, especially where residential windows are oriented
toward open vehicle storage lots.
o
Problems in enforcement of
regulations:
City not responsive in enforcing rules; many incidents happen at night; police
do not respond and say that it is not a priority.
Santa Monica auto dealership owners’ concerns were
generally centered on the challenges they face in adapting to the dynamic
business climate surrounding auto sales.
o
Facility-related concerns: Santa Monica facilities are
smaller than those of newer dealerships in other parts of LA County, which are
preferred by manufacturers; dealers cannot fit all of their sales stock on-site
and must patch together a network of off-site locations for auto storage; dealers
are concerned about their ability to maintain long-term business viability
within present facilities; dealers need to increase repair capabilities because
new car sales are a large part of dealership volume, but profits are in repair;
redevelopment of a dealership places a temporary burden on the business during
construction and the Zoning Code does not allow for issuance of temporary use
permits to keep the business going during construction.
o
Trends to follow: Consolidation of dealerships into large chains selling
several brands of cars; district branding to create identifiable “auto rows,”
such as in Van Nuys and Glendale, allowing dealerships to advertise together
and offer shopping convenience; the unknown impact of internet sales potential;
local competition anticipated from Culver City, Hawthorne, Carson, and for some
brands, Glendale and the San Gabriel Valley; incorporation of rental agencies
within dealerships; growing product lines and “spin-off” brands; manufacturers
requirements for updated signage and improved building appearance to improve
the brand’s image.
Within this shifting environment, the dealers
have viewed the Zoning Code and the City’s planning and building processes as
too restrictive, confusing, time-consuming, and lacking incentive to encourage
them to invest in site improvements.
While the HR&A report included a
comprehensive analysis of the demands placed on auto dealers due to the
economic situation of their industry, staff commissioned an independent study
(Attachment C), conducted by Economic Research Associates (ERA) in order to
make certain that the City’s policy development would be based on an unbiased
source. ERA confirmed much of
HR&A’s data regarding the contribution of auto dealerships to the City
budget and found that while Santa Monica dealerships have increased revenue
over the last few years, it has not increased at the rate experienced in larger
auto mall dealerships. The report
points to a pressing need for the City to revise its policies in some way in
order to retain these businesses and their tax contributions in the coming
years.
Parking Requirements
The Zoning Code requires automobile sales uses to
provide parking as follows:
1
space per 400 sq. ft. of floor area for showroom and office, plus 1 space per
2,000 sq. ft. of exterior display area and requirements for automobile repair
where applicable (2 spaces per service bay), plus 1 space per 300 sq. ft. for
the parts department.
There is no parking requirement associated with
interior automobile storage areas that are off-limits to customers.
Staff’s objective in this review of auto dealership
standards has been to find policy solutions that offer more predictability and
incentive for Santa Monica auto dealerships to redevelop or relocate their
sites within the City. The policy
recommendations are intended to balance the needs of auto dealers and residents
by allowing the dealers to maintain competitive, viable businesses while
reducing or eliminating adverse impacts that nearby residents experience,
including parking, traffic, noise, light and glare. The
HR&A report concluded that the Zoning Ordinance must be revised to allow a
significant increase in FAR and height limits, as already permitted in the
General Plan, in order to meet the spatial needs of auto dealerships. CBA provides a spatial analysis based on
developing a hypothetical 30,000 square foot auto dealership that provides
inventory storage area to meet industry standards. Also examined is the need for increased FAR in combination with a
policy shift encouraging subterranean development. While CBA has reached similar conclusions to HR&A regarding
the need for more floor area on dealership parcels, their study shows that
dealership needs can be met through encouraging subterranean development along
with a smaller increase in allowable FAR and height limits.
The recommendations would result in revisions to the
City’s zoning policies to provide incentive for investment in new facilities
that will improve the City’s commercial corridors where these uses are
clustered, while providing benefit to adjacent residential neighborhoods. Staff requests that the Planning Commission
review the policy recommendations and forward comments to City Council regarding
the following issues:
·
Relocation to
Industrial Conservation District (M1) & Light Manufacturing Studio District
(LMSD)
·
Floor Area Ratio (FAR)
and Height Limit Adjustments
·
Use of parcels in
existing dealerships with Off-Street Parking “A” Overlay District designations
(“A-Lots”)
·
Residentially-zoned “R”
lots with existing automobile dealership uses
·
Approval Processes
·
Temporary Use Permits
Currently, auto sales are not permitted in the M1
District and require a CUP in the LMSD.
Staff proposes to allow auto dealerships in both of these zones and to
raise the threshold for permitting them through a Performance Standards Permit
(PSP) to streamline the process. Staff
proposes to allow height levels and floor area ratios (FAR) in these two zones
that would exceed the FAR to be permitted in the C4 and C6 zones as an
incentive to relocate to the LMSD and M1 Districts. To the extent that existing dealerships are able to relocate
from the C4 district along Santa Monica Boulevard, the Santa Monica Boulevard
parcels will then become available to allow higher quality dealership
redevelopment or new development for other uses. The benefits for residents would thus be experienced both in
relationship to the M1/LMSD development, located sufficiently distant from
residential uses, and in the commercial zones, where a new development would be
required to meet contemporary standards to mitigate impacts on surrounding
uses. Some of the impacts to the
residential neighborhood that would be eliminated or substantially reduced
include noise, light, glare, aesthetics, and use of residential on-street
parking for auto dealership customers and employees.
There are already examples of dealerships that have
moved their repair functions to locations in the M1 Zone, and other potential
relocations that auto dealers have discussed with Planning staff. As this alleviates the impacts on residential
neighbors of commercially zoned dealerships, staff recommends Code changes that
will further facilitate these requests.
Under the current Code, subterranean parking areas are not included as floor area, but other subterranean uses, such as repair, storage and preparation/detailing, are counted fully in determining the project’s FAR. In order to encourage more development of subterranean levels for all uses, staff recommends excluding all subterranean areas from FAR calculations. The dealership could utilize subterranean areas for any function, including employee/customer parking, vehicle storage, vehicle preparation and auto repair.
In conjunction with this policy, some increase in FAR in the C-4 Zoning District is still required as an incentive to develop an auto dealership facility that will meet all needs on-site. Table 3 in the CBA report identifies spatial needs for sales activities, repair, parking and storage for a prototypical dealership under different scenarios. Significantly less above grade FAR was needed when activities are encouraged to be underground; however, some increase in allowable FAR for above-ground development is still required. Based on this information, staff believes that a 1.5 FAR in both the C4 and C6 Zones is justified. Staff believes that an FAR increase of this scale will provide the opportunities for expansion needed without impacting on neighboring properties because it is still relatively low density.
In regard to height, staff recommends allowing a height bonus for projects that include at least one substantial subterranean level. Height should be stepped up toward the main commercial street and away from residential uses to minimize impacts on residential neighbors.
The current auto dealer standards permit rooftop
vehicle storage, discounted by 50% in FAR calculations. However, specific C4 and C6 Zone provisions
prohibit rooftop parking adjacent to a residential parcel or to an alley that
separates residential from commercial uses.
As a result, many dealerships are unable to apply this development
standard.
Rooftop parking that is close to a residential
property line and not properly screened may impact adjacent residential
uses. However, rooftop parking also
offers an opportunity to provide more parking that is relatively inexpensive
for a new development. Further,
screening that blocks rooftop views and ensures residential privacy combined
with setbacks can mitigate its impacts.
Since it appears that even dealerships that provide Code-compliant
parking often need additional parking for their employees, staff recommends
allowing rooftop parking at all dealerships.
Such parking would be designated for customer and employee parking that
exceeds the minimum Code parking requirement.
The regulations prohibiting rooftop parking have been
interpreted to include stacked parking systems with mechanical lifts because
the Code does not include specific reference to these systems. As they are becoming more widespread in use
for vehicle inventory storage, staff recommends adopting language that
specifically refers to use of these systems for storage, encouraging them in
subterranean garages and permitting them with screening and a minimum distance
from residential uses if located above ground.
“A-lots” are parcels that are zoned for residential use, but are permitted to be used for off-street parking in connection with an adjacent commercial business. “A” lots have served to widen the commercial corridors along Santa Monica and Wilshire Boulevards and to a lesser extent along Montana Avenue and Lincoln Boulevard to satisfy the increasing demand for parking. Very limited development is allowed on these lots, which has discouraged any investment or improvement. However, this additional parcel area has become an integral part of the auto dealerships that have A-lots, particularly since the dealerships generally do not have alternatives for expansion in commercially zoned land.
While
commercially zoned parcels are often separated from residential uses by alleys,
A-lots always abut residential properties, resulting in the potential for
direct impact on an adjacent residential use.
Recommendations to expand development opportunities on these lots focus
on providing incentives for dealers balanced with standards to reduce impacts
and improve the quality of life in the neighboring residential area.
Staff
recommends allowing both parking and auto storage in parking structures on “A”
lots, in conjunction with dealership redevelopment. In order to encourage subterranean development and more efficient
“A”-lot use, staff proposes to allow auto storage/parking structures, subject
to the underlying zoning district height limit, in conjunction with at least
one subterranean floor on the A-lot.
The underlying zoning for these lots is either R-2 or R-3, which limit
height for flat-roofed structures to two stories and 23 feet, and three stories
and 35 feet, respectively. Since “A” lots are typically 50 feet wide, it is
likely that an “A”-lot subterranean level would be developed together with a
subterranean level on the adjacent commercial lot. Staff suggests allowing both enclosed upper levels and a rooftop
level for parking structures, provided that rooftop levels are screened with a
parapet that provides privacy to neighbors on all sides of the building. Development on “A” lots would require setbacks equal to the required front
setback of the underlying residential zone, with a design that is compatible as
a transition to the neighborhood.
Further, substantial landscaping would be provided along the side
setback on the residentially abutting side, with landscaping and screening to
provide a greater buffer between the uses. The commercial side would not
require a setback.
13.
Residentially-zoned
“R” lots with existing automobile dealership uses
In addition to A-lots, some dealerships have
residentially-zoned parcels within their site areas that are not Parking
Overlay Zones and extend deeper into the adjacent residential neighborhood.
Section 9.04.18.040, which calls for termination of non-conforming uses,
provides an exception for these lots associated with auto dealerships, allowing
them to remain provided that they are not expanded or enlarged and continue to
serve an on-going commercial use. Any
policy change allowing further development of these residential parcels would
contradict the City’s General Plan, including the recently adopted Housing
Element, which seeks to preserve and expand opportunities for housing in the
City.
Past policies have not succeeded in removing
non-conforming auto uses from residential land. Staff believes that allowing dealerships with both “A” lots and
“R” lots to release the “R” lot in exchange for receiving more development
rights on the “A” lot would benefit both dealerships and the community. Dealership activities would be concentrated
on commercial land and “A”-lot parcels while the “R” lot would lose its
non-conforming status and revert to residential use. New residential structures should be designed to function
compatibly with adjacent auto dealerships, including providing extra insulation
to protect residents from noise.
For development proposals involving a dealership with
a residential lot that does not take advantage of the A-zone incentives and
remove the dealership from the residential zone, staff recommends requiring
screening, landscaping and other aesthetic improvements on the residentially
zoned lot to alleviate some of the noise, light, glare and aesthetic impacts on
the neighboring residential uses.
Table 4 in the CBA report summarizes the approval processes
for establishing or expanding an auto dealership in commercial zones. Staff recommends coordinating and clarifying
Code regulations and increasing the threshold for development through
administrative approval in the C4, C6, LMSD and M1 Zoning Districts. A higher administrative threshold would
benefit smaller dealerships, enabling site improvements based on more specific
performance standards that are appropriate for smaller projects. In the C5 district, the other commercial
zone that allows auto dealerships, staff suggests that the CUP requirement
should remain because this district primarily functions as a concentration of
large-scale office uses. Therefore, a
closer review of a dealership’s operation and design through the discretionary
process to evaluate compatibility is warranted.
Staff recommends defining two levels of auto
dealership standards applicable to projects. Smaller projects that require a
PSP would have operational and physical requirements that are specific,
relatively simple to retrofit, and would absorb impacts of any new
construction. Projects exceeding the
discretionary threshold would need to comply with those standards as well as
other development standards designed to mitigate a larger project’s impacts on
surrounding uses. All projects would
continue to require Architectural Review Board approval. The City’s Urban Designer would review
projects at all levels to achieve higher quality design and improve each
project’s compatibility with the neighborhood.
Automobile dealerships are unique in that parking spaces are needed for both parking and inventory storage. However, although the spaces may look the same, they must be utilized for the purpose that is reflected in a project’s site plan and conditions of approval. There have been cases in which an approved site plan has indicated that an area is to be used for employee and customer parking and, over time, a dealership has begun to utilize that space for vehicle inventory storage. Converting parking into inventory storage violates permit conditions and on a practical level reduces parking for customers and employees, intensifying the competition for street parking.
Dealers have expressed concern that their proposals
for small site modifications might trigger loss of grandfathered non-conforming
rights and require a public hearing. Relocation of uses within the boundaries
of an existing dealership, including both commercially and residentially-zoned
(A-lot) portions, with no associated construction, should be allowed through
administrative approval as long as required on-site parking is maintained in
the revised site plan and administrative development standards are met. This might include relocation of certain
high-impact activities, such as auto repair and preparation, provided that
these uses are relocated farther away from residential uses. Auto dealers have requested this kind of
flexibility, and staff believes that an administrative process should be
offered.
Staff recommends adopting a process for issuing
Temporary Use Permits (TUPs), allowing the repair function in the LMSD and M1
zones only, for auto dealerships in conjunction with issuance of a building
permit for redevelopment of an existing auto dealership. Staff proposes that the TUP be valid for
long enough to reasonably allow completion of construction, with an opportunity
for one 6-month extension. Operational
conditions similar to the performance standards established in the Code should be
specified, and temporary sound barriers should be required if the site is
within 100 feet of a residential use.
Also recommended is a short-term TUP process would
allow quick administrative approval for auto storage in the LMSD and M1 Zones
for periods up to three months annually per dealer per location to provide a
means for the dealers to facilitate the cyclical needs for inventory stock
associated with auto dealerships.
The
auto dealership performance standards and conditional use standards adopted in
1988 included a requirement for existing auto dealerships to submit operational
plans for City approval addressing loading, alley use and test driving. Additionally, all dealerships were required
to comply with new noise control requirements within six months of Ordinance
adoption.
The
City implemented the noise control provisions by prohibiting the use of
loudspeakers at auto dealerships, working with dealers to utilize equipment
that is either less noisy or is muffled with sound absorbing materials, and
restricting the hours during which noisy equipment may be used to 8:00 a.m. –
6:00 p.m., as specified in SMMC 9.04.12.040 (m). The elimination of loud speakers was mentioned several times at
the neighborhood meetings as a noticeable improvement. Most noise complaints were related to
after-hours unloading of automobile inventory on residential streets and to the
lack of police response when complaints were registered.
In
2000, the Transportation Management Division actively pursued compliance of all
existing new and used auto dealers with the requirement to submit test-driving
routes for approval. Dealers are
required to then utilize only their approved operational routes. Over twenty of these plans were approved,
representing many but not all auto sales establishments.
Based
on residents’ testimony during this community process, it is clear that many of
the neighborhood impacts that led to the establishment of Code operational
requirements and their retroactive application to all dealerships still exist. In an effort to address this situation, City
Planning staff has been working with both Transportation Management and Code
Enforcement staff to enforce the requirement for using City-approved
test-driving plans. Letters were sent
in late November to all dealerships reaffirming the Code requirements, with
Code Enforcement follow-up in the last few months.
Staff
believes that many residential complaints can be resolved or substantially
addressed through improved enforcement of the current Code. It does not appear necessary to recommend
any revised requirements to the Code’s operational standards.
RECOMMENDATION
It is recommended that the Planning Commission
conduct a study session on the proposed policy revisions and provide comments
for Council consideration. Following Council
review, environmental analysis in compliance with the California Environmental
Quality Act (CEQA) and proposed ordinance amendments will be presented for
Planning Commission and Council action.
Prepared by:
Elizabeth Bar-El, AICP, Associate Planner
Attachments:
F.
Notice of Public
Hearing
G.
Policy Recommendation
Report, prepared by Cotton Bridges Associates
H.
Economic Background
Report, prepared by Economic Research Associates
I.
HR & A Report, 2001
CP:AS:LBE:F:\PLAN\SHARE\PC\STRPT\04\Auto
Dealerships Continued Study Session.doc
Planning
Commission Mtg: June 2, 2004 Santa
Monica, California
TO: The Honorable Planning Commission
FROM: Planning Staff
SUBJECT: Continued Study Session to Review and Comment on Proposed Policy and Zoning Ordinance Revisions Related to Auto Dealership Development Standards in Commercial, Industrial, Residential and Parking Overlay Zones (Continued from April 21, 2004)
INTRODUCTION
This report recommends that the Planning Commission complete its study session on proposed changes to Zoning Ordinance policies regulating auto dealerships in the City and make recommendations to the City Council. Following Council discussion and direction, staff will conduct environmental review on the proposed text amendments. The proposed ordinance and associated environmental document will then be presented for Commission consideration and Council adoption.
On April 21, 2004, the Commission heard presentations from staff and the City’s consultants regarding recommendations on policy changes pertaining to auto dealerships in commercial and industrial zones in the City, as well as residential zones with Parking Overlay (“A”) designations. The Commission also heard testimony from twelve members of the public, including both auto dealers and nearby residents. In the discussion that followed, the Commission gave some feedback on the proposals and indicated that some of the study’s recommendations should be reviewed comprehensively along with upcoming efforts to revise the General Plan Land Use Element and the Zoning Ordinance. Some additional information regarding “A” lots and coordination with the East-West Parking Corridor Task Force was requested and the hearing was continued.
Planning &
Community Development staff have coordinated the issues overlapping this Task
Force’s work and the Auto Dealers standards study for the last nine
months. Although the recommendations
may vary slightly, staff’s conclusion is that the auto dealerships should be
allowed some development opportunities on the “A” lots to provide enclosed auto
storage. This approach differs from the
recommendation regarding other “A” lots that are not associated with auto
dealerships. The General Plan allows
parking structures to be developed on “A” lots, which could be used for auto
storage, so this proposal is consistent with the General Plan. Due to the particular visual and noise
impacts of the auto dealerships on adjacent uses, staff believes it is
appropriate to make this exception.
Staff conducted a windshield survey of
the current conditions in these two zones to identify potential relocation
sites for dealership and repair activity.
It is assumed that sales facilities require both visibility from a major
corridor (such as Olympic Boulevard or Colorado Avenue) and sufficient area to
accommodate subterranean storage, ground floor display, sales offices and
repair facilities. Repair functions, with sales remaining at existing C4
locations, require less visibility. Therefore, more potential compatible sites
exist.
From the survey, it appears that there
is some current potential in both the M1 and LMSD zones for dealership location
and even more for repair functions, which, it should be noted, is already
permitted and found in both zones. Staff will present a slide show illustrating
the types of sites available in these zones at the Commission meeting.
In both zones, and particularly in the
M1 zone, there are many sites with surface activities and low-scale buildings
that currently are not developed for their highest and best use. Allowing auto dealership as a permitted use
in the M1 zone with additional FAR as an incentive is proposed in order to encourage
auto dealers to locate suitable sites and possibly combine parcels for
development. The proposal would enhance development opportunities, which are
based on many factors in addition to zoning, such as land cost, availability,
and industry trends.
The Commission
requested further information regarding specific dealerships that include
parking overlay “A” lots or residentially zoned lots. Attachment D contains a table showing that out of 21 facilities
associated with auto dealers, there are eight that have “A” lots, ten that have
“R” lots, and six that have both.
When the Council requested that staff study the
needs of auto dealerships and neighborhood issues associated with these uses,
the City did not have plans for a comprehensive review of land use and zoning
policies. Since that time, the Council
has indicated an interest in initiating a comprehensive Land Use Element and
Zoning Ordinance update. This project
has been included in the Division’s Workplan Priorities, which Council will
consider during the May budget hearings.
It is anticipated that the Land Use Element and Zoning Ordinance Updates
will be a two-year project. Staff
agrees with the Commission that the automobile dealership standards and Land
Use Element/Zoning Ordinance efforts should be coordinated in order to ensure a
comprehensive evaluation of the policy issues.
However, the policy study identified automobile
dealer and neighborhood concerns that may require more immediate
attention. The Council asked staff to
consider changes to the auto dealership standards because current Code language
has been discouraging long-term investment in this important sector of the
local economy. In light of the recent
community input on this issue, staff suggests considering incorporating some of
the policy recommendations into an interim ordinance. In turn, this ordinance could be incorporated into the final
zoning ordinance and amended as needed to be consistent with the revised Land
Use Element.
Interim Measures in the LMSD and M1 Zones
Auto repair, the activity within dealerships that
generates the most complaint from nearby residents, is already a permitted use
in the LMSD Zone and auto dealerships are already conditionally permitted in
this zone. The policy study recommends
creating a threshold for administrative approval of automobile dealership
development in the LMSD Zone. As
discussed at the April 21 meeting, the Commission and Council are currently
considering the appropriateness of allowing housing development in the LMSD
Zone, a policy shift that could conflict with encouragement of auto
dealerships. These issues will be
evaluated thoroughly in the Land Use Element Update. Considering the policy
study’s recommendation to facilitate automobile dealership development in the
LMSD Zone in order to shift uses from the commercial corridors, staff requests
that the Commission provide direction regarding interim measures that would be
appropriate in this zone.
In regard to the M1 Zone, the policy study also
recommends encouraging automobile sales by establishing the use as permitted
through an administrative process. As
in the LMSD Zoning District, auto repair is already permitted in the M1 zone,
although auto sales are not permitted.
Staff requests the Commission’s direction regarding introducing
automobile sales as a new use in the M1 Zone through an interim ordinance,
either as permitted or conditionally permitted (CUP).
Interim Measures in the Commercial and Parking
Overlay Zones
Staff recommends incorporating some of the
policies proposed for the C4 and “A” Zones into an interim ordinance to
encourage investment in the next few years that would benefit the businesses
and offer improved neighborhood protection. In particular, any measures that
could help automobile dealers develop subterranean levels, enclose storage and
other activities, decrease reliance on off-site storage and utilize new
technology for stacked parking with appropriate screening should not be
delayed. The City could evaluate the effectiveness of the new policies and
adjust them as necessary during the Zoning Ordinance Revision process.
Santa Monica Auto
Dealers Association Response
Following the April 21 study session, the Auto
Dealers Associate distributed a letter to both staff and the Planning
Commission with their response to proposed policies (Attachment E). The response focused generally on the
dealers’ desire for more liberalized use of their properties in the C4 and C6
Zones as well as their properties in residential zones and on
residential/parking overlay “A” lots.
A major point of disagreement involves staff’s recommendation to allow
parking structures on “A” lots and increase their capacity to meet the
dealerships’ needs but not to extend this entitlement to residential lots
without parking overlay designation, which staff suggests should be removed
from commercial use as a development condition for the rest of the dealership.
Although staff recognizes that some individual
dealers would benefit from more liberal use of their residential lots, staff
continues to believe that such entitlement is an undesirable long-term policy,
which will permanently erode potential for neighborhood improvement. However, if there are specific circumstances
in which development of a dealership’s “R” lot(s) would benefit the surrounding
neighborhood, the parcels involved could be considered through the Zoning Map
Amendment process for Parking Overlay “A” designation. If a parcel is not found to be appropriate
for an “A” overlay, it is likewise not appropriate for long-term development of
an auto dealership facility.
While staff does not necessarily disagree with
the dealers’ point that they could utilize “A” lot structures for dealership
uses other than parking and storage without impacting adjoining residents,
staff did not recommend such use because it would be inconsistent with the
City’s General Plan as it relates to parking overlay districts. Further consideration of this issue should
be folded into the Land Use Element evaluation and revision.
The dealers’ proposed “fourth alternative”
involving a new automobile dealership overlay district relates to the process
for incorporating policies into the Code and Zoning Map rather than to the
substance of such change. Since at this
time staff is recommending an interim solution, staff suggests that
consideration of additional overlay districts be incorporated into the comprehensive
review process.
RECOMMENDATION
It is
recommended that the Planning Commission complete its study session on the
proposed policy revisions and provide comments for Council consideration. If directed by Council, staff would then
prepare an interim ordinance and associated environmental analysis in
compliance with the California Environmental Quality Act (CEQA).
Prepared
by: Elizabeth Bar-El, AICP, Associate
Planner
Attachments:
J. Staff Report
dated April 21, 2004
K. Notice of
Public Hearing
L. Summary of
Commissioners comments at April 21, 2004 hearing
M. Table:
Location of “A” and “R” Lots at Existing Automobile Dealerships
N. Auto
Dealerships Association Response, dated May 11, 2004
Attachment C:
Summary of Commissioners’ Comments,
April 21 Study Session
Commissioner
Johnson:
·
Look at master zoning in LMSD / M-1 districts, consider
segmenting the zone for uses such as housing, automobiles uses and light
manufacturing;
·
Automobile rental function should be included as a permitted
use;
·
Should provide strong incentives for off-site repair services
away from SM Blvd. showrooms;
·
Encourage subterranean parking;
·
Encourage “front-end” public process and meetings with
neighbors;
·Need to be flexible and offer multiple alternatives.
Commissioner Pugh:
·
Automobile sales are often “open-air yard sales” – dealers
need to find better, more up-to-date and sophisticated ways to display and
store inventory;
·
There are cost issues in building subterranean and sometimes
difficulty in trying to dig under an existing building;
·
Incentive for subterranean parking might be permitting the
connection of subterranean parking between lots under alleys;
·
Expressed concern regarding rooftop parking for automobile
dealerships because adding the needed screening would result in the appearance
of a three-story building;
·
Automobile showrooms needs greater interior ceiling height;
·
Agrees that residentially zoned lots should be returned to
residential use when possible.
Commissioner
O’Day:
·
Concerned about auto dealers reaction to the proposed
incentives;
·
Requested the following: a map of improved properties along
the corridors;
·
Other expansion opportunities on Santa Monica Boulevard;
·
Dealers should be encouraged to increase inventory size
on-site;
·
Retain maximum flexibility;
·
Create a fourth option as suggested by Mr. Harding;
·
Agreed with subterranean parking incentives;
·
Must consider potential height impacts on residents in
relation to current problems.
Commissioner
Dad:
·
Land Use Element update should be done before action is
taken on this issue;
·
Likes the idea of placing automobile dealerships on Olympic
Boulevard, impacts of such moves should be considered;
·
Subterranean parking should be excluded from FAR as an
incentive;
·
Agreed with Commissioner O’Day that building heights should
not be allowed to impact neighbors;
·
All options offered by the consultants should be retained, as
well as the option suggested by Mr. Harding, in order to maintain flexibility
and affordability;
·
Return to the Commission with the East/West Task Force
recommendations prior to it being forward to the City Council.
ATTACHMENT C
POLICY RECOMMENDATION REPORT
PREPARED BY COTTON BRIDGES ASSOCIATES
Electronic version of attachment is not available for review. Document is available for review at the City Clerk’s Office and the Libraries.
ATTACHMENT D
ECONOMIC BACKGROUND REPORT
PREPARED BY ECONOMIC RESEARCH ASSOCIATES
Electronic version of attachment is not available for review. Document is available for review at the City Clerk’s Office and the Libraries.
HR & A REPORT, 2001
Electronic version of attachment is not available for review. Document is available for review at the City Clerk’s Office and the Libraries.