June 30, 2009

June 9, 2009

City Council Meeting:  May 12, 2009

Agenda Item: 7-A

To:                   Mayor and City Council

From:              Eileen Fogarty, Director of Planning & Community Development

Subject:          Ordinance Pertaining to Solar Energy Development and Design Standards)

 

Recommended Action

Staff recommends that the City Council introduce for first reading an ordinance amending SMMC Article IX (Zoning Ordinance), to establish an administrative procedure for approval of solar energy systems that meet objective development standards and to allow solar energy systems to encroach into setback areas and extend above current height limits.

 

Executive Summary

In support of the Sustainable City Plan and the Solar Santa Monica program, staff proposes to amend SMMC Section 9.04.10.02.220 (solar energy system design standards), and other related Zoning Ordinance sections, in order to create a streamlined process for permitting solar energy system installations.  The proposed ordinance would establish objective development standards including specific height limits, limitations on installation in the required side and rear yard setbacks, and restrictions on visibility.  The proposal complies with the requirements of California Government Code Section 65850.5 and Health and Safety Code Section 17959.1, which provide that a city or county shall establish a procedure to administratively approve applications for solar energy installations, and reflect current installation methods for both solar photovoltaic and solar heating systems. In addition to amending the solar energy design standards of the Zoning Ordinance, the proposed ordinance includes minor modifications to four sections of the Zoning Ordinance whose current requirements commonly adversely affect installation of solar energy systems. The proposed language concedes some of the City’s design review procedures to facilitate solar installations.

 

The report also addresses the Landmarks Commission’s jurisdiction over installations on designated landmark properties.  Because single-family residential properties are exempt from ARB review they are not subject to design review for solar installations.  The proposed action has been determined to be categorically exempt from the California Environmental Quality Act (CEQA). The proposed text amendment has no financial or budgetary impacts.

 

Background

The City of Santa Monica encourages and supports solar energy system installation and at the same time longstanding City policy also prioritizes ensuring high quality development that is compatible with the surrounding area.  The City was an early leader in providing design standards to address the special needs of solar energy installations.  However, some of these standards (SMMC Section 9.04.10.02.220) have become outdated over time due to changes in technology, and new installation trends.  Additionally, Government Code Section 65860.5 and Health and Safety Code Section 17959.1 (the Solar Rights Act) provides that a city must administratively approve applications to install solar energy systems through the issuance of a building permit or similar nondiscretionary permit.  In addition, some of the Zoning Ordinance’s property development requirements impose further constraints, which, although unintended, impede some components necessary for solar energy systems.

 

The City offers the Solar Santa Monica program to assist Santa Monica residents and businesses in reducing their energy costs and usage through energy efficiency measures and through installation of solar energy systems.  Through this program, City staff works closely with solar installers as well as residents who have purchased solar energy systems.  As a result of communications with these stakeholders, staff has learned more about how current zoning and building codes and the permit approval process result in impediments to installing solar energy systems.  

 

The Office of Sustainability and the Environment has worked with the Planning & Community Development Department to propose revised solar energy and other property development standards and to revise the Planning and Building permit processes for review and approval of solar energy systems. 

 

 


Discussion

The proposed Zoning Ordinance amendment establishes a streamlined, ministerial process for solar installations. The standards are consistent with current installation practices, such that the vast majority of solar energy system applications would comply and require no further review. Installations meeting these standards would be exempt from discretionary ARB review.  Applications to install atypical solar energy systems, such as elevated solar canopies or other proposals in which the solar energy system’s support structure also functions as a building element rather than solely for energy production, would require review and approval of the Architectural Review Board, or by the Landmarks Commission if the installation is proposed on a designated historic resource. 

 

Additionally, the standards would clarify that all solar energy systems proposed on designated Landmarks and Historic District contributor properties would require a Certificate of Appropriateness from the Landmarks Commission Liaison. Such installations would be evaluated in terms of compliance with the Secretary of Interior’s Standards for Rehabilitation.  Although likely rare, by authorizing the liaison to act for the Landmarks Commission on these applications, the hearing process is not required and the review process can be expedited.

 

The following summarizes the solar energy design standard sub-sections:

 

·        (a) establishes a definition of solar energy systems based on the definition used in Section 801.5 of the California Civil Code. 

 

·        (b) minimizes the visual impact as seen from the front of a property, by prohibiting all of the system’s equipment except solar panels and conduit from being visible along the front street elevation. 

 

·        (c) establishes that solar energy systems may be located on any roof, irrespective of its relationship to the underlying district height limit, up to five feet above the roof surface, or seven feet for solar water and swimming pool heating systems, with additional flexibility given to single-family homes.  This proposed five- or seven-foot exception is consistent with other height limit exceptions in the SMMC and would be adequate for standard solar energy system installations. 

 

·        (d) establishes that solar energy equipment, excluding collectors, may project into side and rear yards but no closer than two feet to any property line, in order to permit equipment to be installed adjacent to existing, non-conforming electric meters.

 

·        (e) requires that solar energy equipment be installed in the location that is the least visible from adjacent streets so long as this does not significantly decrease energy performance or significantly increase cost.  This section also sets forth how such determinations are to be made.  Because single-family properties are exempt from ARB review, they are also exempt from this section.  This Section (e) has been the focus of most public comments and is discussed in-depth below.  Solar energy system placement is also governed by both Building and Safety and Fire Code requirements, which would factor into the feasibility consideration. 

 

·        (f) clarifies that any application to install a solar energy system on a property containing a designated landmark or a contributing structure to a designated Historic District would need to obtain a Certificate of Appropriateness from the Landmarks Commission liaison.

 

·         (g) establishes that any proposed installation that does not comply with the solar energy design standards would require review and approval of the ARB, or by the Landmarks Commission for designated historic properties.  These reviewing bodies may authorize installations that exceed the height limit in the applicable zoning district by a maximum of 14 feet.

 

·        (h) exempts properties from ARB review that are in single-family residential zones and properties in multi-family districts developed as single-family (one unit).

 

 

Section (e) effectively requires the solar installation professional to consider less visible locations that still meet the primary energy production objectives.  This section represents a compromise of the design review standards that are typically applied to commercial and multi-family projects to ensure neighborhood compatibility.  Staff also recognizes that the constraints of Building and Safety Code requirements will also factor into the viability of potential alternative placements.  This is a comprehensive approach that best serves the City’s multiple interests and concerns, streamlines the permitting process, and any further reduction in review is not recommended.  Single-family properties will continue to be exempt from ARB review, including solar installations.  As detailed below, the Planning Commission reviewed and recommended approval of this ordinance with a low significance threshold that would reduce the effectiveness of Section (e).

 

A critical aspect in evaluating where to install photovoltaic systems, especially on an existing building, is the performance of the system.  However, there is no reason that the solar installation professional should not also consider aesthetic aspects when designing a system.  To address this concern while retaining a ministerial review process, the proposed ordinance would require solar equipment to be installed in the location that is least visible from the street, with the provision that energy performance is not significantly reduced or the cost of the solar system is not significantly increased compared to a location that is more visible from the street.  The proposed ordinance would define a “significant decrease” in energy production as more than 10%, while a “significant cost increase” would be defined as more than $2,000 for photovoltaics or more than 20% for solar water and swimming pool heating systems.  Photovoltaic systems installed on single-family homes range from $15,000 to $50,000, with the typical installation cost between $30,000 and $35,000.  Solar water heating systems range from $3,000 to $8,000.  Incentives for renewable energy systems currently reduce these costs by 50% to the home owner.

 

These provisions are modeled on State law, but are more favorable to solar energy to reflect the high priority that the City has set on renewable energy generation.  More specifically, State law permits a Home Owners’ Association (HOA) to impose reasonable restrictions on a proposed solar energy installation if the alternative placement does not decrease production by more than 20% or increase the cost of photovoltaics by more than $2,000, or 20% for water heating systems.  The proposed ordinance is consistent with State law, including Government Code Section 65860.5 and Health and Safety Code Section 17959.1 (the Solar Rights Act).

 

Amendments to the following development standards that currently limit solar installations on many buildings are also proposed:

 

·  9.04.10.02.030 Building height and exceptions to height limit.

   - To create an exception for solar energy systems

   - To exempt solar energy systems from a limitation on the percent of roof coverage.

·  9.04.10.02.070 Reflective Materials

   - To exempt solar energy systems from this requirement

·  9.04.10.02.140 Screening mechanical equipment

   - To exempt solar energy systems from this requirement

·  9.04.10.02.180 Permitted Projections into Required Yards

   - To refer to the solar energy design standards [9.04.10.02.220] in regard to projections of solar energy systems into side and rear yards.

 

Planning Commission Action

On November 5, 2008, the Planning Commission reviewed the proposed zoning text amendment and unanimously recommended approval.  The proposed ordinance includes the Commission’s recommendations to revise sub-sections (c) and (e), clarifying the exempt status of single-family properties and defining visibility in terms of the adjacent streets and not alleys or neighboring properties.  The Commission recommended allowing a higher height limit for solar water heaters, which has also been incorporated into the proposed ordinance.

 

The Commission also discussed “grandparenting” existing solar water heating systems, which can be taller than photovoltaic systems, so that they could be removed and replaced if necessary.  Staff has not included special non-conforming criteria but rather addressed the concern by modifying the proposed ordinance to allow solar water heaters up to seven feet in height, compared to five feet for photovoltaic systems. 

 

On March 4, 2009, the Commission further discussed whether the requirement to install solar equipment in the least visible location on existing buildings to receive over-the-counter permit approval as provided in Section (e) was consistent with state law.  This issue is discussed earlier in this report and on the following page.  After in depth discussion, the Commission supported Section (e), but voted five to one to reduce the significant cost increase thresholds from $2,000 to $500 for photovoltaic systems, and from 20% to 10% for solar water and pool heating systems.  The threshold recommended by the Planning Commission is so modest compared to the typical single-family installation cost, which is between $30,000 and $35,000, that virtually any option would likely be determined to exceed $500, rendering Section (e) less than effective. 

 

Sustainable Cities Task Force

On January 12, 2009, the Sustainable Cities Task Force adopted a recommendation that specific criteria be established that would reduce the potential for solar installations to unnecessarily and significantly impact visibility.  However, the Task Force expressed concern that the criteria set forth in subsection (e) of Section 9.04.10.02.220 of the presently proposed ordinance [the proposed visibility standard] would be contrary to State law and the Sustainable City Plan.  As discussed below, legal staff reviewed this concern and concluded that the proposed ordinance is consistent with State law and City policy.

 

California Health and Safety Code Section 17959.1 and California Government Code Section 65850.5 require that a city or county establish a procedure to administratively approve applications to install solar energy systems and prohibit the local government from exercising discretion to deny these applications unless this denial is based on health and safety requirements.  As required by State law, the proposed ordinance would eliminate barriers to the installation of solar energy systems.  Rather than requiring discretionary review by the Architectural Review Board, the proposed ordinance would establish a ministerial approval process governed by objective standards.  These standards include specific height limits for solar energy systems, limitations on the installation in the required side and rear yard, and restrictions on the solar energy system’s visibility.  As to this latter provision, a solar energy system must be installed in the location that is least visible from abutting streets directly in front of the subject property unless that location would significantly decrease energy performance or significantly increase costs.  The determination of least visible location will be made initially by the solar energy system applicant.  That determination is capable of being approved ministerially based on objective measurements.  The measure for determining whether performance is significantly decreased or cost is significantly increased is objectively defined in the proposed ordinance.  The City does not retain any discretion to require diminished visibility based on aesthetic considerations or any other non health/safety considerations if these objective standards are met.

 

General Plan Consistency

The proposed zoning text amendment is consistent in principle with the goals, objectives, policies, land uses and programs specified in the adopted General Plan. More specifically, the amendments achieve the Conservation Element (1975) goal, calling for “Preservation of the ecological balance and natural resources of the city and conservation of the energies and materials without serious interference with community needs.”  An objective associated with this goal is to “encourage activities and efficient operations which favor energy conservation.”

 

The proposed amendment does not substantially change the City’s approach to encouraging use of renewable energy, but rather clarifies the solar energy design standards and simplifies the approval process, thus promoting this Conservation Element goal and objective.

 

The proposal is also consistent with the City’s Historic Preservation Element, which seeks to protect historic and cultural resources from inappropriate alterations, and lists as an objective to ensure compliance with the California Environmental Quality Act (CEQA).  By requiring a Certificate of Appropriateness for designated Landmarks and contributors to Designated Historic Districts, the proposed zoning text amendment meets this objective and protects the integrity of designated historic resources.

 

The proposed Zoning Text Amendment also supports the objectives of the Sustainable City Plan (SCP) and the LUCE Strategy Framework.  Although the SCP is not a General Plan Element, it provides important policy direction that is also contained in the LUCE Strategy Framework.  Language to support solar energy systems is consistent with the goals of these documents to move Santa Monica toward a more sustainable future.

 

Environmental Analysis

The City’s action to modify requirements and procedures pertaining to solar energy systems is a legislative action subject to the requirements of CEQA.  In accordance with CEQA Guidelines Sections 15060-15061, staff conducted a preliminary review and determined that this project is exempt from CEQA on the following grounds:

 

The proposed ordinance is exempt pursuant to CEQA Section 15061(b)(3) in that it can be seen with certainty that the proposed ordinance does not have the potential to significantly impact the environment in that the amendments are procedural in order to encourage and streamline applications to install small-scale renewable energy systems. Furthermore, the proposed text amendment is exempt based on CEQA Section 15331 in that its provisions protect historic resources based on application of the Secretary of Interior Standards to designated historic resources.

 

Public Outreach

In compliance with SMMC 9.04.20.22, notices of the proposed text amendment for both the Planning Commission and City Council hearings were published in the Santa Monica Daily Press a minimum of 10 days prior to the hearings.  In addition, the Green Building Program Advisor has held a series of meetings with solar energy installers and interested community members to discuss the needs involved in installing photovoltaic and solar water heating systems.

 

Financial Impacts & Budget Actions

The proposed action has no financial or budgetary impacts.

 

Prepared by:

Bruce Leach, Special Projects Administrator, Planning & Community Development

 


 

Approved:

 

Forwarded to Council:

 

 

 

 

 

 

Eileen Fogarty

Director, Planning & Community Development

 

P. Lamont Ewell

City Manager

 

 

 

 

ATTACHMENT:

 

A.        Draft Ordinance

 


ATTACHMENT A

 

DRAFT ORDINANCE