Item 8-A

 

Planning Commission Meeting:  June 16, 2004                                 Santa Monica, California

 

TO:                          The Honorable Planning Commission

 

FROM:                    Planning Staff

 

SUBJECT:             Garden of Angels School

 

Address:                1001,1009,and 1010 18th St.

Applicant:                Bambi Forsman, Director, Garden of Angels School.

 

Property Owner:    Church of the Nazarene, Clarence Crites, Pastor

 

INTRODUCTION

 

Action: Application for Conditional Use Permit 03-012 to expand a pre-school to include a school that accommodates kindergarten through 12th grade and Variance 03-024 for an over height hedge and reduction in the number of required parking spaces for the school expansion. With the approval of the variance, the proposal meets all applicable development standards.

 

Recommendation:  Continuation

 

Permit Streamlining Expiration Date:  July 26, 2004

 

SITE LOCATION AND DESCRIPTION

 

The subject property includes two adjacent properties, and a surface parking lot across the street. The Church of the Nazarene, located at 1001 18th Street, is a 9,920 square foot parcel located at the corner of 18th Street with a 62’ frontage on 18th Street and a Washington Avenue frontage of 160 feet.  The adjacent school building and residential site is located on a 9,920 square foot parcel with 62’ of frontage on 1009 18th Street. The surface parking lot site is part of a 19,840 square foot church owned lot across the street that also includes the pastor's residence and the parking lot with a 20-foot driveway accessed from 18th Street. Surrounding uses consist of multifamily residences across Washington Avenue to the north, to the south, and across 18th Court alley to the east in the R2 Zone. Across 18th Street to the west is the related parking lot and single family pastor's residence, also in the R-2 Zone.  Existing on-site uses include the Church of the Nazarene at 1001 18th Street. On the adjacent site, at 1009 18th Street is the former residential one story bungalow schoolhouse and existing one bedroom apartment in a two story accessory structure located over a three bay garage which has been converted to storage and the school office.

 

Zoning District:          R2

 

Land Use District:     Low Density Housing 

 

Parcel Area:              1001 18th Street –9,920 sq. ft.

                                    1009 18th Street – 9,929 sq. ft.

                                                1010 18th Street -19,840 sq. ft.

 

PROJECT DESCRIPTION

 

Proposed Project

 

The Garden of Angels pre-school is located within the church and church owned buildings of the Church of the Nazarene on two adjacent lots at 1001-1009 18th Street.  The proposed project would expand the pre-school to accommodate school-aged children and increase enrollment to have 60 pre-school students, 44 kindergarten through fifth graders, 26 sixth through eight graders and 20 high school age students for an overall student body of 150 students. The school staff would increase from 16 to 20.

 

A Conditional Use Permit is required for the expansion from pre-school  to a private school with grades K-12  in the R2 zoning district. The Variance is required for modification to the off-street parking requirements to allow 22 parking spaces in lieu of the 96 parking spaces required by Code for a multi-grade school. In addition, the Variance request includes a modification to the fence height standards to permit a 12’ hedge in the front yard set back area in lieu of the 42” maximum permitted by Code.

 

Approval of the proposed Conditional Use Permit and Variance would bring the school into compliance with its current operation of approximately 112 students  as well as to allow expansion over the next two years to accommodate kindergarten through grade 12 students, for a total of approximately 150 students.  

 

MUNICIPAL CODE AND GENERAL PLAN CONFORMANCE

 

With approval of the variance the proposed project is consistent with the Municipal Code and Land Use Element as shown in Attachment A.

 

CEQA STATUS

 

The project is categorically exempt from the provisions of CEQA, pursuant to Class 3, Section 15303 (c) of the State Guidelines in that the project entails the conversion of structures totaling less than 10,000 square feet from church use to school use.

 

HISTORIC RESOURCES INVENTORY STATUS

 

The existing buildings on the 1009 18th Street lot were constructed in 1940. The church building on the 1001 18th Street lot was built in 1926 (The Church of the Nazarene). They are not identified in the City's Historic Resources Inventory. No demolition is proposed.

 

RENT CONTROL STATUS

 

Three former residential units are classified as exempt as they are no longer used as rental units. The remaining unit on site is still subject to rent control requirements and will continue to be a rental unit.

 

FEES 

 

There are no additional fees required.

 

PUBLIC NOTIFICATION

 

Pursuant to Municipal Code Section 9.04.20.20.080 and in accordance with the posting requirements set forth by the Zoning Administrator, prior to application filing the applicant posted a sign on the property regarding the subject application.  At least 14 days prior to the public hearing date, the applicant submitted a photograph to verify the site posting and to demonstrate that the sign provides the following information:  Project case number, brief project description, name and telephone number of applicant, site address, date, time and location of public hearing, and the City Planning Division phone number.  A copy of the site posting photograph is contained in Attachment B.  It is the applicant's responsibility to update the hearing date if it is changed after posting.

 

In addition, pursuant to Municipal Code Section 9.04.20.22.050, notice of the public hearing was mailed to all owners and residential and commercial tenants of property located within a 500 foot radius of the project and published in the “California” Section of The Los Angeles Times at least ten consecutive calendar days prior to the hearing.  A copy of the notice is contained in Attachment B.

 

On May 13, the applicant was notified by phone of the subject hearing date.

 

The applicant states that they have attended at least one neighborhood meeting on  September 30, 2003.

 

ANALYSIS

 

Background

 

The original Church at 1001 18th Street was built in 1926. Use Permit (131 U.P.) was issued to convert the single-family house at 1010 18th Street to a parsonage and Sunday School classrooms. In 1979, the Zoning Administrator approved a Use Permit (Z.A Case No. 283-UP) to change the existing Sunday school classrooms at the 1009 18th Street site into a pre-school.  Records show that the three residential bungalows were already used for a school, and were included in the conversion to pre-school by this permit. Garden of Angels Pre-School has been the pre-school operator since 1995. 

 

Conditional Use Permit

 

The pre-school has a State License for 62 children; however, a total of 112 students are enrolled at the school, including 43 kindergarten through fifth graders, 24 sixth through eight graders, and three 9th and 10th grade students (Attachment H - Garden of Angels Pre-school and K-12 handbooks). There are also 16 staff members on site. The proposed project would expand the pre-school to accommodate school-aged children and increase enrollment to 60 pre-schoolers, 44 kindergarten through fifth graders, 26 sixth through eight graders and 20 high school age students for an overall student body of 150 students. The school staff would increase from 16 to 20.

 

The school campus is comprised of facilities located within the church and a church- owned bungalow building on an adjacent lot. There are three classrooms in the bungalow  building, three classrooms in the rear portion of the ground floor of the church, and two classrooms and a dance studio on the second story of the church.  The pre-school is located in the classrooms on the ground floor of the church. A school yard/play area is located between the bungalow classroom building and the south property line. In addition to the on-site classrooms, the school provides a mobile classroom so that 33 grade school students are off site during every school day. The school holds faculty and parent meetings three Tuesday evenings per month with a maximum parking demand of 20 cars. The 2003 -2004 school schedule states that there are 12 evening events such as school performances which use the church nave and end no later than 9:00 pm. The majority of these school events are planned for Thursday and Friday evenings. The schedule also includes one Saturday craft fair per year. 

 

The applicant applied for a Conditional Use Permit and Variance in October 2003 to bring the school into compliance with its current operation as well as to allow expansion over the next two years to accommodate kindergarten through grade 12 students. The school has an unconventional grade system, whereby the children move up a grade each year and  the school expands their programs to accommodate their learning capacity rather than the students moving to another school. In November 2003 the neighbors of the Garden of Angels pre-school forwarded to staff a petition and response to the application for the expansion of the pre-school (Attachment D).  The neighbors cite the traffic congestion, parking, and noise associated with the existing school operations and note that the expansion will amplify these problems.

 

The petition raises a number of concerns about the operation of the school. Staff has reviewed  the concerns and possible solutions where feasible.

 

Traffic congestion

From information provided by the applicant (Attachment F), 38 pre-school students arrive at the school between 9:00 am and 10:00 am and 62 K-12 students arrive at the school between 8:30 am and 9:00 am.  At the end of the day, the pre-school children’s departure is spread out over more time, approximately noon to four.  However, 25 K-12 students depart the school between 4:00 pm and 4:30 pm and 43 depart between 5:00 pm and 6:00 pm. These arrivals and departures represent a significant amount of traffic on this residential street during these hours, particularly since Garden of Angels has no City reviewed and approved student drop- off or pick-up plan in place, or plan to encourage carpools. Furthermore none has been proposed as part of this application.

 

It is possible for the City to designate two curbside loading spaces for drop-off and pick-up which would alleviate some congestion related to pre-school parents parking  in the parking lot across the street and walking their children to the school.  In reviewing the design of the parking lot staff has determined that in its current configuration, with one half of the 20 foot driveway used for parking, the difficulty of entering and exiting  contributes to the drop-off and pick-up congestion. This results in more drivers double parking on the street. Staff believes that with the reconfiguration of the parking lot and a separate exit through 17th Court Alley, drop-off and pick-up circulation could be improved.

     

Parking

There are 22 parking spaces available to the school, 21 spaces are shared with the church in a surface parking lot across 18th Street from the school, and one space is located off the alley next to the rental unit. There is no parking management plan in place at present to maximize the parking on the existing lot. By Code, the pre-school would require 3 parking spaces based upon a floor area of approximately 1,676 square feet. However, the Code requirements for the elementary, junior high and high schools increase the required off-street parking requirement by over 90 spaces. Staff acknowledges the small size of the proposed school operation; however, the 23 available parking spaces would barely accommodate the requirements of the proposed 20 school staff members.

 

When the Church was constructed in 1926 off-street parking was not required.  If constructed today, the church would require 52 spaces, making it legal-non-conforming for parking. At the time the Sunday school was approved in 1970, there would have been no additional parking required as it was considered part of the church use. However, Use Permit 131, which permitted the use of the single-family house as a parsonage and Sunday school classrooms, required that the existing church parking lot of 22 spaces be maintained. Therefore, 22 spaces are required for the church and pre-school combined use.   At the time that the pre-school use was approved in 1979 there was no parking requirement for the use. The parking requirement for the expanded school would be 97 spaces, plus the original 22 spaces of required parking for the school and church, for a total of 119 spaces

 

Staff believes that the parking lot could be reconfigured to allow for a 20 foot entrance driveway, a separate exit, and the addition of eight tandem spaces for staff to alleviate some of the congestion and parking concerns. However, even with the approval of a shared parking plan between the Church and the school, staff does not believe that it would be possible to accommodate all the necessary parking spaces for the proposed project of a full kindergarten through 12th grade school.

 

Noise

The school play yard is located south of the classroom school bungalows toward the street front, adjacent to a multifamily residence on the adjoining lot. This area is proposed to accommodate the outdoor activities of 130 students, including 60 pre-schoolers, 44 K-5th grade students and 26 6th - 8th grade students (the high school students will not likely need a school yard). The area contains picnic tables, play equipment and 2 basketball hoops, and various play elements.  A 4’ gate and fence separates the pre-school play area. An outdoor stage is located behind the bungalow classrooms.

 

The play area directly abuts a multifamily residence to the south for almost the entire length of the shared property line. This is the only area on the subject property available for outdoor activity. The petition and response from the neighbors noted above, which cited noise issues as a concern, was signed by 2 residents of the adjacent building. The neighbors expressed concerns about noise related to amplified music, and "boom boxes" outdoors. The applicant has submitted materials showing that the school has banned the use of electronic noise producing devices.  Since the applicant has not proposed any measures to attenuate the noise impacts from the school play activities, staff believes that the school expansion will exacerbate the noise impacts from the Garden of Angels, particularly on this adjacent multifamily residence. In addition, the increased traffic generated by the school during the mornings and afternoons also leads to adverse noise impacts on the neighborhood.

 

Special Events

The school holds approximately 12 evening events per year.  One of the concerns expressed by the neighborhood is related to parking problems and traffic congestion during evening events. Since the original concerns were expressed by the neighborhood, the applicant has split all-school events over two nights to reduce the number of cars per evening.  Staff believes that approval of any expansion  would require conditions related to special events such as advance notification of the neighbors, valet parking, and a restricted number per year. The applicant has not proposed any measures to regulate special events as part of this application. 

 

Litter

In the petition neighbors have expressed concerns about school related litter in the parking lot, alley and 18th Street frontage.  Again, the applicant has stated their efforts to address these concerns, however there are still large items stored in the alley parking space, and a non-conforming trash receptacle area. Any expansion of the school would require that the trash arrangements be brought up to code. 

 

Formal Code Compliance complaints have also been filed related to trash and debris behind the school and in the alley which have since been rectified.

 

Intensity of Use

The current owner has an approved State License for 62 pre-schoolers but recently applying for a reduction in that amount, for a total of 43 pre-schoolers. The State Licensing officer has not approved all areas designated for the pre-school in the CUP application. If the applicant chooses to pursue approval for the number of pre-school students as listed  in the CUP application, a different classroom configuration will have to be approved by the Licensing Program Analyst. Staff is concerned by the inconsistency between the State approved pre-school location and CUP application for 60 students. It is difficult to evaluate parking requirements and craft appropriate conditions for the pre-school and school-age combined use without a definitive arrangement of classrooms and fixed square footage assignments per use and because the potential expansion of the pre-school to include a school is to some degree determined by the State Licensing requirements for the pre-school. Staff expects a completed report from the State Licensing officer by the time of the June 16 Commission hearing. 

 

There are inconsistent records on the past use of the site. The applicant has submitted information showing that the prior operator of the pre-school was approved for 74 students. There is anecdotal evidence that this operator also included a school age program that may have resulted in as many as 120 students on site. The applicant has stated that at the time of the initial complaints in 2002 there were 135 students, but that in response to neighborhood concerns, the number of over-all students has been reduced to 112. It should be noted that there are no complaints in the City files (which extend back to 1992) prior to the un-permitted expansion to include school–age children.  Staff believes that the size of the site, the proximity of the neighbors to the only available play area, the configuration of the current classrooms, particularly the small size of the bungalow classrooms, and limited parking, make this site unsuitable for the proposed expansion to 150 students.

 

Code Enforcement

The approved use at the site is a pre-school. However, in 2000 the pre-school expanded to accommodate kindergarten through tenth grade students. A complaint was filed in 2002 regarding the school’s operation. The original business license application is for a pre-school. However records show a business license tax receipt for the school and pre-school use in 2003. In 2003 the applicant was cited for operation of a school without the required Conditional Use Permit in the R2 zone, for fire safety issues related to the exiting and fire rating requirements of some of the classrooms, and for an over-height hedge in the front yard. There is also an existing rental unit on site that is located above three single garages which have been converted to storage for the church without proper permits (Attachment  C - Compliance Letter). The current owner did not understand that a CUP was required to expand the pre-school operation to a school that accommodates upper grades. As a result of a code enforcement action, the applicant filed a CUP application to expand the school as well as a variance to allow for the existing over-height hedge in the front yard and a modification to off-street parking requirements associated with the proposed expanded school use. In addition to the CUP and Variance applications, the applicant has filed a plan check for the necessary Building Code improvements for the current occupancy. It is expected that a building permit will have been issued to make these required renovations by the time of the Planning Commission meeting. The school is currently operating under fire watch until the necessary Building Code improvements have been made. The number of students at Garden of Angels has also been reduced from 135 students to 112. 

 

During the enforcement inspections, it became apparent that the church building will need additional Building Code upgrades to allow for the school operation on the upper floors of the church.  These improvements include additional building and safety requirements such as the installation of sprinklers, exiting improvements and a seismic upgrading. The applicant has not filed a plan check for these improvements pending action on the CUP and Variance applications.

 

Staff believes that if any expansion is approved, construction time frames must be established for the necessary improvements such that the school will not function under unsafe conditions.

 

Variance

 

Parking

Staff has consistently calculated parking spaces for other schools that include pre-schools and grades K –12 based upon the parking requirements for each type of school.   For a high school, the required parking amount would be 50 spaces with four additional spaces for each classroom; junior high schools require 30 spaces with one additional space for each classroom; and elementary schools require 10 spaces and one additional space for each classroom. The Code required parking for the proposed project would require a minimum of approximately 96 spaces.  While this is a comparatively small school with small class sizes in the older grades, and flexible shared classroom use with teachers who teach more than one grade level, the applicant has not provided a plan for the shared use of the limited number of parking spaces available to the church and the school. 

 

The project proposes to provide 22 off-street parking spaces. 21 spaces are shared with the church located directly across 18th Street from the school entrance. In addition to the parking lot, there are two spaces on the subject site accessed off the alley - one of them designated for the school office and one designated for the rental unit on-site.

 

The construction of the Church in 1926 did not require off-street parking. By current standards the existing church with 200 fixed seats and 662 square feet of related office space requires 52 parking spaces. If these uses were constructed today, they would require 148 total parking spaces.

 

The church conducts services on Sundays from 7:00 am to 2:30 pm. The Church schedule states regular use of the parking lot outside of Sunday Services includes:

 

·        Sunday evenings from 5:00 pm to 9:00 pm

·        Wednesday Evenings 6:30 pm -9:30 pm

·        Frequent activity Thursday Evenings 6:30 pm -9:30 pm

·        Friday Evenings 6:30 pm -9:30 pm

·        Frequent use on Saturdays

 

The operating hours of the school are 7:00 am to 6:00 pm Monday through Friday, with once a month staff or parent meetings.  Both the applicant and the Church pastor state that they co-ordinate calendars to insure there is no overlap of events unless there is a funeral.

 

Staff  believes that the lot could be re-striped and tandem parking could be allowed with a parking management program to provide eight additional spaces in tandem for a total of 31 parking spaces available to the school on a shared basis. However, 31 parking spaces are less than 1/3 of those required by Code for the school expansion.  With 20 proposed staff members, only 11 spaces would be available to parents, visitors and high school students who would drive to the campus.  In addition, there appears to be the potential for conflicts for the shared parking spaces between after-school events and regular church use on the 12 school event evenings (mostly Thursday and Fridays) per year and when funerals require use of the parking lot.

 

Hedge

The Zoning Ordinance allows for schools to have chain link fences up to eight feet tall in the front yard. The subject site has an approved variance (ZA 4977 Y) for a six-foot high fence in the front yard setback area. The design of the fence with a hedge was approved in 1986 (ARB2955). In the intervening years the hedge has grown higher than the permitted 42 "  for a hedge. The current applicant received an ARB sign approval for signs supported by the over height hedge in March 2003. The hedge has grown to a height of 12 feet.  As the hedge is located at the edge of the playground along the edge of the basketball court, staff believes that the over-height hedge has a benefit to the neighborhood by preventing balls from bouncing over the hedge into the street. In addition, the hedge adds greenery to the streetscape and provides visual privacy for both the school and the neighborhood so that passersby cannot see play equipment and children playing. Both of these benefits could be accomplished to an acceptable degree with the approved 6 foot high fence, however the hedge is an attractive addition to the streetscape and does not provide any hazardous visual obstruction.

 

Neighborhood Compatibility

 

Staff believes that the proposed school expansion is not compatible with the neighborhood.  As evidenced by the complaints filed in the past and the petition and response to the application from the nearby residents, the unauthorized expansion of the pre-school in 2000 has brought parking problems, traffic congestion and noise impacts. There are no records of complaints at the subject site prior to the expansion.

 

The proposed parking for the school includes 21 spaces in a surface parking lot which is shared with the church. Although improvements could be made to the parking lot to accommodate more vehicles, staff believes that there is insufficient parking for the full school program and the church together. This could lead to adverse impacts on on-street parking.

 

According to information provided by the applicant, 62 school age children arrive at the school during the 30 minutes between 8:30 am and 9:00 am, which is a significant amount of traffic generation on this residential street.  Traffic congestion also occurs during the afternoon hours when students are picked up from school.

 

The proposed outdoor activity area for all 150 students is located adjacent to a multifamily residence and cannot be re-located on the campus. An outdoor stage is also located behind the church.  The noise generated by the outdoor activities of these students will have significant noise impacts on the adjacent residence, a 6-unit apartment building built in 1968, which is located less than 10’ from the play area.  In addition, the amount of traffic generated by the school will also have adverse noise impacts on the neighborhood during the morning and afternoon hours when children are dropped off and picked up from the school.  The applicant has not proposed any measures to mitigate noise generated in this are other than the regulation of electronic devices.    

 

Conclusion

 

Staff is concerned that although the over height hedge has the benefits of providing a restraint from bouncing balls, and is an attractive addition to the streetscape, it is not necessary for it to be higher than the previously approved 6 foot fence. Trimming the hedge to the required 42" hedge height would require revisiting the current approved signage for the school, as it is supported by the over height hedge.

  

Staff cannot support the conditional use permit and parking variance for the expansion of the pre-school to accommodate grade school students from kindergarten through 12th grade.  From the petition and response from the neighbors on 18th Street and 19th Street, there are clearly issues with respect to traffic congestion, parking and noise from the existing school operation and a fear that these problems will only get worse with a school expansion of approximately 90 students and 13 non-pre-school staff. Parking, traffic congestion and particularly noise will remain a burden on the neighborhood. There appears to be significant traffic congestion in the neighborhood resulting from the school operation, particularly during the morning.  The subject site has little area for outdoor school activities and what exists directly abuts an existing multifamily residence. Staff believes that allowing the full expansion of the Garden of Angels pre-school would aversely affect the neighborhood.

 

However, staff believes that some expansion of the pre-school to include elementary school children (K-5) may be possible, if the expansion is approved with appropriate conditions that respond to the neighborhood concerns. Key components to make this decision would include:

·        Clarification on the configuration, square footage, and separation of classrooms and outdoor area designated per each use pursuant to the requirements of Community Care Licensing

·        Decreased overall number of students

·        A drop-off and pick up plan

·        Carpool plan

·        Reconfiguration of the parking lot with exit to 17th Court alley

·        Approval of curbside passenger loading

·        A reduced special event program with viable traffic controls

·        A shared parking plan

·        Construction time frames for required Building and Safety improvements.

 

ALTERNATIVES

 

Other than the recommended action, the Planning Commission may:

 

Approve CUP03-012 and Variance 03-024 based upon revised findings and conditions;

Deny CUP03-012 and Variance 03-024 without prejudice, based upon revised findings; or

Deny CUP03-012 and Variance 03-024 based upon revised findings.

 

RECOMMENDATION

 

Continue the hearing to a date certain for clarification of project description and inclusion of additional information to address the concerns identified.

 

 

Prepared by:  Sarah Lejeune, AICP, Associate Planner

 

Attachments:

 

A.     Municipal Code and General Plan Conformance

B.     Site Posting Photo, Notice of Public Hearing, Radius and Location Map

C.    Compliance Letter from Building and Safety Division

D.    Petition and response to application from Neighbors

E.     Correspondence

F.     Student Arrival and Departure Schedule

G.    Photographs of Site and Surrounding Properties

H.     Garden of Angels Pre-school and K-12 Handbooks

I.    Plot Plan, Floor Plans and Elevations

 

 

 ATTACHMENT A

 

 MUNICIPAL CODE AND GENERAL PLAN CONFORMANCE

 

 

CATEGORY

 

 

LAND USE ELEMENT

 

MUNICIPALCODE

 

 

PROJECT

 

Permitted Use

 

---

 

R2

Schools and Day Care Centers (pre-schools) are permitted in the R-2 Zone with a CUP.

 

9.04.08.06.040(c)(l)

 

 

Existing Use permit from 1970 permitting Sunday School classrooms, Use Permit allowing conversion of residential unit to pre-school.

 

No CUP for a school, Does not comply

 

Dwelling Units

 

---

 

1/1500 Parcel Area

13 permitted for 1001 and 1009 18th Street

 

1 rental unit at 1009 18th Street

 

Height of Building

 

---

 

30 feet

 

30 feet

 

Number of Stories

 

---

 

2

 

2

 

Height of Walls, Fences

 

N/A

 

Allows an 8 foot high chain link fence with a variance for a school

 

6 foot high chain link fence approved with variance ZA 4977 Y, 12 foot hedge does not comply, needs variance.

 

Lot Coverage

 

N/A

 

 

 

 

 

 

Parking Access

 

Alley access is encouraged when alley exists.

 

Alley access is required when alley exists, with exceptions per Sec. 9.04.10.08.080.

 

Parking lot is across the street. Two parking places off alley, on site.

 

Parking Space Number

 

 

N/A

 

Pre-school 1 space per 500 sf

1676/500=3.3

K-5: 10+1 per classroom=12

6-8: 30 + 1 per classroom=31

9-12: 50 + 4 per classroom+54

School-100

 

Church: 1 per 4 fixed seats.

200/4=50

638 sf office@1/300=2

Church-52

 

152 total

 

 

22 existing approved for pre-school and Church

 

 

Requires 97 additional spaces for expansion

 

Existing Non-conforming, expansion requires variance.

 

 

Compact Parking %

 

N/A

 

40%

40% x 22+8.8

 

3

Complies

 

Loading Spaces

 

N/A

 

2

 

None          

Does not comply

Needs curbside loading

 

Trash Area

 

N/A

 

Trash enclosure with minimum 5'- 8' solid walls and gate is required.

 

Existing non-conforming trash area would be required to comply with the approval of expansion.