HomeMy WebLinkAboutCorrespondence between 1230PM and 530PM July 20, 2020City of Orange
Community Development Department
Memo
To: Chair Simpson and
Members of the Planning Commission
e
Thru: Anna Pehoushek, Assistant Community Development Directo
From: Robert Garcia, Senior Planner F j
Date: July 20, 2020
Re: Planning Commission Meeting of July 20, 2020
Staff is forwarding correspondence received from interested parties on the proposed Mabury
Tentative Tract Map Project from 12:OOPM to 5:30PM on July 20, 2020.
Printed on recycled paper
Robert Garcia
From:
Frank Sun
Sent:
Monday, July 20, 2020 3:58 PM
To:
Robert Garcia
Cc:
Gary 5heatz
Subject:
Mabury Avenue Existing Trail and Easement
Hi Robert,
In early March MMarch 4`h) I had some email exchange with Mr. Tom Broz regarding the existing trail along Mabury Avenue. At
that time, no detailed development information was available, so I informed Mr. Broz that the existing trail will remain because
it's located in the City's street right-of-way. The Tentative Tract Map #118163 was presented to the SMART Committee April 1"
and as part of the development, a new trail easement would be dedicated to the City and located to the south of the
development. Last week, the existing trail easement question was again brought up by Mr. Broz and I provided Mr. Broz with the
proposed TTM #18163 and informed Mr. Broz that with the new alignment of the trail, the existing trail along Mabury will no
longer be needed and the development has shown a sidewalk along Mabury Ave instead.
5�,ti, P. E.
Assistant PW Director/City Engineer
Public Works Department
t714)744-5529
oCity ud
range
YIMBY Law
125o Mission 5t
San Francisco, CA 94103
hello@vimbylaw.org
7/20�2020
Orange Planning Commission
300 E. Chapman Ave.
Orange, CA 92866
PCpubliccomment@city_oforano.org; pcoleman@cityoforange.org;
Via Email
YIMBY LAW
Re: South Side of Mabury Avenue Between Orange Park Boulevard and Cannon Street
Tentative Tract Map No. 0050-20, Minor Site Plan Review No. 1o1b-20
Dear Orange Planning Commission,
YIMBY Law submits this letter to inform you that the Planning Commission has an obligation
to abide by all relevant state housing laws when evaluating the above captioned proposal,
including the Housing Accountability Act (HAA).
California Government Code § 65589.5, the Housing Accountability Act, prohibits localities
from denying housing development projects that are compliant with the locality's zoning
ordinance or general plan at the time the application was deemed complete, unless the locality
can make findings that the proposed housing development would be a threat to public health
and safety. The most relevant section is copied below:
(j) When a proposed housing development project complies with applicable, objective general plan
and zoning standards and criteria, including design review standards, in effect at the time that the
housing development project's application is determined to be complete, but the local agency
proposes to disapprove the project or to approve it upon the condition that the project be developed
at a lower density, the local agency shall base its decision regarding the proposed housing
development project upon written findings supported by substantial evidence on the record that
both of the following conditions exist:
(t) The housing development project would have a specific, adverse impact upon the public
health or safety unless the project is disapproved or approved upon the condition that the
project be developed at a lower density. As used in this paragraph, a "specific, adverse
impact" means a significant, quantifiable, direct, and unavoidable impact, based on
objective, identified written public health or safety standards, policies, or conditions as they
existed on the date the application was deemed complete.
(2) There is no feasible method to satisfactorily mitigate or avoid the adverse impact
identified pursuant to paragraph (1), other than the disapproval of the housing development
project or the approval of the project upon the condition that it be developed at a lower
density.
(4) For purposes of this section, a proposed housing development project is not inconsistent
with the applicable zoning standards and criteria, and shall not require a rezoning, if the
housing development project is consistent with the objective general plan standards and
criteria but the zoning for the project site is inconsistent with the general plan. If the local
agency has complied with paragraph {2), the local agency may require the proposed housing
development project to comply with the objective standards and criteria of the zoning which
is consistent with the general plan, however, the standards and criteria shall be applied to
facilitate and accommodate development at the density allowed on the site by the general
plan and proposed by the proposed housing development project.
The applicant proposes to subdivide an approximately 15.4-acre site into 22 single-family
residential lots on approximately 10.9 acres and open space dedication of approximately 4.5
acres along the Santiago Creek corridor.
The above captioned proposal is zoning compliant and general plan compliant, therefore, your
local agency must approve the application, or else snake findings to the effect that the
proposed project would have an adverse impact on public health and safety, as described
above.
Yimby Law is a 501(c)3 non-profit corporation, whose mission is to increase the accessibility
and affordability of housing in California.
I am signing this letter both in my capacity as the Executive Director of YIMBY Law, and as a
resident of California who is affected by the shortage of housing in our state.
Sincerely,
&Ar
1
Sonja Trauss
Executive Director
YIMBY Law
YIMBY Law,1260 Mission St, San Francisco, CA 44103
COX CASTLE Cox, Castle8:reet,S ite 200
50 California street, Suite 32U0
� I C H � L 5 C� � son Francisco, California 9411 I -4710
1h P:415.262.5100 F:415.262-5199
Michael H. Zischke
415.262.5109
m zi sc hk e@coxcast le.com
File No. 082654
July 20, 2020
VIA ELECTRONIC MAIL
Planning Commission
City of Orange
300 East Chapman Avenue
Orinda CA 92866
Re, TTM No. 0050-20, Minor Site Plan Review No. 1016-20, Environmental
Review No. 1871-20 - Response to Legal Points Submitted by Mr. Thomas Broz
Honorable Chair and Commissioners:
This letter responds to the legal and procedural issues raised in the letter
submitted this inorning by Thomas Broz, asking that the Commission's consideration of these
matters be continued to a later date. As explained below, the points in Mr. Broz's letter do not
provide any basis for continuing the hearing on these matters, and it is entirely appropriate for
the Commission to proceed with the hearing this evening.
Mr. Broz references the pending referendum of the previously approved Trams at
Santiago project, suggesting these actions should be delayed until after the referendum vote. The
legal effect of the submission of the referendum per Elections Code section 9241 is to suspend
the previously approved general plan amendment, and that is all that it does, it does not freeze all
action on the property, and it is not a moratorium. Further, during the pendency of the
referendum, the City is free to consider development proposals that are "substantially dissimilar"
to the referended action. Lindell v. Town o f'San Anselmo (2003) 111 Cal.App.4th 1099 [when a
measure is pending, city may not re -adopt substantially the same measure, but may adopt a
different measure]. In Lindell, the court stated that the referendum provisions of the Elections
Code do "not tie a legislative body's hands entirely. It does not prevent a legislative body or a
city council from adopting any measures involving the same subject matter. In determining
whether a subsequently enacted ordinance violates the stay provisions of [the Elections Code],
we ask "whether the second legislative enactment is essentially the same as the first." This case
Planning Commission, City of Orange
July 20, 2020
Page 2
also cited an earlier referendum decision which held that a referendum does not bar approval of
"substantially dissimilar" development. Reagan v. City of Sausalito (1962) 210 Cal.App.3d 618.
Here, the tentative tract map is an entirely different development than the much larger Trails at
Santiago project, and the City and Commission are free to proceed.
Mr. Broz asks why the City would accept another project application when there is an
approved project for this site. The prior Trails at Santiago approvals are not now in effect,
however, based on the submission of the referendum petition. Elections Code 9241 [the plan
amendment "shall not become effective until a majority of the voters voting on the ordinance
vote in favor of V]. As stated in the resolution before this Commission, if these new
applications are approved, the new approval by its own terms will disappear if the voters approve
the Trails at Santiago project at the November election.
Mr. Broz also references the certified environmental impact report for the project.
Notably, the City's ability to use an addendum to the prior EIR is not affected by the referendum,
or the pending litigation against the EIR. Unlike a general plan amendment and land use
approvals, certification of an EIR is an administrative act not subject to referendum. Also, by
statute, an EIR under legal challenge is presumed adequate until a court rules otherwise. Public
Resources Code §21167.3. The CEQA Guidelaies and case law confirm that the City and
applicant can move forward with additional approvals. CEQA Guideline 15112(b); Kriebel v.
Citv Council (1980) 112 Cal.App.3d 693, 702. In Kreibel, the court specifically considered the
ability of a city to process a subdivision map with litigation pending over the EIR, and the court
held that "the city and Nielsen were at liberty to proceed with the processing of the subdivision
map" and the approval of the map in that case withstood challenge.
We appreciate the Commission's attention to these points.
Sincerelv.
Michael H. Zischke
MHZ
cc: Gary Sheatz, City Attorney
Robert Garcia, Senior Planner
Milan Capital
Frank Elfend
682654111806193v1