--A community organization dedicated to preserving the character, charm and historical resources of the Mission Hills neighborhood.

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1 32. ashington treet, uite2, #221 an iego, C community organization dedicated to preserving the character, charm and historical resources of the ission ills neighborhood. arlon Pangilinan, enior Planner Planning epartment he City of an iego 1222 First venue, -413 an iego, C pril 29, 2016 e: Uptown Community Plan Update January - pril 2016 F Elements ear r. Pangilinan: e have continued our review of the revised draft of the Uptown Community Plan dated January 2016 and the updated elements released in pril 2016, and have the following comments in addition to those set forth in our letter dated February 12, 2016: I. CPIZ EIG LII s you know, ission ills eritage supports a maximum 0-foot building height limit in the commercial core area of ission ills west of ove treet. here is strong public support for the maximum 0-foot limit in ission ills. graphic titled CPIZ Building eights by ight (inisterial pproval) indicates that structures limited to 0 feet in height can be achieved with a ministerial permit along ashington treet in the ission ills area west of ove treet and 6 feet east of ove treet. hese height limits are also discussed in the Fact heet entitled Uptown Community Plan Update Zoning Code Changes on page 1, in the Implementation Element on page 2, and in the Urban esign Element on page 20. t the arch 24, 2016 City workshop regarding Plan Implementation, we understood your presentation to represent that the inisterial pproval limits in the areas of CPIZ that are not overlapped by iscretionary CPIZ B would be maximum limits for those areas.

2 arlon Pangilinan, enior Planner pril 29, 2016 Page 2 owever, we note that part 3 of able B (Community Plan Implementation verlay Zone pplicability) states in Column 1 (ype of evelopment Proposal): (3) ny development within the boundaries shown on a map identified in ection , where the map shows ype and the proposed development does not comply with the development standards or criteria in the applicable community plan. and states in Column 3 (equired Permit ype/ecision Process): ite evelopment Permit/Process hree. hus, a height over 0 feet west of ove and 6 feet east of ove could be permitted with a ite evelopment Permit under a Process hree. ot only could the ministerial limit be exceeded, but these areas do not even have a maximum limit for discretionary approval. o literally, the sky is the limit for these CPIZ areas. his is a significant loophole in the height limit that is unacceptable to the community. o ensure that the prescribed height limits are adhered to, the following language should be added to the discussion of CPIZ on page 20 of the Urban esign Element: o exceptions to height limits shall be permitted in the areas where CPIZ does not overlap CPIZ B. II. I ILL PPE L UE EIG he arch 2016 zoning map includes the following zones for eynard ay: orthern rea (utter treet on the north and Upas treet on the south) -3-7 which permits 44 dwelling units per acre (du/ac); Central rea (Upas treet on the north and Eagle treet on the south) C-1-4 which permits 44 du/ac; and outhern rea (Eagle treet on the north and utmeg treet on the south) -2- which permits 29 du/ac. e strongly disagree with the proposed density of 44 du/ac for the orthern and Central reas of eynard ay. e continue to support the maximum density of 29 du/ac for all of eynard ay as previously recommended by ission ills eritage (), supported by Uptown Planners, and incorporated by the City into the June 20 draft of the land use map. he higher density of 44 du/ac is supported by the City s General Plan, G s mart Growth Concept ap, or the City s Climate ction Plan.. he igher ensity is ot upported by the General Plan.

3 arlon Pangilinan, enior Planner pril 29, 2016 Page 3 ee Figure LU-1, the Village Propensity ap, on page 9 of the Land Use and Community Planning Element of the General Plan. ccording to that element, his figure is based upon existing and community plan-designated land uses. By overlaying the facilities factors with the land uses, the Village Propensity ap illustrates existing areas that already exhibit village characteristics and areas that may have a propensity to develop as village areas. (emphasis added) eynard ay clearly falls within the Low Propensity range. cropped version of Figure LU-1 is enclosed. he trategic Framework Element of the General Plan states the following on page F-9: Community plans are also the vehicle for implementing state laws pertaining to provision of housing opportunities, and meeting the City s share of regional housing needs. s community plans designate land uses and assign densities, they must preserve or increase planned capacity of residential land uses to ensure that the City is able to meet its share of the region s housing needs. Implementation of community-based goals may cause a shift in densities within or between community planning areas but together they must maintain or increase overall housing capacity. (emphasis added) Community plans and other adopted land use plans are implemented through application of a broad range of zones, regulations and programs. he underlined sentence makes it clear that it is acceptable to propose a lower density for an area when a community plan is updated provided that the overall housing capacity is maintained or increased. It should be noted that other community plans, including Grantville, tay esa, and Centre City, have already added density. hese three planning areas alone account for almost 34,000 additional dwelling units. B. he igher ensity is ot upported by G s mart Growth Concept ap. eference for Quick eference: mart Growth reas by Place ype, ctober, eynard ay is not listed as an Existing/Planned or Potential etropolitan Center, Urban Center, own Center, Community Center, ixed Use ransit Corridor, pecial Use Center, or ural Village. or is it shown on the mart Growth Concept ap, id-city and East County ubregion, ctober 2014 or raft pril cropped version of mart Growth Concept ap, raft pril 2016 is enclosed. C. he igher ensity is ot upported by the Climate ction Plan ransit Priority rea ap. ee the ransit Priority rea (P) ap included as ppendix B of the Climate ction Plan. eynard ay is shown as a ransit Priority rea. cropped version of P ap is enclosed. Furthermore, it must be noted that the 6 foot height permitted by the C-1-4 Zone would result in structures substantially out of scale with the adjacent single-family homes of 30 feet or less.

4 arlon Pangilinan, enior Planner pril 29, 2016 Page 4 hereas, the recommended C-1-3 Zone has a height limit of 30 feet and would be in character with the single family area. In conclusion, we request the City reconsider these proposed density increases on eynard ay and instead proceed with the lower density levels previously proposed. III. E LEI E he Fact heet entitled Uptown Community Plan Update Zoning Code Changes on page 1 states the following: Included as part of the Uptown Community Plan Update process the id-city Planned istrict rdinance (CP) and est Lewis treet Planned istrict zoning regulations are being rescinded and the Community Plan land uses will be implemented through the Citywide Land evelopment Code (LC) zoning. (emphasis added) In 2000, the City s development regulations went through a major revision, and the Planned istrict rdinances (P s) were used to help guide the creation of the development standards for residential and commercial uses contained in the LC. (emphasis added) Part of the intent of the LC update was the (sic) phase out P s and use citywide zoning to implement community plans, which would happen as part of the community plan update process. Unfortunately, the revised LC, and particularly the C-1-1 Zone, do not address the unique needs of the est Lewis treet rea by ensuring that new structures, and modifications to existing structures within the est Lewis treet rea complement the surrounding, architecturally-stable, single-family development. It should be noted that the est Lewis treet rea is a small, commercial area with mostly early wentieth Century buildings completely surrounded by a residential neighborhood. herefore, ission ills eritage recommends that the est Lewis treet Planned istrict regulations be retained. lternatively, we would recommend that the following provision be incorporated into the Urban esign Element in order to carry over the review process set forth in the current est Lewis treet P at ection : he est Lewis treet rea located on the north and south sides of Lewis treet between tephens treet and Lark treet shall be shown on a CPIZ ap as ype B. he purpose of the review under a ite evelopment Permit/Process hree is to maintain compatibility of the existing commercial strip with the surrounding single- family residential area while permitting flexible and feasible commercial development and redevelopment options. It is intended that new structures and modifications to existing structures within the est Lewis treet rea complement the surrounding, architecturally-stable, single-family

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6 E CI F IEG General Plan ECI C ECI CLB Land Use and Community Planning Element Using Geographic Information ystems (GI), this figure shows existing areas that already exhibit village characteristics and areas that may have a propensity to develop as village areas based on having certain existing or planned characteristics; it does not take the place of site-specific planning. hese ECI characteristics include the location of parks, fire stations, transit routes, and existing and community plan designated land uses. ctual village locations will be designated in community plans with the input from recognized community planning groups and the use of locational criteria established under the policies section. Community plans will also house site-specific design guidelines to ensure the successful implementation of each site. any community plans already identify sites suitable for mixed-use and provide extensive design and development policy guidance for development of those sites. L BEC P EL EL CJ 163 L E Pacific cean LE GVE C 7 n a go ie L CI y Ba Figure LU-1 4 Village Propensity CUL VI Value igh Propensity 0 12 IPEIL BEC Low Propensity iles 6 90 E X I C I P I PVIE IU F K, EIE EXPE IPLIE, CLUG BU LIIE, E IPLIE IE F ECBILI FIE, F PICUL PUPE. Copyright angi. ll ights eserved.

7 C-4 C-1 C-6 C-7 C-3 kylineparadise ills P- B UL EV 12 JC JC CC J C-9 P V L I LE E P-3 C-10 ELL UE GU IIG weetwater 12 4 E E E E C V LLL VL E G E E BLLE BLLE GL E L LPI PE E LLI LLI VC GE GE ILL Valle e ro C- ILL LL V E lpine inset FU FU C C J J B C F F C-11 pring Valley 2 2 J J LE E E VE G P-1 P-4 CUC C Z IGUEL IGUEL L E G V E 4 FUEE KE LG-1 LG-2 KL E G G LE P P LL G IIG 1 1 L-7 E P-2 GLI GLI L KE U 70 CUE 60 E- C- LL E LG-3 II VII IIV L-6 E C-2 PL PL Z Z FI V J G 4 4 EUCLI LG For more detailed information,lg see "owntown " map 4 U U II GE EX CE VIE LL I I 7 I G G E UFF UFF outheastern an iego 32nd treet aval tation 94 E EUCLI L E GE VL PIBIU BE LL FF I I L E B B Encanto eighborhoods IPEIL E-1 E-2 FEEL 32 E C EL 2 2 C C-1 KE KE 7 ll mart Growth pportunity reas shown on the map have been identified and recommended for inclusion on the map by local jurisdictions. *ransit network generalized for cartographic purposes. PK U CL & VL UBE BE 4 BL-1 CL LEGEGVE L B B C J EC-1 EC- ap Extent PEG IF F E CL 4 G-1 E Barrio Logan C-2 Eastern rea I E G Golden ill E-3 GFIEL GFIEL EC LE 3 City eights E L 12 L-2 L- 2 KILEE 2 C-2 G-2 IPEIL 3 22 UIVEI UIVEI B IL VL I C-1 EL EL CJ CJ L-9 K K B B ILE P-2 P-1 L-10 C-4 EC-4 EC-2 L-1 L CC-1 0 EZ U EC CII LLE VV pril 2016 L IL I E E CB BI ILLLL G CCEP P I-CI E CU UBEG Kensingtonalmadge GILLEPIE FIEL L- L-4 PEPPE E LLE B B V-4 EC-6 JC K C-2 C-3 College C-1 rea EC-7/ -/ C-7 EC-3 V-3 PPE PPEC C E E CC Local Bus CEE CI I ILL \ ^ [ orth Park LUEL -2 UU igh Frequency Local Bus ormal eights I G G UP-4 UP- Z U I I E G GG GE JUL Lakeside 67 E PG E E treetcar/huttle 0 IIL B B CC lley n Va -1 UP-1 V-1-4 C-6 II -1 BCF apid ransit P-1 K K L L C C KL E PE Express io iss Z V- V-6 V-4 V-3 UP-3 Uptown UP-2 UP-3 C G G II P P rolley/pe ld an iego I VLLE V-2 E E Peninsula P L C V-1 IC IFIC CCIF PP CE/K/etrolink P-2 ZZ II II 200 ransit etwork* from an iego Forward: he egional Plan E I -1-3 E I LI L B B ixed Use ransit Corridor I P E I F FI erra esa avajo V-2-1 EG LE CL LL V L B-1 pecial Use Center LL E P E E 163 ierrasanta E G G ILLL VIL V I II I B-2 cean Beach KE E I FFFF UU ural Village I VI V I LL U LV-1 own Center Community Center LV-3 C FIIC CIIF C P P Urban Center C-7 LV-2 IIC C UL UL E I B B II ission Bay Park IIE E BLB Linda Vista C- CL I E K-2 C-9 I I C LL C-6 E I I B etropolitan Center C-3 LLBB B B E E G IG ission Beach Potential LL G I Existing/Planned PB-3 E E G G PB-2 PB-1 I E G C-2 II V V II E E C C C C L L E E E EE G GE LE LL LL JJ LL Pacific Beach K-1 E E 2 C-4 Clairemont C- esa East Elliott CL IE E C-1 IL U U B-1 KE V IL L GVE C V C GIL GIL L JJL LL L E L ILL IL CL E U LJ-3 mart Growth pportunity reas 0 Z La Jolla LJ-2 \ ^ [ E GE E EG LJ-1 B EL L PI P F L LI G G U-1 Z I C EE E PE U-2 UC I-CI E CU UBEG II U-3

8 ransit Priority reas IEG B