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HomeMy WebLinkAboutCE 78-51/AR 78-74 Poss/Foss Appeal 1978-1980 117 City of Huntington Beach _'• rj' " ,� P.O. BOX 190 CALIFORNIA 92648 � ' . OFFICE OF THE CITY CLERK July 23, 1980 I HEREBY CERTIFY that the foregoing pages , numbered from 1 through 17, inclusive, represent a true and accurate transcription of a tape recording of the proceedings of the City Council , City of Huntington Beach on April 7, 1980. DATED this 23rd day of July, 1980 , in the City of Huntington Beach, County of Orange, State of California. ALICIA M. WENTWORTH , CITY CLERK By: Connie Brockway Deputy City Clerk STATE OF CALIFORNIA COUNTY OF ORANGE On July 23, 1980, before me, the undersigned, a Notary Public in and for said State, personally appeared Connie Brockway, known to me to be the. person whose name is subscribed to the within instrument and acknowledged that she executed the same. WITNESS my hand and official seal . 0MCIA1. SEAL Signature ;�'� EVEIYN SCHUB RT NOTARY PIALIC CALIFORNIA S 'tr OP.AUGE COUNTY Gsb/� �- My comm. expires MAR 25, 1993 ✓P�Gii�G h �" _ Name Typed or Printed r _ , 9 1 Please come forward. State your name and address , 2 please. 3 MR. JAMES FOSS : I 'm James Foss . Along with 4 Charlie Poss , we're the owners of the subject property. 5 I would like to present you first with a brief 6 prepared by our attorney, which outlines some of the legal 7 and factual aspects of our position. 8 Conditional Exception Number 78-51 is a request 9 to reduce the required 6% landscaping to approximately 10 1. 5%, as a requirement to the issuance of a permit for the 11 construction of a Contractors Equipment Yard. 12 The City of Huntington Beach Planning Commission 13 has approved the conditional exception, subject to some 14 twelve conditions . These conditions. are acceptable to us , 15 with the following exceptions : 16 Condition 1 is a .requirement of a fifteen-foot �( O✓ 17 wide landscaped area, witb4six-foot high decorative masonry 18 wall at the fifteen-foot setback, recessed a minimum of 19 forty feet at the proposed driveway. 20 A ten-foot landscaped area, as originally 21 suggested by the Design and Review Board, is adequate to �( 22 uphold the aesthetic standard along Gothard, and in this 23 Cone. The parking areas to the north are only set 24 25 back ten feet, and the masonry wall to the south is only 26 set back three to five feet . M&M Certified Court Reporters (213)637.3550 MACAULEY,BARRETT,CRAM,DAWSON&MELMAN (714)558.9400 • 10 1 1 would like to introduce some photos , which show 2 the surrounding area, including the A-Z dismantling yard 3 to the south, Metzler Lane gulch to the north, the City 4AW 4 park to the,, ast, and the City library and park frontage 5 on Talbert, which illustrates the City's own standards . 6 The requirement that the wall be recessed a 7 minimum of forty feet on both sides of the driveway is 8 unreasonable and unnecessary. The yard would operate with 9 an opaque gate,, which eliminates the need for this recess . 10 Condition 2 requires a landscaped island, or 11 grouping, to be placed at some point within the facility, 12' directly in back of the proposed driveway. 13 This requirement is inconsistent with current 14 requirements of others , and is a safety hazard, and would 15 result -- or could result -- in personal injury and 16 property damage, both within the property and on the 17 sidewalk outside. This is a most unusual and unreasonable 18 requirement. 19 Condition 4 requires that the six-foot block wall 20 be extended around the future intersection of Metzler Lane , 21 with the curved area landscaped. 22 This will reduce the usable property at a time 23 when Metzler Lane is not being constructed. This should 24 not be a requirement until such time as Metzler Lane is 25. improved. There is no current plan to improve this 26 proposed street. M&M Certified Court Reporters (213)637.3550 MACAULEY,BARRETT,CRAM,DAWSON&MELMAN (714)558.9400 i 11 1 Condition 6 requires a one hundred foot by 2 thirty-five foot asphalt-concrete driveway. 3 We propose to place six inches of base material, 4 which will be oiled with rock chip seal . This is sufficient 5 to accomplish the intent of preventing dirt and mud from 6 being tracked. on to Gothard. We request that this 7 requirement be modified. 8 As pointed out by Mr . Sangster, there are four 9 requirements in order to prove hardship to justify a 10 reduction in the 6% landscaping . X 11 The first, Exceptional Circumstance : I think ; \ 12 the depth of this property versus the frontage and usage, 13 along with . the fact that the public does not use this 14 property, is an exceptional circumstance . 15 Landscaping beyond that which is required along 16 Gothard, and along the future Metzler Lane, when installed, 17 would be of no use, and an economic waste. 18 In addition, the area is exceptional in that the X 19 property bu*$ up to a railroad embankment to the east, to 20 the A-Z dismantling yard to the south, and an unimproved 21 gulch to the north. 22 Necessity to Property Rights : As you know; our 23 present use of the property is not the highest and best 24 use . The various .requirements which are being put upon us , 25 including the 6% landscaping requirement , makes the cost 26 so high as to prevent us from using the property for the 1V1(X.M Certified Court Reporters (213)637-3550 MACAULEY,BARRETT,CRAM,DAWSON&MELMAN (714)558-9460 12 1 proposed use. Again, a 6%.. requirement would be of no 2 benefit to the public, and an economic waste . ' 3 Absence of Detriment : There is no detriment 4 to the public. The Development staff -- Services staff. -- 5 takes the position that minimal aesthetics require/ 6% 6 landscaping. In order for the public to even see the 6% 8 landscaping from Gothard, we would have to have a forty- 9 foot setback of the planted area. A ten-foot setback, 10 planted, is sufficient to preserve and promote an I1 aesthetically pleasing atmosphere. 12 The final item is Good Faith: I can assure you, �( 13 we are acting in good faith, and the Development Services 14 Department is not question* this requirement. For example , 15 we are willing to landscape along Gothard in excess of 16 what has been installed by some of our neighbors , in order 17 to promote aesthetic value in the Gothard area . 18 Administrative Review 78-74 . is , Request for Permit a 19 to Operate a Contractors Equipment Yard, at the subject 20 location: 21 The Board of Zoning Adjustments has denied this 22 permit because we will not agree to dedicate and bond a 23 paved right-of-way; Metzler Lane, in addition to the 24 landscaping requirements referred to previously. 25 The requirement of Metzler Lane dedication was 26 appealed to the Planning Commission. The Planning Coumission M&M Certified Court Reporters (213)637.3550 MACAULEY,BARRETT,CRAM,DAWSON&MELMAN (714)558-9400 13 1 was advised by the City Attorney'.s Office that they did 2 not have the right to defer this dedication. 3 The Planning Commission and the Planning Department 4 dealt with this subject in the hearing, but did not include 5 it as an itemized condition in their approval . Presumably, 6 they are taking the position that it is not within their 7 authority :to deny or grant this item.. g Now the City Engineer has recommended that we 9 be required to dedicate a twenty-foot wide strip of land, 10 and install drainage and sewer facilities . While I don' t 11 know the exact alignment of this system, it is probably z: 12 somdwheres' in the neighborhood -of nine hundred feet. The 13 _ storm drain is a fifty-four inch pipe .. These two items 14 could run as much as a. hundred and thirty thousand dollars , �,• 15 OmA., Maybe that request was removed tonight . I 'm 16 not sure what Mr. Sangster was advising you in that area, 17 but the packet that I saw made that part of a recommendation 18 of the Public Works Department. 19 Neither the proposed forced dedication of 20 Metzler Lane, the sewer and storm drain facility easement, 21 or their construction, benefit our property. 22 It is also our position that the requirement 23 of dedication and bonding of this paved right-of-way, and 24 the requirement of the dedication, and the construction . 25 of the drain and sewer facilities, are unconstitutional . 26 The State of California Government Code , Section M&M Certified Court Reporters (213)637-3550 MACAULEY,BARRETT,CRAM,DAWSON&MELMAN (714)558-9400 1v • CITY OF HunTinGTon BEACH DEPARTMENT OF PLANNING AND ENVIRONMENTAL RESOURCES • P. O BOX 190, HUNTINGTON BEACH, CALIFORNIA 92648 (714) 536-5271 TO: Honorable Mayor and City Council ATTN: Floyd G. Belsito, City Administrator DATE: December 14 , 1978 SUBJECT: APPEAL: CONDITIONAL EXCEPTION NO. 78-51 AND ADMINISTRATIVE REVIEW NO. 78-74 - CONTRACTOR' S EQUIPMENT YARD C. POSS AND J. FOSS Pursuant to your request, followinq is a summary of the original request and Planning Commission action on landscaping. 'Mr. ..:Poss had originally requested a reduction from the six percent land- scaping required by code for his facility to approximately 1. 5 percent; however at the time the Planning Commission reviewed the conditional exception request, they did not feel that this magnitude of reduction was conducive to the City' s efforts in regard to Central Park across Gothard from the subject site. • The Commission therefore conditioned additional landscaping along Gothard and Metzler Lane to equal a percentage of approximately 4 . 8 percent of landscaping required for this facility. Respectfully submitted, a James W. Palin Acting Planning Director JWP:df �i' CITY OF HUNTINGTON BEACH INTER-DEPARTMENT COMMUNICATION HUNTINGTON BEACH - • To Honorable Mayor From Office of the City Attorney and Members of the City Council Subject APPEAL TO CITY COUNCIL Date December 13, 1978 CONDITIONAL EXCEPTION #78-51 ADMINISTRATIVE REVIEW #78-74 December 18, 1978 Agenda item D2e As additional backup material for your consideration of the above mentioned appeal of C.W. Pass and James D. Foss, I attach herewith a copy of the opinion of this office relevant to this appeal. This opinion reflects on the legal validity of the , City Ordinances currently in effect and applicable to this appeal. Respectfully Submitted, GAIL HUTTON City Attorney GH:cw • 'cc': Jim Palin, Planning Dept . CITY OF HUNTINGTON BEACH INTER-DEPARTMENT COMMUNICATION • HUNTINGTON BEACH / 1 To GAIL HUTTON From JOHN O'CONNOR City Attorney Deputy City Attorney Subject C.W. POSS PROPERTY ALONG Date September 27 , 1978 GOTHARD - USE PERMIT This memorandum responds to your request of September 20th as to whether Government Code Section 65909 would prohibit the city from requiring dedication of the precise planned street known as Metzler Lane, and the procedure for requesting alleviation of the 6% landscaping requirement on the project . Briefly reviewing the history of this project , C .W. Poss , Inc . , a local contractor established a contractor storage yard on the subject property without securing the appropriate permits from the city; to wit : (a) permit approval from the- Design Review Board • (b) Administrative Use Permit from the Board of Zoning Adjustments Criminal complaints were filed against C .W. Poss , Inc . , on both of these counts , and the Court found C .W. Poss , Inc . , guilty on both counts and imposed as a condition of probation, they procure the necessary permits from the City, and that if a permit is denied that the matter be appealed within the designated time , either through the .hiearchy of the city and to the Court ; provided further, that if at any time an appeal is not pending or the permits granted, they immediately cease use of the property as a contractor storage yard . C .W. Poss , Inc . , through their attorney, is now questioning the validity of City Ordinances which require the dedication of Metzler Lane , and 6% landscaping on the project as a condition of granting their permits . Metzler Lane is a precise , planned street which extends for several hundred feet on the northerly edge of the subject property and is situated between Sja.ter Avenue and Gothard Street . One-half of the precise plan of street alignment lies on the adjacent property to the north, which is undeveloped. The subject ' s property was improved through extensive grading and fill which extended the grade level of the subject ' s • -1- property some ten to fifteen feet abpvethe. existing natural • grade on the adjacent property . Apparently, it will be some time in ,the future before Metzler Lane is completely dedicated and improved, however, a portion is already .dedicated and improved, commencing at Slater Avenue . The precisely planned street , Metzler Lane , would ultimately provide access from the subject property to Slater Avenue as well as provide ingress and egress to the numerous small parcels north of the subject property. , It is! the contention of the property owner that the street is of no value or use to the subject property and .not .reasonably related to the use of the property as .a contractor' s s,to.rage yard, and therefore .dedl.cation is prohibited by. Gov. .'Code 65909 . Government Code 65909. provides : . "§65909 . Prohibited conditions for issuance of permit or variance . No local governmental body, or any agency thereof, may condition the issuance of any building or use permit or zone variance on. any or all of the following: (1) The dedication of land for any purpose not reasonably related to the use of the property for • which the variance, building, or use permit is requested" . (2) The posting of a bond to guarantee installation of public improvements not reasonably related to the use of the property for which the variance, building pr use permit is requested" . The decided judicial decisions have uniformly upheld the requirement of dedication where a precise plan of street alignment so requires , and where the designated use of the property would increase the intensity of traffic . The leading case is Southern Pacific Company V. City of Los Angeles , 51 Cal Reporter 9197 . In the Southern Pacific case , the City. of Los Angeles required dedication of a street as a condition to establishment of a warehouse use . Southern Pacific contended that this requirement was an unconstitutional taking. The. Court , in an extensive discussion of the existing cases , held that since additional traffic may be generated by the use , dedication of the street was justified under the police power . Section 65909 is a codification of that decision which is to the effect that dedication must be reasonably related to the use of the property . In this case , the use of a contractor' s storage yard -2- • • unquestionably generates additional traffic , the street is contiguous to several hundred feet of the subject property, and, therefore, dedication and improvement is justified under the city ' s police powers . Insofar as 6% landscaping is required, this is the uniform requirement for all commercial and industrial developments under city ordinances . If the property owner feels that it is a particular hardship in his case , the appropriate procedure is to apply for a variance under Article 983 of the Huntington Beach Ordinance Code . Section 9830 provides , "when practical .. difficulties, unnecessary hardship, or results inconsistent with .the general purpose and intent of applicable provisions of Division- 9 occur through strict application of their pro- visions , that a request for a conditional exception may be filed: " Sections 9832 . 1 through 9833 set forth the require- ments for a conditional exception whi.ch are as follow: S. 9832 . 1 Exceptional circumstances . That there are exceptional or extraordinary circum- stances or conditions applicable to the land, build- ings, or premises involved, or to the intended use of same, that do not apply generally to the property or class of uses in the same district . S. 9832 . 2 Necessity to property rights . That such • conditional exceptions are necessary for the preservation and enjoyment of substantial prop- erty rights . S. 9832 . 3 Absence of detriment . That the granting of such conditional exceptions will not be materially detrimental to the public health, safety, and welfare or injurious to the conforming land, property, or improvements in the neighborhood of the property for which such conditional exception is sought . S . 9832 . 4 Good faith. That the applicant is willing and able to carry out the purposes for which the conditional exception is sought; that he will pro- ceed to do so without unnecessary delay . S . 9833 Hearing and findings of hardship required . Before a conditional exception may be granted by the Council or Commission, the Council or Commission. shall hold a public hearing relative to the proposed conditional exception, as provided in Article 987 , and findings in support of and relevant to the hardship standard must be made . -3- i If all of the findings are made in accordance with the foregoing provisions a conditional exception may be granted diminishing the requirement of the 6% landscaping. JOHN 0 ONNOR Deputy City Attorney JOC :yr APPROVED: GAIL HUTTON City Attorney • O ` 61 i December 1.3, 1978 C✓lY ���'1 pc 9p,��'V/s pNl✓�, �9/6' '? or✓ To : City Council Members City of Huntington Beach Subject : Storage yard on Gothard Street I am the owner of three acres of land adjacent to Mr. Poss on the south and directly behind the A to Z Auto Wreaking. At the present time my property is virtually land locked from public street access . The current Metzler Lane • precise plan of street alignment makes no provision to solve this problem. Furthermore, the issuance of Mr . Poss ' s storage yard permit without additional restrictions , such as requiring that Metzler Lane be extended south to my property, would insure the permanance of this situation and preclude the development of highest and best use improvements on my acreage . Two important engineering studies are presently being conducted for this area. One study being prepared by Hall and Foreman Engineering will result in the design of a master storm drain system intended to correct the present flooding problems in the area. This- will be of great benefit to my property if street access can also be obtained. The second study was initia�ed as a the result of a meeting held by Mr . Bill Hartge and Mr . Mike Zambori, and attended by Walt Hamilton of Ronald Martin and Associates , Charles Poss , James Foss , • Wilber Metzler , Frank Buccella and myself . Continued At this meeting the three landowners , Metzler, Poss and myself agreed .to fund a feasability study for an extended Metzler Lane . The alignment selected by all the parties would extend Metzler Lane in such a way as to encourage better development in the area. This study will establish the detailed street design, estimate the improvement costs , and estimate the benefits each property owner will derive . The formation of an assessment district for full street improvement is the long range goal . In light of. these considerations , :I respectfully request that the City Council postpone the issuance of the storage yard permit to Mr. Poss until these two studies have been completed. Sincerely yours , • Tom Manthei TM:ge • PROPOSED FINDINGS: 1. There are no exceptional or extraordinary circumstances related to the subject property that do not apply generally to the property or class of uses in the same district. The requirement for 6 .percent of the total site to be landscaped is a City-wide standard and has been applied in numerous instances without creating an undue hardship on other proper- ties in the City . The subject property is virtually 1.00 percent usable and, therefore, the 6 percent landscaping re- quirement would not substantially impair .the use of the property. 2 . Said conditional exception is not necessary for the preserva- tion and enjoyment of substantial property rights on the subject property. . The property owner has full rights to develop and utilize the subject property in compliance with the provisions of the M1 zoning district. The 6 percent landscaping requirement is reasonable and a - standard require- ment for this industrial zone and all other industrial and commercial zones within the City. The proposed equipment storage can still utilize the remaining 94 percent of the subject property. 3 . The granting of such a conditional exception will be detri- mental to the public welfare in the neighborhood insofar as all of the adjacent properties in the general area and all other commercial or industrial properties in the City have provided a minimum of 6 percent landscaping, which has established an aesthetic standard for not only the general area but the entire City. The granting of this reduction in landscaping would afford special privileges which would -undermine this aesthetic standard. 4 . There is no reason to assume that the applicant is not willing and able to carry out the purposes for which the conditional exception is sought without. unnecessary delay. I Fbn S 1�' v Y y CG1NCIi .a 4, . NGTON BEACH nyjh�Y u D—3 �db TO. THE Dt1JA28ER 7$-51 TR 78 -74 -74 MR a 1-.�hCK x _ _ r fiPi.' n. 3ED PROCEEDINGS pr � yr' "°' 7Jz a: ,,. I N D _G X -' 2 3 ME14BERS OF THE CITY COUNCIL IN ATTENDANCE: r *` 4 5 DON MACALLISTER, Mayor r 6 BOB MANDIC, Mayor Pro-Tempore j RUTH BAILEY $ RUTH FINLEY 1A }{' 9 RON PATTINSON yA 10 JOHN THOMAS 11 CLANCY YODER 4 13 MEMBERS OF THE CITY STAFF IN ATTENDANCE. ( irk 14 GAIL HUTTON, City Attorney s 15 ROBERT C. SANGSTER, Deputy City Attorney 16 . JIM PALIN, Director of Development Services 17 :M 1$r•. r1 19 20 ,4 21 i 22 t { - 23 24 25 +: 26 s IYl&.M Certified Court Reporters (213)637.3550 MACAULEY,BARRETL CRAM,DAWSON&MELMAN (714)558.9400 { 3 1 P R O C E E D I N G S 2 3 MAYOR MACALLISTER: All right , the last of the 4 public hearings tonight. .5 Item D-3. A. Reconsideration of an Appeal to 6 Conditions of CE 78-51 and AR 78-74, known as Poss/Foss . 7 Transmittal from Development Service Department, 8 Appeal of Poss/Foss to the Planning Commission's Condition 9 of Approval of Conditional Exception 78- and Administrative 10 Review 78-74. 11 The Superior- Court has mandated that the City 12 Council reconsider the prior denial of its approval to the 13 Commissions . 14 The CE 78-51 is a request to reduce the required 15 on-site landscaping. 16 AR 78-74 is a request to approve site plan, 17 elevation and floor plans , for Permanent Contractor 18 Equipment Storage Yard, in accordance with all applicable 19 code requirements . 20 The subject site is located on the east side of 21 Gothard, approximately a hundred feet north of Talbert . 22 City Attorney Gail Hutton, please! . 23 MRS . HUTTON: Yes . I ' d like to offer the 24 opportunity for the Council to receive some advice from 25 Robert Sangster, the. Deputy , who was assigned to this case, 26 and who has some suggestions and advisements for you. MQ(,M Certified Court Reporters (213)637-3550 MACAULEY,BARRETT,CRAM, DAWSON&MELMAN (714)558-9400 4 1 MAYOR MACALLIS.TER: All right, thank you very much. 2 Mr. Sangster, go right ahead. . 3 MR. SANGSTER: Thank you. 4 Mr. Mayor, members of the Council, we thought; 5 if you' d. like, we might just briefly review some of the 6 legal aspects of what's before you; and Mr. Palin can talk 7 about the planning considerations . 8 This is , basically, a •reconsideration of an 9 appeal to the grant of Conditional Exception Number 78-51, 10 which was made by the Planning Commission, subject to 11 various conditions . 12 The Conditional Exception is to reduce the 13 required landscaping on the subject property from 6% to 14 the applicant's. requested approximately lk%. 15 After the BZA denied the application, the 16 Planning Commission then considered it, and reversed that 17 decision, requiring some 4.8% landscaping. And it imposed 18 some twelve conditions . 19 The appeal was thereafter filed by the applicant, 20 who was unhappy with some of the conditions contained in 21 the staff report of the Planning. Commission' s action, 22 namely, Conditions 1, 29,. 4 and 6 . r23 In the file the . evidence introduced before 24 the Planning Commission, and the BZA, and also , before the 25 Council , is before you, and on file here . 26 The issue is , whether to grant the application M&M Certified Court, Reporters (213)637.3550 MACAULEY,BARRETT,CRAM;DAWSON&MELMAN (714)558-9400 ,;,,, •, 1 to reduce the code required 6`70 landscaping . In order to 2 grant this , you're guided by four standards in the Ordinance 3 Code, and they 're basically factual questions which you 4 have to decide, and they also are set forth in the 5 Development Services staff report; and, briefly, you have 6 to find exceptional circumstances applicable to the subject property distinguishing it from other property in the 8 area, and the zone, the necessity to property rights , 9 and the absence of detriment and good faith on the part to of the applicant. 11 The staff report includes the prior action of 12 both the , BZA and the Planning Commission, and I believe 13 the letter of appeal, which states the objections to various 14 conditions, is also attached. 15 You have three choices -- three alternatives : 16 You may affirm the Planning Commission' s granting; you 17 may overrule that and deny the conditional exception; 18 or you may modify the Planning Commission' s decision. 19 Now, . if the Planning Commission' s granting of 20 the conditional exception is affirmed, you may also modify 21 it by deleting .or adding additional conditions of approval . 22 If the granting is overruled; then, of course , 23 there is no basis for any conditions . 24 The Director of Development Services has 25 recommended overru�flndings . ing he Planning .Comnlission decision, r26 and has proffered I believe those are forth set o t MOiC M Certified Court. Reporters (213)637.3550 MACAULEY,BARRETr,CRAM,DAWSON&MELMAN (714)558-9400 6 1 both in the staff report, and on a separate sheet -- which 2 contains one slight change, the last sentence to Finding 3 3 is a little bit different. 4 I might also note that we sent you, on February PR;or' X 5 21, .various papers relating to pa.*&litigation in this 6 matter. . 7 Once having decided the issue of the conditional 8 exception, then the Council must also address the 9 administrative review. These would be the proposed 10 findings . 11 You might note that the last sentence of Paragraph 12 3 is a little different; a little more directly related to 13 the issue . The only change is the sentence at the end 14 of Paragraph 3: .15 "The granting of this reduction in 16 , landscaping would afford special WOO I� 17 privileges which $hvtrYti undermine the 18 aesthetic standard. " 19 With reference to .the administrative review, the 20 AR, the City. Council may affirm, reverse or modify; the 21 Planning Commission decision, specifying the facts relied 22 upon. 23 Now, basically, this AR. is just administerial 24 review to determine whether the occupancy complies with 25 the variance Ordinance. Code requirements . 26 The use here is an expressly permitted one, so M&M Certified Court Reporters (213)637.3550 MACAULEY,BARRETT,CRAM,DAWSON&MEI.MAN (714)558-9400 • 7 1 that is not a consideration; but. the site plan for the 2 occupancy must meet various requirements ; and those would 3 include: compliance with landscaping; setbacks ; street 4 requirements ; street, alley and highway, dedications ; and 5 so forth. It does not include drainage easement 6 dedications , because that is not one of the express. 7 ordinance requirements . 8 Now, ,if it doesn' t comply with these various 9 code requirements , then the appeal should be denied 10 without prejudice . to filing a -revised administrative 11 review with the. Planning Director . 12 Please note that new conditions not required by 13 the Ordinance Code may be imposed upon the administrative 14 review; so', while the drainage fees may be required, 15 dedication of a drainage easement, mentioned in the City 16 Engineer' s memorandum in the staff report, may not be 17 required. 18 The Director will discuss the planning aspects ; 19 and the applicant should be afforded an opportunity, then, 20 to present any additional evidence -&ket he may have. .� 21 MAYOR MACAL•LISTER: All right, thank you. 22 Staff, is there any further input? 23 MR. PALIN: Mr . Mayor, and members of the City 24 Council, Bob was extremely thorough. There 's really not 25' too much more to say. 26 We do have the original site plan for display, as M&M _ Certified Court Reporters . (213)637-3550 MACAULEY,BARRETT,CRAM,DAWSON&MELMAN (714)558.9400 8 1 approved by the Planning Commission; and we have an overlay 2 which reflects the landscaping in the compromise position 3 that was discussed previously with the' City Council . 4 As indicated by Bob, essentially, the applicant , 5 after review and conditional approval by the Planning 6 Commission, was proposing , essentially, about 4. 6 -- 4. 8% 7 landscaping. 8 That did take into consideration a fifteen-foot 9 setback, the block wall construction, and the ultimate 10 landscaping to be installed at some future date; also , 11 along the orange area on the site plan there, which would X 12 beA Metzler Drive dedication and improvement . 13 Just to quickly recap : Our recommendation is 14 to wipe the slate clean, to deny the request pending here 15 before you tonight; remand the action back to the Board 16 of Zoning Adjustment to act upon a site plan that has 17 full compliance with all provisions of the Ordinance Code. 18 We.'re prepared to answer questions . 19 MAYOR MACALLISTER: Are there any other Council 20 questions at this time, before I open the public hearing? 21 (No audible response to the question. ) 22 Seeing none, I' ll declare the public hearing open .23 in regards .to the reconsideration of appeal conditions of 24 CE 78-51 and AR 78-74. 25 Is there anybody who wishes to speak in regards 26 to this item? M&M Certified Court Reporters (213)637.3550 MACAULEY,BARRETT,CRAM, DAWSON&MELMAN (714)558-9400 14 1 65909, prohibits the requiring of the dedication of land 2 for any purpose not reasonably related _to the use of the 3 property for which the variance, building or use permit , 4 is requested.. 5 Court cases have also required government to 6 demonstrate that some economic benefit would result to the property owner from the nature of the forced dedication. 8 The dedication clearly does not relate to the proposed use 9 of the property. Ingress and egress to the property from 10 Gothard is more than satisfactory. I1 The entire area sought to be dedicated is 12 unimproved and, in fact, the street could not be constructed 13 due to the fact that one-half of the street -- the north 14 half -- is in an unimproved gulch. 15 The dedication and construction of sewer and 16 drainage lines is of no benefit to the present use of 11 the property. The benefit of the drain goes to the 18 surrounding property owners , not to this property. 19 There's more than ample time to require these . 20 dedications ; at such time as the property is developed 21 and built upon. 22 Many. of the proposed requirements are a waste, 23 and will have to be bulldozed into the ground when the 24 property is put to its ultimate use . This , most likely , 25 will include the masonry wall across the front, which we 26 have agreed to install. lrl(X, M Certified Court Reporters . (213)637-3550 MACAULEY,BARRETT,CRAM,DAWSON&MELMAN (714)558.9400 • 15 1 L believe that it is now more important than 2 ever for the people of this country -- including government -- 3 to run their affairs on a sound economic basis . 4 Many of the requirements being imposed upon us 5 here are not sound, are an economic waste, and can not help , 6 and contribute to more inflation: 7 I-11.1 be happy to -answer any of your questions . _ 8 I 've got- one more thing I' d like to give you, 9 and that. is a recital of much of what. I've said here . 10 MAYOR MACALLISTER: All right, thank you, Mr . 11 Foss . 12 Is-there anybody else who wishes to make any 13 comments from the public in regards to this item? 14 (No audible response to the question. ) 15 Seeing none, . I declare the public hearing 16 closed. Council, are there any question, 17 (No audible response to the question. ) 18 Seeing no lights on, a motion is in order -- 19 'Councilman Thomasl 20 COUNCILMAN THOMAS : I ' d like to ask, what' s your 21 when, and what ' s your future , for that. property? 22 MR. FOSS : I would have to say, that.' s speculation. 23 But I most certainly believe that it will end up in 24 industrial-- like industrial buildings -- at a future. date. 25 The use we have. a4-44 to now is -- economically, 26 it won' t be feasible in the long run; and we know that' s OiC M Certified Court Reporters. (213)837.35M MACAULEY,BARRETT,CRAM;DAWSON&MELMAN (714)558-9400 16 1 most like what it will end up by being. 2 COUNCILMAN THOMAS.:4How long off? :VCAV1f- 3 MR. FOSS I would be lying if I tried to put 4 a figure on that I can' t. I can' t say, for sure; but the 5 value of the property is such that it just will not, and 6 can not, remain what it is , for too long. 7 . 'MAYOR: MACALLISTER: All right , thank you. 8 Are there any other questions or comments? q (No audible response to the question. ) 10 A motion is in order. Councilman Mandicl 11 COUNCILMAN MANDIC: Okay pprove the :y 12 Recommendation of the Department of Development Services , 13 and Deny CE 78-51 and AR�-74, with the Findings as Amended. .: 14 MAYOR MACALLISTER: That were passed out a few F. 15 moments ago 16 COUNCILWOMAN BAILEY: Second. 17 MAYOR MACALLISTER: It' s been moved and seconded -- 18 MRS . HUTTO ,Without prejudiced 19 . Without prejudice ; right. AWN 20 COUNCILWOMAN BftTt%f Second. 21 MAYOR MACALLISTER: All right, it' s been moved and 22 seconded. 23 Councilman Pattinson.1 24 COUNCILMAN PATTINSON: Point of information, Mr. 25 Mayor. Should these proposed findings be stated for the 26 record? 1r1CX M Certified Court Reporters (213)837.36W MACAULEY,BARRETT,CRAM,DAWSON&MELMAN (714)558-8400 :v it - 17 1 MAYOR MACALLISTER: I .was going to ask that 2 question. Do we need to read these into the record? 3 4 MR. SANGS-TER: No. 5 .MAYOR MACALLISTER: All right, thank you. Do you 6 have a copy of it? 7 P.zT fL&K.. Yes 8 MAYOR MACALLISTER: Right. All right, seeing no 9 other questions or lights on, call ` for the question. ,t 10 . CLERK: Six ayes ; Thomas no. . 11 12 (WHEREUPON, THE PROCEEDINGS 13 WERE TERMINATED. ) 14 15 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 16 17 r 18 . 19 20 21 22 23 24 25 26 f f - t_ M&M Certified Court Reporters (213)837.35W MACAULEY,BARRETT,CRAM,DAWSON&MELMAN (714)558-9400 ' • 18 1 C E R T I F I C A T E 2 3 I HEREBY CERTIFY that the foregoing pages, numbered 4 from-1 through .17, inclusive, represent a true and accurate 5 transcription of a tape recording of the proceedings of the k. 6 City Council, City of Huntington Beach, 4/7/80, Item D-3. .7 DATED this 5th day of June, a.d. 19801 in the g City and County of Orange, and State of California. 9 10 11 12 13 i 14 c.... ...1� 15 _ i ARTHUR SPRI G 16 17 OFFICIAL SEAL 1 H o PRING NOTARY PUBL C ARTHUR S AR PI CALIFORNIA .I RIVERSIDE COUNTY 19 Mq comm. expires SEAL 26, 1981 4 ' 20 21 f 22 d 23 24 25 26 S' lrl&M Certified Court Reporters . (213)837-3550 MACAULEY,BARRETT,CRAM;DAWSON&MELMAN (714)558-9400 E: e, City of Huntington Beach P.O. BOX 190 CALIFORNIA'92648 OFFICE OF THE CITY CLERK I April 25, 1980 Charles W. .Poss/James D. Foss P. 0. Box 1610 Huntington Beach, CA. 92647 The City Council of.the City of Huntington .Beach at its April 7, 1980 meeting denied your appeal pertaining to Conditional Exception No. 78-51 and Administrative Review No. 78-74. This. is a final decision. You are hereby notified that pursuant to provisions of Section 1094.6 of the Code of Civil Procedure of the State of California You have ninety days from April 25, 1980 to apply to the courts for judicial review. . ALICIA M. WENTWORTH, CITY CLERK By: Deputy AMW:CB:bt CC: City Attorney i i WILLIAM E. GUMMERMAN ATTORNEY AT LAW HUNTINGTON EXECUTIVE PARK-EAST BUILDING 16152 BEACH BOULEVARD,SUITE 279 HUNTINGTON BEACH, CALIFORNIA 92647 TELEPHONE (7141 848-1088 April 22 , 1980 City Clerk City of Huntington Beach P . O. Box 190 Huntington Beach, CA 92648 Attention: Alicia Wentworth Re: Reconsideration of Appeal to Conditions of Approval : CE 78-51/AR 78-74 Dear Ms. Wentworth: Pursuant to Huntington Beach City Ordinance Code, I hereby request that you transmit as soon as possible to me the public hearing transcript .on the Reconsideration of Appeal to Conditions of. Approval CE 78-51/AR 78-74 with the tape of the Huntington Beach City Council meeting of April 7 , 1980. My clients will bear the cost of such transcript and tape by remitting a check to you upon receipt of an appropriate billing sent to me. . Further request is made pursuant to Huntington Beach City Ordinance Section 9815 . 5. 5 for official notice of the decision, which should have been sent within five days of the making of such decision. I would appreciate your cooperation in this matter. If you have any questions regarding these requests, please contact me immediately. rs ve tr ly, illiam E. erman WEG/pb cc: James Foss / J C. W /t;F44 City of Huntington Beach P.O. BOX 190 CALIFORNIA 92649 OFFICE OF THE CITY CLERK ' April 18, 1980 Charles W. Poss/James D. Foss P.O. Box 1610 Huntington Beach, CA 92647 Enclosed is a "Statement of- Action" of the City Council of the ,City of Huntington Beach taken-at its regular -meeting hel.8 .Monday, April 7, 1980 relative to reconsideration of your appeal pertaining to Conditional Exception No. 78-51 And Administrative Review No. 78-74. If you have any questions .regarding the matter, please contact the Department of Development Services - 536-5271 : ALICIA M. WENTWORTH, CITY CLERK By: Deputy AMW:cb enc. cc: James Palin - Director of Development Services CITY OF HUNTINGTON BEACH LO INTER-DEPARTMENT COMMUNICATION ' HUNTINGTON BEACH To CITY CLERK From ROBERT SANGSTER Deputy City Attorney Subject FOSS/POSS v. CITY OF Date April 11, 198o HUNTINGTON BEACH The following is a summary of the remarks we made concerning the hearing of Conditional Exception -No . 78-51 and Administrative Review No . 78-74 at the City Council meeting on April 7, 1980 . This is a reconsideration of the appeal to the grant of Conditional Exception No . 78-51 by the Planning Commission, subject to various con- ditions . The conditional exception is to reduce the required land- scaping from the required 6% to 1-1/2100 . After the Board of Zoning Adjustments denied the application, the Planning Commission granted the CE, requiring approximately 4 . 8% landscaping and imposed some 12 conditions . The appeal was filed by the applicant , based on dissatis- faction with some of the conditions of approval (namely 1, 2, 4 and 6) . The file and evidence introduced before the BZA, Planning Commission, and City Council is here this evening. The issue is whether to grant the CE 78-51 to reduce the required 6% landscaping. In order to grant this exception to zoning requirements, Council must find in favor of the applicant on the standards set forth in Huntington Beach Ordinance Code §9832 . These are factual questions for Council' s determination. They are set forth in the staff report and, briefly, are : 1. Exceptional circumstances applicable to the property that do not apply generally to other property or uses in the zone . 2 . Necessity to property rights . 3 . Absence of detriment, and 4 . Good faith. The staff report includes the Planning Commission's prior action, as well as the BZA' s earlier denial . The letter of appeal is also attached . Based on factual findings, the City Council may : 1. Affirm. 2. Overrule, or 3 . Modify the Planning Commission decision. If the granting of the conditional exception is affirmed, the City Council may delete or add conditions of approval . If the granting of the condi- tional exception is overruled, then, of course, there is no basis for To : City Clerk Foss/Poss v. City April 11, 1980 0 any conditions . The Development Services Director has recommended over- ruling the Planning Commission' s decision and has offered proposed find- ings . I might also note that we sent you various papers relating to litigatioh .over this issue on February 21 . Once having decided the conditional exception, the Council must also address the administrative review application. Again, the City Council may affirm, reverse, or modify the Planning Com- mission decision, specifying the facts relied upon. Basically, an AR is an administerial review to determine whether the occupancy complies with applicable ordinances and codes . The use here is expressly per- mitted -- but the site plan must meet such landscaping and street require- ments as the code requires . If it doesn't the appeal should be denied, without prejudice to filing a. revised AR with the Development Services Director. Please note that no conditions not required by the Ordinance Code may be imposed upon an AR. So, while drainage fees may be required, dedica- tibn of drainage easements mentioned in :the City Engineer ' s memo may not . The Development Services Director will discuss the planning aspects . The applicant will then be afforded an opportunity to present further evidence support the application.t ROBERT C . SANGSTER Deputy City Attorney RCS :ps City of Huntington Beach P.O. BOX 190 CALIFORNIA 92646 OFFICE OF THE CITY CLERK March 19, 1980 Charles. W. . Poss/James .D. Foss P. 0. Box 1.610 Huntington Beach, CA 92647 Gentlemen: The City Council of .the City of Huntington Beach.at its regular meeting held Monday,. March 17, 1980 approved your. request for a continuance .of the recon- si'deration of appeal relative- to Conditional Exception #78-51 and Administra- tive Review #78-74, to the April 7, 1980 meeting. If. we may be of assistance to you, please contact this office - (714) 536-5405. Sincerely, Alicia M..Wentworth City Clerk AMW:cd cc: Jim Palin, Director of Development Services U 6erl —ap_v ryW 1 n160 �C 10 • I• ' CITY OF HUM FINGTON BEACH �2 INTER DEPARTMENT COMMUNICATION 11UNIIN(;I0N MACH To Director of Development Services From City Attorney Subject Foss and Poss v. City of Date March 14 , 1980 Huntington Beach It is our understanding that the reconsideration of the appeals on CE 78-51 and AR 78-74 are set for hearing before the City Council at its regular meeting of March 17 , 1980 . This is a reconsideration pursuant to the writ of- mandate that was forwarded to your office on February 21. We have received a telephone call from Mr. William Gummerman, the attorney for the applicants , requesting that this matter be continued until the following Council meeting. Apparently your department did not notice the applicants that this matter was, being set for hearing and they did not learn of that until we be-. came aware of this oversight and telephoned them last. Wednesday. In the interest of due process , it is suggested that you join with the petitioners in requesting a continuance so that they might have an opportunity to prepare a responsive case . We note also that you. have set this matter for hearing under the com- munications portion of the. agenda While this is not a hearing for which publication is required, please be aware that due process re- quires you to nonetheless afford the petitioners an opportunity to speak and present evidence and other arguments in support of their ap- plications . Accordingly, perhaps it might be better placed on the agenda as a public hearing for which publication is not required under the "D3" portion of the agenda. Alternatively, it could be maintained . under the "M" section with an appropriate notation that the applicant has a right to address the Council and present evidence and argument . In our opinion, there is no legal necessity. to open the hearing up to comments from members of .the public who are not parties to the appli- cation. ROBERT SANGSTER Deputy City Attorney RS: be cc : City Administrator City Clerk REQUEST FOR CITY COUNCIL ACTION Submitted by James W. Palin Department Development Services Date Prepared March 10, , 1980 Backup Material Attached E] Yes No Subject RECONSIDERATION OF APPEAL ON CONDITIONAL EXCEPTION NO. 78-51AND ADMINISTRATIVE REVIEW NO. 78-74 TO REDUCE THE REQUIRED SIX PERCENT LANDSCAPING AND APPROVE AN OCCUPANCY FOR A CONTRACTOR' S EQUIPMENT STORAGE YARD. City Administrator's Comments Approve as recommended . Statement of Issue, Recommendation, Analysis, Funding Source, Alternative Actions: STATEMENT OF ISSUE: Transmitted for recon�sic�,,eration by the City Council are appeals to - - O/Tiov O Planning CommissGoIuion,tapproval of Administrative -Review No.. 78-74 and Conditional Exception No. 78-51. -'The conditional exception is a re- quest to reduce the required onsite. landscaping, while the admini- /strative review is a request, to approve site plan, elevations, and floor plans for a permitted contractor equipment storage yard.in accordance with all applicable code requirements. . The Superior Court has mandated the City Council to reconsider the prior denial of these applications. RECOMMENDATION: The Department of Development Services is recommending that the City Council deny Conditional Exception No. 78-51 and Administrative Review No. 78-74 with findings as outlined in the discussion section of this report. ANALYSIS: Appellant: Charles W. Poss/James D. Foss P.O. Box 1610 Huntington Beach, Ca. 92d47 Applicant: Same Location: East side of Gothard Street approximately 800 feet . north of Talbert Avenue. Request: To establish a contractor' s equipment storage yard (AR 78-74) and to allow a reduction in the required 6 percent landscaping (CE 78-51) . o� Pio 3ne Page Two CHRONOLOGY OF EVENTS: On February 20, 1980, the Orange County Superior Court issued a writ of mandate in the case of Foss/Poss vs. City of Huntington Beach. This suit pertained to the City Council ' s denial of Con- ditional Exception No. 78-51 and Administrative Review No. 78-74. After hearing arguments from both sides, the Court directed the City Council to reconsider the subject appeal and review the appli- cations on their merits and not on the use, which is a permitted one. December 8, 1978: At a public hearing held by the City Council on December 8, 1978, the City Council denied the applicant' s appeal of the Planning Commission' s action and conditions of approval of the November 7, 1978 Planning Commission meeting (transmittal and minutes attached) . November 7, 1978: On November 7, 1978, the Planning Commission over- turned the Board of Zoning Adjustments' denial of the subject appli- cations and approved the administrative review and conditional exception with findings and conditions of approval. (Planning Commission Minutes of November 7, 1978 are attached. ) DISCUSSION• The applications were originally heard by the Board of Zoning Adjust- ments at the September 13, 1978 meeting, where they were denied for the reasons as outlined in the attached Planning Commission staff report dated October 17, 1978. The Board of Zoning Adjustments did not find sufficient exceptional circumstances to justify granting a conditional exception. The applicant appealed the Board of Zoning Adjustments ' denial and was heard by the Planning Commission, and approved with certain conditions imposed on that approval. At the Planning Commission meeting the applicant- indicated that strict compliance with the 6 percent landscaping requirement of the Huntington Beach Ordinance Code. would be an undue hardship on the property due to its size, 300 feet of frontage, 605 feet of depth, and condition of the surrounding area. Discussion took place .as to what amount of landscaping, treatment of masonry wall, present and future improve- ments required for Metzler Lane and other conditions that should be required. It was the consensus of the Commission that: 1) the reduction in the required landscape percentage was justified; 2) that the width of the .landscaping area along Gothard Street frontage should be between 15 and 20 feet; 3) some sort of recess in the landscaping area at the proposed driveway entrance should take place; 4) that the landscaped area or island should be placed onsite directly behind the gate or wall opening to shield the bulk of activity being generated; and 5) Metzler Lane improvements should be bonded for as provided for in the Huntington Beach Ordinance Code and that at such time these im— provements are required or necessary, additional landscaping would be required to be provided along Metzler Lane frontage. The conditions of approval included a total percentage of landscaping of 4.8 percent, of which a portion; along Metzler Lane, would be installed at a future date. Page (Three • Action on the Administrative Review will be determined by the Council ' s decision on the Conditional Exception. It is the applicantts.,.responsibility to prove to the Council that a hard- ship exists, by showing the following: 1. Exceptional circumstances 2. Necessity to property rights 3. Absence of detriment 4. Good faith These four standards identified in Section 9832 of the Huntington Beach Ordinance Code are further defined as follows: 1. Exceptional Circumstance -"That there are exceptional or extra- ordinary circumstances or conditions applicable to the land, buildings, or premises involved, or to the intended use of same, that do not apply generally to the property or class of uses in the same district. " Staff analysis- of the subject site indicates that there are no exceptional or extraordinary circumstances to the subject property. Subject property is a regular shape in configuration with no major topographical irregularities that ,:.' would deprive the applicant from any of the privileges enjoyed by the adjacent property owners. The subject site is adjacent to one improved public street and another unimproved planned street. The subject property is zoned, designated on the General Plan as Light Industrial. 2. Necessity to Property Rights -"That such conditional exceptions are necessary for the preservation and enjoyment of substantial property rights. " The required 6 percent landscaping is not in excess of the landscaping requirements for any other commercial or industrial use in the City. This 3andscaping require- ment does not distract from the preservation nor the enjoyment of the applicant' s property rights. All other commercial and indus- trial uses which have received entitlement from the City subsequent to the adoption of Article 979 have provided the minimum of 6 percent landscaping without experiencing undue hardship. 3. Absence of Detriment -"That the granting of such conditional except- ion will not be materially detrimental to the public health, safety, and welfare or injurious to the conforming land, property, or im- provements in the neighborhood of the property for which such con- ditional exception is sought. " Part of the welfare for the general community is the requirement for a minimal aesthetically pleasing atmosphere. Therefore, the City has established certain criteria for development which will help to assure a certain level of . aesthetic quality. These criteria include setbacks, height limit- ations, screening of heavy or unsightly uses, and the requirement for landscaping. Therefore, the elimination of, or the reduction of the requirements set up as an overall City standard for land- scaping could be considered to be detrimental to the public welfare. Page Four 4. Good Faith: - "That the applicant is willing and able to carry out the purposes for which the conditional exception is sought; that he will proceed to do so without unnecessary delay. " The staff has no reason to believe that the applicant would not act in good faith and would proceed to do so without unnecessary delay. Based on .the above discussion; the Department of Development Services is recommending that the City Council deny Conditional Exception No. 78-51 based on the following findings: PROPOSED FINDINGS: 1. There are no exceptional or extraordinary circumstances related to the subject property.that do not apply generally to the property or class of uses in the same district. The requirement for 6 percent of the total site to be landscaped is a City-wide standard and has been applied in numerous instances without creating an undue hardship on other properties in the City. The subject property is virtually 100 percent usable, and therefore, the 6 percent land- scaping requirement would not substantially impair the use of the property. 2. Said conditional exception is not necessary for the preservation and enjoyment of substantial property rights- on the subject property. The property owner has full rights to develop and utilize the subject property in compliance with the provisions of the Ml zoning district. The 6 percent landscaping requirement is reasonable and a standard requirement for this industrial zone and all other industrial and commercial zones within the City. The proposed equipment storage can still utilize the remaining 94 percent of the subject property. 3 . The granting- of such a conditional exception will be detrimental to the public welfare in the neighborhood insofar .as all of the adjacent properties in the general area and all other commercial or industrial properties in the City have provided a minimum of 6 percent landscaping, which has established an aesthetic standard for not only the general area but the entire City. The granting of this reduction in landscaping could set a precedent in the City which would reduce this aesthetic standard. 4. There is no reason to assume that the applicant is not- willing and able to carry out the purposes- for which the conditional exception is sought without unnecessary delay. Action on the administrative review will be determined by the Council decision on the conditional exception. If the conditional exception is not granted, the applicant' s course of action would be to submit a revised site plan which complies with all applicable provisions of the Huntington Beach 'O inance Code including the landscaping require- ments, to the -Board f Zoning Adjustments for further review and action by the Board. The ouncil, ' in this case, should deny the administrative review based on fai. ure to comply with the landscaping requirements, without' pre`iudi'ce,� o allow filing of a further application with the Director of Development Services and meeting all applicable code require- ments. However, if: Council can identify findings of fact to support Page Five granting the conditional exception, those facts should be identified and staff directed to prepare appropriate findings to support granting Conditional Exception No. 78-51. If Conditional Exception No. 78-51 is granted, and Administrative Review No. 78-74 is approved by the Council, the staff is urging the Council to impose the conditions of approval imposed by the Planning Commission' s approval of November 7, 1978 and one additional condition pertaining to a storm drain for the subject property as depicted on 1975 Master Plan of Storm Drains (see attached memo) . If the conditional exception is not granted and the applicant wishes to resubmit a revised site plan to the Board of Zoning Adjustments that will comply with all ap- plicable provisions of the. Huntington Beach Ordinance Code, the applicant is entitled to have the administrative review application granted. ENVIRONMENTAL STATUS: Conditional Exception No. 78-51 is a categorical exemption (Section . 15105, Class V, California Environmental Quality Act, 1970) . Administrative Review No. 78-74 is covered by Negative Declaration No. 78-69, . adopted by the Board of Zoning Adjustments on September 13, 1978. FUNDING SOURCE: Non Applicable. ALTERNATIVE COURSE OF ACTION: 1. Identify facts supporting granting of Conditional Exception No. 78-57 and direct staff to prepare appropriate written findings for the consideration of the Council and determine what con- ditions should be required. SUPPORTING INFORMATION: 1. Area Map 2. Findings of Fact and Conclusions of Law received and dated 2/19/80 3. Request for City Council Action dated November 28, 1978 4. Council Minutes of December 8, 1978 5. Planning Commission Minutes of November 7, 1978 6. Board of Zoning Adjustments Minutes of September 13, 1978 7. Memo from George Tindall, City Engineer, dated March 6, 1980 8. Letter of Appeal from:_Applicant received and dated Nov. 17, 1978 Respectfully submitted, es W. Palin, irector Development Services JWP:SMB:gc J - lI�M 2 g S NE SLAM AVE j :ERAt. TEL MNNTENANCE YARD G 0 SPEER `.VF AVE a0 � Mill IIIE III u CF-R GF_� (N:JNTMGTrV MNTRAL PARK) W AN AVE I , ILLU U I Q �r ! m i W RONILLD DR 3 MI- o J ~ V owl 0.1 N J m A,� • r C F-R QRV�E " .(NUNT!Y.GTON CENTRAL PARK) T;R CO'' Y ANSFER_ R"DMINISTMITWE. REVIEW 7$- 74 CbMDt-f 10tA RL EA E.L EPT t b N 7 8 - 5'1 MN KACH HUNTINGTON BEACH PLANNING DEFT. s i� FOE CITY OF HUNTINGTON BEACH INTER-DEPARTMENT COMMUNICATION HUNTINGTON BEACH To : James Palin From: George L. Tindall Director Development Services City Engineer Subject : CONDITION EXCEPTION Date : March 6, 1980 NUMBER 78-51, AR-78-74 The subject property, owned by Foss-Poss, contains a natural drainage swale. The 1975 Master Plan of Storm Drains, approved by the City Council, indicates that a storm drain is necessary and is to be constructed in this low area to provide for adequate drainage. In addition a Master Planned Sewer line is also necessary and is to be constructed across this property. Therefore, in accordance with Municipal Code, the development of the subject property would require construction of the Master Planned Storm Drain and the dedication of a 20 foot easement for the storm drain. The costs involved in installing Master Planned Storm Drains is reimbursable under -provisions of the ordinance, subject to availability of funds. It is recommended that any approval of the subject property contain a condition that the Master Planned drainage and sewer facilities be constructed, including the dedi- cation of necessary easements. GLT:ik js NSIN r • 2 '� v FEB 19 pY I 4 lI �'ATTOR 5 I U ^� 6 � 7 I 8 SUPERIOR COURT OF CALIFORNIA I . COUNTY OF ORANGE � 9I 10 i 11 i JAMES D. FOSS and ) CHARLES W . POSS .) ) Case No . 30 91 20 i Petitioners, ) FI.dDINIGS OF FACT AND 13 I ) CONCLUSIONS OF LAW I vs . ) 14 ) CITY 07 Hi, NTINCTON BEACH, ) 15 et al . , ) 16 Respondents . ) ) 17 18 The above entitled cause came on regularly before the I I 19I court on October 15 , 1979 , in Department 22 of the above-entitled i 20 court , before the Honorable Oretta Ferri Sears , Judge of the i 21l Superior Court presiding, without a jury . William E . Gummerman �I 22 appe,ared for petitioners and Gail Hutton, City Attorney , by I I 73 liubert C . IanE; ;i;cr , Deputy City Attorney , cippeared i'or re:; on- 24 d0_nts . ff 25 The transcript and record of the Administrative Pro- 26 ctredIngs hav ins; been received into evidence and exar,;ined b,, the 27I court , acid briefs and arguments having been presented , the court i I 28 makes the following Findings of Fact and Conclusions •of Carr : - j I 1 . I 2 ,� Lhe Court finds, that. : 3 1 . Administrative {Zevie�.a No . 78-711 is a request to I 4 establish a contractor ' s storage ya.rd in a 1411-CD. zone , a use 5 expressly permitted by §9530 ( c ) of the Huntington Beach Ordi- 6 nance Code ; 7 2 . Conditional Exception No . 78-51 is a request pur- 8 suant to Huntington Beach Ordinance Code §9830 for relief from a' 9 code requirement applicable to the property contained i.n Hunt- 10 ington Beach Ordinance Code §9792 . 2 . 2 , imposing a requirement tInatl i 11 a minimum of six percent ( 6% ) of the net area• of the site be land- 12 �' scaped. . I I +- 4 n i. 13 I 3 . _T t The Board of Zoning Adjustments of he Clity 14 initially heard the application and denied it on the grounds set , 15 forth J.n City T7rhibit l . _ On that date the administrative revieih 16 was also denied in view of the denial. of the Conditional l:xcep 17 tion for reduced landscaping. (City Exhibit 1 . ) �. 18 4 . Petitioners .appealed the denials to the Plannir:c 19 Commission, whic.h overruled the Board of Zoning Adjustments at. I 20 I its meeting held November 7 , 1978 , made the necessary findings I 21 pursuant to Huntington. Beach Ordinance Code. 59832 , et seq . , and 22 r;rant;ed the Conditional. Exception subject to various conditions , 23 as set: f'ort:h more f'ul.ly in petltiorners, ' 1`;xhibit A . The _Planning 24 Commission further overruled the Board of Zoning Adjustments and I 25 granted petitioners ' application for administrative review . 26 5 . The petitioners then appealed the decision , of the 27 Tanning Commission to the City Council on the grounds that they I 28 '!"elt some of the conditions of approval were unreasonable � I 2 I - r,�� 1 ( l'M Lt-ionet•s Kh UK L. B . AL :its regular meeting hr:l'3 Decem- 2 leer 18, .1.978, the City Council heard We appeal and denied both 3 Conditional Exception No . 78=5.1 and Administrative Review No . 4 78-74 ; �, II 5 6 . in support of the decii-on , respondents made the 6 findings required by Huntington Beach Ordinance Code 559832 . 1 , 7 9832 . 2 , 9832 . 3; 8 7 . The decision of the City Council to deny the 9 applications was based , in part , upon a premise expressed by 10 , some members of the City Council that was not a basic working ` i 11 premise, namely , that the property use sought for the property 12 '.:;y the petitioners was not a permitted use . In dolig so , those �. 13 I members of the Council failed to determine the merits of peti- 14 I tioners ' claim for a Conditional Exception . 15 16 I PROPOSED CONCLUSIONS OF LAly] { 17 From the foregoing Findings of Fact , the court makes ! 18 the following Conclusions of Law:. i 19 i . Administrative Review No . 78-70 is a request. to j i 20 establish an exphessly permitted use which is not subject to an l21 I� unconditional denial . 22 2 . An expressly permitted use may not be denied ; 23 howevc.-.r• , ',I, review may be dQnl ud .1 r the applicant � I 24 h;r:; not compl.3od with all applicable provis:i.ons of the Huntington 25 Heath 0,:•dinance Code . 26 I ppl.3 . An application for a conditional excepsion ma • � E y be , I. 27 dr�n:i.ed upon evidence that the findings required by Huntington 28 Beach Ordinance Code 19832 , et seq . , do not exist . I I i ;' 3 . T)I(.. pl. 1 (,w c1c.11 i.r1.1 of tl c;at• Ion CoI Conc(]l.- 1 2 tCtlu . cxcet�tio n was _got.i re ;trl.ct;ed to the merits of petitioners ' 3 claims under Huntington Beach Ordlnance Code §9832 , et seq . 4 5 . Petitioners ' appllcation for a Writ of Mandate is 5 � .granted and the City Council is ordered to reconsider its prior. I 6 denial and limit such reconsideration to standards set forth in 7 Huntington Beach Ordinance Code §9832 , et seq . , and other .ap_pli 8 I cable code provisions . 9 LET JUDGIIENT BE ENIIERED ACCORDINGLY. r � 10 D at.ed 11 12 I ORETTA FERRI SEARS -- - `S ORETTA FERRI SEARS 13 + Judge of . tne Superior Court I 14 }. ., 15 16 17 18" 19 20 i I 21 22 i . 23 24 25 26 27 28 I 4� y �, 9 ro ss/�a Ssl r=�c .e II REC JEST FOR CITY COUNCIL ACTION Submitted by Floyd G. Belsito Department Public Works Date Prepared August 23 . , 1ff19 Backup Material Attached X� Yes No Subject S orin nrain anA cAkfflr Fasempnt Through the Foss/Pons Property___ Located E/o Gothard. Street; CC-481 City Administrator's Comments C.t Approve as recommended . CITY CLit 2— statement of Issue, Recommendation,Analysis, Funding Source,Alternative Actions: Statement of Issue: In order to construct the needed storm drain and sewer systems in the Gothard/Talbert industrial area, condemnation of property for the .storm drain and sewer easement must be accomplished, because the property owner will not dedicate the necessary easement. Recommended Action: Authorize the City Attorney to start condemnation proceedings for the storm drain and sewer easements across the Foss/foss property, and authorize -staff to prepare a reimbursement agreement ..with the affected property owners. Analysis: On December 4, 1978, the City Council authorized Hall & Foreman, Inc. , (Consultant Engineer) to design the Gothard/Ta.lbert storm drain and sewer systems The construction drawings were complete and the affected Property owners were contacted for .the granting of storm drain and sewer . easements. Easements were. received from two of the affected property owners, but Mr. Foss and Mr. Poss did not want to commit themselves to the granting of any easements until their pending litigation with the City was resolved. Landowners. in the area are anxious to develop their properties, but cannot do so until the Foss/Poss easement is obtained. Therefore, we . recommend that condemnation proceedings be initiated as soon as possible. This procedure which includes an appraisal, resolution of necessity, and an order of immediate possession will take approximately four months. In .the meantime the landowners who wish to. develop their properties can proceed with administration for the construction of the proposed storm drain and sewer lines within the City's proposed- alignment. Reinforced concrete pipe takes at least three months to manufacture and deliver. Ther•.efore, at the time the City receives an order of immediate possession the storm drain pipe will be available for instal)ate on by .the developers Request for Council Action Storm Drain and Sewer Easement CC-481 August 23, 1979 Page 2 Since the storm drain system is a part of the City' s master plan, the cost- of the construction can be credited against the developer'.s . drain- age fees and any excess construction costs could be `recovered through a reimbursement agreement with the City. Many storm drains and sewers have been constructed in this manner in the past. Alternatives: (1) Do not proceed with condemnation for an easement through the Foss/ Poss property, but construct parallel sewers and storm drains on the north and south properties adjacent to the Foss/foss property. The problem with .this alternative is two fold. First of all, ease- ments have not been acquired from the A to Z Wrecking Yard property owners or from Foss/foss. Easements would be needed from both pro- perties in order to accommodate the storm drain and sewer. Secondly, because. of . the parallel construction of lines, the project would cost approximately $70,000 more than the primary alignment. (2) ' Do not proceed with the condemnation of the easement. This would prohibit development south of the Foss/Poss property until an ease- ment is granted. (3) Authorize the Public Works Department to administer ..the construction project. Under this alternative the storm drain could not- be built before this winter because of the required formal bidding. procedure and following required. council action. Private developers are not subject to the. restrictions that the City is subject to in advertis- ing, bidding and awarding a contract. Funding:. Costs for .the appraisal and condemnation would be financed with the City's sewer and Drainage District 9 funds. As of June 30, 1979, . Drainage District 9 had $580,0.00±.. Setting aside $100,000 for the Slater storm _drain pump station equipment and $200,000 for the building, and also $110,000 for the Talbert Avenue storm drain, east of Gothard .Street, which. will be constructed wit# the Talbert AHFP- project this fall, the drainage district has $170,000- which is sufficient for the proposed project along and through the Foss/foss property. FGB:WAP:lw- __ANNINS _ SECTIONAL DISTRICT • MAP 26 - 5 - 11 • ��� CITY OF - i HUNTINGTON BEACHA& PROPOSED_ GOT14ARD/ ORANGE COUNTY, CALIFORNIA ITALBERT STORM USE OF PROPERTY MAP DRAIN - SEWER ALIGNMENT AND. I WARNER LEqAISI E M E IN A" AA, AVE I ' CF_E I a 1 L� - CEDAR AYE I -_ .. � I I �• � , -H1 I j!! F- ..E isj--_-.: . 'r-. j11� I q_ _ CF-C �i 1 u = __-J� r:F�F 1 - J''Jl .•', .��`'�I 1 1 '� EfCIST IA/� -ST `�B�►N��__ ._::::; I AMO Slows g I' slah4s ff 1 .I I - `'.F_R i.1 PR��IOQ� 05 0: STORM tDB�►/Iii 4lop SrWa�t_ ►�€�EJIIT PRO ED SR1AI I�Q. •AMP ----- -- I *TOORAI�I AL16N Mf�1T / '1Y�I�I.i:.... .1...; , L ! DTNA R R 8 /H _ JL__ 7ALBER M AvE PRAPOS►fD IriALBERT T02t pRA�A� CITY HUNTINGTON BEACH INT -DEPARTMENT COMMUNICATION 9 MUNTINGTON BEACH To Floyd G. Belsito From Paul E. Cook CO,vdeAih . � �� oNF� Subject Gothard/Talbert Date rm Drain• Se tomb r, V �S CC-481 t . Considerable discussion has been heXd recently on the subject matter. For the City Council' s benefit, :the following is a history of the most recent decisions on drainage within the area shown on the attached map. 1. During the winter of' 1977-78 the "A to V Wrecking Yard -property was flooded due to grading of the Foss/Poss property. A remedial drainage system was constructed on the Foss/Poss. property. How- ever, litigation for the prior flooding was undertaken by "A to V naming the City and Foss/Poss at fault in the matter. .2. On. lb/2/78, the City Council authorized the design of the subject storm _drain by Hall & Foreman, Inc. This design has, been completed. 3. Last month, the City Council authorized condemnation proceeding for a _drainage easement across the Foss/Poss property. They also authorized the preparation of a reimbursement agreement with Manthei/Buccella whereby. M/B would install the subject storm drain system in conjunction with the development of their property in the area. However, M/B in their letter of 9/7/79 said they are no longer.. interested in installing the drain because of the City code requirement that only 90% of the total cost is reimbursable to them. It is their contention that the City should proceed with the acquisition of easements and condemnation where necessary as well as letting a contract for construction of the storm drain system. Alternatives I have analyzed. the matter and feel there are many alternatives for the City as follows: 1. Proceed with- acquisition of easements and construction. of the en- tire drain from Gothard to. Talbert. I do not favor this alterna tive because it puts all the burden on the City when the property owners along Gothard will be the primary benefactors. I feel that all easements including Foss/Poss should be dedicated at .no cost to the City' before the City would construct the drain. The total cost of 'this drain is estimated at $275,000.00. 2. Do not participate in any way with the storm drain system, leaving it to future developers to install on, a reimbursement basis. I do not favor this alternative because it indicates bad faith on the. part of the City who has in the past supported the project by' acquiring.. some easements and having the storm drain design completed. In addition, the. City Council has indicated support for light industrial development in the area. Memo to Floyd G. Belsito Sept. 25, 1979 ,Page 2 3. Proceed with a contract to install a storm drain from Gothard easterly to the railroad as shown on the attached map. An ease- ment for this construction has already been granted. I am in favor' of this alternative because it will allow approximately 50 acres to develop- at a cost of only $125,000.00. This cost will be recouped by. the City in a reasona4ly short time through the payment of drainage fees for these 5.0' acres. This alternative will not require the condemnation and payment for any other ease- ment from a private property. owner. The remainder- of the storm drain system from the north side of the Foss/Poss property to Talbert Ave. could be installed by a developer on a reimbursement basis or by the City after all ease- ments have been granted. Recommendation It is my recommendation that .the City Council approve Alternative No. 3 as described above and authorize staff to complete plan and specifications for their approval as .soon as possible. C � Paul E. Cook Director of Public Works PEC: jy Attach. SLC,l_•1ONAL DiST FT MAP 26 CITY OF H UN I G 1 ON 131-ACI ORANGE COUNTY, CALIFORNIA 1 i USE OF PROPERTY MAP PORTION:STO OF/�� 1 G/�OTI4A RDl''� L B ERWARNER T j r - Hill: :il;A^pll �-1 •_ 0.1 . fff (o •- u LJ Li J ;ij - -- 17 17. 1 : .._AREA 1 IMMEPIATEL' ! ! ;S6NEFI mm& E5Y t ! Pao APSE D STORM-DIs PROPOSED STORM ORAIlJ i ; { J - - ; . FVTUR STORM OQAI I i �.... :;'I` ... :::::: : Ta LBEA7 AVE i i DEFERRED ' AY COUNCIL CITY OF HUNTINGTON 8EA4H too INTER-DEPARTMENT COMMUNICATION ; r ......i -I-.? ...................... i M.na+cTa+Kam ` .............................................. To F.•::G,. .,Belsito From Bill Patapoff Subject. othard/Ta.lbert -Storm, Drain Date Sept. 11, 1979 cc-4s1 ; After, ieviewing the Manthei/Buccella. letter of September 7, 1979 the followim ` BCtton$°;rare recommended: i i�ctiat�ye�t The 'trutary area foz the Gothard/Talbert storm drain is .-for the most part und.'ep oped �nvacant .industrial property. The 'natural drain- age courser F� 'fi cape d exc4pt .:for the grading of the Foss/Pos' s property. Becso ��1f,' tthi$- grading the A tq Z Wrecking Yard. building south of. the t`Po® :,� p property;:was flooded ,two winters ago' As a result of the. 4%` d3.Qg F6 0: .-Foss constructed .a 24" and 36" diameter corrugated meta7p pe.;dranage' 'system through their property to remedy the flooding � Ag.�an .interim-. so.lution and until additional development in the areas ahwed, this .system should suffice. Therefore. it is recommended.:'that':as _ a` a` area develo s t � owners be require to: e_ •cati �emdnts and- construct the necessary :storm drains: Since Manthei/Buceella•.indicated in their. letter that there is no incentive for: then io.:.6onstruct- the necessary storm drain system (there- fore not developing -theYr.:``property) , it is, recommended. that the City not proceed "with' the 'condemnation for the storm drain and sewer easements across. the doss%Poss- property. There is -no reason for us to purchase the easement.at this, time, `because we could require it later as a condi- tion of development of the Foss/Foss property. Attached is 'a copy of the Foss/Pose easement appraisal. Furthermore, the reimbursement agreement with Maiithei/Buccella is not needed as was recommended to the Council at. the.ir last 'meeting. An alte -na ; to, the above recommended action is to proceed with condemnation.. and' purchase the 'storm:.drain and sewer easement through the Foss/Poss,-: property: Also in order to encourage industrial develop merit in :the surrounding area,,, instruct the City's engineering staff to administer.'thb construction-, of' a portion of the Gothard/Talbert storm drain -and sewer,.. The drainage district presently has enough money to construct a storm drain along and through the Foss/foss property. . It- is anticipated that this construction could begin in the spring, 1980. In regards: to. the 908 maximum .reimbu.rsement stipulation. in .the . City Ordinance Code, this could be changed to 100% reimbursement by amending:tfi6 0idinance. Most other public agencies offer a 100% re- imbursement. . . . . . . . . Bi Patapoff Civil Engineer Associate WAP:jy September 7 , 1979 Mr, JFkoyd Be,��ita City Ads inistrator City of ROntington Beach P . . Hwatli tow, $each; 92648 Suh, +gt � ' albert,.storm drains t d Dear ! r� We of ,4y ` Che efforts made by you. and the City Council to S0107 , `` a ge problem with an early project of the Goth- ard-Talk N drain. However , due to what we understand are the cone a Chapter 14.48 of your ordinance code imposing a 90% met ursment we find that we cannot justify enter- ing into a rei.mbursment agreement with the City. The project is estimated to cost $253,000. 00 , therefore we would lose $25 , 300 . 00 , right off.`the''top•, even though we are only one of the participants in the project. If 100% reimbursment were possible we would be willing to en- ter into an agreement . However if we must lose the 10%, there is no incentive for us to participate. We urge that you expedite the project by whatever means are at your disposal and if there is any way we can help please contact us . Very Truly Yours , Manthei/Buccella Investments Timothy. M --� -F-- Franklin,<T, 3u.cel la Jy • � E__ CEDRIC A. WHITE, JR., M.A.I. REAL ESTATE APPRAISER 2651 WOODLAND DRIVE ANAHEIM. CALIFORNIA 92801 17141 527-0261 August 31 , 1979 City of Huntington Beach P. 0. Box 190 Huntington Beach, Calif. 92648 Att: Charles" B. Davis Re.: Proposed 15 ' Easement - Real 'Property Agent Foss, et al Property Gothard Street Dear Mr. Davis : .Subsequent to our meeting at the Foss, et al property on the afternoon of August 27, I have made telephone contact with Mr. Foss . Fie was available at 846-7328. It is his residence , and he also has his office there. Accompanying this letter is a copy of the letter I sent to ?1t. Foss . He didn 't feel that we needed to meet at the property. to make an inspection. . However, I did leave an opening for future contact, if that would be his choice. For .preliminary evaluation purposes, I believe there are two methods of analysis: First, the land would have value for •continued incidental industrial type storage purposes , and the easement .acquisi- tion would be 50% of the fee value for this limited type of industrial use. Second, and subject to review by the City Attorney, I would estimate the proposed acquisition as 500 of the fee value . for all "of the industrial uses to which the land is available and adaptable. Please note that soil tests and a title report have not been re- viewed. Both of these could be pertinent in the two evaluations . And, the area of the easement is an estimate , and is . subject to a City Engineer 's calculation . The value conclusions are contained on the. following page , SU!'L"4ARY OF EVALUATION . I have added a third alternate which requires re- view by the City Attorney . As to each alternate., there is no apparent damage -- though some consideration would need to he given in alternates 1 and 2 , if a railroad spur track could not bu placed Charles B. Davis August 31, 1979 Page 2 along or across the 15 ' easement. Accompanying this letter are the following : SUT1A1ARY OF EVALUATION, RIGHT OF WAY MAP, PURPOSE OF APPRAISAL and PREMISE SECTION . Other data and analyses for this preliminary evaluation are retained in my files. Very truly yours , CAW:dh dric A. White, Jr. , M.A. I SUMMARY OF EVALUATION APPROXIMATE CONCLUSIONS FIRST METHOD If open storage land only. $2 .50/� fee x 50% esmt. _ $1 . 25/�. 4650� x $1.25/gi = $5,,813, Say $5 , 800 SECOND METHOD If industrial land available for all zoned uses . $4 .50/tfi fee x 50% _ $2 . 50/t 4650t x $.2 . 50/t, _ $11 , 625 THIRD METHOD If have to dedicate = nominal 4650t, @ nominal = nominal, say $500 •t::i i i t gi: 1 - `J t,- t .� 4f '" �`��`�'r�t�r' r}+'it lYt'f°4]°{r ul-•i�-.t �rr.w tl�.�lr/-.+ �.� �� _ �_� .�—_ i. —;— _�— �— —— + � { � `1':S`A�sr��� ,�R°t J�rr ���15�x { ' L` �• I ill vIA �cP1r��zPti*r r+�` �.•'41 V1' < \ `.� Rs Y,... ,k -t)r\\'-V\ �V 1` t �I 1 AWT 1I Fn . �� � ���}�- # 3 t?„`�, tr1� >x Eke-d((r•-� �. (�_ � � 1 try'+Y , (yi( •�d��.'! �+ +� }}t}, E` \ \ 'tit- ' ::.c 3,tffY yy�1�};/ r its 6�9h� - !�{° i �,$3F�f1t f•�fi� v '� ( 40. �` 1�;&1i•G�t ` �"�ir.,� V}r.. t�..a'` - - - - (J ', i . h hh� { - •.} t jfi�� jNl tlr- F t +{ f{.Ll r„ � ,mil-.� ^ ._ �` t S4 'S e r • '.a i Sit rf!-4 1 ' �� M1• N ' PURPOSE OF THE APPRAISAL The purpose of this appraisal is to estimate the approximate fair market value of property described .as the proposed 15 ' easement, Foss , et al property on Gothard Street, City of Hunt- ington Beach. Date of Value: Current Date The fair market value of the property taken is the highest. price on the date of valuation etc. , as. per Section 1263. 320 in Assembly Frill No. 11 that was effective July 1 , 1976 . PREMISE SECTION This appraisal has been based upon the following assumptions and limiting conditions : 1. That I assume no responsibility for matters legal in character, nor do I render any opin- ion as to the title, which is assumed to be good. All existing liens , easements , leases , bonds and other encumbrances have been disre- garded unless . otherwise specified. The prop- erty is appraised as though under responsible .ownership and competent management. 2 . That while information was obtained from sources felt . to be reliable, it is in no sense guaranteed. 3 . That this is an approximate valuation based upon a preliminary investigation and analysis , and it is subject to refinement after additional study . City of . Huntington Beach f° 7 P.O. BOX 160 CALIFORNIA 92669 OFFICE OF THE CITY CLERK January 16, 1979 William E.- Gummerman; Attorney at Law 16152 Beach Boulevard, Suite 279 Huntington Beach, CA 92647 RE: James D. Foss and Charles W. Poss City Council denial CE 78-51 and AR 78-74 Dear Sir: Enclosed please find the copies of, the file material on the .above- mentioned proceedings, as requested pursuant to $. 1094.6 of the C.C. P. The City has not as yet adopted a Resolution pursuant to S. 1094.6 (g), but your request did bring the matter to the attention of the Legal Department. A statement in the amount of $7.20 is attached for copying the material. Sincerely yours, Alicia M. Wentworth City Clerk AMW Enc. T sa •STATEMENT — IN ACCOUNT WITH City of Huntington Beach Huntington Beach, Calif. .7anuary. 16 19 11L William E. Gummerman, Attorney at Law 16152 Beach Boulevard; Suite 279 Huntington Beach, CA 92647 L J 72 pages @ 10q, each 0.20 Foss & Poss CE 78-51 and AR 78-74 WILLIAM E. GUMMERMAN ATTORNEY AT LAW HUNTINGTON"EXECUTIVE PARK-EAST BUILDING 161S2 BEACH BOULEVARD,SUITE 279 HUNTINGTON BEACH, CALIFORNIA 92547 TELEPHONE (714) 848-1088 January 11, 1979 Office of the City Clerk City of Huntington Beach Post Office Box 190 Huntington Beach, California 92648 Re: James D. Foss and Charles W. Poss, . City Council denial CE No. 78-51 .and AR -No. 78-74 Dear'Ms, Wentworth: Formal request is hereby made pursuant to ..C.C;P. § .1094.6 (c) that you prepare and send to me the complete record of the pro- ceedings involving the above entitled matter. I represent "Messrs. Foss and Poss in these matters, and we will that -record for the purpose of filing the appropriat.! petition for writ:,of mandate. Please don't hesitate o give me a call .if you have any questions concerning this reques u s v ry ruly, ills , unmmerman . WEG/pb cc : City Attorney's Office City of Huntington Beach . Post Office Box 190 Huntington Beach, CA 92648 Messrs, James D. Foss and Charles W. Poss e Post .Office Box" 1610 Huntington Beach, CA 92647 K� City of Huntington Beach P.O. BOX ISO CALIFORNIA 82648 OFFICE OF THE CITY CLERK December.29, 1918 Mr. James D. Foss Mr. Charles W: Poss P. 0. Box 1610 Huntington Beach,_ California 92647 Gentlemen: The City Council of the City of.Huntington Beach at its .regular meeting held Ho'nday, December 18, 1978. denied. CE #78-51 and AR #78-74. "This is a final decision. You are hereby notified that pursuant to pro- visions of Section 1094..6 of the Code of Civil Procedure of the State of California you have ninety days from December 18, 1978 to apply to the courts for judicial review. " If you have any questions. regarding this matter, please contact our -office - '536-5226. Sincerely yours, Alicia M. Wentworth City Clerk AMW:bt CC: City Attorney § 1094.6 • CODEO CIVIL PROCEDURE rr 1094.h. ('fitn­ limit for seeking review of administrative determinations: ; Preparation (if record: Application in local agency] (a) Judicial review of any decision of a local agency, other than school { district, as the term local agency is defined in Section 54951 of the Government Code, or of any commission, board, officer or agent thereof, may be had pursuant to Section 1094.5 of this code only if the petition for writ of mandate pursuant .to such section is filed within the time limits specified. in this section. (b) Any such petition shall be filed not later than the 90th day following the date on which the decision becomes final. If there is no .provision for reconsideration of the decision in any applicable provision of any statute, charter, or rule, for the purposes of this section, the decision is final on the date it is made. If there is such provision. for reconsideration, the decision is ' final for the purposes of this section upon the expiration of the period .during which such reconsideration can be sought; provided, that if reconsid- eration is sought pursuant to any such provision the decision is final for the ; purposes of this section on the date that reconsideration is rejected. (c) The. complete record .of the proceedings -shall be prepared by the. local agency or its'.commissiori; board,.Q ficer, or agent which-made the decision And shall be delivered to the petitioner within 90 days after he has filed a written request therefor. The local agency may recover from the petitioner. its actual costs for. transcribing or otherwise preparing the record. Such record .shall include -the ,transcript of. the proceedings, all pleadings, all notices'. and orders, any proposed decision by a hearing officer, the final decision, all admitted exhibits, all rejected exhibits in the possession of the heal agency or its commission, board, officer, or agent, all written evidence, and any other papers in the case; (d) if the petitioner files_a. request for the record as specified in subdivision (c) within 10 days after the date the decision becomes final as provided in subdivision (b), the time within which a petition pursuant to Section 1094.5 may be filed shall be extended to not later than (lie 30th day following the date on which the record is either personally delivered or mailed to the petitioner or his attorney of record, if he has one. (e) As. used. in this section, decision means adjudicatory administrative decision made, after hearing, suspending, demoting, or dismissing an officer . or employee,.revoking or denying,an application'for a permit or a license, or denying an application for any retirement benefit or allowance. (f) "In making a final decision as defined in subdivision (e), the local agency shall _provide notice to the party that .the time within which judicial review must be sought is governed by this section. As used in this subdivision, "party" means an officer-or employee who has . been suspended, demoted or dismissed; a person whose permit or license has been revoked or whose application for a permit or license has been denied; or a person whose.application for a retirement benefit or allow�ince has been denied. Q) This section shall.he applicable in a local agency. only if the 'f;overning board Ihcreof adopts an ordinance or resolution ivakinb this section applica- ble. if such ordinance or resolution is adopted, the provisions of this seolon 60 (9 Gv Pror.Cod..] �SSt ,I V PROCEDURE § 1006 C.F.I)U R G CODE OFCI IL i RO('El L RC: ,tinations: shall.prevail over any conflicting provision ill any otherwise applicable law relating to file subject platter. Added Slat., 1976 ch 270 § I. If school Revicw of Selected 1976 California Legislation. A Pacific I.J 247. ' I of the thereof, § 1095. [Award of damages: Recovery from public entity] tition for C'alJur ?d lalforccnlent of Judgments§?,Ciovernntenl Toit liability § 13. tic', limits 1.In Cencral, cowry of d:unages by an applicant for administra- Thc gencral provisions of Cock Cie. Prod., live relief• ihc. award of costs it, a prevailing Wing the §I095, allowill: daimig"s ill"iniilchillius actions, a1plicant in a nianchimus proceeding normally lies �1(lil for were ntit iinended to pt.0-ail uder the-spcclfi� within the discretion of the court. 'Tripp v Swoap st:itote, ininnulitics granted to jwhlic entities and public (1976) 17 CM 671, 131 Cal Itp(r 789, 552 P2d 11 oil the cmhlo)ees by (.iu\. C't.,dc; §§818.4, 821.2. State v 749. Superior Court (1)74) 12 C?d 237, 115 Cal Rpir 'clsloll IS 497. 524 P'_d 12M. S.—in Specific Instances 1. period - In :w .aluunisuali\r nlan,l.uuu< lao,'rrdint•. in 1)amagcs l'C'()nSid Mill.11M h\' ploh;ltl„11;11\.lear11e1 \\Ito had riiel\ed 1.for the The imm1?1-unity Ili p of the:ilic Cann Act, granting notices of icrthum ion Irons dcfend;utt school dis. irilnunuly to public entities-and employees for u'1..t hoard of trustees wrsuant In liJ. Code. Jiserninnary arts in grlirlal (Gov..Code, §§+(20.2, 815.'_• suhd. (li)), and for licensing activities in § I3447, based on a decline in pupil attendance Ifr IoC'al ;Ind planned reductiuns.iti services, the that court panicul:u' (Ciuc. Cade. §§ti_I.._,.81#.4,) t:Ikc pn•c•. decision edence o\cr file protisions of Code Civ. Proc., did not err in awarding costs In the leachers, -even filed it § I01)5, providing that if a petitioner ill a Illanda- though judynlcnt writ against them, \where they ctIl1011ef mus action rcco\cn judgnle•nt• he may :its() i'c- Prcv:iiled on file issue whether the hoard had ,,,er ;I:nnugcs agumsl the public entity repre- ordered termination of more employees than nec- 1. 11C11 cssar d a l 15111I r ol• the leachers would have \e-tet� h•. the officer ag:u:nt uhonl. the artioti.is )'• an :ngs, all hrougl,t. O'llagan v Homd of Zoning Adjustment been entitled to relief, would have had judgment, lie fpal (P1714) 38 ('Ak1%2;, 111 Cal Rim >(ll. but for the actions of the hoard in recnlploying '1 of the Ihcm and rendcitng Iheir IM111un nlco,l. Lewin v 4.('n+tti Hoard of lruslecs (1476) 62 CAM 977. 133 (:al \Idellce, Under Code Civ. Pine., § I005, goveiuing re- Rpir 385. 'i1lVlslon t ided in § 1096. Service of the writ 1094.5 2 Cal Jur .,it Adnliilislralke Law §.125. .'IIICg the to file Istralive - 1 Officer - Iise, or agency review ho has ','•c has IcIlied: s hcen Criiin , ,,,I I'?Q,hri,r,Cwit-1 61 IN THI Superior Court OF STATE OF CALIFORNIA In and for the County of Orange ....CITY A.F.MUNTIMOTON...13.EAC .I!Y..CLER.K PROOF OF PUBLICATION Pub1-ic.-H-earing................................... ...................................................................................................... ..... .................. .......... r ,AM Fi P 01110GENAMMINMG-5 U APPEAL TO CONDITIONS OF - State of California I APPROVAL County of Orange Ss. CONM76NAL EXCEPTION' ....Ri r ta...J....Richte- .......................................................... AN0,1- ft f7 ibetp That I am and at all times herein mentioned was a citizen of the I elic.heiftfiilwffi"be field OVA00 unc 3�a Of t&1C.r of h"QW&Beach, United States,over the age of twenty-one years,and that I am not a in the CodhWtha6ber of th`6 VWCen;- party to,nor interested in the above entitled matter;that I am the I ter,-Huntipiti5h Beech,at the 7:30 P.M.,-or is Mdn themifthr as poss.ii-I principal clerk of the printer of the I ble,on Wndaj.,the daY-6,13eceimizi ber.1978,for 'e, '-.-d ACM M an apoeiC*65 Wons -0 M -Hun tington.-Beach..Ind ep.en dent.Revdew.... osed Y Vu ni app '0�ion a newspaper of general circulation,published in the City of I 0.78.51 _W 7 -74 in tra- five'Review No T847,4 isaaesE to Hurit ington**Beach..................................... in an..MI.-- cue i County of Orange and which newspaper is published for the dis- 78-61 isrequest sernination of local news and intelligence of a general character, six (6) Vieweritt anpeapp and which newspaper at all times herein mentioned had and still inatel -hid one .. 'b"ian pin t e an Mil for J has a bona fide subscription list of paying subscribers,and which ., ­1 5'. .8 Le;u; - e as MAO sub newspaper has been established,printed and published at regular Got tF;s funa_5 intervals in the said County of Orange for a period exceeding one north "I'TV111 Ve- AIR 0 review will beN Ati tion lo I A year; that the notice,of which the annexed is a printed copy,has legalidwesOnquon n Planding _[Wn.uon[Wn Uon Awn Bon Rn Gon been published in the regular and entire issue of said newspaper, De A01in en 'Pe_..aona ere M� to and not in any supplement thereof,on the following dates,to wit: lattind 'a So—m-'n-g- and I W reas 9 o fMir- jfrom Wl st N. -1 NEW, November 309 1978 ................................................................. (714) Datgd:N C ................................................................. HUNTING. JBEAEH.- Sy:' -ENT H_ W WORT Pub.'Nov A .................. Hunt. c 1 #105 I certify(or declare)under penalty of perjury that the foregoing is true and correct. Dated at ..............Garden-Grove..................... Calif h..d No-v b JR 19.7a..... . .......... Signature r /� Form No.CAF-51377 REQUOT FOR CITY COUNCISACTION Submitted by :r,1?ames..:W.l Palin . -_ Department Planning Date Prepared November 28 , 1978 Backup Material Attached ❑X Yes No Subject APPEAL TO CONDITIONAL EXCEPTION 78-51/ADMINISTRATIVE REVIEW NO. 78-74 Planning Commission approval of a contractor' s equipment yard located on the east side of Gothard Street 800 feet ± north of Talbert Avenue. City Administrator's Comments Approve as recommended. Statement of Issue, Recommendation, Analysis, Funding Source, Alternative Actions: STATEMENT OF ISSUE: Transmitted for consideration is an appeal to the Planning Commission' s approval of Administrative Review No. 78-74 and Conditional Exception No. 78-51 for the establishment of a contractor' s equipment storage yard. RECOMMENDATION: The Planning Commission recommends that the City Council uphold their approval. of Administrative Review No. 78-74 and Conditional Exception No. 78-51 with the conditions imposed thereon. ANALYSIS: Appellants James D. Foss Charles W. Poss P.O. Box 1610 Huntington Beach, CA 92647 Applicant: Same Location: East side of Gothard Street approximately 800 feet north of Talbert Avenue. Request: To establish a contractor' s equipment storage yard (AR 78-74) and to allow a reduction in the required landscaping (CE 78-51) . PLANNING COMMISSION ACTION ON NOVEMBER 7 , 1978: ON MOTION BY FINLEY AND SECOND BY COHEN CONDITIONAL EXCEPTION NO. 78-51 WAS APPROVED WITH THE FOLLOWING FINDINGS AND CONDITIONS, BY THE FOLLOW— ING VOTE: P10 V78 �a C,ity Council- Appeal• • CE 78-k/AR 78-74 Page 2 FINDINGS: 1. The nature of the use and size of the subject parcel constitute excep- tional circumstances on the property; for example, distribution of landscaping in the amount of proportion to the code requirements would serve no useful purpose in furthering the intent of the Ordinance Code to provide a pleasant street scene. Furthermore, the imposition of landscaping in excess of code requirements along the existing and pro- posed streets for the property complies with the intent of the code provisions. 2. The requirements for six percent landscaping upon the subject site constitute an exceptional hardship for the applicant for the afore- mentioned reasons. Approval of the exception request is necessary for the preservation of property rights in this instance, as the institu- tion of landscaping along the street-side property lines as depicted on the submitted plan is comparable toy or exceeds the amount of land- scaping normally required for small parcels in like zones. 3. Granting of the conditional exception will not be materially detrimental to the public health, safety,' and welfare because of the landscaping treatment proposed within the public view. CONDITIONS OF APPROVAL: The revised plan reviewed and dated November 7, 1978 , shall be the approved, layout, subject to all .of the following conditions: 1. The landscaped area along the Gothard Street frontage shall be at a width of fifteen (15) feet with a six (6) foot high decorative masonry wall at 15 foot setback, recessed a minimum of forty. (40) feet at the proposed driveway. 2. A landscaped island or grouping to be placed at some reasonable dis- tance in the facility directly in back of the proposed driveway opening at a width and length to sufficiently screen as much of the onsite activity from public view as possible. 3. A minimum of a ten (10) foot landscape area shall be provided along the future Metzler Lane frontage at such time that Metzler Lane is physically improved to City standards. 4. The proposed six (6) foot high block wall along the Gothard frontage shall be extended around the future return at its intersection with Metzler Lane and the curved area within the return shall be fully land- scaped at the time of construction of the block wall. 5. All landscaped areas shall be provided with an automatic sprinkler sys- tem and plans for such irrigation and landscaping shall be submitted to the City Planning Department for review and approval. 6. The proposed driveway from the Gothard Street property line into the ,facility shall be paved with asphalt concrete for a minimum width of thirty-five (35) feet and to a depth of 100 feet (or to the proposed �Q) onsite landscaped island) . City Council ,- Appeal • • CE 78-'51/AR 78-74 Pace 3 7. A revised plan reflecting all of the above conditions shall be sub- mitted to the Planning Department for review. 8. The sewer, water, and fire hydrant systems shall be designed to City standards. 9. The sewage disposal shall be through the City of Huntington Beach sewage system. 10. The water system shall be through the City of Huntington Beach water system. 11. The property shall be subject to local drainage assessment district requirements and fees. 12. All applicable ordinances and codes shall be complied with. AYES: Higgins, Russell, Stern, Finley, Cohen, Bazil NOES: None ABSENT: None ABSTAIN: Paone ON MOTION BY FINLEY AND SECOND BY RUSSELL ADMINISTRATIVE REVIEW NO. 78-74 WAS APPROVED SUBJECT TO ALL CONDITIONS IMPOSED UPON CONDITIONAL EXCEPTION NO. 78-51, BY THE FOLLOWING VOTE: AYES : Higgins, Russell, Stern, Finley, Cohen, Bazil NOES: None ABSENT: None ABSTAIN: Paone HISTORY/DISCUSSION: These applications were originally heard by the Board of Zoning Adjustments at its September 13, 1978 meeting, where they were denied for the reasons as outlined in the attached staff report to the Planning Commission dated October 17, 1978. The applicant appealed the Board of Zoning Adjustments' denial and was heard by the Planning Commission at its October 17, 1978 meeting. The Commission at its October 17 meeting expressed sympathy with the appli- cant, in that it was felt that the strict compliance with the landscape per- centage portion of the Ordinance Code would be an undue hardship on the property due to its size - 300 feet ± in frontage and 605 feet ± in depth. Discussion took place as to what amount of landscaping, treatment of masonry wall, present and future improvements required for Metzler Lane, etc. , should be required. It was the consensus of the Commission that: 1) reduction in the required landscape percentage was justifiable; 2) that the width of the landscape area along the Gothard Street frontage should be between 15 and 20 feet; 3) that some sort of recess in the landscape area at the proposed driveway City' Council Appeal • CE 78-51/AR 7$-74" Page A . entrance should take place; 4) that a landscape area or island should be placed onsite directly behind the gate or wall opening to shield the bulk of activity being generated; and 5) Metzler Lane street improve- ments should be bonded for as provided in the Huntington Beach Ordinance Code and that at such time these are required or necessary to install additional landscaping would be provided along the Metzler Lane frontage. The applications were continued until November 7 , 1978, and the staff was directed to establish conditions and findings for the Commission' s consideration (see staff report to Commission dated November 7 , 1978) . These conditions included a total percentage of landscaping of 4 . 8 per- cent, of which a portion (along Metzler Lane) would be installed at a future date. It should be. noted that as of this date a group of adjacent property owners, some of whorl own "landlocked" parcels, have asked the Department of Public Works to act as "lead agency" in conducting a financial feasibility study for the purpose of forming an assessment district. These owners have deposited with the City monies to cover the full cost of said study. This proposed assessment district would include the acquisition of right-of-way for Metzler Lane and construction of full im- provements including sewer, water, and storm drains. ENVIRONMENTAL STATUS : Conditional Exception No. 78-51 is a Categorical Exemption (Section 15105 , Class 5, California Environmental Qualitv Act, 19"70) . Administrative Review NO. 78-74 is covered by Negative Declaration No. 78--69 , adopted by the Board of Zoning Adjustments on September 13, 1978 . FUNDING: Not applicable. SUPPORTING INFORMATION: l. ' Letter of Appeal 2. Area Map 3. . Staff reports dated Oct. 17, 1978 and Nov. 7, 1978 Planning Commission minutes of Oct. 17 , 1978, and Nov. 7, 1978 . 5. Plot Plan Respectfully submitted, am Palin Acting Planning Director JWP-CPS:df �, f , famed D. f oj. Chazled W. lojd P.O. Box 1610 Huntington Beach, Ca.1 i foAnia 92647 Novembea 17, 1978 _ :. . Huntington Beach C.t to Council P.O. Box 190 _`-' Huntington Beach, m CaUif om/ i.a 92648 ` :C— 0 r< Re: 4ppeai .to C.i tV Council ;= Cond i t i_ona,i Cxcepti.oa No. 78-51 Adnu.n taative Review No. 78-74v; %,.ope/z4 .located at 17762 Cjothalzd Sticeet Sentlemen: We henebg appeal dome of the conditi..ond of appzoval impoded ba .the Huntington Beach Planning. Commm dj.ioa in, appzoviag Conditional Cxception No. 78-51 and Admini tAa .Lve 2ev.Lew No. 78-74 to .the Huntington Beach Citg Council. Condi t i on.a l Cxcept.i.on No. 78-51 Conditional Cxcept.ion No. 78-51 id a Aeque dt to /zeduce the zeg died 6% .landdcap ng to appltoxtmate bj 1.5% aj a aequiaement to i mue a peAm t for the con dtlutc ti.on of a con .,zactoa'.d equipment gal d. The C.t to of Huntington Beach l,I . g Conmi�d-d.ion haj app zoved thij Condit i.onat (Exception dub jest to dome tiue.lve conditi.ond. Thoje condi ti_ond ate acceptable except the fotiow.tng which we he2eby appeal toqthehC.i,tg Council. Condit ion No. 1. Th•i d condition zequi�r.e d a landscaped a/tea of 15 feet to fAoast of a 6-,foot high deco/tati.ve madonluj, wa)-i at a 15-,foot Aetbach. We agree to con�dt�u ct the 6-foot high decoaative maaonmt t wail, but obiect to the 15-foot j etbach. It .t d our. f ee.Ling that a 10-toot .lam caped jetback .i j juf ici.ent to accomp,L: h .the intent of .the Civic D.t dtzict gone, would be corvd.t item with othea i"tal,lation d on Sothaad St zeet, and uz fact .t d .the exact .lands caged ,detbach that waa olzi.gi,na bt juggeited bg .the %.fanning Depa2tment. T hi,j waa .incase u ed to 15 feet bcq the l.Canning Commies,j.i.on. A addition, the d condition zeq -iAeA a aece m ed minir m 40 feet waU. on both .d.i.de d of the pnopo�ded duvewact. Th i�d condition wa d p to dumab4 .tmpo ded jo that a tlucch could pu.il into th.vd zece d d ed area in o�rde z to open the gate. We have j nce decided a gate .t d .impzacti..cal foe out ope/tation and the gate w,U. be etimi.nated faom the plans. We, theaefo se, 2eque.dt that the 1zequiAemen t of a necemed 40-foot wail at both •d.ided of the pzopojed dzivewac4 be e.Um uzated. Huntington Beach Ci4 Council Novembez 17, 1978 Page Two Condition No. 2. Condition No. 2 zegaiAe i a laru'�caped iiJand o2 grcoupi.ng to be placed at dome d.i,4tance i u i.de the faci l i tg diaect4 in back of the p2opojed duvewag opening to act ao a ,jc/zeen, of on,4 to acti.v,z tca aom pub Uc view. Th iA zequi�zement .ti incon di dten t with cu went AequuzementA of. other, would 4e da,Ct .in an obdt Luc tion and jaf eta hagaad which could contz.i.bute and Ze du.Lt in pen&donaL in u g and p zopeatg damage. We f ee.L that thiA condition .i i un zeajonab.le, inefficient, dangezoud and object to ..it aA a zequ Aement. Condition No. 4. Thzi,4 condition zequihej that .the 6-foot high eco4ati.ve maoon g waiiL along the S•otha�zd fAontage be extended around the f utu2e i te"ec t i_on of Met3,Lea Lane and .the exiting Sothazd Stizeet. Th j w.L. rceduce our ujabte p2opezt4 at a. time when Meta Lie z Lane .cam not being conAt zucted. T hzii zequi cement ,jhould not be sequeited until such, time that Met,7,LeA Lane ij actuai4 bu,&U. We obiect to .the zequirzemen t of dedication of Met3�Lea Lane which .i.4 diicuwjed in mo�ze deter i below. Condition No. 6. Th i4 condition zequ.if ej a &LZvelwag .into .the faci.UtV pave w.c th aiphait concAete fog a.minimum width of 35 feet and to a depth of 100 feet. We propoje that 6 .inchej of bate mateuaL, o.Lied with a cock-chip .jeat iA juf f LcLent to accomp,UAh .the intent of preventing .the trzaching of diet oiz mud onto Sothalzd St/zeet. We, therze f ooze, aeque it that thi j condition be modified accoAdi.ng y- A ;6�ati.ve'RevLew' No. 78-74 4dm-inijt4a-Lve Review No. 78-74 id a /zequeit foe a pelimit to opeaate a cont4acto,z',j equipment gaicd at dubiect :location. The Boaizd of Zoning 4djuAtinen has denied thud pem. t becau4e we w.i U not ag2ee to dedicate and bond a paved eight-of-wag (Metgie2 Lane) .in addition to the .L�cap.ing Aequin.ement,j 2efe Aed to above. (CC 78-51) The zequiAernen t of .the Metziea Lane dedication waA appealed to .the %dann.ing Comm.ii,dioa. The Planning Commv».ion waj advtied brg the C.itcg.Atto.,znec,',j oface .that .thee did not have .the zight to defeat thij dedication. The Planning Comm iA it on and the P-Lann ing Depa2tment dealt with th A subject in .the healing,fb4 dial not .inc ude it a4 an .t temi_ged condition in theist appltovai. PAe.,junab4 .thee aze taping .the po jit i.on that it ij not within theta authoAiteg to et theA deag o�z gaant. .9t id our. pojition .that .the zequtAement of dedication and bonding of this paved A.ighzt-of--way. .tom uncondti tuti_onaL. The.State of CatZpAni.a Soveznment Code, Section 65909, paohubitj the zequiA ng of the dedication of .land foe ang puzpoje not aeajorzab4 .ze.Lated to .the uoe of .the p�zopezt4 foa which .the vaAiance, bui lL g o z uoe permit ij zequeited. Count cajej have at4o nequi zed goveanmeat to demorwtAate that jome economic benefice would zejuit to the p zo pew owne2 aom the nattute of the f o sced dedication. Hite ing ton Beach City Cowzc i t Novernbe2 17, 1978 Page l h4ee The dedication cLeaa4 doe-4 not zeiate to the paopojed a4e. o, the plLopeatg. 9ngAej,j and egaejj to the paopent4 Morn Sothaitd .i j rno2e than jatiA, actoAy. The entia e. azea fought .to be dedicated .ti unimpltoved and, in ,fact, .the ,jtt zee t could not be corrdtiuucted due to the ,fact ,that one-hall= o4 the i t�zeet (.the north ha if) .i j in an umimpaoved dace guich. Paulo,jed &,z you z zev i.ew .tA a coAV o, .the t/u.a.L b z Leo paepa2ed by, out attolmeg which outtinej and juppo4tj oust pojiti.on segaAding thij dedication and bonding zequiaernemt. We, theaefone, /teque4t .that .the City, Council gAant the appzovaL o4 .the a4e pemmit wi thout the dedication and bonding o4 th i j paved zi.ght-o4-waa. Sinceae.Lg, �4MS D. FOSS CHAL6S W. rOSS haine,j D. f ojj l a4 tnen �Df:ggb CncLo.4u1Le,j PLANNI G • ZONING • DM 31 o 000 SECTIONAL DISTRICT MAP 26 - 5 - i1 _ E :E N DF WA CITY OF .,' INC., VNFIN. ADOPTED APRIL II,1960 r IONC NI G T[NOEDOTO FaiENO TO THCTC[rvT[Rr CITY COUNCIL ORDINANCE NO. 759 LEGEND: AMENDED AMENDED ORD.NO. AMENDED ORD.NO. v—J RESIDENTIAL AGRICULTURAL DISTRICT HUNTINGTON BEACH o a_'0 A IT rCM-M TWO FAMILY RESIDENCE DISTRICT COMMUNITY FACILITIES(EDUCATIOMI DISTRICT .To ii-i9n ® PRUFESSIONAL Q LIGHT INDUSTRIAL DISTRICT _a_m%s�- Ti 2-i-7", MOBILE NOME WSTRICT j O SINGLE FAMILY RESIDENCE DISTRICT ORANGE COUNTY, CALIFORNIA = ." 3 9 =N R3 LIMITED MULTIPLE FAMILY RESIDENCE DISTRICT g3fi C4 HIGHWAY COMMERCIAL 0:5TRICT LL'AMENDED BY ZONE CASE cx-N COMMUNITY FACILITIES(RECREATIONAL)DISTRICT ,°"63 -cD Clv:c DISTRICT 101,148,172,187,192,202,208,211,212,237,304,312,313 i-eo 7N C-C COMMUNITY FACILITIES(CIVIC)DISTRICT 308,326,339.341,348.356.359,369,371,289.487,504.505,509,66-7,66-13,66-14,66-57,PP 66-3 ---- FRONT TARD SETBACK 66-50,67-1, 67-22.PP 67-5,PP 69-I,PP692.PP70-1,70-4,PP70-8,71-17,72-2A,72-28,74-16,PP74-2,77-28, - _ _ ---- ULTIMATE RIGHT OF WAY Y2 23 76-26D,77-22, PRECISE PLAN OF STREET ALGN'�E:rt 2,=e TZ S=s:ls YS 24 WARNER K.e-I°e 1530 AS AVE 26 25 rL rl + N i 1P1 R2 R5 n' So.. FIR DR. 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II■1■IMIIIIIl11 lII1�11■IMU\ �/II■II�i1 a MIIIIMIi �� •• ■■IMMIIIMMIIIIII■oMo IIi1I11I�r�� C: ■IIIII IIIIIIIIII■I y �� I III■III■IIIM■ �I ■■■■MM MMMIIIIIII■ _ ��_ l■IIi ■■■■liII11NINON I1ii •� �■\�� C . .. �IUIIIIIII r .: � �/II ��► IN Publish 11/30/78 NOTICE OF PUBLIC HEARING !/ APPEAL TO CONDITIONS OF APPROVAL O CONDITIONAL EXCEPTION #78-51 & ADMINISTRATIVE REVIEW # AND NEGATIVE DECLARATION #78-89 NOTICE IS HEREBY. GIVSN that a public hearing will be held by the . City .Council of the City of Huntington Beach, in . the Council Chamber of the Civic- Center, Huntington Beach, at the hour of 7:30 P.M. , or as .soon thereafter as possible, on Monday the lath day of December , 1978 for the purpose of c ons ide r ing an appeal to conditions' -of approval imposed by the Planning Commission upon its approval of Conditional Exception No. 78-51 and Administrative Review No. 78-74 on November 7, 1978. Administrative Review No. 78-74 is a request to establish a contractor's equipment yard in an M1-CD, light manufacturing civic district, while Conditional Exception No. 78-51 is a request to reduce the required six (6) percent landscaping to approximately one and one-half (11s) percent .landscaping for the subject yard. The subject site is located on the east side' of Gothard Street approximately 800 feet north of Talbert Avenue. Also for review will be Negative Declaration No. 78-89. A legal description is on file in the Planning Department. All interested persons are .invited to attend said hearing and express their opinions for or against said Appeal Furiher .information may be obtained from the Office of the City Clerk : 2000 Main Street, Huntington Beach, Calif. 92648 (714) 53675226 DAM 11/20/78 CITY OF H nItINGTON BEACH By: Alicia M, ' Wentworth City Clerk • , aces=.::.-.:':•;�.: .: _ .-;;-;:r;.cs. .r LL POINT P£N ONLY.=-PRESS FIRMLY f `` CASH RECEJP�035 40 • 7540 i•:G • .CITY OF HUNTINGTON BGACH 11/17/70 75*00 TL P.O.BOX 711 • HUNTINGTON.BEACH.CALIFORNIA 92648 (714)536.5511' .CITY TREASURER WARREN G:HALL<'.. DEPT..ISSUING �' �'4 DATE / I RECEIVED FROM— ADDRESS- O S x FOR. - AMOUNT RECEIVED • Q � 1 CASH CHECKX A.B.A.ak RECEIVED 9 O � • i ACCOUNT AMOUNT o s' { t l . TOTAL OU i No. ISSUING DEPARTMENT WHITE-CITY ATTORNEY /, CITY OF HUNTINGTON BEACH No. •BLUE-CITY CLERK GREEN-CITY ADMINISTRATOR 'C CANARY-DEPARTMENTAL REQUEST for ORDINANCE or RESOLUTION Date Request made by Department INSTRUCTIONS: File request in the City Administrator's Office quickly as possible but not later than noon, one week prior to the Council Meeting at which it is to be introduced. Print or type facts necessary for City Attorney's use in preparation of ordinance. In a separate paragraph outline briefly reasons for the request of Council Action.Attach all papers pertinent to the subject.All appropriation requests must be cleared and approved by the Director of Finance before submitting to City Administrator's Office. Preparation of an Ordinance or Resolution is hereby requested: �Lac,S� �an__� Gdre� Cam• C, � � i �l I 0 � Desired effective date Signed: !I Approved as to availability of funds 66 � Director of Finance City Attorney— Please prepare and submit printed copies to�his office by: City Administrator • C. W. POSE, INC. DETACH AND RETAIN THIS STATEMENT THE ATTACHED CHECK 15 IN PAYMENT OF ITEMS DESCRIBED BELOW. I HUNTINGTON BEACH, CALIF. IF NOT CORRECT PLEASE NOTIFY US PROMPTLY. NO RECEIPT DESIRED. DELUXE FORM TWC-3 V-2 PATE DESCRIPTION AMOUNT I I I 4 � I V-!Z' } LEGAL NOTICE . . . NOTICE IS HEREBY GIVEN that a public hearing will be held by the City Council of the City of Huntington Beach, California, for the purpose of considering an appeal to conditions of approval imposed by the Planning Commission upon its approval of Conditional Exception No. 78-51 and Administrative Review No. 78-74 on November 7, 1978. Administrative Review No. 78-74 is. a request to establish a con- tractor' s equipment yard in an M1-CD, light manufacturing civic' district, while Conditional Exception No. 78-51 is a request to reduce the required six (6) percent landscaping to approximately one and one-half (1 1/2) percent landscaping for the subject yard. Also for review will be Negative Declaration No. 78-89. The subject site is located on the east side of Gothard Street approximately 800 feet north of Talbert Avenue. A legal description is on file in the Planning Department. Said hearing will be held at the hour of 7; 00 p.m. , on December 4 , 1978 , in the Council Chambers Building of the Civic Center, 2000 Main Street, Huntington Beach, California. lip • NOTICE TO CLERK TO SCHEDULE PUBLIC HEARING ITEM CONDITIONAL EXCEPTION 78-51/ADMINISTRATIVE REVIEW 78-74 NEGATIVE DECLARATION NO. 78-89 TO: CITY CLERK'S OFFICE DATE: November 20 , 1978 FROM: PLEASE .SCHEDULE A PUBLIC -HEARING USING THE ATTACHED LEGAL NOTICE FOR THE 4th DAY OF December 1978. . AP's are attached (Have been sent' to Clerk' s office) AP's will follow No AP's Initiated by: Planning Commission Planning Department Petition * Appeal X Other Adoption of Environmental Status (x) X YES . NO Refer to Pat Spencer Planning Department - Extension # 5457 for additional information. * If appeal, please transmit exact wording to be required in the legal . AR 78 '78-51 10/3/"1 8 - PC 111-010-2 5 Charles Poss 165-261-20 C. W. Poss, Inc. James D. Foss Jahn J. Stanko P. O. Box 1610 P. O. Banc 1610 16771 Bolero Lane Huntington Beach, Cal. 92647 Huntington Beach, Ca. 92647 Huntington Beach, Cal. 92649 111-010-46 Pacific Electric Railroad Robert Morris 610 Main St. 15892 Overton St. . Los Angeles, Ca. 90014 Fountain Valley, Cal. 92708 111-010-62 111-063-19 rnieodore W. Manthei Robert Contorelli 74565 Dillon Rd. 4310 W. 5th St. Desert Hot Springs, Cal. Santa Ana, Call. 92703 92240 11.1-010-57 111-065-22 ! Ohevzon U.S.A, Inc. Eleanore M. Richardson et al Property.Tax Dept 1254 E. 1st St. #7 P. O. Box 7611 Long Beach, Cal. 90802 San Francisco, Cal. 94120 111- .366-1 Ul-481-04 Wilbur E. Metzler Family Hdine Builders, Inc. 11143 S. Budlong Ave. 16168 Beads Blvd. Los Angeles, Cal. 90044 Suite 150 Huntington Beach, Cal. 92647 066--03 165-261--4 Joseph R. Byrd et al Frank Bucoella . 66 Payne St.. 1866 Rhodes Drive Elmsford, New York 10523 Costa Mesa, Cal. 92626 111= 165-261-05 August Rol-dfs Un. F. Barry Clara M. Rohlfs Ray M. Keck 2944 30th St. P.O. Drawer K San Diego, Cal. 92104 Cotulla, Texas 78014 111-066-13 165-261-21 Richard Haster John C. Large P. O. Box 370 Eheodore Manthei Cypress, Cal. 90044 74565.Dillon Rd. Desert Hot Springs, Cal. 92240 111-066-17 165-261-22 Jerry E. Pazzulla Harris H. Hale et al Cluster Banc 1d7-20 (no address) Big Bear Lake, Cal. 92315 I NOTIC.OF Pit FSLIC REARING APPEAL TO CONDITIONS(IF APPROVAL ON CONDITIONAL EXCEPTION 1t78-SI &ADMWISTRATWF REVIEW A 78.74 AND NFGATIVE DECLARATION#78-89 NOTICE.IS HEREBY GIVEN that a public hearing will be held by the City Council of the City of Huntington Beach In the Council Chamber of the Civic Cen- ter, Hunungton Reach, at the hour of 7:30 F.M.,or as soon thereafter as posal- ble,on Monday the 18th doy of Decem- her,1978,for the purpose of ronsidering an appeal to conditions of approval im- posed by the Planning Commission upon its approval of Conditions] Exception No.78-51 and Administrative Review No. 78.74 on November 7,1978.Administra- tive Review No. 78-74 is a request to establish a mntractnr'n equipment yard in an MI-CD,light manufacturing civic district,while Conditional Buwption No. 78.61 is a request to educe the revtuired sit (6) percent landscaping to approxi- mately one and one-half fl'n) percent landscaping for the subject.yard. The subject site is Located on the east-fide.of Gothnrd Street approximately Alk) feet north of Talbert Avenue.Aiw)for review will he Negative Det:laration No.7h-fi9.A legal description is on fide in the Planning Depsrtment.. All interested persons are invited to attend said hearing and exprees their opinions for or against said Apfs•al.Fur- ther information may he obtained from the Office.of the C,itp Clerk,2000 Main `Street, Huntington Reach,Calif. 9,2648 (714)630.6226. Datod:Nov.21),79. CITY OF HuN'rINC TON RE,ACII Hy:Alicia M.WENTWORTH City Clerk Pub.Nov.30,1978. Hunt.Reach Ind.Flee.a tNrO). OFFICE OF THE CITY CLERK 2000 Main Street Huntington Beach, California 92648 C� 5�1 - i City of Huntington Beachv y M` P.O. BOX 190 CAUFORNIAI-N 9Z6�9 S �r�x - ! ; :'. '`-"'t ,., -. OFFICE OF THE CITY CLERK December 20, 1978 Mr. James D Foss Mr. Charles W. Foss P. 0. B.ox. 1610 Huntington Beach, California 92647 Gentlemen: The City Council of the City of Huntington Beach. at its regular meeti.� ,; held Monday, December. 18, 1978 denied 1 0078-51 and AR #78-74. "This is a final decision . You are hereby notified that pursuant. to pro- visions of Section 1094.6 of the Code of Civil P ocedure of the :State rrf California you have ninety days' from December 18,E 1978 to apply to the courts for judicial review." if you have any questions regarding this matter please contact our off.ir.-e.. - 536 - 5226. Sincerely yours, 66" Alicia M. Wentworth City Clerk_ AMW/js B (9 4- r I I I. I r � F 4-rr/ 1 WILLIAM E. GUMMERMAN Attorney at Law 2 16152 Beach Boulevard, Suite 279 Huntington Beach, California 92647 3 714/848-1088 4 Attorney for Defendant, C. W. .POSS S ' 6 7 8 MUNICIPAL COURT OF THE STATE OF CALIFORNIA 9 WEST ORANGE COUNTY JUDICIAL DISTRICT 10 11 THE PEOPLE OF THE STATE OF CALIFORNIA, 12 Plaintiff:, Case No. 78W6576 13 -vs- TRIAL BRIEF 14 15 C. W. POSS, 16 Defendant. ) ) 17 INTRODUCTION 18 The present controversy stems from a disagreement 19 between the -City of Huntington Beach (the city) and the defendant 20 C . W. POSS, INC. (defendant) over what may be constitutionally 21 required of defendant before undertaking operation of a use 22 (contractors storage yard) expressly permitted by Section 9530(c) 23 of the Huntington Beach Ordinance Code. 24 It is defendant's contention that no conditions may be 25 attached pursuant to- Section 9530 since approval there by the 26 Board of Zoning Adjustments can .only be a ministerial act when 27 there are no enumerated standards to -govern the approval of the 28 necessary applications *.and the application relates to an expressly 1 permitted use. However, defendant' s property is also located 2 within the Civic District Suffix Zone (Article -967 of the 3 _Huntington Beach Ordinance Code, -6.9670, et.seq) which is designed t 4 regulate the "orderly harmonious, attractive and aesthetic 5 development of facilities around dgsignated community facilities 6 districts" (Huntington Beach Ordinance Code, 69670) . Pursuant to 7 that section defendant concedes the city may exact conditions for 8 approval of the necessary application. Defendant' s objections to . 9 the proposed conditions are two fold; (1) the conditions imposed 10 to date such as the construction of a solid concrete wall enclosi g 11 the premises, ' the dedication of a :paved right-of-way to the city 12 and the construction of a paved parking area are not reasonably 13 related to the use of :defendant' s property; . (2) defendant's 14 use will not serve to create the need for :the dedication; and 15 . (3) defendant will not -receive an economic benefit from the dedication or other improvements. 16 Defendant further objects to the city' s bringing the 17 instant criminal actions on a second level, that of equitable 18 estoppel. The city issued several,.necessary operational permits 19 . to defendant with full knowledge of-defendant's-intended and 20 actual use of the subject property'; At no time prior to their 21 issuance was defendant cautioned that application approval was a 22 condition precedent to commencing construction and operations an 23 expressly permitted use.. Furthermore, and the more significant 24 point with respect to defendant' s estoppel argument, the city 25 never intimated, before any permit was issued, or before any 26 construction or operational use had begun, that extensive conditi ns 27 (such as the dedication of paved right-of-way) would be required 28 before approval was given to defendant' s application. Rather, at r 30 1 e - - I the time defendant applied for and was given those various permits 2 the city' s conduct indicated that approval was nothing more than 3 a ministerial act. 4 It was only after defendant objected to the reasonable- 5 ness of the city's requirements that the city threatened criminal 6 prosecution and complained about operation of the use without 7 first obtaining application approval. It thus , appears that the 8 city is attempting nothing more than to use the threat of 9 criminal prosecution to exact unreasonable concessions from 10 defendant as a condition precedent to the use of their property I1 as expressly permitted. It is therefore defendant's contention 12 that absent the frustration of some important governmental policy 13 that would result from.defendant's:: Use prior to application 14 approval the city should be estopped from complaining ( in the 15 form of these criminal prosecutions) about construction undertake 16 pursuant to the permits previously issued. 17 18 = STATEMENT.`OF THE FACTS 19 Defendant is' the owner of an unimproved parcel of real 20 property located at 17762 GothardStreet, Huntington Beach, 21 California. Such pro erty is situated within the Civic District 22 Suffix Zone. On the subject property defendant intended to 23 construct a contractors storage yard, a use expressly permitted 24 by Section 9530(c) of the Huntington Beach Ordinance Code. 25 In order to commence construction defendant obtained- an 26 electrical permit,' a grading permit, a fire hydrant use permit, a . . 27 permit to irs tall underground gas ''storage tanks and a permit to 28 tie into the storm drain system. . :At the time the above mentioned - 3 - �- e I permits were obtained the city was well aware of the use defendant 2 intended to make of his property both through oral representation 3 to the city' s Planning Department as well as on site inspections 4 made by the city's building inspectors. However, at no time did S the city, prior to the issuance of.°the permits, condition or even 6 suggest that the commencement of construction was dependant upon . 7 approval of their application. In. fact, defendant was issued the 8 aforementioned permits even though..they had not completed or had 9 approved the necessary :application;-which' had been previously ob- : 10 tained at a meeting with members 'of` the Plannint Department before any permits were issued. 11 Afterissuance_ of the permits, defendant, .'to his consid- . 12 erable expense, commenced construction on the subject property. 13 Included within such construction were the beginnings of a chain 14 link fence surrounding the property. for obvious security reasons. 15 When the city became aware of the construction of the fence they 16 objected claiming a chain link fence was inappropriate alleging 17 that defendant' s use was subject to the standards of Section 9534 18 of the Hunt.nxton_ .Beacli-Drdinanc"o-de. "Uses Subject to Approval 19 of a Conditional Use Permit". Specifically the enumerated 20 standards therein called for the construction of a solid six 21 inch concrete block or,pasonry wall;,with a minimum height of six 22 feet. After defendant .objected on the grounds that Section 9534 23 applied only to "Automobile Storage Yards" the 'city informed 24 defendant that- his property bounded on an undeveloped portion of 25 the -Civic Suffix District and attempted to exact the same condi- 26 tion pursuant to approving any use .subject to the district' s 27 zoning regulations. When defendant objected on the _grounds 'no 28 such standard was enumerated within Section 9674 as a condition -�� 4 _ I to approval the city began its threats of permit revocation and 2 criminal prosecutions. 3 In a letter dated May 19, 1978, the City informed 4 defendant that they were in violation of Sections 9530 and 9674 S of the Huntington Beach Ordinance Code and pursuant thereto 6 defendant would first. have to obtain approval of an application 7 for design review by the Design Review Board and a use permit fro 8 the Board of Zoning Adjustments prior to the commencement of any 9 use- on the subject property. There was no mention of any 10 conditions to approval.. Defendarit::was requested to file only the a 11 appropriate applications. On July° 19, 1978, at a meeting between 12 defendants representative' LES BASICH, JOHN O'CONNOR, the Deputy. 13 City Attorney and CHARLES P. SPENCER the assistant Director of 14 The Planning Department defendant was inf¢cned of the following: 15 (1) the City's belie£ that defendant was subject to the enumerate 16 wall requirement _in Section 9534; (2) that a criminal complaint 17 would be filed against them for violation of Sections 9530 and 18 ' 9674 and (3) that defendant should have first gone before the 19 Planning Board for approval even though the intended use was 20 expressly permitted within the M1 zone. 21 On July 27, 1978, the city, by letter,gave defendant _ 22 notice that its permits for temporary power and a gas pump had 23 been issued in error and that the .city would request the Edison 24 Company to discontinue service until it was determined that 25 defendants use was conforming. Also on July 27, 1978, the city, 26 by letter, cancelled, effective immediately, defendants fire 27 hydrant Use Permit #751. On July. 28, 1978, the city did in fact 28 request the Southern California Edison Company to remove the 3� I service to the subject property. On'.July 31, 1978, defendant fil d 2 the necessary applications for approval and the use permit. 3 It was not until August. 4, 1978 after the criminal 4 complaints had been filed and defendant had agreed to construct 5 the wall that defendant was informed of the dedication and parkin 6 improvement requirements as further conditions precedent to 7 approval of their applications. On August 8, 1978, at a meeting - 8 before the Board of Zoning Adjustments,defendant was informed of 9 the following requirements to approval of their use: (1) the 10 Huntington Beach QXditiance C, od §9730.2 and 9730.4 required 11 defendant to dedicate and pave one-half of a public right-of-way 12 along the. north side of the subject property, (2) paved parking 13 lots with a striped % parking designation for every five thousand 14 square feet of property, and (3) . the screening of the property 15 from public view by the erecting _of the concrete fence. 16 17 I 18 UNLESS THE CITY CAN DEMONSTRATE A RESULTANT FRUSTRATION OF A FUNDAMENTAL GOVERNMENTAL 19 POLICY BY ALLOWING THE DEFENDANT TO CONTINUE CONSTRUCTION 'PRIOR TO APPLICATION APPROVAL IT 20 SHOULD BE ESTOPPED FROM ASSERTING THE PRESENT CRIMINAL VIOLATIONS. 21 22 A long linetof cases have held that once an owner 23 acquires a building permit, and in reliance thereon incurs 24 liabilities in good faith, the owner acquires a vested property 25 right entitled to protection against revocation or subsequent 26 changes ' in the zoning laws. Spindler Realty Corp. v. Manning, 27 (1966) 243 Cal. App. 2d 255, 53 CaZ. Rptr. 7; Trans-Oceanic Oil 28 Corp., v. Santa Barbara - (1948) 85 Cal. App. 2d 776, 194 P. 2d 148; I Kissinger v. City of Los Angeles , (1958) 161 Cal. App. 2d 454, 2 527 P. 2d 10; County of San Diego v. McClurken (1951) 37 Cal. 3 2d 683, 234 P. 2d 972; .Jones v. City of Los Angeles (1930) 211 4 Cal. 304, 295 P.14; Griffin v. County of Marin (1958) 157 Cal. 5 App. 2d 507, 321 P.2d 148. 6 However, in order to come under the protection of a 7 vested rights theory the owner had to demonstrate that the permit 8 were valid when issued. Pettitt v. City of Fresno, (1973) 34 Cal 9 App. 3d 813, 110 Cal. Rptr. 262; Millbrae Assn. v. City of- Millbrae., 10 (1968) 262 Cal. App. 2d 222, 69 'Cal. Rptr. 251. In the present 11 controversy the city alleges the defendants permits were issued 12 in "error" and therefore of no force and effect. As a consequence 13 thereof, the city revoked some of the permits and instituted the 14 present criminal actions alleging defendants use was non-conforming. 15. Notwithstanding the alleged technical invalidity of 16 defendants permits , it is defendants contention that the Doctrin 17 of Equitable Estoppel may still be applied. Equitable .estoppel, .18 in the context of zoning or otherwise, is applicable against the 19 government whenever the effect of its invocation would not defeat 20 the effective operation of an important governmental policy 21 adopted to protect the public. Pettitt v. City of Fresno (1973) 22 34 Cal. App. 3d 816, 822, 110 Cal.. Rptr.. 262, 268. 23 The issue is thus presented: when would a fundamental 24 policy, evidenced by a zoning law, be frustrated by application o 25 the doctrine of equitable estoppel..against a municipality asserting 26 the unlawful nature of construction commenced pursuant to an 27 invalid .building permit. It is defendants' contention that 'such 28 a frustration would exist only when . the desire to revoke an - 7 - D oo I existing permit stems from a subsequent change in the zoning laws 2 which would thereby render the existing use a non-conforming use 3 in relation to the new law. Support for this approach may be 4 found in that line of .cases holding the owner was entitled to S complete construction pursuant to existing permits despite 6. subsequent changes in the zoning laws. _ Dobbins v. Los Angeles, 7 (1904) 195 U. S. 223 25 S. Ct. 18, 49 L. Ed. 169; Trans-Oceanic 8 Oil Corp. v: Santa Barbara (1948) 85 Cal. App. 2d 776, 194 P. 9 2d 148; Jones v. City of Los Angeles (1930) 211 Cal. 304, 295 P. 10 14. a � 11 The preceding authority illustrates the maximum degree 12 to which the courts have been willing to apply a vested rights 13 approach to building permits. Despite the obvious frustration of 14 a governmental policy (evidenced by the subsequent moving law) th 15 owner was allowed to complete construction in accordance with the 16 prior rather than the 'subsequent zoning law. The instant case is 17 distinguishable in several respects; first, defendants' permits 18 were issued prior to the approval of their application and thus, 19 it is possible to claim the permits are technically invalid, 20 second, there has been no subsequent change in the zoning laws an 21 third, the city attempted to revoke, the permits and prosecute for 22 defendants present use of the premises only after defendant 23 objected to the conditions the city imposed fw approval. 24 The distinction between a valid and invalid permit is 25 a marked one to be sure. It- has the effect of depriving defendant 26 of a vested property right. However, it is not that significant 27 that it should prevent defendant from asserting an equitable 28 estoppel against the city's conduct. I Without a change in.:the ,zoning law the city's governmen al 2 policy remains unchanged. The existing violations in no way 3 impede or frustrate that. policy. . .zn fact, since the requisite 4 application has been filed there remains only the ministerial act 5 of approval before defendants',- usp.',conforms with the requirements 6 of Section 9530. Defendants non-conformity with respect to 7 Section 9674 raises the question of the conditions the ' city is 8 attempting to force defendant to comply with. 9 The reasonableness and legality of those. conditions is 10 discussed in following arguments`. ' For purposes of discussion 11 � here their importa.ncelies within the manner in which they were 12 raised and whether it :w' as sufficie.nt . to constitute an estoppel. _ 13 Again, but for those conditions all that would remain 14 for defendant would be.the ministerial act of application 15 approval. However, it is defendants' contention that the city is 16 eatopped from asserting those conditions as a basis of defendants 17 present non-conforming use. First, the issuance of the permits 18 induced defendant to commence construction originally, Second, 19 the city made no mention of any conditions prior to the issuance 20 of the permits. Third, the city was aware that defendant had 21 , commenced construction pursuant to those permits. Fourth, the 22 city was aware that an application had not been approved prior to ermits. Fifth, defendants' use is expressly 23 the issuance of the p 24 permitted under Section 9530; and Sixth, the instant criminal 25 complaints are premised on the fact that defendant is operating a 26 use without an approved application, however, prior to defendants 27 objection to the conditions the city imposed upon defendants' use , 28 the city made no such objection. Thus, it appears that the city is 37 - 9 - e I not really concerned with the penal violations at all, but rather 2 is using the same .to gain a superior bargaining position over 3 defendant. Such a practice bordsk�a', precariously close to abuse 4 of process and if not " it certainly raises the issue of S equitable estoppel. ' 6 The inherent,dangers of. forced dedications are not new 7 and have been noted before: 8 -A third [danger] is that Judicial surveillance of dedication requirements may be'leffective and 9 sporadic.. The result would be diminution of constitutional protection against overextension 10 of the police power, since the cost and delays inherent in .litigation tend to discourage r&-.' 11 � sistance to 'improper demands and induce • compliance b the developer. The unlikelihood 12 of legal challenge may, in turn, reinforce ,,-- . existing incentives - for .local officials to 13 exploit their superior bargaining position by expanding the practice of imposing dedication 14 conditions to. its maximum feasible extent..' Alstyne, "Takin or Damage by police ower: 1S the wear v rse Icon emnatio " 44 ; See also Associated Home 16 Builders v 'Citx of Walnut Creek Cal. pp�. 3d-11299 11439 90 Cal: ptr. 663, 673: 17 18 "But- we- cannot 'eubstriba:-.-to:::the premise-. that the police 19_ power expands;. and -property.:rights''.guaranteed. by the Constitution 20 contract, in proportion to the general fiscal exigencies which make expropriation attractive." . -.. . 21 II.. 22 ONCE ISSUED A BUILDING PERMIT CONSTITUTES A PROPERTY RIGHT THAT MAY`NOT BE REVOKED WITHOUT 23 DUE PROCESS OF LAW 24 The fact that defendants,' permits were technically 25 issued in error shoul& not be relative to their rights of due 26 process in an- attempted -revocation. This is especially true 27 when defendant acted in good faith both in obtaining the permits, in 28 commencing construction and/incurring liabilities in reliance 38 . D 10 - I thereon. 2 It has :bng been held that the governing body of a 3 municipality acts in a-quasi judicial capacity in determining 4 that a validly issued permit should be revoked and that due process 5 requires notice, a hearing and the. .reception of competent evidenc 6 substantially supporting the finding of revocation. Trans-Oceani 7 Oil Corp. v. City of Santa Barbara (1948) 85 Cal. App. 2d 776, 8 194 P. 2d. .148; City-of San Marino v. Roman Catholic Archbishop of 9 Los Angeles (1960) 180 Cal. App. 2d 6579 4 Cal. Rptr. 547; O'Ha e 10 V. Board of Zoning Adjust. , City of Santa Rosa (1971) 19 Cal. App 11 3d 160, 96 Cal. Rptr. 484. Requiring a technically valid permit a• 12 before defendant acquires a right of due process would work an 13 unnecessary hardship for many of the same reasons that defendant 14 asserted in his argument that an equitable estoppel should not be 15 barred simply due to the permits technical invalidity. 16 The revocations in both Trans-Oceanic Oil Corp. aWd 17 City of San Marino were premised upon subsequent changes in the 18 zoning laws. In order that the owner be allowed to complete 19 construction in a manner contrary to the subsequently enacted 20 law it was necessary to find a vested right in the owner. And 21 such a right could be found only in conjunction with a validly 22 issued permit. Pettitt v. City of Fresno (1973) 34 Cal. App. 3d 23 813, 110 Cal. Rptr. 262, -Once a vested right was found,the 24 inescapable conclusion was that .due process was required in any 25 attempted revocation. 26 It is defendants' contention that the requirement of 27 a valid permit relates. only to the finding of a vested right, not 28 to traditional notions of due process. Without a subsequent . 39 - 11 - I change in -the zoning law as in the instant case, it should not 2 first be necessary. to find a vested right before rights of due 3 process attach. Substantial reliance pursuant to governmental 4 authority should be sufficient. S Once the permits were issued and thereafter relied upon, 6 defendant acquired more than a mere license Wevog4b1Q at will. 7 Upon issuance, there arises at least a presumption of validity. 8 In accordance with that presumption, the burden is upon the City, 9 through a noticed hearing affording defendants all their procedural 10 rights, to demonstrate. the permits -invalidity through competent 11 evidence. 12 ::.If .not of forddd---•sonde".sort,;.6f limited property :might and 13 corresponding right of due process, the city, through its' own 14 omissions, subjects .others, such as the defendant, to criminal 15 sanctions without an opportunity to defend. The defendant 16 actually iias no such opportunity in the criminal hearing since 17 once the permit has been revoked the zoning violation takes on 18 aspects of strict liability. Surely the lawf'does not contemplate 19 the city be allowed to 'act in such a careless and reckless manner 20 and still have resort ..to the full letter of the criminal process 21 without first giving defendant the -right to some form of prior 22 confrontation. 23 Granting defendants a right of .due process in this 24 situation . should be carefully distinguished from those cases 25 refusing to recognize a vested right in those owners undertaking .26 construction in willful violation of a subsequently changed zoning 27 ordinance in the hopes. -of acquiring such a right based upon the 28 sole fact they had incurred material expense and liabilities. The =...12 -. .. I two critical differences are, first, there has been no subsequent 2 change in the zoning .laws and second, the defendant acted in good 3 faith both in obtainipg. the permits and in acting. upon the same 4 in commencing construction. 6 7 8 9 10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 26 27 28 - -12a - D - 1 III 2 THE CONDITIONS THE CITY .IS ATTEMPTING TO EXACT PURSUANT TO SECTION 9530 ARE AN ABUSE OF 3 DISCRETION SINCE THERE ARE NO ENUMERATED STANDARDS TO CONTROL SUCH DISCRETION 4 5 Section 953.0 contains no standards whatsoever to govern 6 _ the issuance of permits. And under that section a contractor's 7 storage yard is expressly permitted. After the application has . 8 . been filed,approval should be nothing more than a ministerial act 9 To allow the city to impose conditions to defendants use pursuant 10 to that section would seem to constitute a clear abuse of 11 discretion. In Anderson v. City Council (1964) 229 Cal. App. 2d 12 79, 40 Cal. Rptr. 41 the court stated: 13 ". . .where the legal requirements for the issuance of a building permit have been 14 complied with the issuance of the permit becomes a ministerial act the performance of 13 which may be compelled by the mandate of the Court. 229 Cal. App. 2d at 88; See also 16 McCombs v. Larson (1959) 176 Cal. App. 2d 1U5,—I�7-10T,=al. .Rptr. 140; Munns v. 17 Stenman (1957) 152 Cal. App. 2d 34T,,-551- 32 9 314 P. 2d 67. " 18 19 The cases are legion in- upholding standards for the 20 issuance of building permits couched in general health, 'safety or 21 welfare terms against the charge that they confer unbridled 22 discretion on the administrative body or are unconstitutionally 23 . vague. CEEED v. California Coastal Zone Conservation Com'n (1974 24 43 Cal. App. 3d 3062 3262 118 Cal. Rptr. 315, 329; City & County 25 of S. F. v. Superior Court (1959) 53 Cal. 2d 236, 250, 1 Cal.. Rptr. 26 158, 347 P. 2d 294; Garavatti v. Fairfax Planning Comm. (1971) 27 22 Cal. App. 3d 145, 150, 99 Cal.. Rptr. 260; Staddard v. Edelman 28 (1970) 4 Cal. App. 3d 544., 5482 84 Cal. Rptr. 443. However, a Q �) � . - 13 - I general health and welfare limitation is the limit to which the 2 courts will go. Initially it was thought that such a standard wag 3 too vague since the power to discriminate was nowhere curtailed. 4 In fact, such a standard was often identical to the standards S which governed the municipal councils in exacting such ordinances 6 in the first instance. Thus, the power delegated to the planning 7 commissions was no less than that conferred on municipal councils 8 by the Government Code. See People v. Perez (1963) 214 Cal. App. 9 2d Supp. 881, 29 Cal. Rptr. 781; Redwood City Co. of Jehovah's 10 Witnesses v. City of Menlo Park '(1959) 167 Cal. App. 2d 686, 335 11 P. 2d 195. 12 Section 9530 goes beyond the limit of acceptable 13 discretion. Without even a general welfare limitation the 14 ordinance falls within the general rule that "a legislature's 1S. ' delegation of unbridled discretion 'to an administrative agency is 16 invalid, and thus to _avoid such a result it is necessary that 17 the delegating statute establish an ascertainable standard to 18 guide the_ administrative body. " Stoddard v. Edelman (1970) 4 Cal 19 App. 3d 544, 548, 84 Cal. Rptr. 443 (upholding a general welfare 20 standard) ; State Board v. Thrift-D-Lux Cleaners, Inc. (1953) 40 21 Cal. 2d 4369 4482 254 P. 2d 29; Micheltree v. City�-of Los Angeles 22 (1971) 17 Cal. App. 3d 791, 795, 95 Cal. Rptr. 76; 78. 23 Section 9530 reads in its entirety as follows: 24 "Uses Permitted. The .following uses and :. regulations s all be permitted in the M1, 25 'Light Industrial District, ' subject to 26 approval of .an administrative review appli- cation by the Board of Zoning Adjustments." 27 There are no enumerated standards within the Article (953) contained incpction 9530. Applications for administrative �- I Review are covered by Article 981 (Board of Zoning Adjustments) o 2 Chapter 98 (Administration) . Section 9811.6 states applications 3 for administrative review: "may be approved, conditionally 4 approved or denied by the Board". However, there are no standard 5 or criteria to limit the discretion of the Board. Furthermore, 6 upon reading the article in its entirety it appears that an 7 - approval of an application for administrative review is nothing 8 more than a ministerial act when contrasted with the specific 9 procedures enumerated therein relating to applications for 10 Conditional Exceptions, Plot Plan Amendments, Use Permits. and 11 Divisions of land. , Vor each such application there is provision 12 for a noticed hearing and appellate procedure. There is no such 13 requirement for an Application for. Administrative Review. 14 Illustrative of the ministerial affects of defendants' applicatio 15 is the required filiiig. fee in relation to other applications. 16 For all other applications the fee is seventy five ($75.00) 17 dollars, for applications for Administrative Review the fee is 18 but ten ($10.00) dollars. 19 Upon reading the code sections as a whole, it becomes 20 apparent that the approval of an application pursuant to Section 21 9530 is nothing more than a ministerial function. It does not 22 purport to grant to the' Board of Zoning Adjustments the discretio 23 the city is attempting - to exert upon defendant. 24 25 26 27 28 15 - - . - - _.. . .......,.._�.� I IV 2 THE CONDITIONS IMPOSED PURSUANT TO SECTIONS 9674, 9730.2 AND 9730.4 ARE UNREASONABLE 3 AND CONTRARY TO GOVERNMENT CODE SECTION 65909 4 The criteria for approval of -an .application subject to 5 Section 9674 are set out in Section 9853(a)-(e) . In the operatiodl 6 of an expressly permitted use all the criteria of subsections (a) 7 through (e) are inexplicably met. There remains only the questio 8 whether the city can condition approval upon the dedication of a 9 paved right-of-way is marked on their master plan.- -10 Section 9730.2 reads in its pertinent parts : 11 "RIGHTS-OF-WAY DEDICATION REQUIRED. Prior to • issuance of a building permit, or prior to the 12 use of land for any purpose, the highway, street or alley right-of-way shall be dedicated to or 13 vested in the [city j. . . " 14 First, it should be noted there is no presently existin 15 street to be dedicated. The street in question exists only on 16 the city's master plan. Furthermore, the area to be dedicated 17 ' lies within a totally unimproved section of the Suffix District. 18 The same section that initially subjected defendant to the 19 district's zoning regulations in the first instance. The area is 20 an unimproved dry gulch. 21 Pursuant to Section 9730.4 the city seeks to justify 22 its demand for the dedication of an improved street. That section 23 reads in part: 24 "USE ABUTTING HIGHWAY,. STREET OR ALLEY. INSTALLATION OF IMPROVEMENTS. (a) No 25 certificate of occupancy shall be issued by 26 the Department of Building and Community Development until the abutting highway, street 27 or alley right-of-way has been improved to the center line of such right-of-way. Said improve- ments shall. include curbs, gutters, sidewalks, paving, street trees, street lights, street L 16 - 1 signs, street drainage and sewer and water main extensions in full compliance with the City of 2 Huntinfiton Beach street standards and require- ments. 3 4 Compulsory dedications have been upheld against the 5 attack that they are taking without just compensation. Associate 6 Home Builders v. City of Walnut Creek (1971) 4 Cal. 3d 633, 484 P 7 2d 606, 94 Cal. Rptr. .630; Ayres v. City Council of Los Angeles 8 (1949) 34 Cal. 2d 319 207 P. 2d 1. Although both decisions 9 involved conditions imposed upon a "subdivision plan, forced 10 dedications have been upheld in the private sector as .well. s 11 Bringle v. . Board of Supervisors .(1960) 54 Cal. 2d 86, 351 .P. 2d.. 12 765, 4 Cal. Rptr. 493; Scrutton v. County :of Sacramento_ (1969) 13 275 Cal. App. 2d 412, 79 Cal. Rptr. 872; Mid-Way Cabinet Fixture 14 Mfg. v. County of San Joaquin (1967) 257 Cal. App. 2d 181, 65 i 15 Cal. Rptr. 37; The approach taken in either case is generally 16 similar. The Courts, seeking to establish a standard of 17 reasonableness for the .exactions imposed, balance the public's nee 18 against the property owner's detriment. 19 The cases are in total agreement that the governmental I 20 entity compelling the exactions must show at least a "reasonable I 21 relationship" between those exactions and the needs generated by 22 the owners proposed use of his property. Bringle v. Board of 23 Supervisors (1960) 54 Cal. 2d 86, 89 351 P. 2d' 765, 767, 4 Cal. 24 Rptr. 493, 495; Kelber v. City of Upland (1957) 155 Cal. App. 2d 25 631 318 P. 2d 561; Mid-Way Cabinet Fixture Mfg. v. County of -San j 26 Joaquin (1967) 257 Cal. App. 2d 181, 65 Cal. Rptr. 37; Scrutton v 27 County of Sacramento (1969) 275 Cal. App. 2d 412, 421-22, 79 Cal. 28 Rptr. 872, 879-80. This approach is in conformity with the - 17 - 1 I Government Code, Section 65909 which prohibits "(1) the dedicatio 2 of land for any purpose not reasonably related to the use of the 3 property for which the variance, building or use permit is re- 4 quested. " A more stringent standard was adopted in Sommers v. 5 City of Los Angeles (1967) 254 Cal. App. 2d 605, 62 Cal. Rptr. 52 6 where the court required the government to also demonstrate that 7 some economic benefit would result to the property owner from 8 the nature of the forced dedication. 9 10 A. THE REASONABLE RELATIONSHIP OF THE 11 REQUIRED DEDICATION a 12 Ingress and egress for defendants-..use is more than 13 satisfied by its access to Gothard Street. The city has made no 14 attempt to demonstrate that the dedication will be reaftnably 15 related to the use of defendant's property. In fact, it cannot. si ce 16 the area sought to be dedicated is totally unimproved. Thus, the 17 required dedication is contrary to the mandate of California 18 Government Code, 565909(1) . Furthermore, the city has not 19 demonstrated that defendants use of the subject property will 20 - create a need, present or future, for the dedication. 21 In Mid-Way Cabinet the owner sought a building permit 22 from the county to enlarge its cabinet shop. As a condition 23 precedent to granting the permit, the county required Mid-Way to 24 convey, without compensation, certain access rights and land for 25 a "return road" to a future expressway. These requirements were 26 based upon evidence presented by the county purporting to show 27 increased traffic burdens on streets fronting the plaintiff's 28 property. Examining this evidence the Court of Appeal found: 47 18 • I "Not the slightest hint that there .would be an appreciable increase in traffic, _. On the 2 contrary., other than an inconsequential in- crease of truck deliveries from a possibly 3 expanded cabinet shop output there will be no effect at all. Mid-Way's business is not 4 retail. 257 Cal. App. 2d at 185, 65 Cal. Rptr. at 39." 5 6 The Court went further, quoting a Supreme Court opinion 7 by Justice Holmes, Pennsylvania Coal Co. v. Mahon (1922) 260 8 U: S� 393, 415, 43 S. Ct. 158, 1609 67 L. Ed. 322, 326, as 9 follows: 10 'We are in danger of forgetting that a :strong public desire to improve the public conditions 11- is not enough to warrant achieving the desire a. by a shorter cut than the constitutional way 12 of paying for the change . .257 Cal. App. 2d at 187, 65 Cal. Rptr. at 41. 13 14 The court made specific note that it appeared as 15 though the "planning commission was attempting to avoid the 16 constitutional guarantee of payment of just compensation via the 17 method of exacting "conditionsY to the granting of a use permit 18 arbitrarily inspired and that in doing so it had exceeded its 19 powers. " 257 Cal. App. 2d at 189, 65 Cal. Rptr at 42. Finally, 20 after recognizing that there was no unrestrained right to impose 21 conditions the court noted: 22 Justification of conditions depends upon their being some real relationshipbetween the thing 23 wanted y the landowner trom government and the quid pro quo- exacted by government therefore. ' 24 257 Cal. App. 2d at 192, 65 Cal. Rptr. at 44 (emphasis added) 25 26 In Scrutton v. County of Sacramento (1969) 275 Cal, App 27 2d 412, 79 Cal. Rptr. 872, the plaintiff property owner sought to 28 have her property rezoned from agriculture to multiple family D -ae� - .19 - I residential use 'for the purpose ob:developing apartment units. 21' The planning commission conditionejd approval; on the dedication o 3 certain land to widen •;.=etreets abutting her property and improve- 4 them at her own expense including- avement sidewalks curbs and � 8i,p > > 5 gutters, _ The Court cited a standa;id of reasonableness related to 6 the proposed use. Scrutton v. Couhty of - Sacramento, supra, at 7 422, 79 Cal. Rptr. at =880. 8 There are decisions upholding forced dedications without 9 departing from the standard of reasonableness reported herein. .10 See Sommers v. City of: Los Angeles;" (1967) 254 Cal. App. 2d 605, 11 62 Cal. Rptr. 523; Southern Pacific Co. v. City of Los Angeles 12 (1966) 242 Cal. App. 2d 38, 51 CaI'4_ Rptr. 197. The city has 13 failed to meet its burden of justification. The instant criminal 14 complaints are nothing more than al.vailed attempt to force 15 compliance with the ci, s unreasonable demands to .improve the 16 Suffix District. Evidence of the.:Oroposition that the proposed 17 dedication bears no' relationship to. defendants use of the subject .18 property can be found - nthe fact t gat the origin of the right-of- way requirement can be found on the' city's master plan which was 20 enacted before defendant commenced,;his use. See 13 Hastings L.J. 21 401, 403. Thus, without more,the.;fity has demonstrated only the 22 assertion of naked and.-.arbitrary power. 23 B. ALTHOUGH .:REASONABLE :OiN THEIR FACE THE REGULATIONS ARE UNREASONABLE- AS APPLIED 24 BY THE CITY. 25 The regulations in question are on their face the bare 26 minimum required by the due proce:os clause. However, there is a 27 second level of due process consisting of their administration 28 which is also the subject of judicial review. Defendant' s 20 • , ,l � T a i I preceeding arguments addressed the vagueness of the regulations 2 and the reasonableness of the conditions imposed by the city 3 before they would approve defendant's application. The argument 4 presented here is that the reasonableness of the statute• can .be 5 measured by the actions of the city' s officials in its administra 6 tion and if those actions are found to be unreasonable, then 7 the statute must either be declared void or given a narrowing 8 - construction. 9 It is a fundamental rule`: of law that a statute valid 10 on its face may be unconstitutionally applied. Brock v. Superior 11 Court (1939) 12 C.2d 605, 86 P.2d. 805; People v. Gordon (1951) .42 105 C.A.2d- 711, 234 :P.2d 2870- That issue is usually raised in 13 an equal protection context. Defendant seeks to make analogy to 14 the same argument with respect to .demonstrating that the city's 15 administration of a relatively vague statute in an unreasonable 16. fashion renders the actions taken ,pursuant to such statute void. 17 See People v. Amdur (1954) 123 C.A.2d Supp. 951, 964, 267 P.2 18 445. 19 Defendant does not argue'-that the city may not exact 20 reasonable conditions'.to the operation and use of its property 21 within the Suffix District. Objetion is made not only to the 22 reasonableness of the, conditions .*posed as they relate to de- 23 fendant's property (see argument,"IV; Government Code, §65909) 24 but to the reasonableness of the entire statutory scheme surround 25 ing the administration of the Suffix District. The 'Suffix Dis- 26 trict zone was enacted primarily for aesthetic purposes. How- .. 27 ever, against that backdrop the city has attempted to implement, 28 ,� at defendant's expense, the city's Master Plan. In order to ID, e, I further generate the development and realization of such plan, 2 the city has enacted the dedication requirements in sections 3 9730.2 and 9730.4. These sections have no relationship whatever 4 either to defendant's property onto the Suffix District. They 5 are nothing more than administrative tools for the implementation . 6 of the city's Master Plan. Powerl'.used in this fashion is not a 7 mere regulation within the province of the police power. It is 8 unreasonable to a degree that ,justifies a conclusion that it 9 constitutes a taking without just compensation. If the city 10 wishes to improve the City of Huntington Beach, in accordance 11 with the Master Plan,-. let it pay `its own way. . 12 The requirements of reasonableness, both in the conditio s 13 exacted in their relationship to the property and in the admin- 14 istration of the statutory schemew.are the final and vital dis- 15 tinctions between the police power and the "taking clause" of 16 the constitution. To ignore than distinction is to abrogate 17 its constitutional guarante 18 19 20 Attorney foroefendant 21 22 23 24 25 26 27 28 22 - ���