From: [email protected]
To: "Yuwiler, Robert@Coastal"; "Kraemer, Melissa@Coastal" Cc: [email protected]; [email protected]
Subject: RE: LCP Amendments for Fort Bragg
Date: Monday, December 30, 2024 4:12:40 PM
Attachments: image001.png
Hello Robert,
Thanks for your comments below. I have responded to each of your comments and questions below in Red Bold Text.
Thanks for taking the time to review these draft ordinances.
We will be bringing them forward to the Planning Commission (in Ordinance form) at the end of January.
I will send you a final version of the recommended ordinance after the Planning Commission considers and provides a recommendation.
You can provide any additional comments at that time, and before we bring the ordinance forward to City Council for adoption and submittal.
Thanks very much.
I also have a few questions/comments below and so I look forward to receiving any additional feedback after you read those.
Marie Jones Mariejonesconsulting.com 707-357-6480
……
Hi Marie,
Thanks for sending over initial copies of various LCP amendments proposed for adoption in the new year. After reviewing the proposed CLUDC amendments related to Tiny Homes, Tiny Home Communities, Outdoor Dining, and Planned Unit Development Permits, we offer the following comments, suggestions, and questions on three of categories of proposed changes (we have no comments at this time on the proposed amendments to the PUD permits):
Tiny Homes:
Consider whether the City’s proposal to repeal and replace CLUDC Chapter 17.42.175 also requires updates to the General Plan Element 10 glossary for internal consistency. Great idea. I will make appropriate revisions to the General Plan Glossary.
Tiny Home Communities
Similar to the above comment, consider whether the City’s proposal to repeal and replace CLUDC Chapter 17.42.110 also requires updates to the General Plan Element 10 glossary for internal consistency. Great idea. I will make appropriate revisions to the General Plan Glossary.
Should the reference to 17.42.115 in Table 2-6 instead refer to 17.42.110? We are interested in understanding why the City is proposing to disallow this use in the RR and RS residential zone districts where mobile/manufactured homes and mobile home parks currently are allowed and to allow a new, similar use, in the various Commercial Districts where mobile/manufactured homes and mobile home parks currently are not allowed. Please clarify. There is no RR or RS zoning in the Coastal Zone portion of the City, so it seemed unnecessary to allow it in a zoning district that does not exist in Fort Bragg’s coastal zone area. We decided to allow Tiny Home communities in the Commercial zoning districts because these zoning districts allow 24 units/acre and so lend themselves well to the density of a Tiny Home Community. Additionally, most of the vacant parcels that are larger than 1 acre are in the commercial zoning districts.
With the proposal to repeal the existing mobile/manufactured homes and mobile home park regulations and to change the zoning districts in which similar tiny homes and manufactured home communities are allowed, we are curious whether any existing mobile/manufactured homes and/or mobile home parks in the coastal zone will become nonconforming uses. If so, consider whether any standards for nonconforming uses are necessary to add or modify. Great Comment. I will think about this and develop some solution.
Consider whether the proposed sign provisions of section 17.42.110-A-4-k are internally consistent with the sign standards of chapter 17.38 or whether that chapter should be cross referenced in this section. We can cross reference the sign ordinance requirements.
Outdoor Dining
Proposed changes to 17.42.165(B)1 specify that “A Coastal Development Permit is required for an outdoor dining facility that includes the erection of a pavilion or tent.” To avoid any inconsistency with PRC sec. 30610, it should be clarified that a Coastal Development Permits is required for an Outdoor Dining Facility if the facility meets the definition development and is not otherwise exempt under PRC sec. 30610 and corresponding implementing regulations. We want to allow outdoor dining on existing paved and developed areas (such as patios and landscaped gardens) without requiring a Coastal Development Permit as (per our analysis of water use) existing outdoor dining does not result in an increase in the number of customers (no increase in the intensity of a land use) and so no CDP would be required. Would you be comfortable with the following revision: B1.Coastal Development Permit. A Coastal Development Permit is required for an Outdoor Dining Facility that includes the erection of a pavilion or tent. A CDP may not be required for Outdoor Dining (tables and chairs) that are located in an already developed patio or landscaped area, as determined by the Community Development Director.
How does the city reconcile proposed changes to 17.42.165 (B)3 section d “minimum of 50’ buffer from ESHA” with General Plan element 4- Conservation, Open Space, Energy, and Parks policies OS-1.8 and OS-1.9. “Buffers shall be of a sufficient size to ensure the biological integrity and preservation of the ESHA they are designed to protect. The width of the buffer area shall be a minimum of 100 feet, unless an applicant can demonstrate, after consultation with the California Department of Fish and Game [wildlife], other relevant resource agencies, and the city, that 100 feet is not necessary to protect the resource of that particular habitat area and the adjacent upland transitional habitat function of the buffer from possible significant disruption caused by the proposed development” (emphasis added). Consider amending the standard to something like “Outdoor dining must be located a minimum of 100 feet, consistent with OS-1.8, from any environmentally sensitive area, wetland or rare plant community. A buffer of less than 100 feet may be allowed only if found consistent with OS-1.9.” I will revise it to the 100-foot buffer.
Please confirm that 17.42.165 (B)3 section e conforms with and is adequate to carry out the various water quality protection policies of the LUP. Yes, this conforms with the stormwater requirements of the CLUDC.
The draft changes that we reviewed include a definition of Outdoor Dining Facility to be added to the ILUDC. Consider whether the definition should also be added to the CLUDC. Sorry that was a typo. It should have read as 17.100 not 18.100.
We note that the proposed regulations apply only to restaurants that have an indoor dining component. Does the city have separate regulations for food trucks (mobile food vendors), which may also have facilities for outdoor dining? Consider whether it makes sense to broaden the regulations to include standards for mobile food vendors. Food trucks are regulated through our Municipal Code not our Land Use and Development code. Applicants who want to have a food truck in the Coastal Zone are required to get a CDP and to follow our Muni Code requirements for Food Vending. So far everyone has chosen to avoid the CDP requirement and instead operate in the inland portion of the City.
Thank you for consulting with us early in this process. We are happy to work with you on any of these items and recognize that there may still be changes to come with the submittal. Hope you have a happy holiday and a wonderful new year.
Best,