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City of Glendale Community Development Dept., Planning Division 633 E. Broadway, Rm. 103 Glendale, CA 91206 818.548.2140 www.glendaleca.gov/CDD
Case No. ________________
Date ____________________
Submit this form on the Glendale Permits site at www.glendaleca.gov/permits (Appeal of Planning Decision) For mo
re information about this form and related fees, please call the Planning Division at (818) 548‐2115.
Please co mplete (PRINT or TYPE) the following information:
PART 4 – FINDINGS OF FACT (per Glendale Municipal Code Title 30, Chapter 30.44). To justify your Administrative Exception request, please answer all of the following questions:
A. How will the granting of the exception result in design improvements OR how do the space restrictions of th e site preclude full compliance with Code requirements without hardship? ___________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ B. Why will granting of the exception NOT be detrimental to the public welfare? __________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ C. Why will granting of the exception be in keeping with the objective/s of the applicable re gulation/s? ______________________
Note: Failure to furnish any of the requested information will delay action on the request. Three (3) copies of this application are to be submitted. Attach additional pages as needed.
PART 1 – NOTICE TO APPELLANT (please read carefully)
A. This form must be prepared and filed, within 15 days of the date of the decision being appealed.
B. Every question must be answered.
C. If a question does not apply, you must answer “does not apply” or words to that ef fect.
D. Failure to properly fill out this notice or failure to make a sufficient statement of a case in this notice, even if in fact you have valid and sound grounds for appeal, may cause your appeal to be dismissed forthwith.
E. Attach additional pages for long answers.
F. Prior to compl eting this form, read the Glendale Municipal Code, Title 2, Chapter 2.88 Uniform Appeal Procedure on the City’s webpage at https://library.qcode.us/lib/glendale_ca/pub/municipal_code/item/title_2‐chapter_2_88 Appeal
PART 3 – APPEAL BACKGROUND INFORMATION
A. State the nam e or title of the board, commission or officer from which this appeal is taken ___________________ _____________________________________________________________________________________________________ B. Were you given written notice of the action, ruling or determination? Yes No If “Yes,” attach a copy of the written notice and write the date you received it here ___ ______________________ If “No,” give the following information concerning your receipt of notice of the action, ruling or determination.
Date __________________ Time __________________ Location __________________ Manner __________________ C. State generally what kind of permit, variance, ruling, determination or other action was the basis for the decision from which the appeal is taken __ _______________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ D. State the specific permission or relief that was originally sought from the board, commission, or officer _______ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ E. Were you the party seeking the relief that was originally sought? Yes No If “No,” how are you involved with the permi t, variance, ruling, determination, or other action referred to above? ______________________________________________________________________________________________ _____________________________________________________________________________________________________ F. Does this matter involve real property? Yes No If “Yes,” give the address, or describe the real property affected __________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ PART 2 – APPELLANT INFORMATION
A._______________________________________________________________________________________________________ First Name Last Name Email Address
B._______________________________________________________________________________________________________ Street Address City State Zip Code Area Code ‐ Phone Number Exhibit 14
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City of Glendale Community Development Dept., Planning Division 633 E. Broadway, Rm. 103 Glendale, CA 91206 818.548.2140 www.glendaleca.gov/CDD FOR STAFF USE ONLY Date Stamp
Date received in Permit Services Center ____________ Received by _____________ Fee paid ________________________________________ Receipt No. _____________________________________
Statement of additional facts related to the appeal: ____________________________________________________________ ____________________________________________________________________________________________________________ ____________________________________________________________________________________________________________ ____________________________________________________________________________________________________________
The foregoing statements, contained in PARTS 2, 3 and 4 above, are true and correct to the best of my knowledge and belief.
__________________________________________________ ___ Appellant’s Name – Please Print
__________________________________________ ___ _______________________________ Appellant’s Signature Date Signed
PART 4 – STATEMENT OF ERROR
A. Do you contend that there was a violation of a specific provision of law, which forms the basis for this appeal? ___Yes ___No If “Yes”, state each specific provision of law that you contend was violated: _______________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ B. Do you contend that th
e board, commission or officer exceeded its authority by virtue of any of the provisions of law given in answer “A”? ___Yes ___No If “Yes”, state which provisions, and state specifically each act that was in excess of authority: ________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ C. Do you contend that the board, commission or officer failed to fulfill a ma ndatory duty by any provision of law given in
answer “A”? ___Yes ___No If “Yes”, state which provision, and the specific duty that it failed to exercise:
____________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ D. Do you contend that the board, commission or officer refused to hear or consider certain facts before rendering its decision? ___Y
es ___No If “Yes”, state each such fact, and for each fact, state how it should have changed the act, determination or ruling:
_____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ E. Do you contend that the evidence before the board, commission or officer was insufficient or inadequate to support its action, determination or r
uling or any specific finding in support thereof? ___Yes ___No If “Yes”, state what evidence was necessary, but lacking: ________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ F. Do you contend that you have new evidence of material facts not previously presented, which if considered should change the act, determination or ruling? ___Yes _ __No If “Yes”, state each new material fact not previously presented to the board, commission or officer. For each fact, state why it was not available, or with the exercise of reasonable diligence could not have been discovered and previously presented by the appellant:
Writer’s email:[email protected]
August 24, 2023
VIA EMAIL
[email protected]
Vista Ezzati
CITY OF GLENDALE CITY COUNCIL
613 E. Broadway
Glendale, CA 91206
Re: Legal Action Network
Appeal of 1900 Riverside Drive Design Review Board Meeting August 10, 2023 PDR 000210-2022
PS File No.: 1005-2300
Dear Members of the City Council,
This firm has been retained by Legal Action Network LLC (LAN) which is a network organization of community members, equestrians, business and equestrian business owners, residents, organizations, and other stakeholders that represent the urban horse communities of Los Angeles (Los Angeles Equestrian Center), Burbank, and Glendale, California. The Riverside Rancho in the City of Glendale and the Rancho Equestrian District in Burbank are part of only three urban horse communities in the United States. All three connect to Griffith Park in Los Angeles.
We submitted a letter opposing the demolition of the existing buildings at 1900 Riverside Drive. We understand that despite our opposition, the demolition was approved.
We understand that one of the key conditions that the Design Review Board did impose on the applicant prior to any demolition is that the public easement on Allen be vacated. We understand that the west side of Allen will be their driveway to parking at the rear of their property. This portion of Allen is also frequently referred to as the “Alley”. We have not been informed of the public process of vacating this easement and believe that if it is vacated, the equestrian access over the channel for rental horses will be significantly limited. As we are sure the City Council knows, this public easement is one of the few access points from Glendale to the Los Angeles Equestrian Center. In addition to the use of the existing easement or public horse access, it is used by hikers, emergency vehicles and utilities such as SCE. Simply having a condition that the easement must be vacated prior to any demolition does not provide the public with how they can have their input and concerns about the vacating of the easement heard and considered. As a result, you have forced LAN to file this appeal to protect their rights and ability to address the vacating of the easement.
In addition to the issue regarding the vacating of the easement, the public has provided significant comments and testimony regarding the impacts of this new proposed project and the August 25, 2023
City of Glendale City Council
L:\Client Files\1005\2300 - LEGAL ACTION NETWORK\CORRESPONDENCE\CE\CE.City of Glendale.002 (appeal).docx Design Review Board should have taken these comments into consideration when it approved the request on August 10, 2023. These comments included those made at the March 7, 2023, City Council Meeting.
Let me highlight a few of the issues for our opposition and the basis for the appeal:
1. Since at least 2019 there has been significant communications with the City of Glendale providing evidence that there is a conflict between public dog facilities (kennels) and the equestrian uses in the Rancho.
2. The Health and Safety part of the CE code indicates that uses shall not result in a negative impact on neighboring uses. In this case, the dog kennel will have a negative health and safety impact on the adjacent equestrian facilities, trails and uses.
3. The claim that this property could no longer be used as a horse facility is and continues to be false. It was operating at full capacity until the new property owner ordered the horses to be vacated.
4. The City has been provided with two historical assessments (J. Snow 2018 and J DeCarli 2021) which support that the existing property deserves historic preservation. The approval by this Board of a demolition permit will not allow the community to continue to pursue historic preservation.
For all of the reasons stated in this letter, LAN requests that the City Council affirm our appeal and reverse the approval of the Design Review Board to demolish the existing buildings on this property. In addition, we request that the City Council provide a public process for the consideration of the vacating of the public easement on the west half of Allen also referred to as the “Alley”
Thank you for your consideration of our request.
Very truly yours,
Hunt C. Braly
cc: Clients