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Staff Report

Glendale City Council
August 26, 2025

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Staff Report
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August 26, 2025
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Glendale City Council
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CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Consideration of Development Standards and Conditional Use Permit for Drive Through Restaurant Facilities

1. Motion Providing Final Direction to Staff Regarding Development Standards and Procedures for Approving Developments with Drive-Through Operations

COUNCIL ACTION
Item Type: Action Item
Approved for August 26, 2025 calendar

EXECUTIVE SUMMARY
In response to a number of applications for modifications to existing and new construction of drive-through establishments, as well as community concerns about safety, aesthetics, traffic, and environmental issues, the City Council enacted a moratorium on drive-through establishments that was in effect from September 27, 2022, to September 26, 2024. During that time, the city engaged a traffic and transportation consultant with expertise in drive-through analysis and design, to study and develop solutions for drive-through establishments. On August 13, 2024, CDD staff introduced an ordinance to amend the zoning code requirements for drive-through establishments to include creating definitions for drive-throughs and implementing a conditional use permit (CUP) process. On August 20, 2024, adoption of the ordinance failed with 3 in favor and 2 opposed, where a 4/5th vote is required.

Since then, the topic of drive-through establishments and regulations has been discussed at Council on several occasions. The most recent of these Council discussions was March 11, 2025, resulting in Council’s adoption of a motion directing staff to initiate amendments to Title 30 to regulate new drive-through restaurant facilities and provided specific direction on development standards, types of uses, and requirements for a conditional use permit.

Based on Council direction, staff is proposing a series of changes to the Zoning Code to address new drive-through restaurants. Specifically, staff is proposing establishing 29c
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definitions for different tiers based on intensity of use, implementing a conditional use permit requirement for “Tier 3” and “Tier 4” establishments (most intense use category of drive through), and creating development standards that not only promote good design, but also, mitigate many of the common issues related to existing drive-throughs.

As it relates to development standards, this staff report provides recommendations associated with minimum lot size requirements, vehicle queueing lengths, restrictions on the use of public right-of-way, traffic consultant selection, site planning, and pedestrian and vehicular circulation. This report also contains additional considerations that were not previously discussed, including signage, noise, loading of deliveries, mobile order pick-up spaces, expansions, and direction on non-conforming uses.

RECOMMENDATION
To provide final direction to staff as it relates to the creation of new development standards and conditional use permit requirement for drive-through restaurant facilities.

Following this final direction, staff will prepare amendments to Title 30, present these amendments to the Planning Commission for its recommendation, and, finally, return to Council for introduction and adoption.

BACKGROUND / ANALYSIS
In response to a growing number of applications for modifications to existing and new construction of drive-through establishments, the City Council enacted a moratorium on drive-through establishments that was in effect from September 27, 2022, to September 26, 2024. The moratorium was intended to allow staff time to review existing requirements and develop an approval process for drive-throughs to address safety, aesthetics, traffic and environmental concerns associated with such developments. On August 13, 2024, Community Development Department (CDD) staff introduced an ordinance to amend the zoning code requirements for drive-through establishments to include creating definitions for drive-throughs and implementing a conditional use permit (CUP) process. On August 20, 2024, adoption of the ordinance failed with 3 in favor and 2 opposed, where a 4/5th vote is required.

On November 19, 2024, Councilmember Brotman requested this topic be brought back as an informational item regarding development standards specific to new drive-through establishments. Staff returned to Council on March 4, 2025, with alternatives for development standards. At that time, Council expressed an interest in returning with more information regarding the standards, as well as the difference between implementing the development standards and the previously proposed CUP. On March 11, 2025, CDD staff returned to Council with more information regarding development standards and the CUP process, after which Council adopted a motion (Exhibit # 1) 39c
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directing staff to initiate amendments to Title 30 to regulate new drive-through restaurant facilities, and to return to Council with an update before finalizing those amendments for Planning Commission review and recommendation. As directed by Council, staff will be implementing code amendments that focus on new drive-through restaurant establishments and their intensity. No additional requirements will be placed on existing drive-through restaurant establishments that will continue to be allowed to operate as-is. Council direction did not include changes for other types of drive-through establishments (e.g., bank, pharmacy, retail store, etc.). These types of drive-throughs will continue to be permitted in all zones, with the exception of the DSP where drive- throughs are prohibited, and no development standards will be proposed for these uses.

Drive-through establishments associated with a use that is not a restaurant will continue to be regulated by the minimum drive-through waiting lane standards in GMC Section

30.31.130(H) which range from 60 feet to 120 feet. As it relates to the proposed amendments for new drive-through restaurants, Council direction was as follows:
Study and develop standards and a process to require all new drive-through restaurant facilities that fall within either a “Tier 3” or “Tier 4” category to apply for and obtain a conditional use permit prior to operating. Study and develop new or amended development standards, with options, to regulate all new drive-through restaurant facilities with respect to:
oProhibiting any new drive-through restaurant facilities in zones other than C2, C3 and CH.
oMinimum queuing length requirements.
oMinimum distance from sensitive uses (such as schools, police stations, parks, etc.) and/or from freeway on- and off- ramps.
oProhibiting the use of alleyways for queuing and/or entry into a drive- through restaurant facility.
oRequiring an applicant for a new drive-through restaurant facility to hire a traffic consultant selected by the City.

In October 2023, during the moratorium and as part of the code amendment process, the city engaged JB & Associates, a traffic and transportation consultant with expertise in drive-through analysis and design, to study and develop solutions for drive-through establishments. Additionally, the Mobility Section of the Community Development Department (CDD) partnered with the Public Works Traffic Engineering Division and worked with JB & Associates to assess the performance of existing drive-through establishments in the city and focus on options to improve their overall design and performance. The study prepared by JB & Associates identified seven tasks necessary in developing the drive-through standards that included research on current design guidelines, ordinances and procedures from other cities, conducting field observations, data collection and analysis for trip generation rates, developing guidelines, and 49c
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establishing a traffic analysis procedure. For field observation, data collection and analysis, staff and the consultant selected 15 food-oriented and 4 non-food-oriented drive-through establishments located in the city, with the exception of 2 which were located in Pasadena and Los Angeles at the border with Glendale. Based on this analysis, the JB & Associates study included classifying the different drive-throughs into four different tiers, dependent on the intensity of the use, and establishing queuing length standards based on the tier. Recommendations were also made as it relates to development standards for drive-throughs. In addition to Council’s direction, many of the findings in this study have provided a foundation for staff’s recommended amendments to the zoning code.

Establishing Tiers
According to the City of Glendale’s Transportation Impact Analysis Guidelines, vehicle trips generated by a project should be estimated using the average trip generation rates published in the Institute of Transportation Engineers (ITE) Trip Generation Manual.

When comparing trip generation rates derived from data collection with the ITE averages for fast-food restaurants and coffee shops, there were significant variations that can be attributed to factors such as building size, location, and historical demand for products sold (thereby generating more cars in the queue at one time). To provide a more accurate trip generation estimate for the study, the 19 sites were categorized into the following tiers:

Tier 1: Fast-food restaurants that generate significantly fewer trips than the average rates estimated in the ITE Trip Generation Manual.

Tier 2: Fast-food restaurants that generate trip rates comparable to the averages in the ITE Trip Generation Manual.

Tier 3: Fast-food restaurants that generate significantly more trips than the rates estimated in the ITE Trip Generation Manual.

Tier 4: Coffee shops with a drive-through operation. It is important to note that the ITE Trip Generation Manual includes donut shops with the coffee shop designation.

Definitions
As directed by Council, staff will be implementing code amendments that focus on new drive-through restaurant establishments and their intensity. No additional requirements will be placed on existing drive-through restaurant establishments or other types of drive-through establishments (e.g., bank, pharmacy, retail store, etc.). Council direction was to create development standards for all new drive-through restaurants and also require a conditional use permit (CUP) for new drive-through restaurants that are Tier 3 59c
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or Tier 4. In order to do this, the variations in the type of drive-through and associated intensity will need to be distinguished through a definition, as follows:

Drive-through establishment, restaurant: A business establishment engaged in the preparation and sale of food or beverages, with provisions for serving customers in vehicles for consumption on- or off-site. The drive-through component operates in conjunction with a counter-service, fast-food, or full-service restaurant, as defined in GMC Section 30.70.190. All drive-through restaurants shall be classified into four tiers of intensity, based on a Trip Generation and Queuing Analysis submitted by the applicant. The study shall be prepared to the satisfaction of the Director of Public Works and Director of Community Development and shall compare the historical operation (trip rates) of the proposed business to average rates in the Institute of Transportation Engineers (ITE) Trip Generation Manual and classify the operation into a tier. The purpose of the tier classification is to regulate drive-through operations based on their traffic impacts and are as follows:

Tier 1: Drive-through restaurants that generate significantly fewer trips than the average rates published in the ITE Trip Generation Manual for similar uses.

Tier 2: Drive-through restaurants that generate trip rates comparable to the ITE average rates.

Tier 3: Drive-through restaurants that generate significantly more trips than the ITE average rates.

Tier 4: High-turnover specialty uses with a drive-through component, including but not limited to coffee shops and donut shops, which typically generate high volumes of short-duration trips, often exceeding peak trip generation of Tier 3 uses.

Drive-through restaurants would be allowed in the C2, C3, and CH zones only, which would be a total of 1,475 lots, and either permitted by right and subject to development standards for Tier 1 and Tier 2 businesses, or conditionally permitted and subject to development standards for Tier 3 and Tier 4.

Conditional Use Permit (Tier 3 and 4 Only)
Based on Council’s direction, a conditional use permit (CUP) will only be required for new drive-through restaurants that are classified as Tier 3 or Tier 4. The purpose of a CUP is to allow discretionary review for certain uses because their particular characteristics, including traffic problems incidental to the operation and/or their effect on adjoining land uses, which has the potential to be detrimental to the peace, health, 69c
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safety, and general welfare. Through the CUP, an analysis of the site planning, proposed use, business operations and surrounding neighborhood is done, and if all of the required findings can be made in favor of the proposal, conditions of approval are placed on the project to mitigate any potential negative impacts. Typically, there are four required findings that must be made in order for a CUP to be approved that are related to consistency with the general plan; no detrimental impacts to the public health, safety, general welfare and the environment; compatibility with and no conflicts with adjacent uses and the surrounding neighborhood; and adequate utilities, landscaping, parking and traffic circulation are provided for. When the ordinance was last presented to Council for consideration, staff proposed additional findings for drive-through establishments, some of which were intended to address future development standards.

These four findings are identified below, however, upon further review, staff is not recommending including them moving forward, as they are repetitive of the standard conditions for all CUPs and are already part of the analysis; moreover, the findings will be addressed by the proposed development standards.

1. That the proposed drive-through establishment has adequate vehicle queueing distance, including due consideration for menu board location(s), clear of any adjacent public right-of-way, and shall not create any vehicular or pedestrian travel hazards as demonstrated in a traffic study prepared to the satisfaction of the Director of Public Works.

2. That the proposed location of the drive-through establishment will not result in adverse impacts on the surrounding neighborhood after considering a litter clean- up plan and the hours of operation, site plan, and includes buffering sufficient to control any spillover impacts, including but not limited to noise, light, and debris.

3. That the location and design of the facility is compatible with the existing surrounding uses, includes a prominent main entrance at street or lot frontage, attractive landscaping, and includes sufficient pedestrian amenities in the street lot frontage, and interior floor area.

Development Standards for New Drive-through Restaurants Establishing minimum development standards that are specific to drive-through restaurants is an additional measure to ensure that these establishments can work well in Glendale and mitigate many of the impacts that are common with existing drive- throughs in the city. Providing objective and measurable standards for applicants will establish minimum expectations that are clear and aimed at protecting the community.

Development standards for specific uses are not uncommon in Glendale, GMC Chapter

30.34 establishes these standards for various uses including gas stations, car dealers, adult businesses, and car washes. Staff is recommending development standards for new drive-through restaurants related to minimum lot size, vehicle queueing lengths, 79c
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restricting the use of public right-of-way, traffic consultant selection, and site layout and circulation.

Minimum Lot Size
Establishing a minimum lot size for new drive-through restaurants is a useful tool to mitigate potential negative impacts on surrounding areas, including traffic circulation, parking, noise, and visual impacts. Currently, the GMC establishes minimum lot size requirements for gas stations (14,400 SF), full-service car washes (25,000 SF), self- service car washes (12,500 SF), and car dealers (13,000 SF). In looking at existing drive-throughs in the city and surrounding areas, existing lot sizes in the C2, C3, and CH zones, and standards from other jurisdictions, staff is recommending establishing a minimum lot size of either 20,000 SF or 25,000 SF which takes into consideration operational needs, while also not being overly restrictive in reducing the potential for these types of businesses to locate in Glendale. The council can consider not establishing a minimum lot size or providing direction to staff on the size. The table below provides a breakdown of different options for minimum lot size and how many lots could be eligible under each standard.

Min. Lot Size C2 C3 CH Total
None 575 778 122 1475
10,000 SF 317 320 44 681
20,000 SF 203 107 25 335
25,000 SF 172 81 18 271
30,000 SF 144 69 8 221
35,000 SF 100 31 7 138
40,000 SF 64 25 5 94
45,000 SF 28 22 5 55
Vehicle Queuing Lengths
Establishing minimum standards for vehicle queueing lengths will ensure that the drive- through lane will have enough capacity to prevent traffic from spilling onto streets or parking areas. These would be minimum queueing lengths a new drive-through restaurant would have to comply with, but the development standards would also allow the City to require more, dependent on the City’s review of the required queuing analysis. The study prepared by JB & Associates establishes minimum queuing capacities based on the use as a drive-through restaurant and the different tiers:
Tiers 1 and 2: 10 vehicles (220 feet)
This includes 6 vehicles (132 feet) between the drive-through entrance and order board, and 4 vehicles (88 feet) between the order board and pickup window. Tier 3: 25 vehicles (550 feet)
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Tier 4 (Coffee Shops & Donut Shops): 15 vehicles (330 feet).

This includes 11 vehicles (242 feet) between the drive-through entrance and order board, and 4 vehicles (88 feet) between the order board and pickup window.

Minimum Distance from Sensitive Uses
Council direction was to look into establishing a minimum distance from sensitive uses (e.g., schools, police stations, parks, etc.) and/or from freeway on- and off-ramps. There was no direction on what the minimum distance should be or exact specifications for the type of uses to be considered sensitive. Typically, when analyzing a CUP, Planning staff will review the surrounding neighborhood and identify schools, police or fire stations, parks, libraries, and churches. There is no set standard for proximity of these uses, but the analysis typically involves up to 1 mile around the property. The analysis in a CUP also discusses surrounding residential uses, and conditions of approval are often placed on these types of approvals to mitigate potential negative impacts (e.g., noise, trash, traffic, etc.). Staff has reviewed the existing commercial sites and their proximity to potential sensitive uses and freeway on- and off-ramps, and does not recommend including this as a standard.

Currently, there is limited precedent in the Zoning Code for prohibiting adult business uses and kennels within a minimum distance of other specified uses. There is a prohibition for adult business uses which are only allowed in certain districts in the Downtown Specific Plan (DSP) area; the use is prohibited in the Civic Center, East Broadway, and Transitional Districts. Additionally, adult business uses are prohibited within 450 feet of any church, public or private school or college, park, playground, library, or area zoned for residential uses, and within 700 feet of another adult business.

The second prohibition is related to kennels, which are only allowed in the IND, IMU and IMU-R zones, and are not allowed within 200 feet of a residential zone if outdoor facilities are proposed. From 2002 until 2006, the Zoning Code also had minimum distance requirements for banquet halls and nightclubs, which were prohibited within 200 feet of residential zones. The minimum distance restriction was removed because it restricted a number of commercially zoned sites that were adjacent to residential zones, and because it can be part of the CUP analysis with conditions imposed to mitigate impacts.

As it relates to establishing a minimum distance requirement from freeway on- and off- ramps, there is no precedent in the Zoning Code for this type of standard. Nevertheless, the Public Works Traffic division does review proximity to freeways with project proposals and typically, driveway entrances are restricted within 200 feet of a freeway on- or off-ramp. If Council wishes to establish a minimum distance requirement from a 99c
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freeway on-or off-ramp, staff recommends utilizing the 200-foot standard to be consistent with Public Works’ practice.

Using the City’s internal Geographic Information Systems (GIS) maps, staff was able to study the existing C2, C3, and CH zoned lots and their proximity to various sensitive uses, including schools, churches, parks, libraries, fire stations, and police stations.

Staff was also able to use the GIS maps to study these lots proximity to freeway on- and off-ramps. For both instances, staff studied 200- and 500-foot radii and determined that establishing this type of restriction on a drive-through restaurant business would significantly limit the eligible lots in the C2, C3, and CH zones. The impact was more significant when considering proximity to the listed sensitive uses.

At this time, staff does not recommend pursuing this option given the limited precedent in the Zoning code, the analysis that will be done with respect to this consideration through the CUP process, and given that this restriction could significantly limit the number of eligible lots. Should the Council want to pursue implementing this type of standard, staff is seeking more specific direction on the standards as it relates to the applicable distance and types of uses.

Restricting the Use of Public Right-of-Way
There has been an ongoing concern with several of the existing drive-through establishments with respect to the traffic congestion resulting from vehicles queuing in the street and public alleyways. A development standard would strictly prohibit this occurrence, and for those businesses that require a CUP, it would also become a condition of approval. Council also directed staff to include a development standard that would prohibit the use of alleyways for queuing and vehicle entry. Both of these will be incorporated into the development standards.

Traffic Consultant Selection
The future development standards as well as the CUP submittal requirements will include a vehicle queueing analysis and traffic study that is prepared to the satisfaction of the Director of Community Development and the Director of Public Works. Council’s direction was to require applicants to hire a traffic consultant that is selected by the City.

In discussions with Public Works staff, there is no active list of consultants for this purpose. In order to fulfill this requirement, an applicant would need to go through an RFP process, which in addition to cost would require a minimum of 4 to 6 months to complete. Additionally, without the traffic study and queuing analysis staff is unable to determine the Tier or appropriate requirements to comply with Zoning. Applicants would be required to engage the City to start the RFP process for the study early on in the planning stage, without knowing what tier they would be classified as or what standards to comply with in developing plans. For these reasons, staff does not recommend 109c
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pursuing this as a requirement for new drive-through restaurants. Alternatively, in the early planning stages, an applicant would engage with staff regarding development requirements, including design standards, tier classification, and required technical studies. Once prepared, the required vehicle queueing analysis and study would be reviewed by Public Works and Planning staff for concurrence with the analysis and findings. This is consistent with existing practice and typical of any technical study required by the City for a development project (e.g., historic resource report, noise study, indigenous tree report, etc.).

Site Layout and Circulation
Staff is proposing additional standards specific to site layout and design, and circulation for vehicles and pedestrians.

Site Planning
New drive-through restaurants will be required to place their buildings close to and oriented towards the street, with clearly defined entries that are accessible from the sidewalk. Incorporating outdoor dining will be encouraged for these types of uses, and where proposed, will need to be oriented towards the street to enliven the pedestrian experience. There are existing standards in the parking chapter for outdoor dining areas that are exempt from providing parking, which includes requirements for location, size, fences and roofing.

Landscaping
The Zoning Code has minimum landscaping requirements for parking lots and for those properties that are abutting residential zones, existing zoning standards are in place that require boundary walls and tree plantings. Additional development standards for new drive-through restaurants will require minimum 5-foot-wide planters along property lines exclusive of buildings and required driveways, and minimum 3-foot wide planters will be required to separate the drive-through queue lanes from parking lots and any pedestrian circulation paths. Additional landscaping standards can be implemented that could help minimize light glare from vehicles in the drive-through queue lanes.

Pedestrian and Vehicle Circulation
Development standards will require clear signage and pavement markings to direct vehicular traffic flow for the site, including parking and drive-through circulation. Drive- through lanes will be required to be separate from parking areas through landscape planters, which also helps minimize conflicts with vehicles in the drive-through and those trying to enter/exit the parking spaces. Additional standards for pedestrian circulation will be proposed to ensure that these areas are delineated on-site and designed to minimize conflicts with vehicles.
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As it relates to the drive-through lane, development standards will require the entrance to be 60 feet from the property line and from public street intersections, with the lane sited at the back of the restaurant to minimize visibility from the street. A minimum lane width of 10 feet will be required for straight sections of drive-through lanes, and that will increase to 12 feet along curves with a minimum 10-foot curve radius requirement.

Depending on the findings of the submitted queueing analysis and traffic study, double- lanes or bypass lanes may be required, however these would be dependent on the site and proposed operation and would be implemented through conditions of approval on a CUP.

Additional Considerations
Staff is also proposing additional considerations for drive-through development standards and is seeking council direction on signage, noise, loading, mobile order pick- up, expansions, and existing non-conforming uses.

Signage
Existing zoning regulations for signage do not address the needs of drive-through facilities, which typically need 1 to 2 menu boards and associated ordering devices.

Additionally, there are no provisions that allow for the digital order boards that have become common at many businesses. To address this, staff is recommending amendments to the existing sign code to establish standards for placement, size, and quantity of these types of signs, pending the constitutionality of carving out allowance of such digital signage based on this use. Another consideration for signage at new drive- through establishments would be to require a sign program for the business, which would require additional amendments to the sign code (GMC Chapter 30.33) and design review (GMC Chapter 30.47).

Noise
For those drive-through restaurants that provide late night or 24-hour service in their drive-throughs as part of their operation, establishing noise standards can mitigate impacts on surrounding uses. Development standards regulating noise can be proposed which could establish maximum sound levels allowed after 10 pm and before 7 am, including additional restrictions based on proximity to residential uses.

Loading
There are no provisions in the zoning code that would require a loading space for a typical drive-through restaurant. There are loading space standards, which at a minimum would require at 15’-0” by 25’-0” space for loading, in addition to all other parking and site requirements. Based on the size of most drive-through restaurants, requiring a loading space that large is not necessary, and would take up unnecessary room on the site. Rather than establishing a loading space requirement, staff is 129c
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recommending development standards that limit the hours of deliveries and require them to be done on-site in order to prevent the delivery vehicles from obstructing traffic floor during daily operations.

Mobile Order Pick-Up
Utilizing existing parking spaces for mobile order pick-ups has become more common with many drive-through establishments. There are no provisions in the zoning code that regulate this, and staff is recommending implementing development standards to regulate the maximum number allowed.

Expansions
Staff is seeking direction on how to address expansions of drive-through establishments under two likely scenarios:
Existing drive-through restaurant in the C2, C3, and CH zone that either wants to modify or expand their existing operation, or a change of use that would increase their Tier classification.
New drive-through restaurant that is built under the requirements of a certain Tier, and undergoes a change of use to a more intense Tier. Examples of this include a property developed with a Tier 1 restaurant, changing the use to a Tier 2 of Tier 3, which not only could trigger a CUP, but also additional queue lengths.

Staff is recommending projects in these types of scenarios to be eligible to apply for an Administrative Exception, which has similar findings to a variance, but is reviewed at the director-level. This would be consistent with current practice for existing gas stations, car washes, tire stores and vehicle repair garages that are unable to comply with the specific development standards for their type of use. In these situations, staff has the ability to apply the development standards for drive-through restaurants, work with businesses to get them into compliance where possible, and for those standards they are unable to comply with, staff will still have the ability to apply conditions of approval that would help mitigate some of those impacts.

Existing Non-Conforming Uses
Based on the current code, any existing drive-through in the City would be considered non-conforming because they do not comply with the development standards or CUP requirement. These businesses would be allowed to continue operation as-is, but would not be permitted to make any expansions or modifications under our non-conforming chapter (GMC Section 30.60.030). Any of these establishments that cease operations for more than one year, would forfeit their nonconforming rights. However, for those existing establishments in the C2, C3, and CH zones, staff is recommending implementing an Administrative Exception process, as explained above. 139c
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STAKEHOLDERS/OUTREACH
Not required at this time. Depending on Council direction, where applicable, staff will conduct public outreach for items that impact zoning development standards for drive- throughs.

FISCAL IMPACT
There is no fiscal impact associated with this report.

ENVIRONMENTAL REVIEW (CEQA)
Staff is seeking direction only. CEQA review will be completed prior to any Zoning Code amendment.

CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.

ALTERNATIVES TO STAFF RECOMMENDATION

1. Decline to provide final direction regarding development standards for drive-through developments.

2. Any other alternative not presented by staff.

ADMINISTRATIVE ACTION
Submitted by:

Bradley Calvert, Director of Community Development
Prepared by:

Vista Ezzati, Principal Planner
Erik Krause, Deputy Director of Community Development
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS
Exhibit 1: Council Motion, Dated March 11, 2025
Exhibit 2: Staff Report, Dated March 11, 2025
Exhibit 3: Staff Report, Dated March 4, 2025

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