1 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
July 16, 2025
LETTER OF INTENT
Project Address: 441-445 W Glenoaks Blvd.
Dear Ms. Toledo,
I am writing this letter to share the findings related to the application for the proposed new development at 441-445 W Glenoaks Blvd., Glendale, CA 9102. The project consists of forty- three (43) multi-family rental apartment units, including nine (9) affordable set-aside units.
This letter is an amendment to the previously submitted letter on January 16, 2025, and is structured in four parts as follows:
Introduction: Project Site and Existing Building
Part A: Density Bonus Information
Part B: Concessions Summary and Findings
Part C: Waivers Summary and Findings
The structured letter outlines the density bonus component of the project and provides corresponding findings for the requested concessions and waivers.
If you have any questions or need further information, please feel free to contact me directly.
Sincerely,
Farnoosh Farmer
Farnoosh Farmer, Assoc. AIA.
Associate Partner
BOLADarck Design Corp.
[email protected]
626.381.9677
EXHIBIT 5
2 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
INTRODUCTION: PROJECT SITE AND EXISTING BUILDING
The project site is located on the north side of West Glenoaks Boulevard and consists of two contiguous lots with a relatively flat topography. The site currently features two multi-family residential buildings with eight units and detached carports, all originally built in 1942. These structures will be demolished to prepare the site for the new development.
The property has no associations with events or people significant in history and does not serve as a distinctive or exemplary representative of its architectural style, type, or period.
The property therefore does not meet any criteria for listing on any National, State, or local register for historic resources, and is not considered a historic resource under the California Environmental Quality Act (CEQA).
PART A: DENSITY BONUS INFORMATION
Lot Area: ± 17,100.81 SF
Maximum Number of Units Permitted by Zone: 18 Base Units Number of Additional Units Requested: 25 (25/18 = 138.9% increase) Total Number of Units Proposed: 43 (25 + 18)
Unit Type: Rental
Number of Affordable Units Provided: 9
Percentage of Affordable Units Provided: 9 affordable / 18 base units = 50% Level of Affordability:
• Very Low-Income Households 6
• Moderate-Income Households 3
Requested Concessions: (4 total)
• Height and story
• Floor area ratio
• Common open space
• Additional open space
Are parking concessions requested? Yes (per Density Bonus Law) Child-care facility proposed with the project? No
Project within ½ mile of a major transit stop Yes
Present use of property Residential
Number of existing units on site 8
Number of existing low-income units on site None
Requested Waivers: (5 total) Yes
• Minimum unit size
• Lot coverage
• Interior East setback
• Interior West setback
• Permanent Landscaped Open Space
3 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
The applicant is seeking approval of incentives and concessions pursuant to Government Code 65915 and GMC Section 30.36-Density Bonus Incentives of the Glendale Municipal Code.
The requested incentives or concessions are essential for the feasibility of this proposed project to provide affordable rent.
The code allows for incentives, waivers and/or modification for projects that provide residential rental units designated for very low-income and moderate-income households.
This project proposes to provide 138.9% of the maximum permitted units and qualifies for four incentives.
• Number of Dwelling Units Proposed:
The proposed project involves the construction of a new four (4) story, forty-three (43) multi- family rental apartment units (including six (6) very low-income and three (3) moderate- income households). The project consists of nineteen (19) studio and one bath units and twenty-four (24) one bedroom and one bath units. Parking is provided within a semi- subterranean garage, with a total of twenty-nine (29) parking spaces.
• Maximum Number of Units Permitted per Zoning Code:
This proposed project consists of two lots at 441-445 W. Glenoaks Blvd., Glendale, CA 91202, and is in the R-1250 (High Density Residential) zone. The Glendale City Zoning code permits a maximum density of one dwelling unit for each one thousand (1000) square feet of site area for parcels with a width more than 90 ft. Based on the size of the project site, seventeen thousand and one hundred and eighty-one hundredths (17,100.81) square feet, a total of seventeen (17) units would be allowed if density bonus is not requested. With the requested density bonus, the base number of units in the project will be eighteen (18) units after rounding up.
• Number of Affordable Units meeting Density Bonus Requirement:
The project applicant is proposing to provide nine (9) affordable residential dwelling units (very low and moderate affordable level), which is fifty (50) percent of the maximum number of units permitted per the Zoning Code (when rounded up per GMC §30.36.050.C).
• Amount of Density Bonus Requested:
The proposed project is seeking a one-hundred thirty-eight point nine (138.9 %) percent bonus density units and will be providing a proportionate number of restricted units, calculated as six (6) very low-income units and three (3) moderate-income units. State Density Bonus Law (CA Govt Code § 65915, et seq.) allows up to an automatic one hundred percent (100%) density bonus. Providing twenty-one (21) percent very-low and moderate affordable residential dwelling units allows the project applicant to request a maximum of one-hundred thirty-eight point nine (138.9 %) percent bonus density units. The additional eight (25) units
4 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
above what the Zoning Code allows (maximum eighteen (18) units when rounded up) (§30.36.050-C) allows for four (4) Incentives.
A total of 43 units are proposed for this project, including six (6) very low-income and three (3) moderate-income affordable units, which are as follows:
PART B: CONCESSIONS SUMMARY AND FINDINGS
• REQUESTED CONSESSIONS:
The applicant is requesting the following (4) concessions:
1. Height and Story Increase from 36 ft maximum height (3 stories) to 47 ft (4 stories).
2. Floor Area Ratio Increase from 1.2 in the R-1250 Zone to 2.2.
3. Common Open Space Decrease from 7,700 sf required area (200 sf per the first 25 dwelling units and 150 sf per the additional second 25 dwelling units) to 4,210.4 sf.
4. Additional Open Space Decrease from 980 sf required area to none. • REQUIRED FINDINGS OF FACT (per Glendale Municipal Code Title 30, Chapter
30.36.080):
1. Describe how the incentive or concession results in identifiable and actual cost reductions to provide for affordable housing costs or to provide affordable rents:
Height, FAR, and Density:
Providing the additional height, buildable area, and total proposed unit count would allow for the thirty-four (34) market rate units to offset the cost and financially support construction and operation costs, to set aside the nine (9) affordable units. The additional density and FLOOR
LEVEL
UNIT
NUMBER
UNIT TYPE AREA
(S.F.)
INCOME LEVEL
STUDIO 1-BEDROOM VERY-LOW MODERATE
1ST
FLOOR
102 611.8
105 520.6
107 505.5
2ND
FLOOR
203 598.1
208 550.1
209 604.7
3RD
FLOOR
301 608.1
306 550.1
307 505.5
TOTAL 9 UNITS 6 3 5,054.5 6 VERY-LOW 3 MODERATE
5 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
increase in floor area will provide the additional housing units that will financially support the designated affordable units for very low and moderate-income households.
Common Open Space and Additional Open Space:
Reducing requirements of Common Open Space and Additional Open Space directly translates into cost savings that can be redirected to support affordable housing development and improve the financial viability of providing affordable housing. With less space allocated for open areas, the applicant can use the freed-up land to build more units. This increase in the buildable area allows for a higher unit count, which can generate more revenue from market-rate units. The additional income from these units can offset the cost of setting aside units for affordable housing.
2. Describe how the incentive or concession will not have a “specific adverse impact upon public health and safety,” as defined in paragraph (2) of subdivision (d) of California Government Code Section 65589.5, or the physical environment or on any real property that is listed in the California Register of Historical Resources for which there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact without rendering the housing development unaffordable to low-income and moderate-income households. As used herein, “specific adverse impact upon public health or safety” means a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies or conditions as they existed on the date the application was deemed complete. Inconsistency with the zoning ordinance or the land use designation in the general plan shall not constitute a specific, adverse impact upon public health or safety:
The proposed development requests comply with all zoning codes and adhere to design guidelines that are compatible with and appropriate for the adjacent buildings and site context. The project is enabled through the use of the State Density Bonus specifically under Assembly Bill - AB2345, AB1287, and General Plan Update to meet Glendale City’s Housing Element.
The requested concessions do not include reductions to any standards of any state or local Building and Safety Division (Community Development Department), Fire Department or Engineering Division (Public Works Department) requirements or any other objective, identifiable written requirements pertaining to health and safety.
The proposed project meets the requirements to qualify for a Class 32 “In-fill” Development Project and is exempt from further CEQA review.
The proposed project is consistent with the General Plan, Housing Element to provide affordable housing by allowing developers density bonuses or other financial incentives for providing units for very low-income and moderate-income residents.
6 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
3. Describe how the incentive or concession will not be contrary to state or federal law.
The granting of an incentive or concession shall not require or be interpreted, in and of itself, to require a general plan amendment, zoning change, study, or other discretionary approval. For purposes of this subdivision, “study” does not include reasonable documentation to establish eligibility for the concession or incentive or to demonstrate that the incentive or concession meets the definition:
Height and Story:
The project is requesting a height increase, including the addition of one additional story. This proposed scale aligns with the existing character of the street and surrounding neighborhood.
The area is predominantly residential, with a mix of one-, two-, and three-story buildings nearby, as well as some commercial uses along North Pacific Avenue. Directly across from the project site is a three-story medical office building (Kaiser Permanente), further supporting the appropriateness of the requested height increase within the context of the neighborhood.
Pursuant to GMC §30.11.020 Table 30.11 B, a maximum of three (3) stories and thirty-six (36) foot building height are allowed for properties in R-1250 zone. As proposed, the project applicant is requesting to increase the building height by ten feet and nine inches (11’) up to forty-seven feet (47’) and number of stories to four (4). The requested concessions would enable accommodation of the increased density.
This requested height increase concession will not require a general plan amendment, or zoning change. California Government Code Chapter 4.3. allows for adjustments to development standards for eligible developments. Granting this height incentive or concession will not be contrary to state or federal law. The requested height increase is consistent with the existing development patterns and does not conflict with any legal requirements.
Floor Area Ratio:
The proposed project is requesting a Floor Area Ratio (FAR) concession to exceed the standard FAR limitations set forth by the local zoning regulations. This adjustment is necessary to accommodate the additional density and provide the required affordable housing units.
Pursuant to GMC §30.11.020 Table 30.11 B, the maximum allowed FAR for properties located in R-1250 zone is 1.2. As proposed, the project applicant is requesting to increase FAR to 2.2.
The requested concessions would enable accommodation of the increased density.
This requested FAR concession will not require a general plan amendment, or zoning change.
The increased FAR is compatible with the surrounding neighborhood context, which includes a mix of residential and commercial developments of varying scales. Additionally, the requested FAR adjustment is consistent with the goals of the Density Bonus Law to incentivize the development of affordable housing and meet community housing needs.
7 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
California Government Code Chapter 4.3. allows for adjustments to development standards for eligible developments. Granting this FAR concession will not be contrary to state or federal law and will not undermine the health, safety, or welfare of the community. It will facilitate the financial feasibility of the project while ensuring that the additional units provided are affordable and meet the needs of the targeted income groups.
Common Open Space and Additional Open Space:
The proposed project is requesting a concession for a reduction in the required Common Open Space and Additional Open Space. This adjustment is necessary to accommodate the additional density and ensure the inclusion of affordable housing units within the project.
Reducing the required common open space allows for the more efficient use of the available land and contributes to the overall financial feasibility of the project.
This requested Setback concession will not require a general plan amendment or zoning change. The request is compatible with the surrounding neighborhood context, which includes a mix of residential and commercial developments of varying scales. Additionally, the requested setback adjustment is consistent with the goals of the Density Bonus Law to incentivize the development of affordable housing and meet community housing needs.
California Government Code Chapter 4.3. allows for adjustments to development standards for eligible developments. Granting this concession will not require a general plan amendment, or zoning change. Additionally, the reduction will not compromise the health, safety, or welfare of the community, and it will not be contrary to state or federal law.
PART C: WAIVERS SUMMARY AND FINDINGS
• REQUESTED WAIVERS:
1. Unit Size
Requested: Minimum 500 square feet
Required: Minimum 600 square feet
2. Lot Coverage
Requested: Maximum 53.45%
Required: Maximum 50%
3. Interior Setback (East)
Requested: Minimum 5’-6’ – Average 9’-9”
Required: Minimum 8’-0” and 11-0” – Average 11’-0” and 14’-0”
4. Interior Setback (West)
Requested: Minimum 7’-9’
Required: Minimum 8’-0” and 11’-0”
5. Permanent Landscaped Open Space
Requested: 8.4% of lot area (1,780 square feet)
Required: Minimum 25% of lot area (4,275.2 square feet)
8 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
• REQUIRED / MANDATED FINDINGS
Pursuant to GMC Section 30.36.080(B), the Director of Community Development shall grant the request for waivers or reductions in development standards pursuant to this section only if he or she makes all of the following written findings:
1. Describe how the application of said development standard(s) will have the effect of physically precluding the construction of the housing development at the density and with the incentives or concessions granted pursuant to this chapter:
This finding can be made for each requested waiver as follows:
Reduction in Minimum Unit Size: To make the project physically feasible, the applicant seeks waiver from requirements of GMC §30.11.050 A to reduce the minimum six hundred (600) square feet unit area to five hundred (500) square feet. The project is designed to optimize density to provide nine (9) units affordable to very low-income and moderate-income households and provide for a balanced unit mix to serve a variety of income levels. The requested waiver from the minimum 600 square feet unit size is needed to allow for the construction of the additional density and affordable units as well as balancing unit mix physically possible to build. The waiver will allow relief to provide affordable units and the more balanced unit mix that will meet the design of the proposed development project. The requirements of GMC §30.11.050 A would physically preclude the construction of housing with the eight (9) affordable units and balanced unit mix at the density and with the incentives or concessions.
Increase in Lot Coverage: As proposed, the project applicant is requesting to increase lot coverage to fifty-three-point forty five (53.45) percent. Pursuant to GMC §30.11.030 Table
30.11-B, the maximum allowed lor coverage for properties located in R-1250 zone is fifty (50) percent of the lot size. The project is designed to optimize density to provide nine (9) units affordable to very low-income and moderate-income households and provide for a balanced unit mix to serve a variety of income levels. The requested waiver from the maximum 50% lot coverage is needed to allow for the construction of the additional density and affordable units as well as balancing unit mix physically possible to build. The waiver will allow relief to provide affordable units and the more balanced unit mix that will meet the design of the proposed development project. The requirements of GMC §30.11.030 Table 30.11-B would physically preclude the construction of housing with the nine (9) affordable units and balanced unit mix at the density and with the incentives or concessions.
Reduction in interior setback on East and West side: To ensure the project is physically feasible, the project applicant is requesting a waiver from the interior requirements outlined in GMC §30.11.030 Table 30.11-B. This waiver is necessary to avoid physical constraints that
9 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
could hinder the successful implementation of the development. The project is designed to optimize density to provide nine (9) units affordable to very low-income and moderate- income households and provide for a balanced unit mix to serve a variety of income levels.
The requested waiver from the minimum and average interior setback requirements is needed to allow for the construction of the additional density and affordable units. The overall project massing complies with the allowable zoning standards and massing, except for a few instances where the building mass extends slightly beyond the prescribed setback limits.
These instances are minimal and are a result of design considerations aimed at enhancing the functional layout of the building and optimizing the use of available space.
Without the requested waivers, the project density would be reduced, the number of affordable units reduced, and the balanced unit mix would be affected which will make it physically impossible to build the project at the allowable density with the desired unit mix and number of affordable units and with incentives or concessions.
Reduction in required permanent landscaped open space: Providing the minimum required permanent landscaped open space will effectively preclude the construction of the housing development at the proposed density. By providing the mandated landscaped open space, the available land area for construction will be significantly diminished. This constraint could prevent the project from achieving the planned number of housing units, as the development may not have sufficient space to accommodate the density initially proposed.
2. Describe how the waiver or reduction in development standards will not have a specific, adverse impact, as defined in paragraph (2) of subdivision (d) of California Government Code Section 65589.5, upon health, safety, or the physical environment, and for which there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact:
These findings can be met. The project is exempt from the California Environmental Quality Act and no significant environmental impacts have been identified. The project is designed to comply with the various sections of the Glendale Municipal Code as administered by different City Departments (e.g. Fire, Glendale Water & Power, Public Works, Building & Safety, etc.).
Aside from the three incentive / concession requests and waivers, the project otherwise fully complies with the Zoning Code (GMC Title 30). Further, the provision of additional housing and affordable housing benefits the public health and safety and is consistent with the General Plan Housing Element goals of providing a wide range of housing types, including affordable housing. The proposed waiver requests meet the design guidelines that are compatible and appropriate to the adjacent buildings and site context.
In terms of the requested decrease in minimum unit size, sixteen (16) out of forty three (43) units range between 502.6 sf to 591.6 sf. The design ensures that each unit remains functional and livable without leading to overcrowding or excessive density that would negatively affect the physical environment or the quality of life for residents. The reduction in minimum unit size does not compromise the health or safety of future residents or the surrounding community. The project will still meet all applicable building code requirements, including
10 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
those related to ventilation, fire safety, electrical systems, plumbing, and structural integrity.
These regulations ensure that the reduced unit size does not lead to unsafe living conditions or create unhealthy environments.
The project’s impact in terms of increased lot coverage is mitigated by certain factors: The building uses several design techniques that reduce the apparent massing and scale of the building, including a variation in building form and façade, and a variety of exterior finish materials that help break up the apparent building size.
Regarding the two waivers requested for the reduced interior setback on East and West side, overall project massing complies with the allowable zoning standards and massing, except for few instances where the building mass extends slightly beyond the prescribed setback limits.
These instances are minimal and are a result of design considerations aimed at enhancing the functional layout of the building and optimizing the use of available space.
The reduced interior setback does not negatively affect the surrounding community or the environment. The project will maintain necessary separation and ventilation standards, ensuring that any adjustments to setbacks are in line with the overall safety and livability standards required by law. The waiver or reduction in the required interior setback will not have a specific, adverse impact on health, safety, or the physical environment, as outlined in California Government Code Section 65589.5. The project will still comply with all relevant safety regulations, including fire safety and building codes. The reduction is necessary for the financial viability of affordable housing development and does not result in significant harm or negative effects that cannot be mitigated. As such, the concession does not conflict with the goals of providing safe, sustainable, and affordable housing while preserving the welfare of the surrounding community and environment.
The waiver or reduction in the required permanent landscaped open space will not have a specific, adverse impact, as defined in paragraph (2) of subdivision (d) of California Government Code Section 65589.5, upon health, safety, or the physical environment. The proposed reduction in landscaped open space does not compromise public health or safety.
The project will continue to meet all applicable building and safety codes, including those related to fire safety, emergency access, and infrastructure (such as stormwater management). The reduced landscaping will not interfere with critical safety features, such as firebreaks, emergency vehicle access routes, or adequate spacing between structures.
Additionally, the reduced landscaped area will not result in a significant adverse effect on the physical environment. The project has been designed to include other environmental mitigations, which offset potential environmental impacts.
Given the overall design of the project, the reduction in the required permanent landscaped open space does not lead to a specific, adverse impact on health, safety, or the physical environment, and there are no additional measures that could be taken to mitigate such impacts, as they do not exist in this case.
11 408 S. Pasadena Ave.
Suite 6
Pasadena, CA 91105
TEL: (626) 381-9677
3. Describe how the waiver or reduction in development standards will not have an adverse impact on any real property that is listed in the California Register of Historical Resources:
This finding can be met. The property does not meet any of the eligibility criteria for listing in the national, California, or Glendale Registers, and therefore, is not considered a historic resource under CEQA.
4. Describe how the waiver or reduction in development standards will not be contrary to state or federal law.
This finding can be met. The waivers or reduction in development standards will not be contrary to state or federal law and do not require any other discretionary entitlement. The project complies with State Density Bonus Law, the California Environmental Quality Act (CEQA), and the City’s Density Bonus Ordinance, and is designed to comply with the various sections of the Glendale Municipal Code as administered by City Departments (e.g. Fire, Glendale Water & Power, Public Works, Building & Safety, etc.). No other known federal or state laws would conflict with granting the waiver/reduction.