McMillan, Acquanette (Netta)
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julianna
Monday, March 27, 2023 9:30 AM
PublicComment-AutoResponse
'julianna'; 'David Delgado'; 'Garth Garrett'; Amy Deavoll; Tina Miller'; 'martin ratliff; Annette Yasin
RE: AGENDA ITEM #15 - QUASI-JUDICIAL ACTION - OPPOSITION TO CROWN CITY
BILLIARDS & LOUNGE
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RE: Agenda Item #15. QUASI-JUDICIAL ACTION: APPEAL OF THE BOARD OF ZONING APPEALS' DECISION OF ZONING ADMINISTRATOR'S DETERMINATION NO. 56, 1312 NORTH LAKE AVENUE - CROWN CITY BILLIARDS & LOUNGE, AKA JERRY'S FAMILY BILLIARDS (Planning Dept.)
Honorable Mayor and Members of the City Council,
I am writing as a Mentor Avenue resident and property owner for over twenty years and Past President of the Bungalow Heaven Neighborhood Association to urge you to uphold the Board of Zoning Appeal's unanimous decision to support Zoning Administrator's determination No. 56 and rule that Crown City Billiard's & Lounge ("the pool hall"), a legal nonconforming 'grandfathered' use that sells alcohol (beer and wine), located at 1312 North Lake Avenue and within 150 feet of a residential zoning district shall only be permitted to operate from 7am to 10pm, per Zoning Code Section
17.40.070 (Limited Hours of Operation). For many years, late-night pool hall patronage until at least lam coupled with the use of the Blocks parking lot to the rear for the convenience of patrons has severely negatively impacted the health, safety, and welfare of residents.
The applicant argues that a zoning restriction on the nonconforming pool hall's hours of operation, which had not been in effect at the time the business opened in the 1980's, is not applicable as the use has been continuous, and also constitutes a taking since it impacts negatively the business's financial success. On the contrary, the legal nonconforming use as a vested right did not deprive the owner the use of his property upon adoption of changes to the zoning ordinance but instead eliminated all competition as it allows him to reap the benefits of a windfall arising from his existing location and the prohibition against similar types of businesses coming into the district. At the same time, the use is not exempt from further reasonable regulations. All zoning is restrictive and the City's legitimate exercise of its police power to protect the health, safety, and welfare of the community, which the US Supreme Court first upheld in the landmark 1926 case, Euclid v.
Ambler. The courts have subsequently held that a use that becomes nonconforming as a result of changes in zoning regulations is still subject to reasonable regulations under a city's police power to protect the public health, safety, and welfare that are enacted subsequent to the use being established [Rhod-A-Zalea v. Snohomish County, 1998). Pasadena's limitation on hours of operation to 10pm for businesses located within 150 feet of a residential zone, which was adopted after the pool hall first opened—as have similarly the City's probation on public indoor smoking or reduction in proliferation of liquor licenses-is both reasonable and non-discriminatory in that it applies to all commercial uses in the same zoning district regardless of original opening date.
Additionally, the use of Block 5, a cooperative lot to meet parking requirements for businesses along Lake Avenue and Washington Street, has become an attractive nuisance. The lot might also be considered 'legally nonconforming.' A parking lot at that location would not now be permitted in our residentially-zoned National Register historic district and demolishing the contributing historic homes to create the lot would also be prohibited. All businesses that have enjoyed Block 5 for parking have closed well before 10pm, except for the pool hall. When late-night pool hall patrons exit into the rear alley to the lot, after a rousing game and good time, they tend to be loud and/or inebriated and may linger together for some time, which disturbs the enjoyment of a good night's sleep for residents. Additionally, since it is rarely policed, the lot has become an attractive nuisance, a place for more dangerous, non-pool hall-related individuals for late-night 'partying/ drug use and dealing, or other illegal activities, often accompanied by the presence of firearms. Only when pool hall 1Item 15
operations were limited to 10pm and the lot became relatively empty and less attractive did residents begin to feel safe and enjoy some relief from the noise and trash.
Moreover, to operate the pool hall past 10pm, the applicant has the right and shall apply for a Conditional Use Permit (CUP). A CUP requires a public hearing before the Zoning Administrator and allows neighboring residents who are impacted by a use to participate in the decision. Some conditions for operating the pool hall after 10pm might include the following to curtail nuisances:
Signs shall be erected in Block 5 reminding patrons to be quiet and respectful of neighbors.
No parking shall be allowed in Block 5 after 10pm and the lot shut by physical barriers. Any vehicles remaining shall be citied and/or towed. Patrons may park along Lake Avenue without restrictions.
After 10pm, ingress and egress shall be from the front entrance on Lake Avenue only.
After 10pm, exiting from the rear of the business shall not be permitted for any reason except a bona fide emergency.
No unaccompanied minors shall be allowed on the premises at any time; no minors shall be allowed on any day after 10pm.
•
In the interest of residents, please rule to restrict the pool hall's hours of operations from 7am to 10pm per Zoning Code Section 17.40.070 (Limited Hours of Operation) and recommend the appellant apply for a CUP if changes in hours are desired.
Thank you for your concern and consideration.
Sincerely,
Julianna Delgado
Mentor Avenue Resident
Past President, Bungalow Heaven Neighborhood Association Julianna Delgado, M.Arch, Ph.D, FAICP
President, Southern California Planning Congress
Planning Commissioner, City of Pasadena
Design Commissioner, City of Pasadena
Member, Mayor's Housing Task Force, City of Pasadena
Professor Emerita, Department of Urban and Regional Planning Co-Director, California Center for Land and Water Stewardship California State Polytechnic University, Pomona
After enlightenment, do the laundry.
- Zen proverb
2 McMillan, Acquanette (Netta)
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Carol Polanskey
Monday, March 27, 2023 11:29 AM
PublicComment-AutoResponse
Regarding the March 27 Council Meeting agenda item 15 - Crown City Billiards Some people who received this message don't often get email from •^earn why this is important CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. Learn more....
Dear City Council,
Regarding the March 27 Council Meeting agenda item 15:
15. QUASI-JUDICIAL ACTION: APPEAL OF THE BOARD OF ZONING APPEALS' DECISION OF ZONING ADMINISTRATOR'S DETERMINATION NO. 56,1312NORTH LAKE AVENUE - CROWN CITY BILLIARDS & LOUNGE, AKA JERRY'S FAMILY BILLIARDS (Planning Dept.)
Recommendation: It is recommended that the City Council:
(1) Uphold the Board of Zoning Appeals' decision and uphold the Zoning Administrator's Determination that the hours of operation for the business are between 7:00 am to 10:00 pm, pursuant to Zoning Code Section 17.40.070 (Limited Hours of Operation).
I'm writing to voice my support for upholding the Zoning decision that Crown City Billiards' hours of operation are between 7am and 10pm.
I will not be able to attend the meeting in person, so I'm writing to make the following points:
I have been a member of the bungalow heaven community for about 30 years, during which time my neighbors have reported continual late-night public-nuisance problems in the Block 5 parking lot, including the last few years when Crown City Billiards was the only business open past 10pm. Things have recently been much quieter when Crown City was complying with a 10pm closing time.
Crown City seems to claim that they have a Conditional Use permit, but no such permit exists. (See below for excerpt from Board of Zoning Appeals report.)
There is no reason why that particular commercial property has to remain a billiards hall for all time; however, there is a reason why there is a zoning law that limits hours of operation to 10pm when in close proximity to a residential area - it maintains a reasonable level of quality-of-life for the residents. That, and the basic facts of the case, are why the Zoning Board decision must be upheld.
Martin Ratliff
Pasadena
Excerpt from Board of Zoning Appeals report:
However, as it relates to the hours of operation, the applicant has not provided documentation that the City approved hours of operation between 10:00 pm and 7:00 am.
Further, any ability to operate with nonconforming hours was abandoned when the appellant submitted the Code Compliance Certificate form and indicated that the business would operate from 9:00 am to 10:00 pm. The 2017 form was relied on by City staff to support the issuance of the Code Compliance Certificate. The approved hours of 1 3/27/2023
Item 15
operation are consistent with Zoning Code Section 17.40.070; where a business may only operate between the hours of 7:00 am and 10:00 pm by-right when the site is within 150 feet of a residential zoning district.
A Conditional Use Permit would need to be approved to operate between the hours of 10:00 pm and 7:00 am. As of the date of this report, a Conditional Use Permit application has not been submitted.
2 Jackson Tidus
A LAW CORPORA?(ON
RECEIVED
2023 HAR 27 PH 3: 24
.^iTY Ci£i^<
CITY OF PASADENA
March 27,2023
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Mayor and City Council
City of Pasadena ("Cfty")
IWNorthGarfiddAve.
Pasadena.CA 91101
c/o Mark Jomsky. City Clerk
RE: March 2 7. 2ft23 City Council Asenda Item Mf5
APPEAL OF TflE BOARD OF ZOM\'G An'EALS'DECISION OF
ZO^l\(..4fWlMSTRArORISDE/f:RM/^ TfOV .Va 56.
1312 ,\OR TH L4 KK 417: VtT - CRO H ;V Cl fY BtLUARDS&
LOiWC.E. ^KA JERRY'S FA.WU BIU.IARD^ (Pltinnins I>ept)
Honorable Mayor and City Council:
This firm represents Crown City Billiards in the above-refcrenccd appeal. Were this letter addressed to tlw Superior Court, it would simply begin—and end—with this 0{xning paragraph. The City staff expressly concedes that the operation of Crown Billiards as a billianls halt wth unrestricted hours of operation is a vested legal nonconforming use:
Tfi^^kMSfttesy.^s a nonconformine use. Records indicate that the billiards use has been in operation since January 1985, At the time it was establislted. thg Mlli(frtl\ wvp wa'i allowrd aitd there were HO restrktiifffSftnhffHrs of operation applicable to its zoning district (C-2). (March 27, 2023 Staff Report, p. 3 [emplmsis added])
The City staff docs not make or support a claim oftcrmination of the vested legal nonconforming use, either by violation of applicable law. discontinuance of the noiKonforming use, or abatement by operation of law. as would be required by the City's Zoning Code. (Zoning Code, §17.71.060)
Irvine Office
2030 Warn Street. t2th flow
Irotne, Catlfomia 92614
1949.752.8585 »949.752.0597
Wcttlake VWa&e Office
2815 Town»6a(e Rotrf. Sinte 200
WwtlaM Village, Catlfornte 91361
tWS 230 0023 f 805 230 0087
www^acksontidus.lffw
3/27/2023
Item 15
Mayor and City Council
City of Pasadena
RE: Crown Cit> Billurds—Agnnda Item IS
March 27. 2 23
The remainder of this letter is designed to educate the City leaders about legal nonconfonning use, a fundamental vested right, because City staff has absolutely refused to do so, much to the potential detriment of the C'ity's law-abiding taxpaying residents. City siaK has utterly abdicated its duty to even mention the City's Zoning Code regarding r^uiremenls for termination of legal nonconforming iise in its staff report preferring instead to subject the City to liability for the taking of frown Billiards' valuable property right to remain in operation undor its vested legal nonconfonning use.
LEfiALNONCONFORMINd USE AVOtDS TAKINGS L1AB1UTY
Let's start wilh the basics. Local governments have constitutional police powers; "A county or city may make and enforce within its limits all local, police, sanitary, and other ordinaunces and regulations not in conflict with general law." (Cal. Constitution. Art XI. See. 7) But those constitutional police piwws cannot be exercised to take private property without just compensation: "Private property may be taken or damaged for a public use and only when jiet compensation, ascertained by a jury unless waived, has first been paid to. OT into court for, the ovmer." (Cal. Constitution, Art. Xi, Sec. 19)
Legal nonconforming uses first came into existence with the advent of American zoning regulation in the eariy twentieth centur>. Eariy municipal planners were concemetl that if landt^Wriwrs were made to disconlinue existing uses in order to comply with newly cnact^l zoning regulations, the regulations would be subject to challenge as an unconstitutional taking of private property, Rather than resolving the issue at the time. and possibly teing the loss of the planned zoning concept entirely, they decided that valid existing uses would be allowed to continue as exwptions carved out of an overall plan. (44 AMJUR POP 3d $31. § 1; see Zoning Code. §17.71.040.)
Under common law, a legal nonconforming use is a lawful use of propeny. prior (o adoption of a zoning ordinance or a subsequent amendment w revision thereof, which the ordinarwe thereafter prohibits, but which is allowed to contini^ afla' enactment of the zoning onlinaiwe (Goat Hill Tavern v. City of Cmlti Mew (1992) 6 Cal.App.4th 1519, 1522) "Oenerally, govcmniental entities do not apply newly enacted zoning ordinance to close business lawfully o^rating at the time those ordinances become etTective," {Bawr v Ciiy of San Diego (1999) 75 Cal.App.4th 1281. 1292)
The City's Zoning C'ode accordingly dettiws legally nonconforming land uses as uses ''ttiat were lawful before (he adoption or amendinent of this Zoning Code, but which would be prohibited, regulated or restricted differently under the current tenns of the Zoning Code or under future amendments." (Zoning Code. § 17.17.010(A)). The City stafl'*s report is nMably completely bereft of any mention of this section or its definition. 1'he City's Zoning Code expressly allows a legal nonconforming use to continue wthout intcrruprion by suteequently enacted /.oning Code or future amendments: "A nonconfonning use Mayor aixl City Coum;il
City of Pasadena
RE: Crown City Billiards—Agenda Item IS
March 27,2023
may be maintained and continued; provided there is no increase or enlargement of the area. space, or volume occupied or devoted to die nonconfonning use. except as allowed by this Chapter." (Zoning Code. § 17.71.030(A)(1)). Again. "Each and even nonconforming use or structure may be continued aiid maintained, provided that there is no addition, altcratioii, or enlargement to any use or structure, except as allowed by (his Chapter, or unless ordered discontinued, modiftcd, or removed as a public nuisaiwe in compliartcc with Municipal Code Chapter 14.50 (Property Maintenance and Nuisance Al^tcmcnt)." (Zoning Code, § 17.71.040) The right to continued nonconfomiiug u<» attached to the property as a ieffA nonconforming use is not purely ait economic privilege, but is. instead, a fundamental vested right ty avoid an iux;onstiiutional taking of private property, ((kiat Ml! Tavern v. City of Costa h-fesa. supr^ 6 Cal.App.4lh at 1529-1531)
California courts have long held that when land has been put to a lawfiil use prior to tiw enwtmcnt of a zoning ordinance. Ihcre may be a vested right to continue that use. even though it is inconsistent with (he ordinance. (Etimont/s v. County of Los Angeles (1953) 40 Ca(.2<l 642, 651; demons v. City' of Los An^te.t (1950) 36 Cal.2<l 95, 104.) The "vested rights" doctrine, insofar as it coiwems such nonconforming uses, rests primarily un the constitutkinal tar against Hikings. (Jones v. City of IMS An^elesi (1930) 2 11 Cal. 304.3 10-321.) As a fundamental vested right, legal nonconfonning use is entitled to itutependent review by the Superior Court, meaning the Superior Court will give no dctcrcncc to the Cityts determination as to aiylication of legal nonconforming use in this instance. (Goal Hill Tavern v.
Cily ttfCosia Me.ta. supra, 6 Cat.App.4lh at 1529-153 1) LEUAL NONCONroRMING USE CONTINUES REGARDLESS OF FUTURE ZONING CODE OR AMENDMENTS. INCLUDING ORDINANCH A592 AND ITS REQUIREMENT
FOR A CONDITIONAL USE PERMIT
Despite and in express contradiction to the aht>ve detlnitions and principles. City staff argues that subsequent Ordinaiwe 6592, which aj^ties new hours to existing businesses, somehow takes away the vested legal noncontbrming hours of operation use of the property and requires a conditional iisc permit for hours of use.
City staff cannot be more wwng. City staffs argument misreads the <tefimtion of legat noiiconforming use contained in the City's Zoning Code, fails to acknowledge the express langiiage of the City's Zoning Code exempting the property from the Ordinaiwe 6592 conditional use requirement, ami fails to ^knowledge the common law iweoedent of the Goal Hil! Tavern case.
As set forth above, legal nonconforming use is detincd as uses "that were lawful before tlt>e adoption or amendment of this Zoning Code. but which would be prohibitaj. regulated or restricted diflcrcnlly under the current terms of the Zoning Code or under future amendmt?rit$."1 (Zoning Code, § 17.1?.010(A) (underline addedj). Ordinance 6592 is iu&l such a future amendment which do^s not take awav the lcyal nonconformine hours of operation use.
Mayor and C'it) C<xincil
City of Pasadena
RE: Crown City Billiards-
March 27,2023
Pa^4
Agenda Item 15
Fuarttwmiore, City stafl" fails to read the express provisions of its Zoning Code which expressly addresses the particular situation of Ordinance 6592. which added a requirement of a conditional use permit for an hours of operation use that was previous.ly permitted without a conditional use pcnnit (in this instance hours of operation beyond 10 p.m.):
Notwithstanding the other pnnisions of this Chapter, ng use identified in this Zonjng Code as a "Condittonat LMe"All^ffi Ifiwiyiy in existence as oftlie etTectjve date of thesw rei*ulations, shall be deemed no|iwnlormine solely by reason ot'thejagElisaliog of the Conditional Use Perniit prwcdural requircmcnte, in compliance with Section 17.61.050; provided, (hat:
A. Use allowed with Conditional Use Permit approval. A
land use that was legally established wttluiut a Conditional Use Permit but would be required by currCTt Zoning Code provisions to have Conditional Use Pennit approval, shall not be altend or enlarged in any way unless a Conditional Use Permit is first obtained. (Zoning Code. § 17.71.1(N). in pertinent pan [underline added])
Thus, under tlw express language of the City's Zoning Code. the addition of the conditional use permit r^virement by Ch-dinaiwe 6592 did not make the property hours of operation use unlawful and did not require a conditional use permit, unless the use is to be expanded (there is no expansion involvwl in this situation).
Finally. City stafl' fails to take into account the common law precedent u|rfiolding a prwxisting legal nonconforming use pertaining to hours of operation atler sutMequCTt requirement for a conditional use pemiil under (lie (jwil WU Tavern case. 1'he background facts in the Goaf Hilt Tavern case we remarkably similar to this situation. The property o^tiwrhad a pre-existing legal nonconfonning use. Neighboring propeny owners, attributing incidents regarding liomelessness in a city forking lot adjacent to the business, arc asking the City to apply limitations on hours ot* operation basal on city zoning requirements en^ted after the business initiated legal operation. There was no evidence that the property operation constituted a nuisance. The Court of Appeal in Goat flill Tavern hdd that the Tavern had a .vested fundamental rieht to continue its hours of operaiJQn arul thai the City could not shut down tte operation of the business. (Goal Hill Tavern v. City of Costa Mesa. supra, 6 Cal.App.4lh at 1522-1525 & 1529-1531 funlikc this situation, the Goat liill Tavern had also obtained a conditional ILSC permit to expand the business fffcmiscs, but in other respects, this situation is similar])
Similar to die Gfwl Hill Tuvcrn case, in this silualion, neighborhood residential omiers, firustrated wth the t'ity's operation of the City's adjacent parking lot and homeless people using die lot, have conveniently pointed the finger of blame at adjoining propert)' owner Crown Billiards (with the City staff willingly joining in rather than taking responsibility for operation of Mayor and City Council
City of Pasadena
RE: Crown City Bittiards—Agenda Item 15
March 27, 2023
PageS
the City tot). Crown Billiards operates a legitimate competition pool hall frequented by white collar workers, with no parking lot spillover or noise or fighting problems. The adjoining residents made a substantial number of police calls in die vear hcfore the subiecl citation seeking to shut down Crovvn Billianls, non£j)fthem attributable tQiJhi; operation of Cn>wnJE[HI[ards (in fact, in the year after the cilalion. the neight»rs stopped making so many firjvolous police cads and the call volume substantially decreased). But increased volume of resident police calls designed to shut down or change the hours of a legal nonconforming legitimate business could not shut down Goat Hill Tavern and should not be allowed to shut down an even more quid and proper and beneficial City business Stx:h as Crown Billiards in this instance.
LEGAL NONCONFORMING USE CONTIHU£S
REGARDLESS OF TIIE DISPUTED CODE COMPLIANCE CERTIFICATK The City's Zoning Code provides express situations in which a vest«j legal noncoaforming use may be terminated. (7x>ning Code. § 17.71.060). As addressed above, given that the vested legal nonconfonning hours of operation use cannot be in violation of law. the City has failed to establish termination by operation ot* law under Zoning Code Section
17.71.060(A)(t), Neither does the City contend that it has passed an abatement ordinance to abate the vested legal nortcontbrming use under Zoning Code Section 17.71.060(C).
The City's only otter argument for temiinadon is based upon an apparently falsified Code Compliance Certificate applicatioii, apparently claiming that the application manifested an diandonment of the vested legal noncontbrming use hours of operation under Zoning Code Section 17.71.060(8).
That apparent argument fails becaiuse the mere ex^ession of an intention to abandmi the vested legal nonconforming hours of operation use is not sufiRcient under the City's 7<oning Code to trigger abandonnwnt of a vested IcgaJ nonconfomiing use. More is required. The nonconforming use must be actually "discontinued for any reason for a continuous period of at least 12 months" and (here must be evidence presented by the City staff of such discontinuance. including "the actual remo\ral of equipment, furniture, machinery, structures, or other components of the nonconfonning use and not replaced, the turning off of tlw previously eonncctal utilities, or [the lack of any] business r«;eipt&/records or any necessai^' licenses available to provide evidence that the use is in continual o^ration." (7x>ning Code. §
17.71.060(B)(3)). I-'urthermore. there was no determination of abandonment by the Zoning Administrator that would support City statTs argument, given that the Certificate document mysteriously and suddenly appeared only after the 7oning Administrator's decision. (Id.) City staff is apparently relying on some type of estoppel argument in connection with the disputed Code Compliance Certificate application. However, in order to establish estoppel, the City would have to present evidence that it reasonably relied upon the Certiticate as sufficient for abandonment. (Lents v. McMahm ( 1989) 49 CalJd 393. 399) The City could not have legally reasonably relied upon the Certittcate for abandonment becau^ the City's Zoning Code requires more: actual cessation of use of the vested legal nonconforming hours of operation me. (/^ning Mayor and City Council
City of Pasadena
Rfc; Crown City Billwnls—Agenda Item 15
March 2 7. 2023
Code. § 17.7I.060(BX3)>. Funhcrmore, as the City concedes, Crovm City (iilliards has not ceased operation of its vested legal conforming hours ofoperatitMi use at any dmc foltowiiig the Certificate application, thus providing no factual basis for the City to reasonably rely upon (he Ceruftcatc application.
Assuming, arguendo. that the suspect Certiricate could be relied upon to establish abandonment, which it cannot the City's argument that the C'eniflcate csn be relied upon as an official writing despite express direct evidence that the hours portion was not tilled out by the authorized representative of Crown City Billiards is inconwt. ITw presumption for official writings is simply a presumption aiTccting the burden of evidence. (Evidence Code. §1450).
That presumption has been completely overecxne by the Declaration of Frank Yanez and by the expert opinion of Michael N. Wakshu]) ofQ9 Consuldng, both providing direct evidence thai the same person did not till out the hours part of the form. with the added handwriting of a different person for tlw portion providing the listed hours of operation.
It does not take a handwriting expert to see that letters like "P" and numbers like "8", and imleed the entire handwTiting style. are handwTitten completely ditYcrcnt on the top portion of the Required Infonnation and the hours p«iriion of the Required Infonnation. It docs not take a handwTiting expert to note tlw strange circumstances of the Certificate's sudden presentation by City staff after the Zoning Administrator decision and to note that the box for "Denied" was crossed out aiid diat the box for "Approved" was checked instead, and that ttie prior stafT signature (at^arently for the "Denied" box) was vvhited out and replaced with a new signature.
Stated simply, the circumstances of the Certificate's appearance and the alterations to the Certificate just plain stink and make the Certificate application and asscned approval unreliable as evidence of anything.
In conclusion, none of City staffs, arguments support upholding the Zoning Administrators and Board of Zoning Appeals decisions. In fact, everything presented supports granting this appeal and confirming the property's vested legal nuncontbrming uses of a billiards hall mthoui litnitation on hours of operation.
Why would the City Council follow the City staflTs advice and subject the City to liability for taking a vcstCTl legal minwnfonning property interest when there is absolutely no evidence of any nuisatice caus<Ml by the Crown Billiards use, when the use is contributing significantly to use of local City restaurants, hotels ami other commercial uses, when the use and its occupation of a portion of the adjoining City lot is actually helping to keep away homeless who would cause problems, and when its continued operation is allomng the two special needs Yanez children the material sup$»n they desperately need? This whole sham citation simply doesn't make sense from a legal, factiuil. policy or any other standpoint (unless appeasing a few complaining neighbors is considered sound policy- making). Please do the right thing, grant the appeal, dismi&s the citation, and find that the property has a present vested lega! twnconforming use for a billiards hall without limitation on hours of operation as PCT the City's Zoning Code. Crown City Billiards intends to continue to Mayor and City Council
City of P&sadcna
RE: Crown City Billiards Agenda Item 15
March 27. 2023
Page?
operate its business responsibly and to not allow any nuisance caused by its operation in tfw adjoining City parking lot, Thaiik you.
Very u
Jack^Sn Tidus
Cc: James Lawson
Frank Yanez
Michele Bagneris, City Attorney inba.eneris'a'cift-otoasffitea&nfl