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Agenda Report
November 17, 2025
TO: Honorable Mayor and City Council
FROM: Planning & Community Development Department
SUBJECT: APPEAL OF THE BOARD OF ZONING APPEALS' QUASI-JUDICIAL DECISION TO APPROVE MINOR CONDITIONAL USE PERMIT #7318
TO ESTABLISH A SAFE PARKING LAND USE AT AN EXISTING
RELIGIOUS FACILITY (ALL SAINTS CHURCH) AT 202 NORTH
EUCLID AVENUE
RECOMMENDATION:
It is recommended that the City Council:
1. Find that the action proposed herein is categorically exempt from environmental review pursuant to State CEQA Guidelines Section 15301 (Class 1, Existing Facilities), and there are no features that distinguish the project from others in the exempt classes, and therefore, there are no unusual circumstances; and
2. Adopt the findings in Attachment A to uphold the Board of Zoning Appeals' decision and approve Minor Conditional Use Permit #7318, with the conditions in Attachment B.
BACKGROUND:
Hearing Officer Public Hearing
On June 18, 2025, the Hearing Officer considered an application for Minor Conditional Use Permit (MCUP) #7318 for a Safe Parking use at an existing religious facility site.
The project proposal was for up to 25 unhoused individuals in a maximum of 25 vehicles. A full description of the proposal and analysis are contained within the Hearing Officer Staff Report (Attachment C). At the conclusion of the public hearing, and after public testimony, the Hearing Officer made the required findings in the affirmative and approved the MCUP (Attachment D).
On June 30, 2025, three requests were filed to appeal the Hearing Officer's decision to approve the MCUP to the Board of Zoning Appeals (BZA). The first request was filed by Silvia Nardoni of Archimedes Law Group, LLP on behalf of The Maryland Homeowners Association (Attachment E). The second request was filed by Park and Velayos, LLP, on behalf of ARE-Pasadena No. 5, LLC. (Attachment F). The third request was filed by Erica Tamblyn on behalf of the applicant, All Saints Church (Attachment G). A Hearing MFFTIMP.OF 11/17/2025AGENDA ITEM NO.17
Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17, 2025
Officer addendum was submitted which provided responses to each appeal (Attachment H). Two of the appeals cited various concerns related to the establishment of the use and the applicant filed an appeal based on opposition to a condition of approval that was added by the Hearing Officer related to restrooms for the proposed use.
BZA Public Hearing
On September 25, 2025, the BZA considered the appeal of the Hearing Officer's decision to approve the MCUP. Responses to the appeals are contained within the BZA staff report (Attachment I). At the conclusion of the public hearing, the BZA made a motion to uphold the Hearing Officer's decision by a vote of 5-0 and approved the MCUP (Attachment J). The BZA added or modified the following conditions of approval to address concerns and issues raised at the public hearing, all of which are included in staff's recommendation- please note that staff has proposed to modify some conditions as shown in Attachment B in underline/strike-out format:
Condition #12: Water, trash, and restroom facilities shall be provided, maintained, and accessible to clients during Safe Parking facility hours. The portable restroom facility shall be accessible to the Safe Parking program participants only (i.e., locked and equipped with a key code mechanism). The portable restroom sen/ing Safe Parking shall be separate from the restroom serving the Safe Haven temporary homeless shelter. The restrooms shall be located so that participants of both programs do not cross paths utilizing their designated restroom. Prior to operation of the Safe Parking land use, a site plan indicating the location of both restrooms shall be submitted for review and approved by the Zoning Administrator.
Condition #21: Recreational vehicles (e.g., motorhomes, travel trailers, camper vans, etc.) shall not be allowed to be used for the Safe Parking program.
Condition #22: Within six months of exercising the privileges granted by this application, the applicant shall file an application with the Planning Division for a Hearing Officer Review of this MCUP, to be considered at a duly-noticed public hearing. Public notice for the hearing shall be given in the same manner required for this MCUP, as well as to any parties who request to be so notified. The purpose of the public hearing is to ensure the effectiveness, and compliance with, all conditions of approval herein. These conditions may be modified or new conditions added to reduce any impacts of the use. The Hearing Officer may revoke the MCUP pursuant to the procedures in Zoning Code Section 17.78.090.
On October 6, 2025, two requests were filed to appeal the BZA's decision to the City Council. The first was filed by Silvia Nardoni of Archimedes Law Group, LLP on behalf of The Maryland Homeowners Association (Attachment K). The second was filed by Park and Vetayos, LLP, on behalf of ARE-Pasadena No. 5, LLC. (Attachment L). These are two of the same appellants from the BZA hearing. The applicant was satisfied with the restroom conditions required by the BZA and did not appeal a second time.
The hearing before the City Council is a de novo hearing where the Council can approve the project as recommended, approve the project with changes to the Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17, 2025
conditions of approval, or deny the project. This is a quasi-judicial action.
Site Characteristics
The All Saints Church site has an area of 2.8 acres and is located at the southeast corner of Walnut Street and Euclid Avenue on land zoned PS (Public and Semi-Public).
The site consists of three contiguous parcels under one single ownership. The northern two parcels are developed with a 109-space surface parking lot and the southern parcel is developed with religious facility buildings and a courtyard. The Zoning Code defines a site as "a lot or group of contiguous lots not divided by any alley, street, other hght-of- way or c/Yy //m/Y ^/7a? /s proposed for development in accord with the provisions of this Zoning Code and is in a single ownership or has multiple owners, all of whom join in an application for development."
Adjacent Uses
North - Kaiser Permanente Administrative Regional Offices South - Restaurant and Courtyards for The Plaza Las Fuentes East - Hotel, Office, and Restaurant
West - City Hall and Los Angeles County Courthouse
The closest residential uses are approximately 300 feet to the northwest (Euclid Square Apartments) and are separated from the Safe Parking use by East Walnut Street and other uses. Additional residential uses are located more than 500 feet to the south (Maryland Condominiums) and are separated by existing religious facility buildings and the courtyard for Plazas Las Fuentes.
Adjacent Zoning
North - CD-MU-G (Central District Specific Plan Mixed Use General subarea) South - CD-MU-G
East - PD-12 (Walnut - Los Rabies Planned Development)
West - PS
Previous Zoning Cases
Master Development Plan (approved in 2012): 15-year plan for expansion of All Saints Church that includes a new columbarium, and a multiple-story, four- building complex (approximately 50,300 square feet) consisting of offices, meeting rooms, recreational space, and dining areas.
Conditional Use Permit #6070 (approved in 2013): To modify the size and location of a building approved by the Master Development Plan.
Conditional Use Permit #6898 (approved in 2021): To allow a Temporary Homeless Shelter use (Safe Haven) at an existing Religious Facility (All Saints Church). The proposed homeless shelter would allow up to 12 participants to shelter overnight at the facility at any one time.
Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17, 2025
Safe Parking Use
In September 2023, the City Council adopted Ordinance No. 7414 to implement General Plan Housing Element Program #19: Homeless Services, which included adding a Safe Parking use as part of a Religious Facility, College, and Transportation Terminal with the approval of an MCUP. This program was included in the Housing Element to address the needs of individuals sheltering in their vehicles which are typically different from chronically homeless individuals living outdoors. By maintaining access to vehicular shelter, individuals participating in safe parking programs may maintain work and community ties not afforded to individuals living on the street.
Without safe parking, people living in their cars risk citations, towing, or impoundment fees that increase instability and threaten those ties.
The City's Zoning Code defines the Safe Parking use as "a parking program, operated on property outside of the public right-of-way and managed by a social service provider, that provides individuals and families with vehicles a safe place to park overnight and services to facilitate a transition to permanent housing." Applicable standards and operational requirements were added under Section 17.50.265 (Safe Parking) of the Zoning Code (Attachment M).
Safe Parking Application
On April 15, 2024, the City Council authorized the City Manager to enter into a funding contract with Shower of Hope in the amount of $305,000 to operate a Safe Parking use at All Saints Church contingent on obtaining an MCUP for the program. Shower of Hope is a non-profit organization that provides mobile shower services, hygiene items, other community resources and organizes safe parking programs to people experiencing homelessness and housing insecurity in Los Angeles County. The Housing Department is the responsible city department for overseeing the contract which requires the approval of an MCUP.
On March 5, 2025, the applicant submitted an MCUP application to establish a Safe Parking use at the site. The proposed program, named Destination Hope Pasadena, is a collaboration between All Saints Church and Shower of Hope and will provide services and a designated overnight parking area for unhoused individuals within an existing surface parking lot in the northern portion of the site. Shower of Hope will manage and operate intake, case management, and provide resources to participants as they seek employment and/or permanent housing.
The applicant has stated they intend to continue to operate the temporary homeless shelter that was approved under Conditional Use Permit #6898 in 2021 (Safe Haven) The shelter allows up to 12 participants to shelter overnight at the facility at any one time. This is a separate entitlement from the proposed Safe Parking MCUP, and it operates under adopted conditions of approval specific to that use. Any changes to that CUP will require a separate process through the Hearing Officer.
Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17, 2025
ANALYSIS:
City staff reviewed the proposed Safe Parking use for compliance with the Zoning Code and also incorporated conditions of approval to ensure proper site management and to reduce potential impacts on surrounding properties. The proposed conditions of approval are included as Attachment B. Staff has provided an underlined/strike-through version of the conditions to show what is recommended to change from the BZA hearing. There are a few conditions that staff is proposing be modified from what was approved by the BZA to provide clarity for implementation, differentiate the requirements from other on-site activities, and reaffirm the impermanence of the use through limiting the number and use of portable restroom facilities on-site.
Zoning Code Requirements
The Zoning Code requires the program operator to prepare a site plan and management plan (Attachment N). This should include the hours of operation, total number of vehicles and size of vehicles served on-site, the monitoring and oversight program, and the neighborhood communications strategy plan. Based on the submitted information, up to 25 participant vehicles would be allowed to park within the existing parking lot from 7:00 p.m. to 7:00 a.m. daily. No more than 25 people would be permitted overnight at any one time. As a condition of approval, a program representative shall be available during all hours of operation to respond to calls related to the operation. The program operator is also required to ensure that only vehicles registered in the program are parked overnight during program hours and have a parking pass displayed at all times.
Additionally, the Zoning Code requires performance standards for the Safe Parking use.
The safe parking use is required to be managed by a program operator that participates in the Pasadena Continuum of Care Program and Coordinated Entry System and provides access or linkage to the Coordinated Entry System.
The Zoning Code requires clients to enter a written agreement with the program operator to use the parking spaces overnight (Attachment 0). Per the agreement ("Destination Hope Safe Parking Rules and Guidelines"):
Only one vehicle allowed per individual or family. Vehicles may only be occupied by clients and household members; no guests allowed;
• No storage of items outside of vehicles. Designated areas to remain clean and tidy at all times;
No camping outside of vehicles;
No loud noises outside of vehicles, including audible music, alarms, phones and electronics. Quiet hours shall be from 10:00 p.m. to 6:00 a.m.; No alcohol or drugs on the premises; and
No cooking inside or outside of vehicles.
Additionally, participants will be assigned a Shower of Hope caseworker. As described by the applicant, participants would be evaluated for the program every six months.
Clients will be able to participate in the program if it is below capacity. If the program Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17, 2025
has a wait list, participants not actively participating in transitioning to a more permanent living situation will be removed from the program after a year of stay. Participants may also be removed if they violate the program agreement.
•
•
Conditions of Approval
In addition to the items noted in the management plan, performance standards and written agreement, a summary of the following conditions of approval have been added to address concerns regarding noise, safety and ongoing operations. :
Noise (Condition #7): Comply with the City's Nosie Ordinance, to ensure interior noise levels at nearby residential uses are not negatively impacted.
Response to Complaints (Condition #11): Require a program representative be available during all hours of operation to respond to calls.
Maintenance (Condition #17): Remove litter and debris from the property and surrounding sidewalk and street on a daily basis. Any graffiti shall be removed within 48 hours.
Lighting (Condition #18): Comply with the City's Outdoor Lighting Ordinance to avoid glare and reflection onto adjoining properties and the public-rights-of-way.
Permitted Vehicles (Condition #21): Prohibit recreation vehicles (RVs).
Operations (Condition #22): Within six months of operations, submit an application for the MCUP to be reviewed by the Hearing Officer at a public hearing. The Hearing Officer may revise the conditions or revoke the MCUP.
Security (Condition #23): Provide one private security guard, dedicated to the Safe Parking use, to ensure the site is monitored throughout the night and vehicles have valid parking passes.
During the program hours, participants must have access to a restroom and handwashing station. The location of the restroom is an area where the staff recommendation differs from the BZA decision. As approved by the BZA and included as a condition of approval, the restroom facility can be portable and located within the parking lot. It shall be accessible to the Safe Parking program participants only (i.e., locked and equipped with a key code mechanism). There is currently a portable restroom located in the same parking area as the proposed use and this is used by participants of the Safe Haven temporary overnight shelter. The BZA conditions allow a second portable restroom to be added to the site but occupants must not have access to each other's restrooms so the existing portable restroom would have to be located elsewhere in the parking lot.
Staffs recommended condition at the BZA hearing was to allow only one portable restroom at the site and the applicant would have to utilize other existing restroom facilities within the church to accommodate the Safe Haven temporary shelter. Staff does not support a second portable restroom in the parking lot or in a location that is visible from the public right of way. If a second portable restroom is used in lieu of using church restrooms, it would have to be located where it is not visible from the public right of way. Safe Parking is intended to be a program where users come in and vacate the Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17, 2025
site daily returning it to its previous condition, the addition of a second portable restroom in the parking lot conflicts with the limited operation of the use.
The full conditions of approval can be found in Attachment B and as noted the conditions are presented in a strikethrough format to denote what staff is proposing to change from the BZA conditions.
REQUEST FOR APPEAL:
As previously noted, two requests were filed to appeal the BZA's decision. The first was filed by Silvio Nardoni of Archimedes Law Group, LLP on behalf of The Maryland Homeowners Association (Appellant 1) (Attachment K). The second was filed by Park and Velayos, LLP, on behalf of ARE-Pasadena No. 5, LLC. (Appellant 2) (Attachment L).
APPEAL POINTS AND RESPONSES TO APPEALS:
First Appeal (Appellant D:
1. The Zoning Code does not allow Safe Parking on the proposed parking lot because it is not a religious facility site.
Staff's Response: The All Saints Church site consists of three contiguous parcels under single ownership. The northern two parcels are developed with surface parking and the southern parcel is developed with religious facility buildings and a courtyard. The Zoning Code defines site as "a lot or group of contiguous lots not divided by any alley, street, other right-of-way or city limit that is proposed for development in accord with the provisions of this Zoning Code and is in a single ownership or has multiple owners, all of whom join in an application for development."
The site is occupied by a religious facility. The Zoning Code defines a "Religious Facility" as a facility in which the primary use is religious worship. The use may include some related accessory activities by-right including religious education, ministry, clothing and food distribution, counseling, employment assistance, referral services, and support groups. The proposed Safe Parking use is permitted as a related accessory activity with an MCUP. Further, Safe Parking could only occur in a designated parking lot which further demonstrates that when the safe parking regulations were established it was recognized that the parking lot associated with the qualifying use was part of the site.
The Safe Parking use will be located on the parking lot, which has 109 parking spaces. Specifically, the Safe Parking use will occur on the northernmost portion of the lot, within 25 parking spaces. The religious facility uses the lot daily, including for weeknight events until 10:00 p.m. The lot also is used by the Los Angeles Courthouse on weekdays. They use the lot for court parking from 7:00 a.m. to 5:00 p.m. and this is not proposed to change.
2. The proposed Safe Parking use is not an exempt project under the California Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17, 2025
PageS of 12
Environmental Act (CEQA) as involving "negligible or no expansion" of existing use because the proposed Safe Parking operation is a change of use, and the intensity of activity will expand significantly, causing a negative environmental impact.
Staff's Response: CEQA requires the proposed project be compared to the existing conditions (i.e., the site as it exists when the application is submitted).
The existing conditions are considered the environmental baseline and are used to assess the environmental impacts of a project. In the case of All Saints Church, surface parking and services for people experiencing homelessness have occurred at the site for many years. A Class 1 (Existing Facilities) categorical exemption includes the operation, permitting, licensing or minor alteration of existing structures where there is negligible or no expansion of use.
The proposed use would not result in any alteration of the existing building or project site.
The safe parking of no more than 25 individuals or vehicles would occur on an existing surface parking lot with 109 spaces. The operation of a Safe Parking use on a religious facility site is considered an accessory use in the Zoning Code and is therefore a negligible expansion of an existing use.
The applicant has provided a list of weekly events in which the parking lot is used by the religious facility volunteers, parishioners, or staff. These include youth night and adult choir practices which occur Wednesday and Thursday nights, respectively, each week until 10:00 p.m. and city ordinance does not limit the hours during which volunteers, parishioners and staff are permitted to park on this lot. The number of parking spaces within the parking lot area is not increasing or proposed to be altered.
The All Saints Church is a religious facility with the primary use of religious worship. The facility also operates related accessory activities including administrative offices, religious education, counseling, choir and church group activities, clothing and food distribution, charitable activities, and support groups.
It should also be noted that the religious facility presently operates the Safe Haven temporary homeless shelter on the property nightly from 10:00 p.m. to 7:00 a.m., which is a similar operation to the safe parking use. Both uses include the temporary shelter of unhoused individuals in a secure location with accessible restroom and washing facilities and a required case management program. The addition of the Safe Parking use is a negligible expansion to the existing All Saints facility and its other related accessory activities. Furthermore, no construction or permanent physical alterations to the All Saints facility is required to accommodate the proposed Safe Parking use.
3. The proposed Safe Parking operation would negatively affect the safety of the neighborhood, as the evidence, below, and which was presented to the BZA demonstrates.
Staff's Response: The proposed use would not be detrimental to the area with adoption of the recommended conditions of approval. Specifically, the conditions Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17, 2025
require oversight of the program by an on-site state certified security guard, limit outdoor lighting, and limit outdoor activities. The conditions of approval require that personal belongings remain within participant vehicles; and that the premises, sidewalk, and street remain in a litter and graffiti-free manner.
Additionally, only registered participants may be parked overnight during the program hours and would be monitored by the security guard. The restroom is a/so required to be accessible only to Safe Parking participants and maintained in a clean and sanitary manner. Should the program operator fail to comply to enforce the written agreement as stated, the Zoning Administrator, at any time, can call for a review of the approved conditions at a duly noticed public hearing.
T77ese conditions may be modified, or new conditions added to reduce any impacts of the use. The Hearing Officer may revoke the Minor Conditional Use Permit if sufficient cause is given.
Second Appeal (Appellant 2):
1. The decision does not comply with the provisions of the Zoning Code.
Staff's Response: The All Saints Church site is zoned PS (Public and Semi- Public) and consists of three contiguous parcels under single ownership. The northern two parcels are developed with surface parking and the southern parcel /'s developed with religious facility buildings and a courtyard. In the PS zoning district, an MCUP is required to establish a Safe Parking use on a religious facility site. The project also meets the operational requirements of the Zoning Code.
2. The BZA did not make the appropriate findings supported by substantial evidence.
Staff's Response: The BZA adopted the findings necessary for approval of the MCUP to establish a Safe Parking use at the site. The BZA found that the use meete all applicable specific land use standards required by the Zoning Code in that there will be a program operator which participates in the Pasadena Continuum of Care Program and Coordinated Entry System; restroom, water, and trash facilities will be provided; only authorized vehicles will be permitted to park overnight; and clients will be required to enter a written agreement with the program operator with specific terms and conditions. Further, the use is consistent with Goals and Policies in the Housing and Land Use Elements of the General Plan, as the use provides sen/ices to individuals experiencing homelessness. Lastly, the BZA found that as proposed and conditioned, the project would not be detrimental to surrounding properties or to other residences in the immediate neighborhood. The project is required to provide a state licensed security guard during the hours of operation, limit outdoor lighting, and limit outdoor activities.
3. The decision did not comply with CEQA or provide evidence to support an exemption from CEQA.
Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17, 2025
Staff's Response: See response to First Appeal, Comment #2.
COUNCIL POLICY CONSIDERATION:
General Plan Consistency
As conditioned, the proposed Safe Parking use is consistent with General Plan Policy
4.4 (Service-Enriched Housing) and 4.6 (Homeless Housing and Services). These policies require that adequate opportunities and support is provided for organizations that provides housing and services to people experiencing homelessness. The proposed Safe Parking program integrates support services including case management and housing navigation. In addition, the use would provide a safe and secure location for people experiencing homelessness to park their vehicles and sleep over night. As such, the proposed use is consistent with the City's policies to provide service-enriched opportunities for people experiencing homelessness.
Additionally, the use is consistent with General Plan Policy 2.7 (Civic and Community Services) to provide diverse uses and services to support residents. All Saints Church is an existing religious facility in which community gatherings related to religious services and other social groups occur. The proposed Safe Parking use would provide a consistent, dedicated space for unhoused individuals to sleep and have access to restrooms. Participants would be assigned a case worker to provide resources to assist in finding permanent housing.
ENVIRONMENTAL ANALYSIS:
This project has been determined to be exempt from environmental review pursuant to the guidelines of the California Environmental Quality Act (Public Resources Code §21080(b)(9); Administrative Code, Title 14, Chapter 3, §15301, Class 1, (Existing Facilities), and there are no features that distinguish this project from others in the exempt class; therefore, there are no unusual circumstances. Section 15301 exempts the operation, permitting, licensing or minor alteration of existing structures where there is negligible or no expansion of the use. The safe parking of no more than 25 vehicles would occur on an existing surface parking lot with 109 spaces. The operation of a Safe Parking use on a religious facility site is considered an accessory activity to an existing use and is therefore a negligible expansion of an existing use.
Furthermore, CEQA Section 15300.2(f) states that a categorical exemption shall not be used for a project which may cause a substantial adverse change in the significance of a historical resource. The site is located within the boundaries of the Pasadena Civic Center Historic District, listed on the National Register of Historic Places, and contains the AII-Saints Church religious facility, a contributing historic resource to the district. A "substantial adverse change" in the significance of a historical resource means an alteration that materially impairs the physical characteristics that convey its significance and justify its eligibility. The proposed project, operation of a Safe Parking use on an existing parking lot, would not materially impair the significance of the historical resource as the project would not physically alter, destroy, or demolish it, or its Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17, 2025
surroundings in a way that diminishes its historical value. Therefore, a categorical exemption could be used.
CONCLUSION:
Staff finds that the findings necessary for approving MCUP #7318 to allow for the establishment of a Safe Parking use at an existing religious facility site can be made.
Therefore, staff recommends that the City Council approve the MCUP subject to the findings in Attachment A and recommended conditions of approval in Attachment B.
FISCAL IMPACT:
There is no direct fiscal impact as a result of this action.
Respectfully submitted,
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JENNIFER F(AIGE,
Director of Planning & Community
Development Department
Prepared by:Concurred by:
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Planner
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Planning l\^anager
Approved by:
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MIGUELM^RQUEZ
City Manager
Minor Conditional Use Permit #7318 (All Saints Safe Parking) November 17,2025
Attachments: (15)
Attachment A:
Attachment B:
Attachment C:
Attachment D:
Attachment E:
Attachment F:
Attachment G:
Attachment H:
Attachment I:
Attachment J:
Attachment K:
Attachment L:
Attachment M:
Attachment N:
Attachment 0:
Minor Conditional Use Permit Specific Findings
Minor Conditional Use Permit Conditions of Approval
Hearing Officer Staff Report (dated June 18, 2025, without attachments) Hearing Officer Decision Letter (dated June 23, 2025)
Hearing Officer First Appeal Application (dated June 30, 2025) Hearing Officer Second Appeal Application (dated June 30, 2025) Hearing Officer Third Appeal Application (dated June 30, 2025) Hearing Officer Addendum (dated August 29,2025)
BZA Staff Report (dated September 25, 2025, without attachments) BZA Decision Letter (dated September 30,2025)
BZA First Appeal Application (dated October 6, 2025)
BZA Second Appeal Application (dated October 6, 2025)
Zoning Code Section 17.50.265 (Safe Parking)
Site Plan and Management Plan
Written Agreement (Rules and Guidelines)