BLUE FOLDER ITEM
Blue folder items are additional back up material to administrative reports and/or public comments received after the printing and distribution of the agenda packet for receive and file.
CITY COUNCIL MEETING
DECEMBER 10, 2024
J.1 PUBLIC PARTICIPATION ON NON-AGENDA ITEMS
PUBLIC COMMUNICATION
From: Frank Briganti
To: CityClerk
Subject: Support Letter. Re: BCHD illegal action
Date: Monday, December 9, 2024 1:58:36 PM
Attachments: Draft RBCouncil Letter.pdf
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
Please forward to all listed ton the Letter!
ThanksDR Frank
Sent from my iPad
TO: Redondo Beach City Council, City Attorney, Planning Commission, Planning Director, Planning Manager
EMAIL: [email protected],
[email protected],
[email protected],
[email protected],
[email protected],
[email protected],
[email protected],
[email protected],
[email protected]
SUBJECT: Public Comment - BCHD’s Law Firm RUTAN’s Legal Argument to the Redondo Beach Council and City Attorney was based on Incorrect Information The following narrative explains how Rutan & Tucker LLP (RUTAN) correspondence to the City of Redondo Beach regarding BCHD contains material errors that render at least some of its claims moot.
Neither BCHD, RUTAN nor the City of Redondo Beach City Attorney appear to have reviewed the RUTAN correspondence nor vetted the claims. The errors were glaring and simple to find.
Based on BCHD’s claims of suing the City, undoubtedly predicated on this attorney work, correspondence and advice of RUTAN, the City of Redondo Beach Council spent $18,000 on an unneeded Addendum to its General Plan EIR. Should the City of Redondo Beach continue to increase the FAR of BCHD to 1.25 based on false assertions, the surrounding property owners will be further damaged by larger commercial activity, especially since BCHD and the privately owned development it plans will service 80% to 95% non-residents of the District and over 90% non-residents of Redondo Beach. All damages will accrue to the health, welfare and property values of surrounding residents.
We enter this into the record at Redondo Beach and request the City Council protect surrounding property owners and reverse its intent to grant BCHD a 1.25 FAR based on flawed legal analysis and incorrect “facts” by RUTAN.
The Council record has many references to BCHD’s proposed litigation, the Council’s reaction, and the Council’s choice to prepare an Addendum based on BCHD’s litigation threats. HOWEVER – THE
CITY FAILED TO ASSESS THE FALSE NATURE OF THE ARGUMENTS PRIOR TO ITS CONSIDERATION OF THE EIR ADDENDUM. It is not the job of the residents to review and interpret legal correspondence, despite the fact that we suffer the damages of the City’s failure to do so in a timely fashion.
Rutan & Tucker LLP (RUTAN) represents the real estate development actions of BCHD and AES owner Leo Pustilnikov. RUTAN filed comments at least twice (June 26, 2023 and again January 31, 2024) on behalf of BCHD and claimed in brief:
“similarly situated properties in the City with a public or institutional (P) land use designation and PCF zoning designation are owned and controlled by the City, for which there is a different maximum FAR of 1.25.”
RUTAN goes on to further claim:
“the City is seeking to establish a parcel-specific land-use restriction which limits the Campus to a unique 0.75 FAR not shared by its own public or institutional (P) designated properties of a similar size and use.”
Both statements misrepresent the facts of the situation, either by error or intent, and are FALSE The only parcels with proposed 1.25 FAR are 415 Diamond (P-CIV zoned) and 200 N PCH (P-SF zoned). As RUTAN notes, BCHD is P-CF zoned. All three parcels are Public-Institutional (P-I) land use, but all three have different zoning and therefore belong to different zones, despite sharing a common land use designation.
Furthermore, the P-I land use previously had a Planning Commission determined FAR. That is no longer allowable in California as planning standards must include objective standards and measures.
Therefore, FARs must be assigned and quantitative. The City elected to determine a default FAR for PI land use of 0.75. BCHD is currently built out to 0.77 FAR. BCHD as one of about 20 P-I land use parcels was by default assigned the 0.75 base FAR. The other two public safety parcels in different zones were assigned 1.25 FAR. A single Google search of “City of Redondo Beach zoning map” refers directly to the City of Redondo Beach’s website and color coded GIS maps of zoning. All zoning can be confirmed by observation.
As stated at the beginning of this correspondence, the City Council appears to have acted in reaction to BCHD’s litigation threats when it spent $18,000 on an Addendum to the EIR. The public has never heard any discussion of the inaccuracies in the RUTAN correspondence and we can only assume that at least some of the basis for the Council’s action was ill considered.
This is a request for the Council to order a thorough analysis of the RUTAN work, evaluate it for accuracy, and then consider whether or not the material error presented, along with the Council’s ordered review and analysis nullify the litigation threat sufficiently to leave BCHD parcel at 0.75 FAR in the default P-I baseline.
The attachment that follows provides a more in-depth analysis of the RUTAN incorrect assertions and their resulting incorrect conclusion based on Government Code 65852.
ANALYSIS OF RUTAN COMMUNICATION TO THE CITY OF REDONDO BEACH The RUTAN Communication on behalf of BCHD
BCHD's counsel, RUTAN, made the following statement to the City of Redondo Beach:
A. THE PROPOSED FAR REQUIREMENTS FOR PROPERTIES WITH A
PUBLIC OR INSTITUTIONAL (P) LAND USE DESIGNATION VIOLATE GOVERNMENT CODE § 65852. (emphasis added) The proposed FAR requirements violate the uniformity requirements of the Planning & Zoning Law. As required under Section 65852 of the Government Code (emphasis added), with regards to zoning districts:
“All such regulations shall be uniform for each class or kind of building or use of land throughout each zone, but the regulation in one type of zone may differ from those in other types of zones.” (emphasis added) In Neighbors in Support of Appropriate Land Use v. Tuolumne County (2007), the courts held that “the foundations of zoning would be undermined if local governments could grant favored treatment to some owners on a purely ad hoc basis. Cities and counties unquestionably have the power to rezone and their decisions to do so are entitled to great deference; but rezoning, even of the smallest parcels, still necessarily respects the principle of uniformity. This is because a rezoning places a parcel within a general category of parcels (those in the new zone), all of which are subject to the same zoning regulations. The county’s action in this case, by contrast, placed the [landowner’s] land in a class by itself.” Similarly, there appears to be one parcel of its size with a public or institutional (P) land use designation and P-CF zoning designation subject to this proposed maximum FAR of
0.75 – the Campus. Why? Because the other similarly situated properties in the City with a public or institutional (P) land use designation and P-CF zoning designation are owned and controlled by the City, for which there is a different maximum FAR of 1.25.
In essence, the City is seeking to establish a parcel-specific land-use restriction which limits the Campus to a unique 0.75 FAR not shared by its own public or institutional (P) designated properties of a similar size and use."
Let’s assume that RUTAN is not attempting to mislead the Redondo Beach City Council or City Attorney and is factually providing and applying Government Code 65852. It is important that RUTAN is not deliberately misleading the Council, because Council members have made numerous statements following the RUTAN assertions based the need for “spot upzoning” BCHD to 1.25 FAR on the RUTAN representation of Government Code 65852 (GC 65852) and litigation threats.
The resulting action of the Council will disadvantage surrounding residents and take property value from them that will likely not be compensated. A 0.75 FAR will not create the level of destruction of neighborhood character and property value as the 1.25 FAR that RUTAN advocates for above.
Dissection and Analysis of the RUTAN claim
1. RUTAN appears correct that all three parcels in its discussion (BCHD, 415 Diamond, 200 N. PCH) are in the proposed land use of Public-Institutional (P-I). RUTAN created its own naming convention of “public or institutional (P)” but it’s meaning is clear from context.
2. RUTAN appears incorrect in its assertion that the BCHD and other City-owned parcels are zoned PCF, yet have different FAR. There are none. BCHD is P-CF. 415 Diamond is P-CIV. 200 N PCH is PSF. (see https://redondobeachgis.maps.arcgis.com/apps/PublicInformation/index.html? appid=56b9e46bf9014bf08684b8e53a4658cb ) If different zoning within land use allows for different regulations for those zoned parcels, then there is no violation of GC 65852 from having different regulations for the three parcels. Clearly, that is not consistent with the meaning of the RUTAN communication nor its assertion that BCHD should have 1.25 FAR because the other two parcels are in the same zone as BCHD and have 1.25 FAR.
3. Having established that the three parcels in the RUTAN discussion have different zoning (P-CF, PCIV and P-SF) the only consistent theory that supports BCHD and RUTAN is that the parcels share P-I land use (called P by RUTAN).
4. The proposed default Floor Area Ratio (FAR) by the City of Redondo Beach for the default land use of P-I (including BCHD) is 0.75 FAR. The exception is two parcels that are currently zoned P-CIV and P-SF within the P-I land use and have a proposed 1.25 FAR. BCHD and all others are defaulted.
5. Based on the RUTAN presentation and its interpretation of GC 65852, all P-I land use must have the same regulations, that is, the same FAR in this discussion. P-I is broad and encompasses schools and school property, City property, and BCHD. Therefore, the choices can be other than only 0.75 and 1.25 FAR, however whatever FAR regulation that is selected must be uniform for all P-I per RUTAN claim.
6. If the RUTAN theory and interpretation of GC 65852 is correct, then the Redondo Beach addendum to the PEIR for the General Plan supporting 1.25 FAR for BCHD is in error. The PEIR invests in the false narrative that the three parcels in P-I land use can somehow be endowed with a 1.25 FAR, while all other P-I parcels are relegated to some non-uniform FAR. The RUTAN interpretation and theory does not allow for selective “upzoning” nor “downzoning”. The theory requires “regulations shall be uniform for each class or kind of building or use of land throughout each zone” directly from GC 65852. The three parcels have no commonality other than their land use of P-I.
They do not share common zoning.
7. If the RUTAN theory and interpretation of GC 65852 is incorrect (willfully or in error), then there is no issue with BCHD (P-CF) having a different FAR than P-SF and P-CIV parcels within the land use P-I. GC 65852 also states “the regulation in one type of zone may differ from those in other types of zones.” If the City of Redondo Beach’s P-I is not the “zone”, but the actual zoning (e.g., P-CIV, P-CF) is the “zone”, then those parcels are allowed to have different regulations and the BCHD 0.75 FAR is not in violation of the GC.
8. Under the RUTAN theory as advanced, the “zone” is the land use, P-I. All P-I parcels MUST CARRY THE SAME REGULATIONS, including FAR per GC 65852.
9. If the RUTAN theory as advanced is incorrect and the “zone” is at the zoning level of P-CF, P-SF, and P-CIV, then the RUTAN theory does not support the conclusion that BCHD must be allowed the same FAR as the P-CIV and the P-SF parcels. The three parcels would represent three distinct zones.
10. Either way, whether RUTAN is correct or incorrect, the current situation of different regulations within land use (P-I) and different regulations within zoning (P-SF, P-CIV, P-CF) fails to satisfy the requirement of GC 65852. P-CF’s carry different FARs and P-SFs carry different FARs within parcels. This is not allowed based on RUTAN interpretation of GC 65852.
DIVISION 1. PLANNING AND ZONING [65000 - 66342]
( Heading of Division 1
added by Stats. 1974, Ch. 1536. )
CHAPTER 4. Zoning Regulations [65800 - 65912]( Chapter 4 repealed and added by Stats. 1965, Ch. 1880. )
65852.
TITLE 7. PLANNING AND LAND USE [65000 - 66499.58]( Heading of Title 7 amended by Stats. 1974, Ch. 1536. )
From: Stop BCHD
To: CityClerk; Michael Webb; Marc Wiener
Cc: Kevin Cody; [email protected]; [email protected]; [email protected] Subject: Legal Issue - Violation of Government Code by the City of Redondo Beach Date: Thursday, December 5, 2024 2:24:01 AM
Attachments: image.png
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
Based on a plain English reading of the Government Code reference provided by BCHD's law firm Rutan, it seems quite clear that the Cityhas violated the GC by not providing the FAR
1.25 to EACH AND EVERY P-I land use parcel.
On the other hand, if the City believes that Rutan's view is incorrect, then BCHD's threat of litigation is flaccid and the City would recover its costs from BCHD in Court.As a result, residents and taxpayers are being damaged by setting the BCHD fAR at 1.25 needlessly based on an idle threat by BCHD.
This is very problematic for residents and taxpayers.
Search Phrase:
CODE TEXT
GOVERNMENT CODE - GOV
ARTICLE 2. Adoption of Regulations [65850 - 65863.13]( Article 2 added by Stats. 1965, Ch. 1880. )
All such regulations shall be uniform for each class or kind of building or use of land throughout each zone, but the regulation in one type of zone may differ from those in other types of zones.
--
StopBCHD.com ([email protected]) is a Neighborhood Quality-of-Life Community concerned about the quality-of-life, health, and economic damages that BCHDs 110-foot above the street, 800,000 sqft commercial development will inflict for the next 50-100 years.
Our neighborhoods have been burdened since 1960 by the failed South Bay Hospital project and have not received the benefit of the voter-approved acute care public hospital since 1984.Yet we still suffer 100% of the damages and we will suffer 100% of the damages of BCHDs proposal.
From: Mark Nelson (Home Gmail)
To: Judy Rae
Cc: [email protected]; [email protected]; CityClerk; [email protected]; [email protected]; info; [email protected]
Subject: LTE - BCHD interprets the Measure BC loss as an endorsement of its flawed plans Date: Saturday, December 7, 2024 8:07:49 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
From 9AM to noon on Friday 12/6, BCHD hosted a half-day (yes, 3 hours is half a "BCHD work day") strategic planning workshop. Remarkably, BCHD interpreted Measure BC's loss by nearly 20 points (it required two-thirds to pass and received 47%) as an endorsement of building an allcove building and also demolishing the Hospital and preparing the campus for private development. BCHD spent $580,567 of resident-taxpayer funds on Measure BCs rejection, yet somehow BCHD interpreted the loss as an endorsement of the projects that BCHD sought to fund in Measure BC? How can that be?
BCHD asked for $9 million to cover cost overruns on the allcove building. The allcove service and building require 30 years of unfunded operation for a 91% non-resident service area based on the contract that BCHD signed with the State. BCHD also asked for $21M to tear down the Hospital and prepare the campus for PMB LLC's gargantuan, 100% private facility that will service 80% non-resident tenants. So voters said "no" to the funding and BCHD thinks that means "yes" to the actions? BCHDs board and executives are disinterested in what the majority of the electorate had to say, and that's been the same experience that surrounding neighborhoods have had from BCHD for years now.
Mark Nelson
Redondo Beach
From: Stop BCHD
To: CityClerk; Nils Nehrenheim; Paige Kaluderovic; Todd Loewenstein; Scott Behrendt; Zein Obagi; Michael Webb; Marc Wiener; Sean Scully; Joy Ford; Cheryl Park; James Light Cc: Kevin Cody; Garth Meyer; Douglas Boswell; Wayne Craig; Sheila W. Lamb; Gale S. Hazeltine; Robert Gaddis Subject: Public Comment - Spot Upzoning of BCHD and 200 N PCH Parcels Violates GC 65852 Date: Monday, December 9, 2024 5:40:18 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
In Rutan & Tucker (RUTAN) correspondence to the Council on behalf of BCHD, RUTAN cites Government Code 65852 with the following:
[“All such regulations shall be uniform for each class or kind of building or use of land throughout each zone, but the regulation in one type of zone may differ from those in other types of zones.” (emphasis added) In Neighbors in Support of Appropriate Land Use v. Tuolumne County (2007), the courts held that “the foundations of zoning would be undermined if local governments could grant favored treatment to some owners on a purely ad hoc basis. Cities and counties unquestionably have the power to rezone and their decisions to do so are entitled to great deference; but rezoning, even of the smallest parcels, still necessarily respects the principle of uniformity.]
BCHD has requested to be spot upzoned to a 1.25 FAR for its P-CF zoned parcel. Council has taken the first step to the spot upzoning by conducting an $18,000 environmental analysis that supports only the action of spot upzoning of the single BCHD parcel.
Assuming that RUTAN is not attempting to mislead the Council, and that RUTAN provided a faithful interpretation of GC 65852, then the Council CANNOT spot upzone the BCHD parcel without providing uniform treatment to all P-CF. Per GC 65852, all P-CF parcels require uniform treatment (see RUTAN above "even the smallest parcels still necessarily reflects the principle of uniformity.)
Further, the Council increased the FAR of 200 N PCH to 1.25. 200 N PCH is zoned P-SF, yet other P-SF parcels were not granted the uniformity REQUIRED by GC 65852 as provided in comments by RUTAN.
Last, the 415 Diamond parcel is zoned P-CIV, and has no peers in P-CIV. Therefore, it appears that it has, and can remain, FAR 1.25 as its own zone.
This is a very concerning issue to the residents and taxpayers impacted by the proposed spot upzoning of the BCHD parcel. The Council appears bound to the principle of uniforming in FAR assignment within zones - and - the Council appears on a path of violation of GC 65852 with both the spot upzoning of the 200 N PCH parcel and the BCHD parcel. We ask the Council to adhere strictly to the law and reevaluate its non-uniform zone restrictions in favor of full compliance with GC65852 as presented by RUTAN on behalf of its client BCHD. If the Council believes that RUTAN provided false information, the public has a right to know that as well. Thank you.
StopBCHD.com
--
StopBCHD.com ([email protected]) is a Neighborhood Quality-of-Life Community concerned about the quality-of-life, health, and economic damages that BCHDs 110-foot above the street, 800,000 sqft commercial development will inflict for the next 50-100 years.
Our neighborhoods have been burdened since 1960 by the failed South Bay Hospital project and have not received the benefit of the voter-approved acute care public hospital since 1984.Yet we still suffer 100% of the damages and we will suffer 100% of the damages of BCHDs proposal.
From: Stop BCHD
To: CityClerk
Cc: Communications
Subject: Public Comment All Agencies: Why didn"t BCHD promote the Strategic Half Day on 12-6-24? Date: Thursday, December 5, 2024 4:07:57 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
BCHD left it off their calendar of events on FB. They didn't email it out. Is this all part of a BCHD echo chamber scheme to limit public input? Seems pretty sleazy for a so-called public agency.
--
StopBCHD.com ([email protected]) is a Neighborhood Quality-of-Life Community concerned about the quality-of-life, health, and economic damages that BCHDs 110-foot above the street, 800,000 sqft commercial development will inflict for the next 50-100 years.
Our neighborhoods have been burdened since 1960 by the failed South Bay Hospital project and have not received the benefit of the voter-approved acute care public hospital since 1984.Yet we still suffer 100% of the damages and we will suffer 100% of the damages of BCHDs proposal.
From: Stop BCHD
To: Communications
Cc: CityClerk; Nils Nehrenheim; Paige Kaluderovic; Todd Loewenstein; Scott Behrendt; Zein Obagi; Michael Webb; Garth Meyer; Kevin Cody
Subject: Public Comment BCHD Properties Committee and Board, cc: City of Redondo Beach Council Date: Monday, December 9, 2024 6:37:02 PM
Attachments: image.png
image.png
image.png
image.png
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
Beach Cities Failed Development District?
BCHD's $6.3M allcove building grant is only 30% of the required cost. BCHD's inexperience in development created a massive failure in cost estimation and contingency for the allcove building. If BCHD accepts the $6.3M, then District Taxpayers have a 30-year, unfunded obligation to service SPA8 with allcove building and services. BCHD refuses to publicize its failure to even analyze the cost of the liability prior to inking the State funding agreement.
BCHD's interpretation of the Measure BC outcome is defective. Measure BC rejected de minimis funding for the allcove building and the commercial development demolition of the 514 building. The ELECTORATE sent a clear message that it doesn't want TAXPAYER FUNDS spent on either project. Further, BCHD wasted $600,000 of taxpayer funding on the unneeded election.
The following from BCHD is nonsensical. BCHD will need to TERMINATE the demolition, use the 514 building until 2030 when the 510 lease is up, and then proceed.
Voters did not support demolition of the 514 building.
Voters did not support the allcove building or its $170M, 30-year, SPA8 service liability..
Measure BC was the only loser in Redondo Beach measures and was less than 7% of funding of the 3 measures.
CLEARLY - VOTERS SENT A NO CONFIDENCE VOTE TO BCHD
:
The community is mounting a full opposition campaign to BCHD's spot upzoning request.
BCHDs project cost estimate for 200,000 to 300,000 sqft of high rise is delusionally low highlighting BCHD's lack of development expertise.
BCHD claims that its $14M pre-development budget is within the norms. That implies that 100% costs, including the pre-development costs for the project will be $47M and that leaves $33M for construction, or $110 to $165 per sqft. The cost of a frame and stucco single family home is $400 per foot or 3 to 4 times BCHD commercial estimate. "The cost of building a home in Los Angeles is significantly higher than in other US cities and states. On average, the cost per square foot ranges from $400 to $450 for a standard single-family property in 2023" Further, the cost of commercial construction is $250 (office) to $600 (medical) per sqft in Los Angeles County. BCHD's pre-development work is largely throw away work that will need to be duplicated by the 100% private developer's team.
$2.1M for 400-feet of bike path fully demonstrates BCHD lack of construction experience
BCHD conducted deferred maintenance of its site instead of spending on a bike path. 400-feet of bike path should not exceed $100,000 per Caltrans.
--
StopBCHD.com ([email protected]) is a Neighborhood Quality-of-Life Community concerned about the quality-of-life, health, and economic damages that BCHDs 110-foot above the street, 800,000 sqft commercial development will inflict for the next 50-100 years.
Our neighborhoods have been burdened since 1960 by the failed South Bay Hospital project and have not received the benefit of the voter-approved acute care public hospital since 1984.Yet we still suffer 100% of the damages and we will suffer 100% of the damages of BCHDs proposal.
From: Mark Nelson (Home Gmail)
To: CityClerk; Communications; Kevin Cody; Nils Nehrenheim; Paige Kaluderovic; Zein Obagi; Jane Diehl; Martha Koo; Michelle Bholat; Noel Chun; Todd Loewenstein; Michael Webb; Marc Wiener; Sean Scully; Scott Behrendt; Nicole Wesley
Subject: Public Comment: City of Redondo Beach is violating GOVERNMENT CODE § 65852 by Spot Upzoning BCHD FAR to 1.25
Date: Wednesday, December 4, 2024 3:08:41 AM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
According to BCHD's counsel, Rutan, the following is materially true: "A. THE PROPOSED
FAR REQUIREMENTS FOR PROPERTIES WITH A PUBLIC OR INSTITUTIONAL (P) LAND USE DESIGNATION VIOLATE GOVERNMENT CODE § 65852. The proposed FAR requirements violate the uniformity requirements of the Planning & Zoning Law. As required under Section 65852 of the Government Code, with regards to zoning districts: “All such regulations shall be uniform for each class or kind of building or use of land throughout each zone, but the regulation in one type of zone may differ from those in other types of zones.” In Neighbors in Support of Appropriate Land Use v. Tuolumne County (2007), the courts held that “the foundations of zoning would be undermined. . .if local governments could grant favored treatment to some owners on a purely ad hoc basis. Cities and counties City of Redondo Beach June 26, 2023 Page 3 2284/037374-0001 19245138.8 a06/26/23 unquestionably have the power to rezone and their decisions to do so are entitled to great deference; but rezoning, even of the smallest parcels, still necessarily respects the principle of uniformity. This is because a rezoning places a parcel within a general category of parcels (those in the new zone), all of which are subject to the same zoning regulations. The county’s action in this case, by contrast, placed the [landowner’s] land in a class by itself.” Similarly, there appears to be one parcel of its size with a public or institutional (P) land use designation and P-CF zoning designation subject to this proposed maximum FAR of 0.75 – the Campus.
Why? Because the other similarly situated properties in the City with a public or institutional (P) land use designation and P-CF zoning designation are owned and controlled by the City, for which there is a different maximum FAR of 1.25.1 In essence, the City is seeking to establish a parcel-specific land-use restriction which limits the Campus to a unique 0.75 FAR not shared by its own public or institutional (P) designated properties of a similar size and use."
Many other P-I land uses are denied upzoning to FAR 1.25. BCHD and two selected City Parcels were both upzoned in a discriminatory fashion that violates the Government Code cited above by BCHD's counsel Rutan. All three parcels must be returned to the base FAR of
0.75, or alternatively, all P-I parcels must be upzoned to FAR 1.25. As a parent of an RBUSD student, it is clear that this policy will deny students the benefits of higher FAR development on RBUSD surplus land.
Mark Nelson
Redondo Beach