City Council
Report
City Council Meeting: March 14, 2023
Agenda Item: 10.C
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To: Mayor and City Council
From: David Martin, Director, Administration
Subject: Introduction and First Reading of an Ordinance Amending the Text of the Zoning Ordinance to Establish an Outdoor Space Program to Allow Outdoor Commercial Activity on Privately-Owned Property and Other Minor Amendments Related to Emergency Response and Economic Recovery, Including Extension of Certain Permit Timeframes; Adoption of Resolution Establishing Fees for Permits Subject to Outdoor Space Program Recommended Action
Staff recommends that the City Council:
1. Adopt a finding of Categorical Exemption pursuant to Sections 15301 (Existing Facilities), 15303 (New Construction or Conversion of Small Structures), and 15304 (Minor Alterations to Land) of the California Environmental Quality Act (CEQA) Guidelines.
2. Introduce for first reading an ordinance to amend the text of the Zoning Ordinance to establish an Outdoor Space Program allowing outdoor commercial activity on privately-owned property and other minor amendments related to emergency response and economic recovery, including extension of certain permit timeframes.
3. Adopt Resolution establishing a fee review of applications subject to the Outdoor Space Program.
Summary
The temporary outdoor space on private property program is set to expire on June 30, 2023, unless further extended or permanently adopted. The Planning Commission reviewed the proposed permanent program at their January 25, 2023, meeting and voted 5-0 (2 absent) to recommend that the Council approve the program, with some revisions. The Planning Commission’s recommendations are detailed in the Discussion section of this report.
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In its review, the City Council should focus on whether the proposed zoning amendments establishing a permanent outdoor space on private property program are appropriate in providing the necessary continued economic support to existing Santa Monica businesses and new businesses seeking to expand their commercial activity outdoors, thereby contributing to the City’s economic vitality.
Additionally, staff recommends the Council codify the permit timeframe extension established pursuant to Emergency Interim Zoning Ordinance Number 2698 (CCS), which allowed an additional two (2) years added to all planning entitlements active as of March 13, 2020, which was when the COVID-19 emergency was declared, until December 31, 2022, due to unavoidable delays caused by the COVID-19 pandemic and to further economic recovery efforts. Although the permit timeframe extension IZO expired on December 31, 2022, codifying these provisions in the Zoning Ordinance is recommended for future referencing purposes to assist with establishing permit expiration dates for all projects granted the time extensions during this period of the COVID-19 pandemic moving forward.
The COVID-19 pandemic resulted in sudden closures and reduction in services throughout the Santa Monica business community. As part of the City’s economic recovery efforts, the City established the Santa Monica Temporary Outdoor Use Permit Program for businesses in accordance with State and County health emergency orders and social distancing requirements. Under this initial program, businesses applied to temporarily use areas within the public right-of-way including sidewalks, on-street parking spaces for parklets, portions of the Santa Monica Pier and Third Street Promenade, and private outdoor space for commercial activities. The program has supported a variety of businesses including restaurants, fitness, personal services, and retail within both public areas and within on-site surface parking lots or open space on privately-owned property of the subject business. Use of outdoor space in the public right-of-way has converted to the permanent Santa Monica Outdoors Parklet program and reversion to the existing sidewalk dining program. The focus of this report is establishment of a permanent use of outdoor space program located on private property 3 of 38
as the last remaining area of outdoor spaces temporarily authorized during the pandemic.
The temporary outdoor program was established and has evolved through a series of emergency orders beginning on May 29, 2020 (Eighteenth Supplement to the Executive Order) and continued throughout the COVID- 19 pandemic, consistent with State and County health orders. Temporary outdoor use permits have been issued to businesses through a streamlined review process at no cost.
Background
Temporary Outdoor Space Program
On June 8, 2021, the City Council converted these enabling emergency orders into two Emergency Ordinances and adopted 1) Emergency Ordinance 2673 (CCS) authorizing the continued use of outdoor public space on sidewalks or streets via parklets (parklet program); and 2) Emergency Interim Zoning Ordinance (“IZO”) 2674 (CCS) adopting interim zoning regulations authorizing the continued use of outdoor space (private outdoor space program) located on privately-owned property for commercial activity.
Interim Zoning Ordinance 2674 also extended certain zoning changes necessary for continued emergency response and economic recovery, including, but not limited to, temporary permitted uses for emergency shelters, public safety facilities, and drivethrough facilities for COVID-19 testing and vaccination purposes; flexibility in issuance of temporary use permits; and flexibility in retail sales of alcoholic beverages, and offsite sale of alcoholic beverages by restaurants, consistent with emergency regulations issued by the California Department of Alcoholic Beverage Control (“ABC”).
On May 10, 2022, the City Council further extended the terms of both Ordinances and authorized the extension of fee waivers associated with monthly licensing fees for businesses using City-owned property or public right-of way for sidewalk use and parklets. Council subsequently adopted a permanent parklet program in July 2022 adding Chapter 6.42 Santa Monica Outdoors Parklet Program to the municipal code. 4 of 38
Emergency Interim Zoning Ordinance 2704 (CCS) extended the private outdoor space program and interim zoning regulations through December 30, 2022.
On June 1, 2022, the Planning Commission adopted a Resolution of Intention, Resolution Number 22-012 (PCS), declaring its intention to consider recommending to the City Council that the City Council amend text of the Zoning Ordinance to establish an Outdoor Space Program to allow outdoor commercial activity on privately-owned property, and consideration of other zoning changes related to emergency response and economic recovery, including, but not limited to, amendments to allow for flexibility in offsite sales of alcoholic beverages by restaurants and to ensure consistency with expanded authorization to allow outdoor commercial activity on certain public outdoor spaces.
On October 11, 2022, the City Council further extended the term of the private outdoor space program and interim zoning regulations through June 30, 2023. This extension was granted to allow businesses to continue utilizing their private outdoor space while staff prepared a permanent private outdoor space program with zoning amendments that would enable such program.
Permit Timeframe Extension: IZO 2698 (CCS)
On January 25, 2022, the City Council adopted Emergency Interim Zoning Ordinance Number 2688 (CCS) amending SMMC Section 9.37.090 to codify two-year extensions for permits issued under the Zoning Ordinance as enacted through the Executive Order, to expand eligibility to permits issued through December 31, 2022 or issued pursuant to a complete application submitted through December 31, 2022, and to increase flexibility for an application of a first-time extension for those permits. On March 22, 2022, the City Council adopted Emergency Interim Zoning Ordinance Number 2698 (CCS) extending the interim zoning regulations established by IZO 2688 to December 31, 2022.
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Discussion
Planning Commission Recommendation
On January 25, 2023, the Planning Commission voted to recommend that the City Council adopt the proposed zoning amendments establishing a permanent outdoor space on private property program and other zoning changes related to economic recovery. The Commission expressed the importance of continuing to provide support to Santa Monica businesses following the COVID-19 pandemic, acknowledging the success of the City’s temporary outdoor space program, emergency orders, and interim zoning provisions supportive of economic recovery. The Commission was supportive of the proposed permanent outdoor space program and recommended a few changes to the draft program that would provide businesses with additional flexibility by not restricting the overall size of outdoor spaces or limiting the conversion of existing surface parking lots to accommodate outdoor spaces. Specifically, the Commission recommended the following changes to certain provisions within the draft program proposed by staff:
1. Allowable Size of Outdoor Space. The temporary program currently in effect does not include any size limitations on outdoor spaces for each eligible business. The temporary program provides flexibility in this manner where requirements are limited to ensuring ADA accessibility and that fire and building Code requirements associated with the buildings on the subject property are not impacted.
Staff Changes Originally Proposed to the Planning Commission: Based on business survey response and site inspections, the size of existing outdoor spaces established by businesses during the COVID-19 pandemic range from 300 to over 1,600 square feet in size. In balancing the use of existing surface parking lots consisting of parking, circulation, and loading, staff suggested a maximum size of 1,000 square feet per business and no greater than 50% of the existing surface parking lot may be converted to open space. 6 of 38
Planning Commission Recommendation: While some Commissioners supported establishing a maximum size limit of 1,000 square feet per each business, the Commission voted to not restrict businesses with a size limitation and to not restrict existing surface parking lots with a maximum percentage of conversion.
The Commission believed that both provisions would be too restrictive for businesses to achieve practical outdoor spaces based on varying conditions of each surface parking lot. Additionally, based on the limited number of neighbor complaints during the COVID-19 pandemic on the temporary program related to the use of outdoor spaces or loss of on-site parking on private property, the Commission was not concerned with the need for establishing size limits of outdoor spaces or maintaining on-site parking. Instead, the Commission recommended that outdoor spaces shall have no size limit for each eligible business provided the outdoor space complies with Building Code, Fire Code, and objective transportation/circulation standards established in the Administrative Regulations for the Program by the Mobility Division. This recommendation is consistent with the current temporary outdoor space program which does not include size or parking conversion restrictions. This would allow for greater flexibility for staff to work with businesses in establishing outdoor spaces that work for both the business and overall safety in vehicular circulation of the site.
Staff agrees with the Planning Commission’s recommendation to not include a size limitation on outdoor spaces for each eligible business for the reasons stated above. This is reflected in the permanent program analysis in this report.
2. Conversion of Parking Spaces for Outdoor Spaces. As mentioned, the current temporary program does not include limitations on the number of parking spaces that can be converted for outdoor space, except that no ADA accessible parking spaces, associated access driveway aisles, or path of travel serving such ADA spaces may be converted or modified. Additionally, all required building egress or exit path to the public right-of-way shall be maintained, and the outdoor space is 7 of 38
required to be sufficiently protected by installation of large planters or other appropriate barrier.
Staff Changes Originally Proposed to the Planning Commission: Staff had included a maximum conversion of existing parking lots not to exceed 50% of the existing parking spaces in conjunction with the maximum square footage of outdoor space allowed per business as stated above. This was intended to help balance the use of existing parking lots and address properties where multiple businesses are seeking outdoor space while ensuring that remaining unconverted portions of the lots provided adequate circulation. The draft provision included that an applicant may request to exceed this percentage in accordance with procedures currently established in the Zoning Code (pursuant to SMMC Section 9.28.180 Reduction of Required Parking) which includes but not limited to providing satisfactory evidence demonstrating that the number of maintained parking spaces is sufficient in meeting the parking demand of the site.
Planning Commission Recommendation: In efforts to simplify the review and to ensure that businesses can achieve workable outdoor space, the Commission recommended to not restrict the number of existing parking spaces that can be converted, considering the varying size and existing conditions of each parking lot. The Commission believed that outdoor spaces should be designed in a safe manner in coordination with ensuring adequate vehicle/loading circulation and accessibility with any remaining parking spaces. Therefore, the Commission recommended there should be no limit to the number of existing parking spaces that can be converted provided that the outdoor space complies with Building Code, Fire Code, and objective transportation standards established in the Administrative Regulations for the Program by the Mobility Division Staff agrees with the Planning Commission’s recommendation to not include a conversion of existing parking space limitation for the reasons stated above, except that accessible parking spaces (ADA spaces) shall be maintained as 8 of 38
required by law. This is reflected in the permanent program analysis in this report.
Current Outdoor Space Program: IZO 2724 (CCS)
The subject zoning amendments are focused on establishing a permanent outdoor space program that continues to support outdoor commercial activity within on-site surface parking lots or other available open space on private property, continuing the support for business retention/expansion and economic recovery efforts following the pandemic.
The current Temporary Outdoor Space program has been critical in supporting businesses during the pandemic. Its overall success provides a new perspective on the City’s approach to its economic recovery moving forward. For current private outdoor space permits, parking requirements (except those relating to accessible parking) and maximum floor area ratio are temporarily suspended to the extent necessary to accommodate the temporary outdoor spaces and uses permitted under the IZO.
The current temporary program allows businesses (with minimal restrictions) to utilize on-site surface parking lots and other on-site open areas for expanded outdoor dining, fitness, personal service, or retail to help offset any pandemic-related indoor use restrictions or accommodate customer preference of being outdoors while encouraging social distancing. Currently, 94 local businesses have been issued temporary outdoor permits. This opportunity to use outdoor space on private property serves many businesses that are not eligible or not able to have a parklet in front of their business, particularly on commercial streets with higher traffic speeds such as Pico Boulevard and sections of Wilshire and Ocean Park Boulevards.
Currently, outdoor dining is the primary activity of these private outdoor spaces. Similar to rules governing parklets under the Santa Monica Outdoors Parklet Program, table service and alcohol sales are permitted within these spaces. The program has supported a variety of other businesses including fitness and physical training, personal services including hair salons, and retail establishments. 9 of 38
Staff evaluated the overall use of private outdoor space by businesses during the pandemic including business outreach and surveys, and site visits to determine which businesses are actively using their permitted outdoor space. Staff observed the existing conditions of these permitted outdoor spaces including general size and location, parking spaces converted, and the types of furnishings, shading devices, and the overall condition of any barrier, enclosure, or decking materials. Approximately 37 of the 94 local businesses issued a permit are still utilizing their permitted outdoor space. All other businesses did not have any outdoor areas visibly present at their sites at the time of survey, indicating they are no longer using their outdoor space. Relaxed indoor safety protocols have likely attributed to this reduction. The survey also indicated the closure of some business.
Staff’s evaluation informed the development of appropriate standards considering the size and location of permitted outdoor areas, parking needs, building/fire accessibility, and operational requirements to ensure neighborhood compatibility, particularly on sites abutting residential districts. Potential changes to certain development standards such as floor area ratio and parking requirements has been evaluated, in addition to possible operational requirements for these outdoor spaces to ensure overall neighborhood compatibility. The intent of the permanent program is to continue to provide businesses with the necessary flexibility in utilizing surface parking lots or other open areas on-site for commercial activity, while addressing Building Code requirements and Zoningrelated policies.
This proposal involves zoning amendments to certain development standards including, but not limited to floor area ratio and parking, and the addition of new outdoor space standards consisting of operational requirements for these outdoor spaces to ensure overall neighborhood compatibility with adjacent land uses. 10 of 38
Analysis
Business Outreach: Survey and Site Evaluations
Surveys were provided to businesses participating in the program to solicit feedback on evaluating business needs and the conditions of existing outdoor spaces established under the temporary program. The intent of the survey was to understand the effectiveness of the current program and business interest in maintaining their outdoor space under a permanent program moving forward. Businesses provided positive feedback on the program and expressed the importance of their outdoor space to their business operations.
On August 3, 2022, staff distributed a virtual survey to 94 businesses currently permitted under the temporary private outdoor space program. Staff received 24 responses over the two-week survey period. The results of the survey helped inform the proposed standards for the subject program. Survey feedback is summarized in the findings below:
Of the 24 respondents, 20 use the space for a restaurant use, two use the space for fitness use, one is for general personal services, and one is for a bar use. 11 of 38
Survey: Types of Uses of Current Temporary Outdoor Space Permits The survey results show that a majority of the operators (66%) use their private outdoor space almost daily, with the remainder of the operators (33%) use their space weekly. 12 of 38
Survey: Current Usage of Temporary Outdoor Spaces
The size of the outdoor spaces range from 300 square feet and to over 1,600 square feet, as shown in the figure below.
Survey: Size of Outdoor Spaces
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A majority (81%) of the outdoor spaces provide 17 or more additional seats in their private outdoor areas. Of these operators that provide 17 or more seats, 9 (64%) of them are 1,000 SF or greater. Additionally, restaurants make up for a majority of the operators that occupy at least 1,000 (72%), and a majority of the operators that provide at least 17 seats (80%).
Survey: Number of Seats within Outdoor Spaces / Percentage of Businesses Based on the results of the survey, and from site visits to existing operators, staff originally proposed a maximum outdoor area of 1,000 square feet per operator intended to provide a balance of uses within these surface parking lots including overall circulation, loading, and access to existing parking. Although operators have the flexibility to propose these outdoor spaces in any combination of common open space on the site, it is expected based on the temporary program that a majority will occupy the surface parking lots associated with the commercial use. Allowing 1,000 square feet of parking area is equivalent to approximately 6-7 standard parking spaces and aligns with current operations of private outdoor use areas. However, the Planning Commission believed such requirement would be too restrictive for businesses to 14 of 38
achieve workable outdoor spaces based on varying size and conditions of each surface parking lot. Consistent with the temporary outdoor program where businesses established their outdoor spaces according to their needs with no size limitations, the Commission believed this approach should be maintained based on the varying sizes of outdoor spaces established during the Pandemic, and the overall positive performance of the temporary program. To ensure that the permanent program accommodates business needs, the Commission recommended to not include a size limitation. As stated above, staff concurs with the Planning Commission’s recommendation, and this is reflected in the proposed ordinance.
Staff also received feedback on business interest in making future improvements to their outdoor space in terms of constructing permanent railings or structures. Many existing permit holders expressed interest in adding planter boxes to use as enclosures, temporary floor covering like artificial turf, canopies or other shade devices, and ambient lighting.
Survey: Business Interest in Design Improvements
The complete survey results are provided as an attachment to this report.
During the pandemic, the City’s emergency orders authorized the temporary use of certain City-owned parking lots, parks, and the Pier specifically for outdoor fitness under lease agreements. This was in response to the immediate need for outdoor fitness 15 of 38
during County restrictions on indoor activity and to provide additional designated fitness areas other than the beach and parks supporting the City’s Park Fitness Permit Program. A few fitness operators expressed interest in using privately-owned surface parking lots for outdoor fitness. Proposals involved leasing underutilized public parking lots from private owners and operating outdoor fitness instruction and classes.
However, the temporary private outdoor space program goals are focused on supporting the recovery of existing local businesses operating within commercial buildings where outdoor space is ancillary to the primary indoor space. As such, program eligible businesses are required to have leased space within a physical commercial building, and therefore businesses operating entirely outdoors on underutilized surface parking lots is not permitted.
As part of the permanent program, staff considered the possibility of allowing outdoor fitness use on privately-owned commercial parking lots. However, the Zoning Code has historically prohibited business from solely operating outdoors on private property for compatibility reasons and to ensure such business activity does not impact surrounding uses and neighborhoods. Allowing businesses to operate solely outdoors could result in operation-related noise impacts to adjacent commercial or residential uses. Also, such allowance could unfairly impact competing fitness and exercise businesses (financially) leasing space within existing buildings in accordance with current zoning requirements.
While staff views outdoor fitness as beneficial to the community, it would be more appropriate for outdoor fitness spaces to be ancillary in size and in support of a larger primary space within an enclosed building to ensure neighborhood compatibility. Also, due to the reduction in County health and safety protocols, staff has not received additional inquiries to specifically operate fitness in this manner.
Furthermore, there are other options for outdoor fitness uses under the City’s Park Fitness Permit Program which allows fitness instruction in designated areas of the beach and public parks. Staff had also received inquiries about generally allowing uses to occupy underutilized parking on sites developed with commercial buildings. However, for these similar reasons, staff does not recommend a provision to allow businesses to solely operate business outdoors on underutilized parking lots. Accordingly, as aligned 16 of 38
with the temporary program, proposed outdoor spaces would be ancillary to the primary use operating within a building located on the same or adjacent parcel. The Planning Commission did not provide any comments contrary to staff’s recommendation on this item.
Temporary Outdoor Program Evaluation and Inter-Departmental Review Based on the outreach conducted to businesses and inter-departmental coordination with relevant City divisions, staff has assessed the current operation of the temporary outdoor space program and proposes certain changes to improve the program as it transitions from temporary to permanent.
Since the start of the temporary program, economic recovery staff including Planning, Mobility, Building and Safety, Resource, Recovery and Recycling (RRR), and Economic Development Divisions have been in close coordination to address any safety issues and community concerns. Staff has also provided assistance to address business needs during the pandemic.
Economic Development Division
The Temporary Outdoor Space Program has been critical in supporting business recovery during the pandemic. The proposed program intends to provide continued flexibility for businesses to utilize outdoor space while also ensuring that uses are compatible with their surroundings. As discussed above, fitness operators had expressed interest to Economic Development staff to operate solely outdoors on underutilized surface parking lots. At this time, due to a reduction in County health protocols associated with the pandemic, diminished interest from fitness operators, and inconsistency with Zoning Ordinance regulations, staff does not see an immediate need to permit or address this in the permanent outdoor space program.
Mobility Division
Planning staff coordinated with the Mobility Division to ensure that any concerns raised associated with parking, loading, or circulation are addressed in the regulations for the permanent program. As part of the economic recovery team, mobility staff has not 17 of 38
experienced any explicit issues or complaints regarding parking availability or with the operation of outdoor spaces authorized during the temporary program. With the proposed program, and as recommended by the Planning Commission, mobility staff would review proposed outdoor spaces and establish standards to ensure that outdoor spaces are designed to minimize impacts to loading, parking, and overall parking lot circulation. This would allow for greater flexibility allowing staff to work with businesses in establishing workable outdoor spaces while ensuring the overall safety and circulation of the site. To address these concerns, Mobility would establish the following:
▪ Require a Parking and Loading Operations Plan (PLOP) for any outdoor space that may impact the loading area;
▪ Ensure the safety of outdoor spaces where customers or staff would have to cross an alley to access the outdoor space;
▪ Prohibit the removal of curb cuts necessary for access to active parking areas; ▪ Require the closure of curb cuts where outdoor spaces block existing, underutilized curb cuts;
▪ Require bollards or other safety features, as deemed appropriate.
Building and Safety Division
Building and Safety requirements for the temporary program will generally remain consistent moving forward as information on permitting and plan review would be included in the Administrative Regulations for the new permanent program. As further described in the next section, these standards and regulations for the design of outdoor spaces include but not limited to accessibility, railing height, canopies, electrical, and lighting. Staff would prepare review procedures and informational tools for businesses on building permit thresholds and any upgrade requirement to existing facilities in an Outdoor Space Manual later discussed in this report.
Resource, Recovery, and Recycling (RRR)
RRR staff has not experienced any major issues with the existing operators with private outdoor space under the temporary program. Staff would continue to review applications to ensure that refuse operations including but not limited to clearance and overall driveway visibility are not impacted by new outdoor proposals. 18 of 38
Comparison of Current and Proposed Program Standards
The current temporary program was established to be flexible with minimal zoning requirements considering indoor health and safety restrictions on indoor usage throughout the pandemic. As part of the City’s economic recovery efforts and business retention, program requirements were based primarily to address fire, life, and safety issues, consistent with the evolving county health and safety requirements. Therefore, the typical zoning standards including, but not limited to allowable size, location, parking, and operating hours were not required.
The permanent program maintains this similar approach in encouraging business to utilize outdoor space as shown to be important for businesses retention during the pandemic. Accordingly, while the proposed program maintains flexibility for businesses, staff proposes additional performance and operational standards to ensure these outdoor spaces do not significantly impact the site and its surroundings, do not create parking circulation conflicts, and are compliant with fire and Building Code requirements.
Below is a summary of the existing temporary program requirements and the proposed changes in the permanent program:
1. Permitted Uses: Eligible Commercial Activity within Outdoor Space. Limited to non-residential zoning districts. Allowable commercial uses are based on the underlying zoning district, except that auto repair/service and liquor stores are explicitly prohibited. The outdoor spaces are accessory to a legally established business that is located on the same parcel or an adjacent parcel. Allowable commercial uses would remain based on the underlying zoning district and the outdoor use would remain as an ancillary component to an established business on-site or on an adjacent parcel provided its under common ownership.
Proposed Changes: Requirements would remain generally the same, however with a few additional amendments and clarifications. The program would add 19 of 38
Animal Care, Sales and Services (i.e., grooming, kennels, and pet day care services) as ineligible uses. Clarifications include that eligible outdoor spaces may be located on existing surface parking lots supporting on-site commercial uses even though such parcels may be zoned residential, subject to the standards established in the program. For example, there are approximately 65 sites developed with existing commercial parking lots that currently serve the commercial buildings on-site that are zoned either R1, R2, R3, or with an A-lot overlay, as shown in the map below. These parcels are directly behind the commercial buildings facing the boulevards and adjacent to residential to the rear. These surface parking lots have historically been utilized for parking that supports the on-site commercial uses. The proposed change would allow commercial activity on these parking lots.
Figure 1: Residentially zoned parking lots adjacent to commercial 20 of 38
2. Floor Area Ratio and Parking Requirements Suspended. To enable and accommodate the use and flexibility of outdoor spaces, zoning requirements including floor area ratio, and parking were suspended for the temporary program. Consistent with ensuring there is flexibility and overall equity for businesses to achieve outdoor space, outdoor space would be exempt as floor area, floor area ratio, and from parking requirements for existing and new outdoor spaces.
Proposed Changes: Sections of the Zoning Ordinance would be updated to exempt outdoor spaces permitted pursuant to this program from floor area, floor area ratio, and parking requirements. As such, outdoor spaces established pursuant to this program will not be considered an expansion of a use and will not require additional parking or count towards maximum floor area ratio. These proposed changes remove the burden of providing additional parking for the outdoor space and ensure that any legal non-conforming uses may participate in the program.
Assembly Bill (AB) 2097: Effective January 1, 2023, AB 2097 eliminates minimum parking requirements for any residential or commercial development within a half-mile of a major transit stop, as shown on figure 1 below:
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Figure 2: ½ mile radius from major transit stops, per AB 2097 Although there are some commercial zones that are outside of the ½ mile radius minimum parking exemption per AB 2097, many of the commercial boulevards and areas of the City are within the radius where projects are exempt from minimum parking requirements. Consistent with the intent of AB 2097, the program would provide flexibility in overall parking whereas eliminating existing parking for the purposes of converting such area for outdoor activity would be allowed up to a certain percentage, and parking would not be required for the expanded outdoor space.
Based on the business surveys, businesses had expressed the need for outdoor space and did not express concerns that the reductions of on-site customer parking were impacting their business. Additionally, through the pandemic, the City’s economic recovery staff had not received complaints about parking issues due to the outdoor space program allowances resulting in the loss of on-site 22 of 38
parking. The City has received few temporary outdoor space permit applications within the last year suggesting that most of the City’s businesses interested in the program may be accounted for. As such, staff does not anticipate a significant increase in new applications upon the program’s adoption. Also, a majority of the businesses participating in the temporary program are located on streets that do not qualify under the Parklet Program due to traffic speeds and therefore commercial street parking remains available for these businesses.
3. Allowable Size of Outdoor Space. Currently, there are no size limitations on outdoor spaces. The temporary program provides flexibility in this manner where requirements are limited to ensuring ADA accessibility and that fire and building Code requirements are not impacted.
Proposed Changes: Based on business survey response and site inspections, the size of existing outdoor spaces range from 300 to over 1,600 square feet in size. As mentioned, the Planning Commission recommended that outdoor spaces shall have no size limit for each eligible business provided the outdoor space complies with Building Code, Fire Code, and objective transportation/circulation standards established in the Administrative Regulations for the Program by the Mobility Division. Staff also proposes that any outdoor space provided in the parking lot be a single, contiguous area per business.
4. Conversion of Parking Spaces for Outdoor Spaces. There are currently no limitations on the number of parking spaces that can be converted for outdoor space, except that no ADA accessible parking spaces, associated access driveway aisles, or path of travel may be converted. Additionally, all required building egress or exit path to the public right-of-way shall be maintained, and the outdoor space is required to be sufficiently protected by installation of large planters or other appropriate barrier.
Proposed Changes: As recommended by the Planning Commission, no changes are proposed. The Commission believed that outdoor spaces should be designed 23 of 38
in a safe manner in coordination with ensuring adequate vehicle/loading circulation and accessibility with any remaining parking spaces. As mentioned, the Commission recommended there should be no limit to the number of existing parking spaces that can be converted provided that the outdoor space complies with Building Code, Fire Code, and objective transportation standards established in the Administrative Regulations for the Program by the Mobility Division
5. Location Requirements: Outdoor spaces may be established by converting surface parking areas or any common open areas on-site including courtyards and roof areas. Currently, there are no setback requirements for outdoor spaces from adjacent land uses such as residential.
Proposed Changes: A new setback requirement for the outdoor space of at least 15 feet as measured from the property line abutting residential uses is being proposed in order to mitigate the potential impacts of outdoor spaces on residential uses. Outdoor spaces would be clear of driveways, drive aisles used to access active parking spaces, loading areas, and ADA required parking.
6. Decks, Canopies/Structures, and Heaters: Building permits are required for the construction of any decks or platforms exceeding certain size and height thresholds. Additionally, temporary canopies exceeding 700 square feet in aggregate size and or placed within 12 feet of any building requires approval of a Fire permit. Also, Fire permits are required for the use of electric or propane heaters which include restrictions when using in conjunction with temporary canopies/tents.
Proposed Changes: No changes are proposed that would alter the building permit thresholds for deck or platform construction, or the need for businesses to obtain fire permits when using electric or propane heaters. Although the temporary program has allowed the use of temporary canopies or pop-up tents during the pandemic to promote immediate economic recovery, staff 24 of 38
recommends prohibiting the use of temporary tents or canopies as permanent fixtures. The current program includes Fire and Building Code requirements for temporary canopies, however the use of permanent structures with fixed foundations and adequate fire rating is recommended from a safety perspective.
Permanent trellis or shading canopy structures would require permanent foundations and would address fire concerns associated with temporary pop-up canopies. During winter seasons, temporary canopy/tents may be approved through issuance of a fire permit on a temporary basis. Furthermore, requiring permanent railings, shade structures, fixtures, or related materials integrated with the existing building or site is consistent with pre-pandemic requirements for outdoor spaces, subject to staff-level architectural review.
Building and fire permit requirements for heaters, decks, canopies, and related structures would be established within the Administrative Regulations as described below.
7. ADA Access and Building Egress: Outdoor spaces are subject to ADA requirements, including egress for existing buildings and for new outdoor spaces.
ADA access and building egress requirements will be established in the Administrative Regulations.
Proposed Changes: No changes are proposed.
8. Hours of Operations: Operating hours for outdoor spaces are currently based on the business’s operating hours prior to the pandemic.
Proposed Changes: Staff recommends establishing operating hours for specific uses including restaurants and fitness/physical training within outdoor spaces in efforts to ensure the neighborhood compatibility with adjacent land uses.
Additionally, to ensure operational consistency, the closing hours specified for restaurants aligns with the established hours for outdoor alcohol service 25 of 38
conditioned in Alcohol Exemption entitlements. Specifically, staff recommends the following operating hours:
▪ Restaurants: 8am-11pm
▪ Fitness/Physical Training: 7am-7pm
Establishing operating hours are intended to minimize noise and activity from nearby sensitive uses such as residential. Consistent with the current zoning Code which allows any restaurant serving alcoholic beverages to seek an alcohol Conditional Use Permit (CUP) instead of an Alcohol Exemption permit, a restaurant may also seek extended outdoor operating hours by applying for an alcohol CUP, subject to Planning Commission consideration.
9. Noise. Outdoor spaces are subject to the City’s Noise Ordinance. Additionally, all forms of speaker amplification are prohibited.
Proposed Changes: No changes are proposed. Staff recommends additional clarification to prohibit the use of televisions or similar screen projectors within outdoor spaces to ensure amplified noise is contained indoors.
10.Alcohol Use. Restaurants are required to obtain all required alcohol permits or approval from the City (Alcohol Determination, Alcohol Exemption, or Conditional Use Permit) and from the Alcohol Beverage Control (ABC).
Proposed Changes: No changes are proposed.
11.Administrative Regulations. The program would include a provision for the Director of the Community Development Department to establish administrative regulations to implement the requirements of the program. The administrative regulations would include, but not be limited to, specific fire department and building Code requirements, design standards for decks, barriers, shading 26 of 38
devices, lighting, and furniture, and additional operating conditions for conducting the outdoor space activity authorized by the program. Below is a summary of requirements to be established:
• Building Code and Permit Requirements and Standards for the following:
o Structures, shading devices, decks, decorative lighting, electrical, plumbing, or mechanical connections.
o ADA requirements, including building accessibility and maintaining accessible parking spaces.
o Similar to the Parklet Program, wastewater fee requirements are applied only in situations where a restaurant increases seat capacity (i.e., net increase in seats). Also similar to the Parklets Program for businesses transitioning from their temporary to permanent outdoor space permits, the program would offer a similar three-year payment plan on any wastewater fee
requirements for existing restaurant permit holders only, with the payment option available through the renewal period ending March 31, 2024.
• Fire Department Permit Requirements and Standards for the following:
o Temporary canopies.
o Propane and electric heaters.
• Mobility Division Requirements and Standards for the following:
o Driveway clearances and overall visibility and safety. o Parking and Loading Operations Plan (PLOP).
o Overall review of parking lot access and circulation. • Design Standards:
o Barriers/Railings
o Permanent canopies or sunshade devices.
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o Allowable furnishings (tables, seating, umbrellas, flooring, exercise equipment, etc.)
o Lighting fixtures
o Signage
Santa Monica Pier
The current temporary program allows for conversion of pier areas not a part of the primary Pier deck driveway/walkway public right-of-way, which is subject to the sidewalk dining program. The proposed program would continue to allow outdoor spaces on the Pier in these areas, however staff recommends fewer restrictions for these spaces due to the uniqueness of the Pier layout and considering the Pier is not in proximity to residential uses. As with all proposals for the Santa Monica Pier, any outdoor spaces would be reviewed by the City’s Pier and Beach Administrator, in coordination with the Santa Monica Pier Corporation to determine the appropriate size and location.
Pier businesses would be subject to the program requirements, except for the following standards:
▪ Maximum Size: No size restrictions are proposed. The appropriate size of the outdoor space would be determined by City staff and the Santa Monica Pier Corporation.
▪ Location: No setback requirements are proposed since the Pier is not located in proximity of sensitive land uses such as residential.
▪ Hours of Operations: No separate hour restrictions are proposed for the outdoor spaces.
▪ Conversion of Parking Spaces: This standard would not apply since businesses do not have their own private parking areas on the Pier. 28 of 38
Existing Non-Conforming Uses
Existing businesses that are considered legal non-conforming uses would also be eligible for the program. This would include uses that were legally established however are non-conforming as a land use that is no longer permitted in the district or if the business lacks the required planning entitlement approvals such as a Conditional or Minor Use Permit.
Pursuant to SMMC Section 9.27.050 Legal Non-Conforming Uses, such uses would not be able to expand in size or intensify business operations. Existing uses that are no longer permitted in the district would not be able to expand, while non-conforming uses without proper land use entitlements would need to obtain their required permits in order to expand operations.
Consistent with the City’s economic recovery efforts in retaining existing businesses, staff believes that legal non-conforming uses should also be eligible for the outdoor space program. Flexibility on allowing non-conforming uses to expand under the program would support these businesses currently restricted from making necessary improvements such as having outdoor space, in response to the pandemic.
Furthermore, the proposed program standards including location, and operating hours would be in place to ensure the compatibility of outdoor activity with nearby uses. As such, staff believes the limited expansion allowed under the program would not be detrimental and would further provide support to Santa Monica businesses.
As discussed, outdoor space would be exempt as floor area and floor area ratio (FAR).
Accordingly, since the outdoor space would not be considered floor area, the added space would not be considered an intensification of the use and such businesses would not be restricted by the non-conforming section of the Zoning Code.
Existing Businesses with Temporary Outdoor Space Permits Existing businesses would be able to retain their existing permitted outdoor spaces in compliance with their permits (issued via City Grows/Clear Forms) and temporary program requirements. New outdoor space permits would be required for businesses 29 of 38
seeking modifications including size expansions or relocations of their outdoor space, subject to new program requirements. Whether a business elects to retain their permitted outdoor spaces or seek modifications resulting in intensification, businesses would be required to submit plans with the City for review.
Permit Renewal Process for Existing Temporary Outdoor Space Permit Holders The program would require that existing permit holders renew their permits by filing for a permanent outdoor space permit through a Zoning Conformance Review. Renewal application fees would not apply. Businesses would submit plans to reflect the outdoor space they were originally permitted during the temporary program to establish a record of plans with the City since drawings were not required as part of the temporary outdoor space permits issued during the pandemic. The City would ensure that all existing outdoor spaces are in compliance with building and fire Code requirements and that businesses have obtained required permits as required by the temporary program.
Outdoor space application review fees would be waived for existing businesses renewing their permits. Existing permit holders seeking modifications to their permits resulting in an intensification of the outdoor space would be required to obtain a new permit, subject to the new standards.
Permits Renewed by March 31, 2024
Existing permit holders would have until March 31, 2024 to renew their permits. This would provide existing businesses with adequate time to prepare drawings and file their application to obtain their permanent permit. Existing permit holders who do not renew prior to this date would need to apply for a new outdoor space permit, subject to the new adopted standards and requirements. Staff will continue business outreach providing updates on the permanent program leading up to and following Council adoption. Staff is in process of preparing the administrative regulations and informational tools for businesses on the program, including an Outdoor Space Manual, similar to the SM Parklets Manual produced by staff for the parklet program.
Renewal applications will be accepted on the effective date of this Ordinance (30 days after second reading of this Ordinance). Staff will continue business outreach to existing 30 of 38
permit holders to support businesses in submitting their renewal applications by October 31, 2023 to allow for sufficient processing time by the City prior to the March 31, 2024 renewal date.
Establishment of SMMC Section 9.31.199, Outdoor Commercial Uses on Private Property
Chapter 9.31 Standards for Specific Uses and Activities would be amended with the addition of Section 9.31.195, Outdoor Commercial Uses on Private Property that would include the program requirements.
Consistency with Existing Zoning Ordinance
In addition to the new establishment of Section 9.31.195, Outdoor Commercial Uses on Private Property, the following existing ordinance sections would be amended for consistency with the proposed program.
▪ 9.04.080 Determining Floor Area
Floor area exclusions established in this section would be amended to include outdoor square footage pursuant to the proposed outdoor space program. ▪ 9.04.090 FAR Determining Floor Area Ratio
Floor area ratio exclusions established in this section would be amended to include outdoor square footage pursuant to the proposed outdoor space program. ▪ 9.27.050 Legal Non-Conforming Uses
Restriction that a non-conforming use is not permitted to expand in area would be amended where the square footage of the outdoor space allowed pursuant to the proposed outdoor space program would not be considered an expansion of an existing non-conforming use.
▪ 9.28.040(A)(4) Calculating Off-Street Parking and Loading Spaces Parking exclusions established in this section would be amended to include outdoor square footage pursuant to the proposed outdoor space program. 31 of 38
▪ 9.31.200 Outdoor Dining and Seating
This existing section establishes outdoor dining and seating standards for eating and drinking establishments when associated with sidewalk dining. This section would remain but would be amended with updated language to specifically apply to outdoor space proposed along the sidewalk public right-of-way and amended to provide consistency in waiving parking requirements for any outdoor dining areas.
Zoning Conformance Review – Application Fees
A fee resolution is proposed to establish an application fee for a Zoning Conformance Review for Outdoor Spaces. A one-time application fee would apply to new permit applications or modifications to existing outdoor space permit applications. Once approved, permits would not be required to be renewed thereafter. As discussed, existing businesses with a temporary outdoor space permit issued during the pandemic will be required to renew their permit initially to make their temporary permits permanent, and will not be charged this application fee to covert their existing permits.
Staff recommends the establishment of a Zoning Conformance Review fee for outdoor space applications of four hundred thirty-three dollars and thirty-two cents ($433.32) excluding any applicable building permit, fire permit, wastewater fees for restaurants, as required for the Parklet Program, or Architectural Review Board fees. This fee amount is based on plan reviews performed by the City’s Mobility Division ($247.02), Planning Division ($107.52), and Resource Recovery and Recycling Division ($78.78). These rates are consistent with the Parklet Program review fees..
Other Zoning and Land Use Related Changes
Other Changes Related to Emergency Response and Economic Recovery: IZO 2724 (CCS)
A range of zoning and land-use related changes were made throughout the pandemic through emergency orders. The interim zoning regulations extended and amended by 32 of 38
IZO 2724 include the following allowances that have helped to facilitate emergency response and support business recovery. Based on the current relaxing of state and county health and safety protocols, staff recommends the following zoning changes related to emergency response and economic recovery expire on June 30, 2023, as established by IZO 2724.
• Permitted Use in all Zoning Districts: Public Safety Facilities and Emergency Shelters. This allowance provided flexibility in establishing uses related to health and safety supportive of emergency response and the pandemic recovery. Based on current state and county health and safety protocols with the State’s COVID State of Emergency ending on February 28, 2023, this provision would terminate.
Although this provision would sunset with the IZO, staff will further evaluate other mechanisms to reestablish the allowance of emergency shelters within the context of the City’s local emergency declaration for homelessness in light of new state legislation requirements and may seek further direction from Council, as needed.
• Drive-through facilities only for COVID-19 testing and vaccination purposes at hospitals, clinics, and pharmacies. The Zoning Ordinance prohibits new drivethrough facilities. This special exception was necessary to allow the establishment of testing and vaccination sites remain ongoing and some level of demand is anticipated to continue. Many of these facilities were established within tented parking spaces where tests or vaccinations are administered while patients remain in their vehicles. While the level of demand for testing and vaccination sites are declining, indoor health or pharmacy facilities can accommodate demand whereas there is less demand for temporary drivethrough facilities necessary during the pandemic. Therefore, this allowance is unnecessary at this time.
• Temporary Use Permits for uses permitted pursuant to 9.31.370(b) of more than 45 days and not exceeding 180 days (6 months). Extending the temporary use 33 of 38
permit period up to 180 days provided flexibility for outdoor temporary uses supportive of economic recovery efforts and consistent with social distancing practices during the pandemic recovery along with the associated permit fee waivers. As indoor masking and social distancing requirements have declined, so has the need and demand for temporary outdoor uses through a Temporary Use Permit. Examples of prior temporary uses utilizing this provision during the pandemic included outdoor drive-in theaters and pop-up outdoor retail events.
Eliminating the waiver of a Minor Use Permit for these temporary use permits valid for up to 180 days would be appropriate at this time. Although this provision will expire, staff contemplates amending this section in the Zoning Code with a similar provision in the near future.
• Off-site alcohol sales for restaurants, and flexibility in retail sale of alcoholic beverages, consistent with the State Alcoholic Beverage Control (ABC) requirements. The Alcoholic Beverage Control now allows off-sale privileges for restaurants and breweries as a result of the pandemic. This provision recognized this expansion of alcoholic beverages “to-go” as allowed by the State and allowed such privileges for restaurants, breweries, etc. consistent with ABC requirements. Therefore, no changes are necessary at this time as this is already mandated by the State.
Extension of Permit Timeframes: IZO 2698
Pursuant to SMMC Section 9.37.090, unless otherwise provided by the Council and/or Planning Commission, planning entitlements have two years to exercise rights, typically obtained by issuance of a building permit or commencement of a use, as applicable.
Special timelines apply for housing projects that have received City, State, or Federal funding and include at least 50% of units affordable to low-income households (three years), and all projects in the Coastal Zone receive an additional six months.
Interim Zoning Ordinance 2698 allowed for an additional two (2) years added to all planning entitlements active as of March 13, 2020, which was when the COVID-19 emergency was declared, until December 31, 2022. The additional two years to 34 of 38
exercise rights codifies extensions granted by emergency orders due to unavoidable delays caused by the COVID-19 pandemic and further allows applicants additional time to proceed with their projects due to the economic impacts of COVID-19, which has affected business operations and the construction industry. This IZO expired on December 31, 2022.
In addition, impacts of COVID-19 had increased the uncertainty for applicants who needed to request additional extensions beyond the two additional years already granted. SMMC Section 9.37.090(C) does not allow applicants to submit a request for time extension any earlier than 6 months before the expiration of their permit. That timing restriction is in place because it is expected that applicants are diligently pursuing exercising rights for their permits and must be able to demonstrate cause for extension of the permit. The IZO allowed applicants to request a time extension at any time prior to 30 days before the expiration of their permit.
Although the permit extension IZO expired on December 31, 2022, staff recommends codifying this permit timeframe extension in the Zoning Ordinance for future referencing purposes to assist with establishing permit expiration dates for all projects granted the time extensions during this period of the pandemic moving forward. The proposed amendments wound (a) extend deadlines to exercise and continuously pursue the rights granted under planning entitlements, permits and approvals issued; (b) allow applicants for planning entitlements, permits and approvals issued and still active to request a First Time Extension or Other Extension pursuant to SMMC Sections 9.37.090(C)(1) and
9.37.090(C)(2) at any time at least 30 days prior to the expiration of the permit generally starting in March 2020 and ending in December 2022.Staff has included changes to SMMC Section 9.37.090 as provided in attached Ordinance, reflecting the effectiveness of the IZO provision during the pandemic.
Environmental Analysis
The proposed amendments establishing standards and requirements for outdoor space located on private property, amendments to existing Zoning Ordinance sections for consistency, and amendments codifying permit timeframe extensions established 35 of 38
pursuant to Emergency Interim Zoning Ordinance Number 2698 (CCS) supporting economic recovery are categorically exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Sections 15301, 15303, and 15304 of the CEQA Guidelines.
• Section 15301 of CEQA Guidelines provides (Class 1 Existing Facilities) exemption for the operation, repair, maintenance, permitting, or minor alteration of existing public or private structures, facilities, mechanical equipment or topographical features, involving negligible or no expansion of use beyond that existing at the time of the lead agency's determination. Projects that fall into this class of exemption include alterations to existing streets, sidewalks, gutter, bicycle facilities, and other similar facilities and additions of safety or health protection during for use in conjunction with existing facilities. The proposed amendments would allow alterations to private property for outdoor space use. Therefore, the project falls into the Class 1 exemption. • Section 15303 of CEQA Guidelines provides (Class 3 New Construction or Conversion) exemption for the conversion of existing small structures from one use to another where only prior modifications are made to the exterior. The amendments would provide for new construction and/or conversion of outdoor space. Therefore, the project falls into the Class 3 exemption.
• Section 15304 of CEQA Guidelines provides (Class 4 Minor Alterations to Land) exemption for minor public or private alterations in the condition of land, water, and or vegetation which do not involve removal of healthy, mature, scenic trees. New outdoor space established as a result of the amendments would install amenities including landscaping and paving. Therefore, the project falls into the Class 4 exemption.
In addition, none of the exceptions specified in Section 15300.2 of CEQA Guidelines would apply that would preclude the use of these CEQA exemptions - The project site is not located in a sensitive environment, the project will not have a significant effect on the environment due to unusual circumstances, the project would not damage scenic resources, the project would not be located on a hazardous waste site; and the project would not cause a change to a historical resource. Therefore, this project is categorically exempt per Sections 15301, 15303, and 15304 of the CEQA Guidelines. 36 of 38
Text Amendment Findings
1. The proposed amendments to the text of the Zoning Ordinance are consistent with the General Plan in that the amendments implement LUCE policies to adapt to changing conditions and to support small businesses. Specifically, Goal LU9 states to actively monitor and manage land use changes to address community needs, promote citywide sustainability and ensure community livability. In response to the pandemic, the City’s economic recovery efforts seek to support and allow businesses to adapt to the current health and safety conditions. The proposed zoning amendments establishing standards and requirements for outdoor space supports local business retention and promotes new business opportunities citywide, addressing needs of the business community and residents. In addition, Policy LU13.4 seeks to reduce regulatory costs on small businesses and for the City to continue exploring ways to streamline the approval process for new and existing businesses. Accordingly, the proposed amendments support small businesses by simplifying land use standards encouraging the commercial use of outdoor space. The proposed amendments are consistent with citywide goals and policies related to maintaining a diversified and sustainable economy. Consistent with Goal E1 which seeks to create an economic base that satisfies the commercial needs of the City’s residents while providing employment opportunities and a strong fiscal infrastructure for the City and consistent with Policy E1.1 which states to make land use decisions that respond to changing market conditions and meet the needs of City residents and visitors, the proposed amendments will encourage the commercial use of outdoor space to meet the economic needs for business retention and the establishment of new business as part of the City’s economic recovery efforts following the current pandemic. Furthermore, consistent with LUCE goals and policies, permit timeframe extensions are necessary due to the devastating impact the pandemic-mandated closures and limitations have had on the local economy, 37 of 38
and necessary to stimulate economic recovery to protect the public health, safety, and welfare of the City.
2. The proposed amendments to the text of the Zoning Ordinance are consistent with the purpose of the Zoning Ordinance to promote the growth of the City in an orderly manner and to promote and protect the public health, safety, and general welfare in that proposed amendments will provide continued support necessary for the City’s business retention and economic recovery efforts while ensuring the protection of neighborhoods following the current Pandemic. Additionally, the permit timeframe extensions are necessary to promote the growth of the City and protect the public health, safety, and general welfare by assisting with unavoidable delays in project development and processing caused by the Pandemic.
Financial Impacts and Budget Actions
There is no immediate financial impact or budget action necessary as a result of recommended action. Staff will return to Council if specific budget actions are required in the future.
Establishing the permanent outdoor space program on private property would generate revenue from Planning application fees and possibly plan check, building permit, or fire permit fees based on proposed improvements warranting permits. This revenue is necessary to recover the costs of reviewing and processing permits. Current Temporary Outdoor Space permit holders renewing their permits to transition from temporary to permanent status will not be charged a Planning application fee.
Accordingly, permit renewal applications would not result in fees generated. However, new outdoor space proposals or modifications to existing permits resulting in an intensification of outdoor space would be subject to the proposed Zoning Conformance Review application fee of four hundred thirty-three dollars and thirty-two cents ($433.32) generating fees moving forward.
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Prepared By: Steve Mizokami, Senior Planner
Approved Forwarded to Council
Attachments:
A. CDD-Ord-Private Outdoor Space 031423
B. CDD--Fee Resolution--Zoning Conformance for Private Outdoor Space 031423 C. Business Outreach Survey Results (August 3, 2022)
D. Written Comment
E. PowerPoint Presentation