T
O: Planning Commission
F
ROM: Kelvin Parker, Community Development Director
DAT
E: September 23, 2024
S
UBJECT: Municipal Code Amendment (MCA) 2024-70004
L
OCATION: Citywide
REQUEST:
To amend Chapters of 3, 4 and 10 of Title 9 of the Thousand Oaks Municipal Code to implement the 2021-2029 Housing Element Programs 4 and 6 for Voluntary Lot Mergers, SB-35 Streamlined Process and Incentives for Affordable Housing with Lot Consolidation.
RECOMMENDATION:
A
dopt a Resolution based on the findings contained therein, recommending that City Council:
1. Find that pursuant to Sections 15183 and 15168(c)(2)(5) of the California Environmental Quality Act (CEQA) no further environmental document is required because the proposed actions are consistent with the City’s goals, policies and anticipated programs contained in the adopted General Plan and Housing Element under a certified Program EIR; and
2 . Adopt an Ordinance approving MCA 2024-70004 amendments to Chapters of 3, 4 and 10 of Title 9 of the Thousand Oaks Municipal Code.
PLANNING COMMISSION REVIEW:
U
nder the City of Thousand Oaks Municipal Code (TOMC) and state law, Planning Commission is required to review, conduct a public hearing on, consider, and make recommendations to the City Council regarding the Proposed Ordinance. The City Council, at a subsequent public hearing, will consider Planning Commission’s ATTACHMENT #1
Housing Element Implementation (MCA 2024-70004)
September 23, 2024
recommendations and decide whether to adopt, not adopt, or adopt with modifications to the Proposed Ordinance.
BACKGROUND:
6th Cycle 2021-2029 Housing Element
The Housing Element is one of the mandated elements of the General Plan and serves as the primary guide to meet existing and projected housing needs of Thousand Oaks’ residents from June 30, 2021, through October 15, 2029. State law requires all jurisdictions to update and obtain certification for their Housing Elements every eight years following the State Department of Housing and Community Development (HCD) Regional Housing Needs Assessment (RHNA) allocation process. On December 5, 2023, the City Council adopted the General Plan 2045 and the 2021-2029 Housing Element and on May 29, 2024, HCD found that the adopted Housing Element is in substantial compliance with the State Housing Element Law.
The Housing Element contains 18 programs and actions the City is required to implement in order to maintain certification, with implementation being confirmed through the annual reporting process to HCD. To date, Programs 1 and 5 have been completed (in part), Program 2 has been completed, and Programs 3 and 8 are in progress.
The Housing Element programs being addressed as part of the proposed Municipal Code Amendment include the following:
Goal 1: Provide a wide range of housing opportunities for persons of all income levels.
Program 4: Lot Consolidation
Consolidation of small lots allows a developer to utilize the land more efficiently, achieve economies of scale, and offer opportunities for improved site design and amenities. The City will encourage the consolidation of small lots to facilitate the development of mixed- use and multi -family developments, particularly for affordable housing through the following actions:
• Eliminate the administrative hearing process and noticing requirements for lot consolidation and develop appropriate lot consolidation incentives that provide flexibility in site planning to facilitate mixed- use and multi -family development.
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Lot Consolidation
During the review of the Housing Element, HCD noted that the Thousand Oaks Municipal Code currently requires a discretionary process for merging or consolidating lots. To encourage development on adjoining parcels and facilitate redevelopment for affordable housing, enabling this process to occur without a public hearing facilitates streamlined qualified housing projects on multiple parcels to proceed as intended by State law. This facilitates the consolidation of small parcels identified within the Housing Element site inventory for the purposes of meeting the City’s RHNA.
Program 6: Streamlined Review
Pursuant to State law, the City will facilitate residential development by the following action:
• Establish a streamlined, ministerial review process for qualifying multi - family residential projects (SB 35).
SB-35 Streamline Approval Process
SB-35 allows qualifying development projects with certain minimum affordable housing guarantees to move more quickly through the local government review process and restricts the ability of local governments to reject these proposals.
This is a voluntary program that a project sponsor may elect to pursue, provided that certain eligibility criteria are met. The bill was signed into law in 2017 and became effective on January 1, 2018. The bill created a streamlined approval process for infill developments in localities that have failed to meet their regional housing needs allocation (RHNA). The bill amends Government Code Section 65913.4 to require local enti ties to streamline the approval of certain housing projects by providing a ministerial approval process, removing the requirement for CEQA analysis, and removing the requirement for discretionary entitlements granted by the Planning Commission.
This report provides discussion/analysis for:
1) T ext amendments to Chapter 3 Subdivisions to add Section 9- 3.1218 Voluntary Lot Mergers , to allow lot consolidation through a ministerial process.
2) Text amendments to Chapter 10 to add Article 8 Incentives for Lot Consolidation for Affordable Housing.
Housing Element Implementation (MCA 2024-70004)
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3) Text amendments to Chapter 4 to amend Section 9- 4.2816 Administrative Permits for ministerial review of qualifying affordable housing projects as required by SB-35.
The draft resolution recommending approval of the Municipal Code Amendment to the City Council is contained in Attachment #1.
DISCUSSION/ANALYSIS
Proposed Voluntary Lot Mergers
The proposed amendment to the TOMC would establish a ministerial process for lot consolidation, referred to as a Voluntary Lot Merger, which is allowed pursuant to the Subdivision Map Act (“Map Act”) Government Code section 66499.20.3.
The Map Act gives the local jurisdiction the authority to regulate and control the development and subdivision of parcels of land. Currently, the TOMC Sections 9-
3.1210 through 9-3.1216 only provide for a city-initiated merging of nonconforming contiguous lots, which requires noticing and potential hearing when challenged by property owners under Subdivision Map Act (“Map Act”) Government Code section 66451.11. Under this process, only the City has the authority to initiate the merging of contiguous parcels if they are nonconforming/substandard and meet the specific standards outline in the Map Act.
Section 66499.20.3 of the Map Act gives the City the authority, by ordinance, to create a reasonable process to allow the merging of two or more parcels that do not all into the category of a Lot Line Adjustment, a Tentative Map, a Reversion to Acreage, or a Parcel Merger, as defined in the Map Act.
Section 9-3.1218 is proposed to be added to Chapter 3 Subdivision, Article 12 Reversions and Mergers. Voluntary Lot Mergers consist of two or more contiguous parcels or lots combined as one property regardless of whether the lots are conforming. The proposed code provision provides standards of approval related to compliance with the Subdivision Map Act, minimum zoning, required access, no impacts to improvement agreements or existing easements , and the application process.
Review of Voluntary Lot Mergers would follow a similar ministerial review process that Community Development Department currently does with Certificates of Compliance, where lots are determined to be created legally under the Map Act.
Voluntary Lot Mergers proposed with a development entitlement application would be processed concurrently as part of the overall project.
Housing Element Implementation (MCA 2024-70004)
September 23, 2024
The proposed Voluntary Parcel Merger would streamline the review process since a public hearing and detailed studies/documentation would not be required.
Additionally, the proposed changes will be cost -effective for the property owners and facilitate land assemblage for development.
Housing Element Program 4 also includes other implementation actions that do not require a Municipal Code Amendment, including new administrative procedures and making information related to lot mergers available to affordable housing developers and property owners. This also consists of providing technical assistance to interested developers and property owners regarding lot consolidation potential on procedure and promot ing the program through brochures and information on the city website.
Eligible Projects for Incentives
Residential development projects that consist of lot consolidation and meet either of the following location and affordability criteria would be eligible for incentives:
1. Housing Inventory Sites (HIS) that construct at a minimum, the number of residential units at the level of affordability identified in the Housing Element Appendix C: Sites Inventory; or
2. Mixed-Use (MU), Mixed-Use Overlay Zone (MUOZ) or Multiple-Family (R- 3) zoned sites not identified in the HIS associated with a rental development proposal consisting of a minimum of 20 percent of the units affordable to lower-income households or an ownership development proposal consisting of a minimum of 20 percent of the units affordable to moderate- income households.
Proposed Incentives
To accomplish the amendment for incentives, Article 8 Incentives for Lot Consolidation is proposed to be added to Chapter 10 Affordable Housing of Title
9. The proposed incentives for affordable housing projects include processing, location flexibility , and relief from certain development standards and objective standards as detailed below.
• Processing: A pre-application will be processed with no fees imposed.
Housing Element Implementation (MCA 2024-70004)
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• Location: Housing Element Inventory Sites and other multifamily or mixed- use sites may be consolidated either separately or in combination when properties are adjoining and proposed to be merged.
• Development Standards: Proposed i ncentives related to development standards include: 1) reducing and waiving certain Mixed- Use (MU) standards that would facilitate housing while maintaining the built form intended by the zoning district ; and 2) allowing R-3 zoned properties the ability to utilize the MU standards or otherwise modified by this ordinance.
• Objective Standards : Proposed incentives related to objective standards include: 1) a reduction of minimum courtyard area; and 2) waive the 50% limitation of units within a stacked dwelling building type project.
Properties zoned MU, Mixed Use Overlay (MUOZ), and R-3 would permit projects that qualify for a residential project using the incentives due to the minimum residential density range of 20 units per acre that could support affordable housing.
Notable incentives proposed for existing R- 3 parcels are an additional height allowance and relaxed parking requirements to match the standards of the Mixed- Use Zone and described below in Table 1 and Table 2. Currently, the R-3 zone allows a maximum height of 35 feet for multifamily development projects with an allowance to go up to 45 feet for projects with 20 percent in the lower income categories. The proposed incentive would allow for up to a maximum height of 50 feet, consistent with Neighborhood High land use designation. The use of MU standards would also retain height maximums with setbacks as the buildings approach 50 feet in height. An additional incentive would include a reduced side yard setback when applying the maximum height step backs side yard adjacent to a residential zone. Lastly, projects on R-3 zoned parcels would be able to use the MU zone parking ratio requirements, which do not require any covered parking.
Certain Mixed- Use zoning standards are proposed to be waived for qualifying affordable housing projects to allow for greater flexibility and make the projects more financial ly feasible. The standards waived are typically associated with mixed-use development projects versus residential projects, where standards exist for ground floor commercial uses , such a mini mum floor plate height of 14 feet associated with a shopfront , minimum retail depth of 60 feet and public exterior space of 3 percent of the building footprint associated with publicly accessible commercial uses.
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Table 1 below is a summary comparison of certain development standards for the MU/MOUZ zoning and the associated proposed incentives.
Table: 1 Incentives for Qualifying Projects
DEVELOPMENT
STANDARD
MU / MUOZ INCENTIVE
Height -
Maximum
50 feet
Within 50 feet of residential
zone or exclusively
residential use:
• 30-feet from property
line - 25 feet maximum
• 30 feet to 50 feet from
property line - 45 feet
maximum
• O ver 50 feet from
property line - 50 feet
maximum
50 feet
Within 50 feet of rear yard abutting
a residential zone:
• 30-feet from property line - 25
feet maximum
• 30 feet to 50 feet from property
line - 45 feet maximum
• O ver 50 feet from property line -
50 feet maximum
Within 50 feet of side yard abutting
a residential zone:
• 20- feet from property line - 25
feet maximum
• 2 0 feet to 40 feet from property
line - 45 feet maximum
• Over 40 feet from property line -
50 feet maximum
Side Setback –
Minimum
20 feet from a residential
zone
Reduce to:
8 feet (single-story)
10 feet (two-story walls)
Third Floor
Setback –
Minimum
10 foot average from first
floor street front building
façade
Waive
Minimum Ground
Floor Windows
(% Ground Floor
Façade)
45% for ground floor
residential
Reduce to:
35% for ground floor residential
Ground Floor
Plate Height –
Minimum
14 feet Waive
Public Exterior
Space – Minimum
(Mixed-Use
Projects)
3% of area of building
footprint
Waive
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Table 2 b elow shows the parking ratio requirements for MU and R -3, which demonstrates that covered spaces are not required under the MU zoning.
Table 2: Parking Incentives for Qualifying R-3 Zoned Projects
PARKING REQUIREMENTS – MINIMUM
MU R-3 INCENTIVE
Residential:
Studio 1.0 spaces / unit 1.0 covered spaces / unit 1.0 spaces / unit 1 Bedroom 1.0 spaces / unit 1.0 covered spaces / unit 1.0 spaces / unit 2 Bedroom 1.5 spaces / unit 1.5 spaces (1 covered) /
unit 1.5 spaces / unit
3+ Bedroom 2.0 spaces / unit 2.0 spaces (1 covered) /
unit 2.0 spaces / unit
Guest Parking 0.5 spaces / unit 0.5 spaces / unit 0.5 spaces / unit
Certain Objective Design Standards are proposed to be reduced to provide flexibility and are further detailed in Table 3 below:
• Open space requirements for Courtyard, Stacked Dwelling and Mixed- use Block building types. This includes the reduction of Minimum Courtyard area from 15% to 10% of lot area, reduction of the minimum courtyard dimensions reduced by 10 feet in length and width and reducing the courtyards a minimum proportion to no less than 1:2 between any horizontal dimension and adjacent building height.
• Waive the requirement that a maximum of fifty percent (50%) of the total units within a project can be in a stacked dwelling building type. This limitation would pose a design constraint on smaller developments that would propose this commonly used building type.
The recommended incentives to the Objective Design Standards are based upon Planning Commission and City Council approv al of recent projects where modifications were requested for courtyard area requirements . Notable projects include the 1730 Loz Feliz Apartments and the 2150 Hillcrest Road Specific Plan.
Housing Element Implementation (MCA 2024-70004)
September 23, 2024
Table 3: Objective Design Standards Incentives
Proposed Streamlined Review
The proposed amendment will facilitate residential development by establishing a streamlined, ministerial process for qualifying multi -family development projects pursuant to SB-35. Under Government Code Section 65913.4, qualifying housing projects with at least 50 percent of base units deed restricted as affordable to lower income households must follow the streamlined requirements and process under Government Code Section 65913. 4. Ministerial projects would be subject to all objective zoning standards, municipal code requirements, standard operational Building Types:
Courtyard, Stacked
Dwelling and Mixed-
use Block
Standard Incentive
Minimum Courtyard
area
15% of lot area 10% of lot area
Minimum Courtyard
Dimension
Minimum courtyard
dimensions must be
forty feet (40') when the
long axis of the
courtyard is within forty-
five (45) degrees of an
east/west orientation
and thirty feet (30')
when the courtyard is
within forty -five (45)
degrees of a north/
south orientation.
Minimum courtyard dimensions
must be thirty feet (30') when the
long axis of the courtyard is within
forty-five (45) degrees of an
east/west orientation and twenty feet
(20') when the courtyard is within
forty-five (45) degrees of a
north/south orientation.
Minimum Courtyard
Dimension
Courtyard dimensions
must have no less than
a one to one (1:1)
proportion between any
horizontal dimension
and adjacent building
height.
Courtyard dimensions must have no
less than a one to one (1:2)
proportion between any horizontal
dimension and adjacent building
height.
Stacked Dwelling
Type
A maximum of fifty
percent (50%) of the
total units within a
project can be in a
stacked dwelling
building type.
A maximum of one hundred percent
(100%) of the total units within a
project can be in a stacked dwelling
building type.
Housing Element Implementation (MCA 2024-70004)
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conditions and only require the issuance of building permits and payment of associated permit and impact fees. Attachment #2 provides the overview of the approval process and the eligibility for affordable housing streamlined approval.
The proposed amendment would add the following language to TOMC Section 9-
4.2816 Exempt Housing Projects:
Housing projects with at least 50 percent of base units deed restricted as affordable to lower income households that meets the requirements and process as further detailed in California Government Code Section 65913.4.
Following adoption of the ordinance, an application specific to this process will be created and information and materials will be made available to assist applicants.
ENVIRONMENTAL REVIEW
The proposed amendments are activities that were anticipated for the implementation of the adopted goals, programs and policies contained in the City’s recently adopted General Plan. The amendments are consistent with t he development density adopted in the General Plan and supporting elements and pursuant to CEQA Guidelines Sections 15183 and 15168 (c)(2) and (c)(5), no further environmental review or documents are required. The activit ies of amending project review procedures , development standards for affordable housing, and adopting ordinances to implement such programs will facilitate development as intended by the General Plan and the Housing Element and were analyzed under the certified Program EIR. These specific actions are called out as program implementation of the 2012- 2029 Housing Element. Any conceivable impact of the proposed amendments would also be speculative in the absence of specific development proposals.
CONCLUSION
The proposed Municipal Code Amendment implement s the measures set forth in the Council adopted 2021-2029 Housing Element by establishing ministerial approval for lot mergers, incentives for qualified housing projects with lot consolidation and a streamlined review process for SB -35 projects. These measures will further facilitate the processing of qualifying residential development projects and incentivize affordable housing to meet the Regional Housing Needs Assessment for the City of Thousand Oaks. This Municipal Code Amendment is necessary to maintain certification of the 2021- 2029 Housing Element by HCD.
Housing Element Implementation (MCA 2024-70004)
September 23, 2024
Staff recommends that the Planning Commission approve the draft resolution recommending that the City Council approve MCA 2024-70004 as set forth in the attached ordinance (Attachment #3).
Prepared by: Iain Holt, Senior Planner
Attachments:
Attachment #1 – Resolution Recommending Approval to City Council Attachment #2 – SB35 Streamlined Approval Process
Attachment #3 – Municipal Code Ordinance
CDD:660-21/kr/H:COMMON/Planning Commission/Agenda Packet/2024/2024-09-23/HE Prog Lot Consol SB35/07A Housing Element Implementation MCA-2024-70004 Staff Report/pz (FILE ID: MCA 2024-70004)
ATTACHMENT #s 1 and 3
(To the 9/23/2024 PC Packet)
To avoid duplication, the final, signed Planning Resolution and its Exhibi A (draft Ordinance) are included for Planning Commission Attachment #s 1 and 3.
ATTACHMENT #2
S
B35 Affordable Housing: Streamlined Approval Process
W
HAT IS SB35 AFFORDABLE HOUSING STREAMLINED APPROVAL?
SB-35 allows qualifying development projects with certain minimum affordable housing guarantees to move more quickly through the local government review process and restricts the ability of local governments to reject these proposals. This is a voluntary program that a project sponsor may elect to pursue, provided that certain eligibility criteria are met. The bill was signed into law in 2017 and became effective on January 1, 2018.
T
he bill created a streamlined approval process for infill developments in localities that have failed to meet their regional housing needs allocation (RHNA). The bill amends Government Code Section 65913.4 to require local entities to streamline the approval of certain housing projects by providing a ministerial approval process, removing the requirement for CEQA analysis, and removing the requirement for discretionary entitlements granted by the Planning Commission.
IS MY PROJECT ELIGIBLE FOR SB35 AFFORDABLE HOUSING STREAMLINED APPROVAL? In order to be eligible for streamlining, the project must meet all of the following criteria:
• Affordability: At least 50% of the proposed residential units must be dedicated as affordable to households at 80% AMI for either rental or ownership projects. In order to assure that the affordable units remain so dedicated, they must comply with the City of Thousand Oaks Inclusionary Housing Program with regard to monitoring, enforcement, and procedures for eligibility. • Number of Units: The development must contain at least two or more net new residential units. • Zoning and Residential Uses: The development must be located on a legal parcel or parcels that are zoned for residential uses. At least 2/3 of the floor area of the proposed development must be dedicated to residential uses.
• Location: The development must be located on a property that is not within a coastal zone, prime farmland, wetlands, a high fire hazard severity zone, hazardous waste site, a delineated earthquake fault zone, a flood plain, a floodway, a community conservation plan area, a habitat for protected species, or under a conservation easement.
• Demolition of Residential Units: The project does not demolish any housing units that have been occupied by tenants in the last 10 years; are subject to any form of rent or price control, or are subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of moderate, low, or very low incomes.
• Historic Buildings: The project does not demolish a historic structure that has been placed on a national, state, or local historic register.
• Consistent with Objective Standards: The project must meet all objective standards of the Zoning Code at the time of SB -35 application submittal. Such objective standards are those that require no personal or subjective (discretionary) judgment, such as objective dimensional requirements, and as otherwise set forth below.
• Prevailing Wages: If the development is not in its entirety a public work, as defined in Government Code Section 65913.4 (a)(8)(A), all construction workers employed in the execution of the development must be paid at least the general prevailing rate of per diem wages for the type o f
w
ork and geographic area.
(To the 9/23/2024 PC Packet)
• Skilled and Trained Workforce provisions: A skilled and trained workforce, as defined in Government Code Section 65913.4 (a)(8)(B)iii, must complete the development if the project consists of 50 or more units.
• Subdivisions: The development did not or does not involve a subdivision of a parcel that is subject to the California Subdivision Map Act, unless the development either (i) receives a low-income housing tax credit and is subject to the requirement that prevailing wages be paid, or (ii) is subject to the requirements to pay prevailing wages and to use a skilled and trained workforce. • Notification to California Native American tribes: After providing notice of the intent to develop the site to California Native American tribes that are traditionally and culturally affiliated with the geographic area of the proposed development site, a determination by the City that: the development site is not a tribal or cultural
resource on a national, state, tribal or local historic register list; that the parties to a scoping consultation have documented an enforceable agreement on methods, measures, and conditions for tribal cultural resource treatment; or that the parties to the scoping consultation do not disagree as to whether a potential tribal cultural resource will be affected by the proposed development.
WHAT IS THE PROCESS FOR STREAMLINED APPROVAL?
Prior to accepting an application for SB-35 approval, the City must notify relevant California Native American tribes about the proposed development. A notice of intent to submit an SB-35 application shall include a Project Application, SB-35 Application Supplemental, State Density Bonus application supplemental (if required), a Preliminary Application pursuant to SB-330, and architectural plans. If there is no response to the notification of intent or there is an agreement reached in a scoping consultation and the project application is deemed complete and eligible for SB-35 review, the project is eligible for SB-35 (ministerial) approval. If there is no agreement reached, a project is not eligible for SB-35 approval. Provided that the notification and scoping session result in either an agreement or no response, SB-35 timelines shall commence provide a building permit is submitted.
Projects that elect to take advantage of streamlining stipulated in SB-35 must submit a building permit application and an SB-35 Streamlined Development application demonstrating the project’s eligibility.
CEQA review is not required for SB-35 eligible projects because they are subject to a ministerial approval process. The building permit will not be subject to any applicable neighborhood notice requirements in the Zoning Code, and the Department will not accept Discretionary Review applications for these projects because they are subject to a ministerial approval process.
SB-35 includes timelines for streamlined review. Planning staff must determine if a project is eligible for streamlining within 60 days of application submittal for projects of 150 or fewer units, and 90 days for projects containing more than 150 units.
If the Department provides written comments to an Applicant detailing how a project is not SB-35 eligible as proposed, or requests additional information to make such a determination, then the 60 or 90 day timeline will restart upon submittal of a revised development application in response to that written notice.
Any design review or public oversight must be completed in 90 days for 150 or fewer units and 180 days for projects with more than 150 units, measured from the date of the SB-35 application submittal. The Development Services Director may decide, on a case by case basis, to schedule a design review hearing for an SB-35 project at the Planning Commission.
State Density Bonus Projects under CA Govt. Code Section 65915 Projects that use the State Density Bonus Program and meet all other eligibility requirements above qualify for streamlining under SB-35. Any waivers, concessions, or incentives, conferred through the State Density Bonus Law are considered code-complying, and therefore are consistent with the objective standards of the Zoning Code. In addition, qualifying 100% affordable projects may qualify for the State Density Bonus set forth in CA Govt. Code Section 65915.
cdd:660-21\H:COMMON\Planning Commission\Agenda Packet\2024\2024-09-23\HE Program 8 Lot Consol SB35\07A Housing Element Implementation MCA-2024-70004 Attach 2 SB35 Streamlined Approval Process\pz (FILE ID: MCA 2024- 70004)
To: Planning Commission
From: Kelvin Parker, Community Development Director
Date: September 23, 2024
Subject: Regarding Item 07A – Municipal Code Amendment (MCA) 2024-70004 The following contains proposed revisions to the Draft Ordinance for the Municipal Code Amendment (Attachment #3). Remissions are shown as strikethroughs and additions are shown as underlined follows:
Attachment #3 – Municipal Code Amendment:
• Pages 2, 3 and 5, change format of Code Section references consistent with other code references. For example: Section 9 -3.1218.c.1.i.(c)(1)(i) through c.1.vii.(c)(1)(vii) on page 2.
• Page 3, a mend Section 9-3.1218(c)(2) reads: “Unless otherwise specified in this Article, the voluntary merger application shall be processed ministerially without a public notice or hearing.” (page 3)
• Page 7, a dd to Section 9-4.2816 an ellipsis at the start of the new subsection (b ) and change the reference from “Government Code 65913.4” to “Government Code Section 65913.4”
cdd:660-21\H:COMMON\Planning Commission \Agenda Packet \2024\2024-09-23\Supplemental\09-23-2024Supplemental 1 .docx\pz [MCA-2024-70004]
CDD:660-21/ih//H:COMMON/City Council/CC Agenda Items/2024/12032024/ HE Prog Lot Consol SB35 MCA 2024-70004 Attachment 1 PC Report Reso Supplemental.pdf/pz (FILE ID: MCA 2024-70004)