9A
Date: August 11, 2026
To: Honorable Mayor and Members of the City Council
From: Michelle Ramirez, Community Development Director
By: Austin Lujan, Planning Assistant | [email protected] Subject: Community Development – Supplemental Material #2 for Agenda Item 9A
DISCUSSION
Attached herewith for your consideration is a correspondence received after the item was prepared and distributed.
ATTACHMENTS
1. Email regarding public comments
2. Correspondence
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From: Ramirez, Michelle
Sent: Monday, August 10, 2026 2:02 PM
To:
Cc: Lieu, Betty <[email protected] >; Kalani, Sharon <[email protected] >; City Clerk <[email protected] >;
; Chaparyan, Aram <[email protected] >; Santana, Danny <[email protected] >; Huizar, Carlos <[email protected] >; Garcia, Robert <[email protected] >; Lujan, Austin <[email protected] > Subject: RE: Tuesday night's Agenda item for MHE25-00051
Good Afternoon Ms. ~
My name is Michelle Ramirez, and I am the Community Development Director for the City of Torrance. Thank you for your email and for bringing this matter to our attention.
I would like to clarify that the discrepancy you noted was simply a scrivener’s error. The project number was correctly identified earlier in the notice, and all other information, including the applicant’s name and project address, is accurate.
Please be assured that all public comments submitted under either project number, MHE25-00051 or MHE26- 00051, will be accepted and included in the public record.
As a reminder, all comments submitted before 5:30 pm today will be published for public review prior to the meeting. Comments received after 5:30 pm, but before the adjournment of the meeting, will also be accepted and added to the record.
I hope this helps clarify the matter. Should you have any additional questions or concerns, please feel free to reach out to me.
Thank you again for your interest and for taking the time to contact the City.
MICHELLE RAMIREZ
Community Development Director - Community Development Department 310-618-5996 | [email protected]
TorranceCA.Gov |
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This email, and any attachments to it, may contain confidential information and is intended for the sole use of the intended recipient(s). If you are not the intended recipient, or believe that you may have received this email in error, please notify the sender and delete this email and any attachments.
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From:
Sent: Monday, August 10, 2026 12:33 PM
To: Kalani, Sharon <[email protected] >; Lieu, Betty <[email protected] >; City Clerk <[email protected] >
2 ATTACHMENT 1
Cc:
Subject: Tuesday night's Agenda item for MHE25-00051
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Good afternoon Honorable Mayor, Council Member Lieu and Ms. Poirier, It has been brought to our attention that the notice sent to surrounding neighbors last week listed the wrong MHE number (see below) for public comment. I volunteered to reach out on all our behalf. We would like confirmation that all comments submitted will be included in the record despite the city’s error on this notice.
Thank you in advance for your attention to this matter.
Kindly,
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ATTACHMENT 2
2 Hillside Exemption, may make mandatory findings concerning height, mass, views, light, air, privacy, compatibility, and cumulative impacts while disregarding the second story physically attached to and constructed above the garage. It may not. The City must evaluate the structure that will actually be built – the project as a whole.
At bottom, the staff report rests on a perceived clash between two codes that do not, in fact, conflict. The report treats the ministerial ADU statutes and the discretionary Hillside Overlay as though honoring the former requires the City to disregard the latter. There is no such conflict. Nothing in the ADU laws directs the City to pretend that a structure it must otherwise count “toward the overall height and number of stories” simply vanishes when the Council weighs height, mass, views, light, air, and privacy under the Hillside Overlay. The two codes operate on the same physical building and are readily reconciled: the City may approve the ADU ministerially while still describing—and making findings about—the complete structure that will actually be built.
I. The Staff Report Expressly Segments A Single, Integrated Structure
The garage and ADU are not physically independent projects. They appear in the same plans, occupy the same lot, and form a single attached structure. Indeed, the Code defines a “structure” broadly as “[a]nything constructed or erected which requires location on the ground or attached to something having a location on the ground,” and the garage together with the ADU built upon it is a single such structure. The ADU sits on top of and beside the proposed garage. Although the garage alone may measure approximately 10½ feet high, the complete integrated structure reaches approximately 23½ feet and is two stories. The physical presence of the second story does not disappear merely because the ADU is processed ministerially.
The Torrance Municipal Code addresses this precise circumstance: an attached ADU “shall count towards the overall height and number of stories of the structure it is attached to.” TMC § 92.2.10(E)(5)(C). The staff report does not analyze that language. It does not explain why the attached ADU counts toward the structure’s height and stories under the ADU ordinance but may be disregarded when the City determines whether that same structure qualifies for streamlined review under the Hillside Overlay.
Instead, the report measures the garage alone at 10½ feet, compares that isolated measurement to the 14-foot Minor Hillside Exemption threshold, and concludes that the proposal qualifies. That reasoning establishes only that the garage component, if it stood alone, would be below 14 feet. It does not establish that the complete two-story structure shown in the plans qualifies for a Minor Hillside Exemption. In reality, there is no component of this project that stands apart at 10½ feet.
The distinction is decisive. The Council need not exercise discretion over the ADU to recognize the ADU as a physical fact. Nor does considering the completed building’s height, mass, and impacts amount to denying the ADU. It simply ensures that the Council’s findings on the separate discretionary entitlement describe the project that will actually exist. And, that the project will be subject to the Precise Plan, as any proposed project more than 14 feet tall in Hillside Overlay Zone is required to be.
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The segmentation also drove the City to the wrong review track altogether.
Development within the Hillside and Coastal Overlay is presumptively “subject to approval by the Planning Commission of a Precise Plan,” subject only to narrow exceptions that do not apply here. TMC § 91.41.1(a). Consistent with that framework, the City’s own standards call for a noticed public hearing for “projects that involve building envelope expansions or new structures that do not involve an ADU.” This project expands the building envelope—the attached garage grows from approximately 401 square feet to 694 square feet, and the roofline rises to approximately 23½ feet to accommodate the second story—yet the Director elected to process it as a Minor Hillside Exemption rather than require a Precise Plan of Development.
Only by treating the integrated structure as a stand-alone 10½-foot garage can the streamlined exemption be made to fit.
The consequence is not merely procedural. The Precise Plan process is where the Hillside Overlay’s substantive protections are actually applied. Among other things, it requires the applicant to install story poles (silhouettes) demonstrating the height, width, and depth of the proposed development so that the decision-makers and the public can assess its true effect on the view, light, air, and privacy of surrounding properties. TMC § 92.21.11. Because the City did not require a Precise Plan, no story poles were installed, and no comparable objective analysis of the completed structure was performed. The very review designed to evaluate the impacts at issue here was bypassed.
II. The Report Uses Inconsistent Project Descriptions
The staff report alternates between two incompatible descriptions of the proposal. For purposes of the Minor Hillside Exemption, it describes only a 694-square-foot, 10½-foot-high garage. But in discussing General Plan consistency, the same report recognizes “one and two- story additions” to the residence.
The City cannot consider the second story when it supports a finding of General Plan consistency while declaring that same second story irrelevant to height, compatibility, views, light, privacy, and Hillside Overlay review. The governing findings must be based on one consistent and accurate description of the physical development. The findings must incorporate the plan in its entirety.
This inconsistency is especially important because the Planning Commission identified the same problem. The staff report acknowledges that the Commissioners found the plans incomplete, had difficulty evaluating the project while being instructed not to consider the ADU, and unanimously determined that required findings E, F, G, H, I, and J were not met.
Following public testimony and deliberation, the Commission voted unanimously (7-0) to deny the project, identifying findings E, F, G, H, I, and J, as not being met and that the project lacked sufficient information and advised the applicant to revise the project. The recommendation to reverse that decision does not meaningfully answer the Commission’s concern; it repeats the instruction that caused the concern in the first place.
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III. The Proposed Findings Address The Garage, Not The Completed Building
The draft resolution makes each material finding about the “proposed garage” alone. It states that the garage will not substantially affect view, light, air, or privacy; has been designed to cause the least intrusion; will harmonize with nearby properties; will not harm neighboring property values; will not be materially detrimental; and will not cause an adverse cumulative impact. Those findings do not address the completed development. A garage-only finding cannot establish that the structure with an attached second-story ADU will cause no substantial impact or the least possible intrusion. The second story contributes height, mass, bulk, windows, and potential view and light obstruction. Each is directly material to the Hillside Overlay protections the Council must apply.
The report’s impact analysis illustrates the resulting gap. Staff concludes that the garage will not affect views because neighbors to the east sit at a higher elevation, and that existing vegetation will protect the northern neighbor’s privacy. But the report does not analyze: the view or light impacts of the second story; obstruction of western light for properties below the project; whether existing vegetation is permanent, protected, or tall enough to screen second- story construction; the completed structure’s compatibility with nearby one-story residences; or the cumulative effect of allowing integrated two-story projects to obtain streamlined review by isolating their lower components.
The gap is especially clear when the report’s conclusions are measured against the specific findings the Hillside Overlay requires. Those findings turn on whether the development will adversely affect and has been designed to cause the least intrusion upon, the “view, light, air and privacy of other properties in the vicinity,” and whether it provides “orderly and attractive development in harmony with other properties in the vicinity.” TMC § 91.41.6. On each, staff substituted its own subjective conclusion for the objective analysis the Overlay contemplates—stating, for example, that “in the judgment of staff” the garage will not have an adverse view impact because the neighbors to the east sit higher, without analyzing the approximately 23½-foot roofline or the properties situated below and to the west. Nor does the report address whether the same living area could have been provided through a single-story attached design that would intrude far less on surrounding views and light.
The “harmony” finding is equally unsupported. The surrounding neighborhood is characterized by one-story, ranch-style homes—long, low profiles with broad, low-pitched roofs. The proposed structure instead presents a two-story, modern design with a high, steeply pitched roof, contemporary windows lacking the shutters or divided panes found on the existing house, a modern garage door, and none of the rake-board detailing of the primary residence. Set on a downslope lot, that design adds conspicuous mass when viewed from the street and from the properties below, and combines two discordant architectural idioms on a single site. A finding that the completed structure will present “orderly and attractive development in harmony with other properties in the vicinity” cannot rest on a description that omits the very second story responsible for the incompatibility.
These omissions are not ancillary. They concern the precise findings required for approval. Under Topanga Assn. for a Scenic Community v. County of Los Angeles (1974) 11 7 5
Cal.3d 506, the findings must bridge the analytic gap between the evidence and the agency’s decision. Findings directed to a hypothetical garage-only structure cannot bridge that gap where the plans show a materially taller, two-story building.
IV. The Report Does Not Provide Complete Development Calculations
The report lists proposed lot coverage of 40 percent and a floor-area ratio of 41 percent, but its statistical table identifies only the existing residence and the proposed garage; it does not identify the ADU’s floor area or show the calculations underlying those percentages.
The report therefore does not establish whether the attached ADU was included in lot coverage, floor-area ratio, or net-interior-area calculations. Nor does it address whether the complete project exceeds the net-interior-area threshold requiring a Precise Plan of Development. If staff believes some or all ADU area must be excluded from a particular calculation, the report should identify the governing provision and show the calculation. A conclusory statistical table that omits the ADU cannot support the necessary threshold determination.
The record also contains unexplained numerical inconsistencies. The report describes the lot as 6,736 square feet but lists it as 6,719 square feet in the statistical table. The original neighborhood notice described a 790-square-foot garage, while the recommendation now concerns a 694-square-foot garage. The report is also internally unclear about the existing garage, which it describes as “401′-6″”—a figure that does not plainly state whether staff means 401 square feet or a linear dimension. These discrepancies should be corrected before the Council relies on the report’s calculations or approves the entitlement. Not least of all because the public is entitled to comment on the actual project proposed.
V. The CEQA Determination Uses The Same Incomplete Project Description
The recommended action asks the Council to determine that “the project” is categorically exempt under CEQA Guidelines section 15301. Yet the environmental discussion supports that recommendation only by stating that additions to a “one-story single-family residence” are categorically exempt.
That description conflicts with the report’s acknowledgment that a second-story ADU and “one and two-story additions” are proposed. The report does not identify whether the CEQA project includes the ADU, whether the ADU is being treated under a separate exemption, or whether the environmental determination considers the complete physical development. Even if a categorical exemption ultimately applies, the City must accurately and consistently identify the project to which it applies.
VI. The Draft Resolution Contains Material Procedural Irregularities
The draft resolution presented for the August 11, 2026 meeting recites that the Council already conducted a hearing, upheld the appeal, and approved the request on July 14, 2026. Yet, the report itself is dated August 11, although its internal page headers also refer to July 14. 8 6
These provisions should not appear in a proposed resolution before the Council has acted. At minimum, they suggest that the recommendation and findings were not fully updated to reflect the present proceeding and record.
The Council should not adopt findings that inaccurately recite a prior approval or appear to predetermine the outcome of the pending hearing. A corrected resolution and staff analysis should be circulated before any approval is considered.
Separately, the report departs from ordinary practice in a way that compounds these concerns. On appeal, staff typically carries the Planning Commission’s action and findings forward and explains its recommendation in relation to them. Here, the report says little about the Commission’s unanimous findings and instead recommends reversal with scant objective analysis of its own. The Council is thus asked to overturn a 7–0 denial without a reasoned staff response to the findings on which that denial rested.
VII. Requested Action
For these reasons, we respectfully request that the Council deny the Applicants’ appeal and affirm the Planning Commission’s denial without prejudice. The Planning Commission correctly recognized that it could not make the required findings on incomplete plans and an artificially narrowed description of the project.
At minimum, the Council should continue the matter and direct staff to prepare a corrected analysis that:
1.Defines the complete physical project, including the attached second-story ADU;
2.Applies TMC § 92.2.10(E)(5)(C) to the height and number of stories of the integrated structure;
3.Provides complete and transparent lot-coverage, floor-area-ratio, and net-interior-area calculations;
4.Requires story poles (silhouettes) under TMC § 92.21.11 and an objective analysis of the completed structure’s height, width, and depth and of its effect on views, light, air, and privacy;
5.Determines whether the complete structure requires a Precise Plan of Development rather than a Minor Hillside Exemption;
6.Evaluates the completed structure’s effects on views, light, air, privacy, neighborhood compatibility, and cumulative impacts;
7.Responds separately and with supporting evidence to each of findings E through J that the Planning Commission determined could not be made;
8.Uses the same accurate project description for the entitlement analysis and CEQA determination; and
9.Corrects the discrepancies in the project dimensions, lot area, meeting dates, and proposed resolution.
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