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HomeMy WebLinkAbout1976-07-20; City Council; 3719; Lot Frontage Panhandle LotsI • Jfr ^ . *"•-•• -W^ '"'/_ , v^, . • >—> v-^- X ' CITY OF CARLSBAD ^^ t^ ' Initial; AG.EKDA BILL NQ. ^//7 •' • Dept. Hd.J DATE:' July 20, 1976 City Atty\ DEPARTMENT: "PLANNING _ _• ^ City'Mgr.fj i .rv />£/ SUBJECT: (ZCA-72) Lot Frontage (Panhandle Lots) Statement of the Matter At the direction of :the City Council, the Planning Commission drafted an ordinance amendment revising the method for approval of lots with substandard frontage (panhandle lots). Hearings were held and the draft approved as Exhibit "A" dated June 2, 1976 with modifications as noted in Planning Com- mission Resolution No. 1259. Generally this ordinance revision will permit panhandle lots if certain conditions exist and with the approval of the Planning Commission with minor subdivisions and the City Council with major subdivisions. The present method allowing panhandle lots is contained in City Council Resolution 816 and Supplemental Policy 12, which requires a Variance. For many reasons, this has not been an appropriate method to approve panhandle lots. Exhibi ts: Planning Commission Resolution No. 1259 Exhibit "A", June 2, 1976, ZCA-72 Staff Report, dated June 9, 1976 City Council Resolution 816 and Supplemental Policy 12 Memorandum to City Manager dated February 27, 1976 Letter from Jack Kubota dated May 6, 1976 Recommendation: If the City Council concurs with the recommendations of the Planning Commission, it is recommended that the City Council instruct the City Attorney to prepare the necessary documents adopting ZCA-72 as contained in. Exhibit "A" dated June 2, 1976 and modified by Planning Commission Re- solution No. 1259. Agenda Bill #3719 Page 2 July 20, 1976 Council action 7-20-76 Following the public hearing the City Attorney was instructed to prepare the necessary documents as recommended by Planning Commission Resolution #1259 and Exhibit "A", and that subsection (9) be more clarly defined. PLANNING COMMISSION RESOLUTION NO. 1259 RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CARLSBAD, CALIFORNIA, AMEND- ING VARIOUS CHAPTERS AND SECTIONS OF TITLE 20 AND TITLE 21 OF THE CARLSBAD MUNICIPAL CODE TO REVISE THE REGULATIONS REGARDING LOT FRONTAGE (PANHANDLE LOTS) CASE NO.: ZCA-72 APPLICANT: CITY OF CARLSBAD WHEREAS, the Planning Commission of the City of Carlsbad did adopt Rese- ts lution of Intention No. 128 declaring its intention to conduct a public hear- 9 ing to consider a Zone Code Amendment to revise the regulations regarding pan- handle lots; and WHEREAS, the Planning Commission received all testimony from those persons 12 interested in and opposed to, if any, the proposed Zone Code Amendment; and WHEREAS, the Planning Commission does make the following recommendations 14 which in their opinion are necessary to carry out the general purpose of Titles 15 20 and 21 of the Municipal Code; and T Pi The Planning Commission recommends that the City Council delete City Counci 17 Resolution No. 816 and Supplemental Policy No. 12 ("Panhandle" Lot Policies) and 18 that ZCA-72, Exhibit "A" dated June 2, 1976, as attached, be adopted with the 19 following changes: 20 (1) Modify subsection (1) of Section 21.08.080 and Section 21.10.080 21 as follows: 22 "(1) The area of the buildable portion of the lot shall be a minimum 10,000 sq. ft. or the minimum required by the zone if greater area is 23 quired. In zone districts permitting less than 10,000 sq. ft. lots, a panhandle lot may be less than this area provided evidence is sub- 24 mitted on a site plan that demonstrates that all requirements of this Section will be met; however, in no case shall the buildable 25 portion of the lot be less than 8,000 sq. ft. in area. Furthermore, such plan shall be considered the approved site plan and any future 25 modification to the parking and turnaround areas, or horizontal expansion of buildings shall be submitted to the Planning Com- 27 mission. The Planning Commission may approve, approve with condi- tions or deny any such modifications." 28 1 (2) Modify subsection (8) of Section 21.08.080 and Section 21.10.080 as follows: 2 "(8) Each lot shall have three nontandem parking spaces with an 3 approach not less than twenty-four feet in length with proper turn-around space to permit complete turn-around for 4 forward access to the street. This parking and access arrange- ment shall be designed to the satisfaction of the City Engineer." 5 (3) Delete subsection (9) of Section 21.08.080 and Section 21.10.080. 6 (4) Modify and renumber subsection (10) of Section 21.08.080 and Section7 8 9 10 n six feet beyond this point."11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 21.10.080 as follows: "(9) Structures permitted in the access portion of the lot shall be limited to mail boxes, fences, trash enclosures, landscape containers and name plates. Except for mail boxes, these structures shall not be greater than forty-two inches high within twenty feet from the street property line or higher than (5) Renumber remaining subsections of Section 21.08.080 and Section 21.10.080 for consistency. NOW, THEREFORE, BE IT RESOLVED by the Planning Commission of the City of Carlsbad that it does recommend approval to the City Council of an amendment to Title 20 and Title 21 to revise the regulations regarding panhandle lots as per Exhibit "A" dated June 2, 1976, attached hereto. PASSED, APPROVED AND ADOPTED at a regular meeting of the Carlsbad Planning Commission held on June 9, 1976, by the following vote, to wit: AYES: Comissioners Jose, L'Heureux, Larson and Dominguez. NOES: None. ABSENT: Commissioners Fikes and Watson. ABSTAIN: Commissioner Nelson. Stephen M. L'Heureux, Chairman ATTEST: Donald A. Agatep, Secretary 28 -2- ^ ' • O A F T x •'*' June 2. 1976Exhibit "A" BP:cpl ORDINANCE NO. AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA, AMENDING VARIOUS CHAPTERS AND SELECTIONS OF TITLE 20 AND TITLE 21 OF THE CARLSBAD MUNICIPAL CODE TO REVISE THE REGULATIONS REGARDING PANHANDLE LOTS. The City Council of the City of Carlsbad, California, does ordain as follows: SECTION 1: Title 21, Chapter 21.04 of the Carlsbad Municipal Code is amended by the amendment of Section 21.04.210 and 21.04.265 to read as follows: • 21 .04.265- Lot width. "Lot width" means the horizontal distance of the line constituting the required front yard setback, as required in certain zone classifications, or for those zone classifications without required front yards, the lot width is the horizontal distance between the side lot lines measured at right angles to a line comprising the depth of the lot at a point midway between the front and rear lot lines." SECTION 2: Title 21, Chapter 21.08 of the Carlsbad Municipal Code is amended by the amendment of Section 21.08.080 to read as follows: "21.08.080 Lot width. (a) In.the R-A zone every lot shall have.'a minimum lot width as follows: (1) Lots required to have an area up to ten thousand square feet, sixty feet; (2) Lots required to have an area..of-at least ten thousand square feet and up to twenty thousan-d square feet, seventy-five feet; (3) Lots required to have an area of twenty thousand square feet or more, eighty, feet. "" w •«**•(b) The City Council for major subdivisions or minor subdivisions on appeal and the Planning Commission for minor subdivisions may approve panhandle or flag-shaped lots where the lot width and yards shall be measured in accord with this section if the following circumstances are found to exist: (1) The property cannot be served adequately with a public street without panhandle lots due to unfavorable conditions result- int from unusual topography, surrounding, land development, or lot configuration. (2) Subdivision with panhandle lots will not preclude or adversely affect the ability to provide full public street access to other properties within the same block of the subject property. (c) In approving a panhandle lot a determination shall be made as to what portion of such lot shall be the buildable lot; for purposes of this chapter, the buildable portion shall be the entire lot exclusive of any portion of the lot less than thirty-five feet in width that is used for access to the lot. Also, a deter- mination shall be made on which property lines of the buildable lots are the front, sides and rear for purposes of providing required yards. (d) Any panhandle lot approved pursuant to this section shall meet the following requirements: (1) The area of the buildable portion of the lot shall not be less than twelve thousand square feet. (2) The width requirement for the buildable portion of the lot shall be met as required for interior lots in the zone district. (3) The yard requirements of the zone district shall be met as required for interior lots. (4) The length of the portion of the lot fronting on a public street or publicly dedicated easement afforded access to the bu.ildable lot shall not be greater than one-hundred-fifty feet for a" single lot or two hundred feet when two such lots are adjoining. (5) The minimum . width for such access portion shall be twenty feet except where the access portion is adjacent to the same portion of another such lot, in which case the required minimum frontage shall be fifteen feet. This is'with the condition that a joint easement ensures common access to both such portions as agreed upon by the owner of such lots and is so recorded. (6) An improved driveway shall be provided within the access portion of the lot from the public street or public easement to the parking area on the buildable lot of at least fourteen feet wide for single lots and twenty feet wide when serving more than one lot-; The minimum overhead clearance shall be 10 feet. The drive- way shall be constructed to accommodate public service vehicles with a minimum of two-inch thick asphalt concrete paving on proper base with rolled edges. (7) Drainage from the lot shall be channeled down the private access to a public street, or special drainage means must be provided to the satisfaction of the City Engineer. (8) EaclTlot shall have three non-N., nrfem parking spaces with a minimum backup area of twenty-four feet and designed to the satisfaction of the City Engineer. (9) A forty-two inch high enclosed refuse pickup area not . less than three feet by six feet in inside dimensions shall be pro- vided within the access portion, and within twenty-five feet of the public street frontage. This enclosure shall not encroach into the required driveway. (10) No structures, except trash enclosures, mail boxes, fences, landscape containers and name plates may be erected in the access portion of the lot. (11) The property owner of such a lot shall agree to hold the City or any other public service agency harmless from liability of any damage to the driveway when being used to perform a public service. (12) Any other condition the City Council or Planning Commission may determine to-be necessary to properly develop such property." SECTION 3: Title 21, Chapter 21.10 of the Carlsbad Municipal Code is amended by the amendment of Section 21.10.080 to read as follows: • ' "21.10/080 Lot Width: (a) In the R-l zone every,lot shall have a minimum lot width as follows: (1) Lots required to have an area up to ten thousand square feet, sixty feet; (2) Lots required to have an area of at least ten thousand square feet and up to twenty thousand square feet, seventy-five feet; (3) Lots required to have an area of twenty thousand square feet or more, eighty feet. (b) The City Council for major subdivisions or minor subdivisions on appeal and the Planning Commission for minor subdivisions may approve panhandle or flag-shaped lots where the lot width and yards shall be measured in accord with this section if the following circumstances are found to exist: (1) The property cannot be served adequately with a public street without panhandle lots due to unfavorable conditions resulting from unusual topography, surrounding land development, or lot configu- ration. (2) Subdivision with panhandle lots will not preclude or adversely affect the" ability to provide full public street access to other properties within the same block or the subject property. (c) In approving a panhandle lot a determination shall be made as to "what portion of such lot shall be the buildable lot; for pur- poses of this chapter, the buildable portion shall be the entire lot exclusive of any portion of the lot less than thirty-five feet in width that is used for access to the lot. Also, a determination shall be made on which property lines of the buildable lots are the front, sides and rear for purposes of providing required yards. (d) Any panhandle lot approved pursuant to this section shall meet the following requirements: (1) The area of the buildable portion of the lot shall not be less than twelve thousand square feet. (2) The width requirement for the buildable portion of the lot shall be met as required for interior lots in the zone district.. (3) The ua'rd requirements of the zone district shall be met as required for interior lots. .(4) The length of the portion of the lot fronting on a public street or publicly dedicated easement afforded access to the buildable lot shall not be greater than one-hundred-fifty feet for a single lot or two hundred feet when two such lots are adjoining. (5) The minimum width for such access portion shall be twenty feet except where the access portion is adjacent to the same portion of another such lot, in which case the required minimum frontage shall be fifteen feet. This is with the condition^ that a joi nt easement ensures common access to both such portions a-s agreed upon by the owner of such lots and is so recorded. (6) An improved driveway shall be provided within the access portion of the lot from the public street or public easement to the parking area on the buildable lot of at -least fourteen'feet wide for single lots and twenty feet wide when serving more than one lot. The minimum overhead clearance shall be 10 feet. The driveway shall be constructed to accommodate public service vehicles with a minimum of two-inch thick asphalt concrete paving on proper base with rolled edges. (7) Drainage from the lot shall be channeled down the private access to a public street, or special drainage means must be provided to tfje satisfaction of the City Engineer. (8) Each lot shall have three non-tandem packing spaces with a minimum backup area of twenty-four feet and designed to the satis faction of the City Engineer. (9) A fortyi-two inch high enclosed refuse pickup area not less than three feet by six feet in inside dimensions shall be pro- vided within the access portion, and within twenty-five feet of the public street frontage. This enclosure shall not encroach into the required driveway. - (10)No structures, except trash enclosures, mail boxes, fences, landscape containers and name plates may be erected in the access_portion of the lot. (ll)The property owner of such a lot shall agree to hold the City or any other public service agency harmless from liability of any damage to the driveway when being used to perform a public service (12) Any other condition the City Council or Planning Commission may determine to be necessary to properly develop such property." 3 SECTION 4: Title 21, Chapter 21.44 of theCarl sbad MunidipaV'Ctode is amended by the amendment of Section 21.44.030 to read as follows: "21.44.030 Limitation on issuance of building permit. No build- ing permit shall be issued for any building or structure to be erected on a lot having less than twenty feet frontage on a dedicated public street or a public dedicated easement accepted by the City or on a lot situated at the terminus of a street that should be extended. Where the panhandle or flag-shaped, portion of a lot is adjacent to the same portion of another -Such lot, the required minimum frontage on such street or easement shall be fifteen feet provided a joint easement ensuring common access to both such portions is agreed upon by the owners of such lots and recorded. The City.Council based on a report from the City Engineer-may.gr^nt an exception to the limitations of this section for lots situated at the terminus of a street that should be extended." SECTION 5: Title 21, Chapter 21.46 of the Carlsbad Municipal Code is amended by the deletion of Section 21.46.220. SECTION 6: Title 20, Chapter 20.16 of the Carlsbad Municipal Code is .amended by. the deletion of Subsection (8) and by the'amendment of Subsections (4), (5) and (6) as follows: "(4) Every lot shall have a width as specified in'litle 21 for the zone in which the lot is located at the time the final map is submitted. (5) Except for panhandle or flag-shaped lots approved pursuant to Title 21, lots whose side lines are approximately radial to the center of a cul-de-sac or the center of the intersection of two'dead-end streets shall have at least thirty-three feet of frontage measured at the right-of-way lines. «. -' (6) Panhandle or flag-shaped lots, if permitted pursuant to Title 21, shall have minimum frontage of twenty feet OQ a dedicated public street or publicly dedicated easement accepted by the City. Where the panhandle or flag-shaped portion of a lot is adjacent to the same portion of another such lot the required minimum frontage on such street easement shall be fifteen feet provided a joint easement insu- ring common access to both such portions as agreed upon by the owner of such lots and recorded." SECTION 7: Title 20, Chapter 20.24 of the Carlsbad Municipal Code is amended by the amendment of Section 20.24.090 to read as follows: "20i24.090 City Engineer — Duties. The City Engineer is author- ized and directed to carry out the duties assigned to him by this title including but not limited to the following: -5- (1) Obtain the recommendations of other Citv departments governmental agencies or special districts a! 'ma be deemeScts a may be deeme °Ut this chaDter^ndNSH-r ?"!! ten^ive P^cel map filed pursuant to (3) Refer to the Planning Department for report and to the Planning Commission for decision on any tentative parcel map contain- ing proposed panhandle or flag-shaped lots that do not meet the mini- mum lot width requirements of the zone but which may be permitted pursuant to Title 21. The processing of such maps shall be deferred until the Planning Commission has determined whether or not to approve the panhandle lots. If such lots are not approved, the City Engineer shall disapprove the map. If such lots are approved by the Planning Commission the City Engineer shall continue to process the map in accord with this chapter. (4) Approve, conditionally approve or disapprove tentative parcel maps, and report as provided in this chapter this approval, conditional approval or disapproval directly to the subdivider. (5) Waive the requirement for filing and recordation of a parcel map for certain subdivisions as provided for in this title." SECTION 8: Title 20, Chapter 20.28 of the Carlsbad Municipal Code is amended by the amendment of Section 20.28.020 to read as f ol 1 ows : "20.28.020 Panhandle-shaped lots. Other provisions of this £;i tie. notwi thstandi ng, a panhandle-shaped or flag-shaped lot, if permitted by Title 21, shall have a minimum frontage of twenty feet on a dedicated public street or publicly dedicated easement accepted by the City. Panhandles may not serve as access to arty lot except the lot of which the panhandle is a part. Where the panhandle or flag-shaped portion of a lot is adjacent to the same portion of another such lot, the required minimum frontage on such street or easement shall be fifteen feet provided a joint easement ensuring common access to both such portions is agreed upon by the property owner and recorded." EFFECTIVE DATE: This ordinance shall be effective thirty days after its adoption, and the City Clerk shall certify to the adoption of this ordinance and cause it to be published at least once in the Carlsbad Journal within fifteen days after its adoption. INTRODUCED AND FIRST READ at a regular meeting of the Carlsbad City Council held on the _ day of _ , 1976, and thereafter. -•• ......... ~ .................. " • --..,... ............... ..... . -6- PASSED AND ADOPTED at a regular meeting of said Council held on the day of , by the following vote, to wit: AYES: NOES: ABSENT: ROBERT C. FRAZEE, Mayor" ATTEST1: MARGARET E. ADAMS, City Clerk (SEAL) -7- WOODSIDE/KUBOTA & ASSOCIATES, INC. •NOINKERS 2965RooseveltSt. .P.O. Box 1095 .Carlsbad, California 92008* (714)729-1194 May 6, 1976 •Q Mr. Bud Plender, Assistant Planning Director City of Carlsbad 1200 Elm Ave. Carlsbad, Calif. 92008 Subject: ZCA-72 - Lot Frontage (Panhandle Lots) - City of Carlsbad. Dear Mr. Plender: Thank you very much for the opportunity to meet with you on Wednesday May 5, 1976, to discuss in detail the several suggestions of the under- signed with respect to the subject proposal. Specifically, we brought to your attention our concerns for the re- commendation that a "panhandle lot" have a lot area requirement different from the zoning of the area itself. Stated another way, we do not distinguish between a regular lot and a panhandle lot the problem of "useful lot area" with respect to the various private uses made of the property. If there are specific problems encountered by the City you should consider additional design features of the lots, which has the effect of reducing the "buildable" area of the lot, which the home- owner would understand. We also call to your attention that the proposed requirement for a trash receptacle along a private driveway may be very counter-productive to your goal; namely, a tidy neighborhood where the weekly trash pick- up will be properly screened off. It is the opinion of the undersigned that no matter what requirement you make for trash receptacles, the user will, by his conduct, determine what is really going on in the way of cleanliness. Our family has lived in the neighborhood for 18 years now as immediate neighbors to two panhandle lots created in the early 1950's, which have proved to be outstanding residential sites and dwelling units. Three of us share a common driveway, common trash pick-up area, and other fa- cilities, and have done so in complete harmony. We see a distinct advantage to the City and the potential home-owners in fine "panhandle lots". We share your enthusiasm in bringing about good controls and our goal here is to offer some constructive suggestions. In Orange County, Santa Ana t 1,,,-r, v i//.iyno.. "Si V MEMORANDUM, June 9, 1976 TO: PLANNING COMMISSION FROM: ASSISTANT PLANNING DIRECTOR ITEM: ZCA-72 - LOT FRONTAGE (PANHANDLE LOTS) REQUEST: A code amendment to provide for lots with reduced frontage if reasons exist for such reduction. RECOMMENDATION: It is recommended that the Planning Commission direct Staff to prepare for the City Council necessary documents for the approval of ZCA-72 as per Exhibit A, dated June 2, 1976, and the deletion of City Council Resolution 8l6 and Supplemental Policy No. 12. FINDINGS: 1. The amendment is in compliance with the Carlsbad Environmental Ordinance of 1972 since: a) The amendment will promote developmentinithe areas where services exist; b) The amendment will provide an alternative development method to rezoning properties to higher density. 2. The amendment is in compliance with the General Plan since: a) The General Plan encourages development in areas with existing services. 3. The amendment is desirable since: a) In areas of steep cult to provide full terrain, it is sometimes diffi- street access to all property; b) There are many narrow deep lots existing that cannot be subdivided with standard frontage and public streets are not practi cal . HISTORY;sbad processes panhandle lot requests Ordinance and a variance to the Zone ion Ordinance provides for processing stipulations that the frontage of the Presently Carl through the Subdivision Ordinance. The Subdivis panhandle lots with the "handle" have a minimum frontage of 20' on a dedicated street and a length of not more the street on which the For example, a 600-foot with a lot depth of 200 than two-thirds the distance from panhandle fronts to the rear lot line deep lot could have a handle of 400' The Zoning Ordinance, however, does not provide for panhandle lots. Zoning requires minimum lot widths to be measured from the setback line of the front yard. Some years ago it was decided that panhandle lots were desir- able in certain instances. Possibly because of time con- straints the more logical ordinance amendment method was not used and the City decided to create a policy that sets stan- dards and requires a variance (see Resolution 816 and sub- sequent Policy No. 12 attached). This method has two major drawbacks which are: 1. A policy does not establish criteria by law and can be enforced indistriminately; 2. Prior to approving a variance, certain findings must be met to meet State law. DISCUSSION: Background: At the March 11, 1976 meeting, the City Council reviewed the problem and history of panhandle lot development and directed Staff to prepare a draft ordinance and set the matter to Planning Commission hearing. The draft ordinance was prepared based on the following assumptions: 1. It is generally desirable for each lot to have legal frontage with access on a public street or private street approved through a planned development. 2. For normal circumstances this frontage should be adequate to provide driveways, on-street parking and areas for refuse pick up. 3. For unusual circumstances such as rough terrains or other outside influences, the Zone and Subdivision regulations should provide an alternative method to provide access to a lot. 4. Since these unusual circumstances must be discretionally determined, the decision should be made by the Planning Commission or City Council. 5. Lots with substandard frontages are appropriate in only the R-A and R-l zones. In multiple-family residential development zones, uses are permitted that have more traffic than can be accommodated safely with panhandles. 6. Panhandle lots do cause some problems in a residential area and therefore special requirements are needed to mitigate these problems. -2- Based on these assumptions the ordinance amendment was drafted doing the following: 1. Places regulations in the City Code instead of the Council policy; 2. Deletes the requirement of a variance for the approval; 3. Approval is to be by the City Council in major subdivisions and Planning Commission in minor subdivisions; 4. Prior to approval certain findings for the necessity of a panhandle must be made; 5. Certain development standards are required for panhandle lots; 6. Panhandles are to be limited to the R-A and R-l Zones. 7. Redefine lot and lot width; 8. Amends Subdivision Ordinance accordingly.. For discussion regarding policy decisions reviewed by the City Council,'please refer to a memorandum to the City Manager dated February 27, 1976. SPECIFIC COMMENTS ON ZCA-72: The following is a discussion of the draft ZCA-72. Please refer to Exhibit A, 6/2/76, for reference. Section 1, Definition: To accommodate the proposed changes, the definition of lot width needs amending. The present definition requires the measurement to be taken at the mid- point depth of the lot. With a panhandle lot, the midpoint is harder to determine and this requirement is unnecessary anyway. The attached ordinance does not include a revised definition for "Lot" since the City Council recently adopted such revision when adopting ZCA-64 (PUD Ordinance). Sections 2 and 3: The section of the R-A and the R-l Zones re- garding lot width was reworded though the requirements remain the same. The major change is the new section added to the R-A and R-l Zones that permits lots with private access. The key point of this section is that a panhandle lot must have an area of at least 12,000 sq. ft. and the access is not counted in this re- quirement. Also, the Planning Commission will determine if the private access is viable for each particular lot based on topo- graphy and surrounding land uses and lot configuration. Other requirements are basically those required in the present policy. -3- Section 4.5, 6, 7, 8: These sections amend the Subdivision Ordinance for consistency with the amendment to the Zoning Ordinance. The major change is to provide for Planning Commission approval of parcel maps with panhandle lots. Correspondence: Staff received a letter from Jack Kubota, of Woodside/Kubota Assoc., Inc. regarding a couple of items in the proposed amendment. Specifically, they are "lot area" and trash receptacle. Staff did not change the proposal based on Mr. Kubota's concerns, but we do suggest the Planning Com- mission consider them. Attachments: Exhibit A, dated 6/2/76 City .Council Resolution No. 816 Supplemental Policy No. 12 Memorandum to City Manager from Planning Director, 2/27/76 Letter from Jack Kubota, 5/6/76 BP:cpl/mdp (6/3/76) -4-