HomeMy WebLinkAbout1990-03-13 - AGENDA REPORTS - GH PALMER ASSOC DEVAGMT (2)•
PUBLIC HEARING
DATE:
SUBJECT:
DEPARTMENT:
Ll
AGENDA REPORT
City Manager Approval.
Item to be presented' y:
Mark Scott
March 13, 1990
Proposed Development Agreement,
G. H. Palmer Associates
Community Development /v6
Overview
The City of Santa Clarita and G. H. Palmer Associates are proposin g•.
to.enter into a Development'Agreement. Under the terms:of the.
proposed agreement (attached)',,G. H. Palmer Associates,agrees`to
construct or to pay for..numerous.,and substantial road' system
improvements
which,' 'in aggregate, far exceed the normally required..
development exactions. In return for this conside.ration,.::the;City
would approve various project applications by. G. H: Palmer
Associates, and.would agree to hold various development codes and
regulations constant as. they relate to these projects.for,a.period
of ten years. (A more detailed explanation of these provisions is
provided below.)
What is a Development Agreement?
As per the League of California Cities legislative task force on
development agreements:
A development agreement does not take the place of any:of the:
existing.land use approval requirements. It is like.a planned
unit development which is used for complex development
proposals to set forth the basic outline of the development.
The difference is that under a development agreement -both the
city and the developer are committing themselves to proceed in
accordance with the terms of the agreement. The city may
agree to process further applications in accordance with its
i plans and laws in existence at the time of the agreement. In
effect, the city promises not to change its planning or zoning
laws applicable to this development for a specified period of
gime. Thus future land use decisions are not made according
to the cities' laws and policies in effect at that time, but
are made according to the laws in effect when the agreement
was entered into. In return, the developer may agree to
Agenda
Item:
construct specific improvements, provide public facilities and
services, develop according to a specified time schedule or
make other commitments which the city might otherwise have no
authority to compel a developer to perform.
There are no precise requirements setting forth exactly what
must be contained in a development agreement or exactly at
what stage of the approval process a development agreement may
be entered into. The laws applicable to development
agreements (Government Code Section 65864 et seq.) were
deliberately written to be flexible. They are designed to
allow the public agency and the developer to enter into an
agreement corresponding to the specific problems that are
raised by a particular development.
Statutory requirements indicate that a development agreement
must specify the time during which the city agrees not to
change its regulations, the permitted uses of the property,
the density or intensity of uses, the size of buildings, and
provisions for dedication or reservation of land for public
purposes. The agreement may also include any other terms and
conditions including time schedules for development or
additional public services and facilities to be provided by
the developer.
Required Actions
In order to be approved, a development agreement must ultimately be
adopted by ordinance of the City Council. Prior to this action, the
City's Planning Commission is required to hold a public hearing
following proper public notice. The Planning Commission does not
approve or disapprove the development agreement. Rather, it makes a
recommendation in writing to the City Council. In most instances,
the recommendation must include the Planning Commission's
determination whether or not the proposed development agreement:
(1) is consistent with the objectives, policies,
general land uses and programs specified in the
City's general plan (see below);
(2) is compatible with the uses authorized in, and the
regulations prescribed for, the land use district
in which the real property is located (see below);
(3) is in conformity with public convenience, general
welfare and good land use practice;
(4) will be detrimental to the health, safety and
general welfare;
�5) will adversely affect the orderly development of
property or the preservation of property values.
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In the case of the City of Santa Clarita, which currently operates
without an adopted General Plan, State law provides that instead of
Findings 11 and 12 (above), the Planning Commission must make
findings whether or not the proposed development agreement meets all
of the following requirements:
(1) There is a reasonable probability that the land use
or action proposed will be consistent with the
General Plan proposal being considered or studied
or which will be studied within a reasonable time.
(2) There is little or no probability of substantial
detriment to or interference with the future
adopted General Plan if the proposed use or action
is ultimately inconsistent with the plan.
(3) The proposed use or action complies with all other
applicable requirements of state law and local
ordinances.
The Current Proposal
The Planning Commission has now reviewed the Development Agreement
and the individual projects associated with it. Both the Santa
Catarina and the Vista Terrace projects were approved, conditioned
on adoption of the Development Agreement. The Colony Project was
denied. The Planning Commission recommends adoption of a revised
Development Agreement absent those portions which relate to The
Colony.
In order to pursue construction of the City's much needed road
system, the City approached G.H. Palmer Associates to determine
whether there might be an opportunity to obtain road funding as part
of a development agreement which would, in turn, secure approval of
various proposed development projects. In summary, the original
agreement calls for the applicant to construct or otherwise fund the
following improvements:
* Golden Valley Road would be fully improved to 4 travel
lanes within the Santa Catarina project, and graded for 4
lanes/paved for 2 lanes from the project to Soledad Canyon
Road.
* The applicant would acquire right-of-way and construct
Newhall Ranch Road (graded for 4 lanes/paved for 2 lanes)
from its intersection with Golden Valley Road to the
existing easterly terminus of Newhall Ranch Road.
* The applicant would also contribute $3 million to be used
toward the cost of constructing the Rio Vista Road bridge
from Bouquet Canyon Road to Soledad Canyon Road.
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* As part of his Westcreek project, the applicant would
improve Rio Vista Road through that project and would
realign Dockweiler Road to the City's specifications. (It
should be noted that in order to achieve these
improvements, the applicant would remove already
constructed road improvements and utilities, and construct
them again on new alignments. The work required herein is
very substantial and more costly to the applicant than one
might otherwise recognize without visiting the site.)
* As part of his Vista Terrace project, the applicant will
participate in private, joint funding of Golden Valley Road
from Sierra Highway to the Antelope Valley Freeway
(including 4 lanes of paving, bicycle paths and a gateway
entry treatment).
* As part of The Colony project, the applicant will construct
Jake's Way to 4 -lane width through the project to its
terminus at Sierra Highway. The applicant will also
complete Lost Canyon Road through his project and will
construct the bridge improvements over the railroad
property, with the understanding that he may be (but is not
guaranteed to be) reimbursed for the bridge by other future
development projects which benefit by the construction.
In consideration of the above, under the original Development
Agreement proposal, the City would approve several development
proposals, including:
* Tentative Tract Map No. 45022 and related applications for
the project known as Vista Terrace (at Golden Valley Road
and Sierra Highway).
* Tentative Tract Map No. 31236 and related applications for
the project known as Santa Catarina (Southwest of Sky Blue
Mesa).
* Vesting Tentative Tract Map No. 45023 and related
applications for the project known as The Colony (east of
the Antelope Freeway and west of Woodfall Road).
* Agreement to allow the affordable housing requirement (for
226 units) for the applicant's Westcreek Project to be
transferred to a nearby, existing multi -family residential
project which is also owned by the applicant.
* Agreement, through the Development Agreement, that
approvals will be good for a period of ten years and that
various rules of development (i.e., zoning codes, fee
schedules, etc.) will be held constant for the duration of
the agreement.
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As with any Development Agreement, there are publicly negotiated
trade-offs involved. In return for the substantial funding of road
system improvements, the applicant has received expedited
application review and would benefit from a secured, 10 -year
approval of projects.
City Council Review Procedures
Staff had previously noticed the Development Agreement and related
projects for City Council public hearing on March 13. This was done
as a good faith gesture toward the applicant who has some severe
time limitations involving the financing on his Westcreek project.
Because there are now appeals pending on several elements of the
package, however, it is necessary to do further public
notification. Therefore, the formal City Council public hearings
cannot be started on March 13. Staff is suggesting the following
sequence of meetings:
March 13 - Staff introduction of the Development Agreement and
related projects, and continue the public hearing
to March 27
March 27 - Formal public hearings and possible first reading
of ordinance to adopt the Development Agreement
April(tba) Any continued public hearings and second reading of
ordinance to adopt
The March 13 session relating to the Development Agreement should be
confined by the City Council to receiving information from staff and
the City Attorney,.and for the City Council to seek any
clarifications of fact or analysis that the Council may desire prior
to formal public hearings. It is not advisable to receive any
public testimony from either the applicant or the general public on
March 13.
Regarding the March 27 formal public hearings, the City Council will
want to conduct them in the following manner:
I. Development Agreement
Open the public hearing to receive overview comments only.
(Specific testimony on the various projects should be made
under the project -specific public hearings.)
* Staff report by Director of Community Development
* Overview comments by City Manager and Public Works
Director
* Testimony by applicant (G. H. Palmer Associates)
* Public comments in favor
* Public comments in opposition (or "other").
- Prior to rebuttal comments or City Council comments, recess
the public hearing and move on to the specific project
public hearings. (City Council will return to this public
hearing later.)
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II. Santa Catarina Project
- Open the public hearing (a consolidated public hearing on
any appeals and on rezoning for the site)
- Staff report by Director of Community Development
- Testimony by applicant
- Public comments in favor
- Public comments in opposition (or "other")
- Applicant's rebuttal
- City Council questions of staff or any speaker
- Close the public hearing
- Entertain a motion
- Discussion on motion
- Vote to approve, deny, or continue
III. Vista Terrace
- Open the public hearing on the appeal
(Note: Staff anticipates that the appellants may opt to
defer this hearing pending City Council review of the
Development Agreement. This situation is described in
detail below.)
IV. The Colony Project
- Open the public hearing (a consolidated public hearing on
an appeal, prezoning and annexation)
- Staff report by Director of Community Development
- Testimony by applicant
- Public comments in favor
- Public comments in opposition (or "other")
- Applicant's rebuttal
- City Council questions of staff or any speaker
- Close the public hearing
- Entertain a motion
- Discussion on motion
- Vote to approve, deny or continue
V. Return to Development Agreement Hearing
- Ask for any additional staff comments (the public hearing
will still be open)
- If desired, accept any additional public comment
Applicant's rebuttal
- If appropriate, close public hearing or continue the public
hearing
- If closed, entertain a motion
- Discussion on motion
- Vote to introduce ordinance approving the Development
Agreement, deny or continue
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Support Documents
Staff has included various documents in this binder to support the
City Council's review of the various applications. These materials
include:
Tab 1 Development Agreement
* Copy of the original Development Agreement (as proposed to
the Planning Commission)
* Copy of the revised Development Agreement (as modified by
the Planning Commission to remove The Colony project)
* Copy of G.H. Palmer Associates agreement with the School
Districts which affect Santa Catarina and The Colony
projects.
Tab 2 Santa Catarina Project
* Copy of the resolution of approval for this project
* Copy of letter from G.H. Palmer Associates to Charlotte
Belsick regarding proposed changes to the Santa Catarina
approval
* Copy of the March 1 staff report to the Planning Commission
* Copy of the February 6 staff report to the Planning
Commission
* Copies of materials received in testimony from the public
Tab 3 Vista Terrace Project
* Copy of the resolution of approval for this project
* Copy of the March 1 staff report to the Planning Commission
Tab 4 The Colony Project
* Copy of the March 1 staff report to the Planning Commission
* Copy of the February 6 staff report to the Planning
Commission
* Copy of letter from Sanford Goodkin supporting the land use
proposal.
The City Council was previously given copies of the environmental
documents for the Santa Catarina, Vista Terrace and The Colony
projects. Staff has not distributed copies of the numerous traffic,
soils, geology, architectural and other background consultant
reports. If City Council members feel a need to see any of this
material, staff will make it available.
Similarly, the Santa Catarina project file includes a great deal of
correspondence from residents in the area, and the Development
Agreement file includes numerous letters of support that had been
sent tg the Planning Commission. Staff has not included all of
these materials in this binder, but will attempt to organize these
materials and make copies available to the City Council under
separate cover prior to March 27.
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ANALYSIS
The remainder of this report will be dedicated to summarizing the
issues relating to the three specific projects. This review will
include a summary of Planning Commission comments on each.
SANTA CATARINA
Due to the extensive coverage, this project is no doubt familiar to
the City Council. The project application calls for construction of
1,452 condominium units on a site of roughly 135 acres. There would
be 10 lots created, with a maximum of 11 dwelling units per acre.
The applicant is requesting zone change from A-2-1 (Heavy
Agricultural) and M-1.5 (Restricted Heavy Manufacturing) zoning to
RPD -11U zoning (which means Residential Planned Development, 11
units per acre). A conditional use permit (CUP) was also approved
to implement this zoning. (The staff reports under Tab 2 provide
greater detail.)
During the Planning Commission process, three public meetings were
held by staff with residents of the neighborhood and numerous
smaller sessions were also conducted both in City Hall and on-site.
Staff estimates that more than 150 residents participated in one or
more of these meetings. The applicant also participated in many of
the sessions.
Both the Planning Commission and the residents addressed numerous
questions to staff and the applicant during this process. Staff
asked the applicant to respond to many of these questions and his
written reply is provided as part of the March 1 staff report,
included under Tab 2.
After extensive public testimony, staff recommended approval of the
project on the basis that the following questions had been
adequately answered:
Question #1 Is the Development Agreement concept a reasonable
and realistic concept7
Staff answer: Yes. The concept is that the City needs to find a
means to catch up with years of infrastructure
deficit (in this case for roads) without assessing
citywide debt or taxation. While many residents
expressed concern that the Santa Catarina project
would create new traffic, staff sees the situation
as one where the net gain far outweighs any new
traffic flow, and that the eventual full system of
roads will resolve the existing traffic congestion
problem. This project represents a necessary first
step for the City.
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Question #2 Are the environmental reports and mitigations
adequate for this project?
Staff answer: Yes. After exhaustive review by the community and
various agencies throughout the State and the
region, there do not appear to staff to be any
unmitigated and significant impacts. As mentioned
in the March 1 staff report, the applicant worked
with staff to mitigate or eliminate those concerns
expressed by the Planning Commission and
residents. Briefly, these included:
Schools - The applicant entered into agreements
with the Hart and Saugus Districts. (A copy of the
agreement is included under Tab 1.) An attorney
representing the Districts appeared before the
Planning Commission supporting the agreement. Some
residents felt the Districts should not have CP
agreed, but the City has no control, obviously,
over.that situation.
Interface Impact with Existing R-1 Homes - The
applicant provided charts illustrating that the
nearest existing homes were more than 300 feet away
from the closest of the Santa Catarina units, and
were elevated by at least 100 feet above the Santa
Catarina units.
Further, the applicant worked with staff and made
dramatic upgrades to the quality and design of the
condominium project. Extensive landscaped
buffering will also be provided. The City will
have complete architectural and landscape design
control to ensure this level of quality. The
result will be that the interface with existing
homes will be controlled.
Because of these design and topographical
mitigations, staff saw no reason for concern over
interface problems.
Traffic - Residents felt strongly that the project
would contribute to more traffic through their
residential streets (particularly Ermine and
Steinway). City traffic engineers felt equally
strongly that the net impact would be to reduce the
traffic impacts on the.existing area, although it
is clear that Ermine Street, at and near the point
of connection, would receive increased traffic
volume.
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After working extensively with the neighbors, staff
altered its recommendation to provide that Ermine
Street would be connected, but not opened at least
until the Santa Catarina project is completed and
until other arterial roadway connections are made
to the satisfaction of the Planning Commission and
City Council. Further public review would be
required.
Staff does believe that the Ermine Street
connection will eventually be deemed desirable, but
it is not necessary to serve the Santa Catarina
project.
Utility Capacities - Staff is unaware of any
capacity problems with any of the local utility
providers.
Hillside. River and Open Space Needs - The
applicant agreed to City review and approval of all
grading work. He also agreed to dedicate Lot 10,
along the Santa Clara River, to the City to allow
protection of the river environment. Similarly,
the canyon area on the eastern end of the project
will be maintained as natural open space.- Staff is
unaware of any significant, unaddressed concerns
relating to hillside and river matters.
Question #3 Can the City Support the proposed multi -family
residential land use for this site?
Staff answer: Yes. This is the most difficult of the four
questions to answer. However, the applicant has
made it simpler by designing a sensitive hillside
project and preserving so much open space area.
Several considerations are relevant:
* This entire area is not suited for single-family
residential use. The site is split by the Golden
Valley Road alignment and it is located very close
to a major arterial intersection of Highway 126 and
Golden Valley Road. Further, the site looks down
over an industrial development.
* Given the above, it is likely that, at minimum,
some transitional treatment between residential
uses would be desirable within or near the site.
* From a topographical standpoint, the separation in
grade from Label Avenue makes it a logical
transitional point. (Golden Valley Road itself
creates the other obvious possibility.)
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While staff joined the Planning Commission in wishing for less
density, staff advised that the land use consistency issue could be
answered in the affirmative.
Question 14 Is the project itself acceptable?
Staff answer: Based on all of the above and the sensitive design
treatment, staff feels the project is very
acceptable.
The Planning Commission accepted the staff recommendation and
approved the project on a 4-1 vote. Commissioner Garasi commented
that the applicant had made substantial improvements that brought
the project nearly to where she could support it, but that the land
use and density concerns still caused her concern.
The applicant followed up the Planning Commission meeting by
accepting the challenge by Mayor Darcy and other City officials to
keep working with the neighbors to try to resolve their ongoing
concerns. On March 6, the applicant and one of the neighbors
presented a further compromise which they wish to have considered by
the City Council. The substance of this compromise is included in
writing under Tab 2, and can be summarized as follows:
* Reduction in the density of the project on Lots 3,
4 and 9 by replacing multi -family attached units
with single-family detached units.
* Contribution of $75,000 toward sound buffering of
nearby homes through joint committee with the
residents.
* Contribution of $50,000 for maintaining and
enhancing the riparian on the east side of the site.
* Contribution of up to $100,000 for park
improvements on a hillside pad between the
applicant's property and nearby residents'
properties.
* Agreement to dedicate land for a fire station at
the northerly end of the applicant's property.
In consideration for the above, the applicant and the residents
joined in asking the City to modify the Development Agreement and
Tract Map to delete the $3 million Rio Vista bridge contribution,
the pedestrian bridge over Golden Valley Road, and the obligation to
construct or bond for the northerly portion of Golden Valley Road.
Staff supports only reduction of the bridge contribution, not to
exceedc$3 million. Staff does not support the other two requests
regarding the pedestrian crossing and the Golden Valley Road
extension.
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Lease vs. Sale of Units - One other issue not mentioned above is the
issue of lease vs. sale of units. The applicant is well aware of
the City Council's sentiments and has stated that his intent is to
sell all units. The Planning Commission sought to include language
memorializing this agreement, but the City Attorney's office and Mr.
Palmer's attorney both advised that such language is not legal.
However, Mr. Palmer did agree to include a provision stating that if
the units are ever leased, the lessee will be given an opportunity
for lease -purchase of the units. Staff is not certain of the
enforceability of such language, but if reflected the best effort of
the Planning Commission, staff and the applicant to meet the City
Council's objective.
VISTA TERRACE
The Vista Terrace project was very well received by the Planning
Commission and was approved conditioned upon approval of the
Development Agreement.
Vista Terrace is one of five private developments which are working
together to pursue construction of Golden Valley Road improvements
as called out under this portion of the Development Agreement. The
City is working with these parties in hope that a mutually
satisfactory assessment district structure can be established for
this purely private improvement financing.
The parties to this proposed financing have appealed the Planning
Commission's approval, seeking to remove the condition requiring
approval of the Development Agreement. In fact, staff would be
willing to consider dropping the condition, but not while the
Development Agreement is still being actively pursued on the
expedited timeframe.
As for the Vista Terrace project itself, the Planning Commission had
reviewed it several months earlier and asked for several
modifications. The developer had met all of those conditions to the
satisfaction of the Commission, so they approved the project
unanimously.
THE COLONY
The application for The Colony calls for subdivision, pre -zoning and
annexation of a vacant 46.2 acre site adjacent to the Antelope
Valley .Freeway. The applicant is seeking to construct 800
condominium units, with appurtenant parking, landscaping and
recreation facilities. They are seeking an R -3 -17U -DP zoning,
meaning Limited Multiple -Family Residential, 17 dwelling units per
acre, Development Program zoning. A conditional use permit (CUP)
would be necessary to implement the project.. An Oak Tree Permit is
also included to allow possible intrusion within the protective zone
of three California Coast Live Oaks. However, the applicant has
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indicated that this may not be needed.
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The project is currently within the County of Los Angeles and is not
clearly contiguous to the City. The applicant would be required to
secure annexation to exercise any entitlements, and is aware that
this is his obligation to satisfy. The City would agree, under the
Development Agreement, to cooperate in seeking the annexation.
(Additional detail concerning the project is provided in the
February 6 staff report under Tab 4.)
As with the Santa Catarina project, the Planning Commission asked
staff and the applicant, during the February 6 public hearing, to
address a number of concerns. The applicant's responses to those
issues are incorporated in the March 1 staff report under Tab 4.
At the March 6 continued public hearing on The Colony, the applicant
presented several oral arguments in support of his proposal,
including:
(a) Design - The project architect presented a model
and renderings of a very different and good quality
architectural design for the project. The design
provides for significant upgrading of the quality
of the project and appeared to be well-received by
the Planning Commission. Landscaping designs were
also presented, depicting both internal landscaping
and the buffering provided along the site exterior.
(b) Circulation - The applicant explained his agreement
to construct the Lost Canyon bridge over the
railroad property. Mr. Palmer will seek City
support in requiring future projects in the City to
reimburse their proportionate share of the cost.
(c) Coordination with Neighboring Projects - At the
Planning Commission's request, Mr. Palmer met with
John Morrisette and with Bill Kloyd concerning
their adjacent projects. Staff attended the
meeting with Mr. Morrisette and it appeared to
resolve coordination issues. Mr. Kloyd testified
at the March 6 public hearing and expressed a
variety of sentiments, some favorable and some
unfavorable toward The Colony project.
(d) Land Use - Mr. Palmer prepared and presented an
overall evaluation of land uses on the eastside of
the Antelope Valley Freeway. His conclusion was
that the best location for non-residential uses
would be further south --either at the conjunction
of the 14 Freeway and Route 126 or at San Fernando
Road. He presented a report by real estate
economist Sanford Goodkin stating that The Colony
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site is inadequate for non-residential uses because
of the limited size and inadequate freeway access.
Mr. Goodkin's report is included under Tab 4.
(Further staff comment on these arguments is
provided below.)
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The Planning Commission eventually voted 4-0 to deny the project.
In doing so, they asked staff to communicate to the City Council the
following reasons for their action:
(a) The Commission felt that approval of
multiple -family residential land use is
inconsistent with the work the GPAC is doing, and
that it is premature to approve it without full
evaluation of the GPAC's position.
(b) Commissioners felt that Business Park zoning should
be evaluated for the site, though they acknowledged
that it may not prove to be the proper land use.
(c) It was felt that the need for jobs creation on the
east side of the City should be addressed before
new residential zoning is granted.
(d) The Commission asked for evaluation to determine
how much multiple -family residential development
can be supported in the Canyon Country area.
(e) The need for berms, walls and/or grade separation
from the railroad tracks was cited as a very
serious concern, for sight and should attenuation
and to protect the safety of residents.
(f) Commissioners expressed doubts over the use and
design for the strip of property south of the
railroad.
(g) The Commission suggested further evaluation of the
river and how/whether some sort of channelization
is needed.
Staff's position on The Colony project was that time had not allowed
staff to perform the comprehensive planning analysis that the
Planning Commission had desired. Due to the public's involvement,
staff's attention over the last month has been primarily focused on
the Santa Catarina project. It should be understood that this does
not represent opposition to The Colony. In fact, there may be
compelling reasons to support it. These include:
(a) The County has adopted the Canyon Park/Provence
Specific Plan, which calls for multiple -family
residential development across a broad portion of
the land to the south of The Colony. This could
possibly create conflict with the GPAC's tentative
plan.
jb) The on/off ramps at Jake's Way are designed only as
a half -cloverleaf. Without encroaching upon the
river, there are problems and extreme costs
associated with any plans for a full cloverleaf.
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(c) If freeway access is restricted, then traffic to a
business park in the area (per GPAC) will either
have to approach from the south on Lost Canyon Road
(through a residential area) or from Sand Canyon
Road (past the elementary school and Pinecrest
Centers).
Staff felt that further study of these issues and those of the
Planning Commission would lead to proper decisions on The Colony
proposal. Staff will continue to work diligently in an effort to
clarify these issues. The GPAC's continued review of the land use
map (including a scheduled workshop on Saturday) may also be of
assistance.
City Council Options
As indicated, the March 13 meeting is only an introductory session,
so formal City Council action, other than continuance of the public
hearing, is not necessary or appropriate. City Council comments or
questions will, however, be appreciated.
On or after March 27, the City Council will have several options,
including:
(1) Adoption of the entire Development Agreement
package, including Santa Caterina, Vista Terrace
and The Colony.
(2) Adoption of a reduced Development Agreement
package, with reductions to the Santa Catarina
and/or The Colony projects.
(3) Denial of the Development Agreement, with or
without approval of any of the three projects.
(For example, the Vista Terrace project could be
adopted with or without the Development Agreement.)
(4) Variations of the above.
Staff will be pleased to address any further City Council questions
on March 13.
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