PURPOSE:

To present alternative methods and a recommendation for regulating the concentration and separation of second dwelling units (granny flats) in single-family neighborhoods.

And:

To present recommended language for a notification to be sent to adjacent and nearby property owners advising them of a proposed second dwelling unit, and also advising them of the limitations on appeals of decisions regarding second units.

BACKGROUND:

On April 1, 2003, City Staff presented a draft ordinance to the City Council with  proposed amendments to the Burbank Municipal Code (BMC) regulations for second dwelling units in the single-family zones (Exhibit B).  The changes: a) deleted certain requirements of the code in response to court rulings and state legislation (AB 1866) regarding occupancy and discretionary review of second dwelling units; and, b) proposed a number of new development standards to help regulate second units in the aftermath of these rulings and legislation.

The Council directed staff to further research and report back on two of the proposed amendments.  First, the Council desired information on alternative methods for regulating the separation and concentration of second dwelling units on a neighborhood (street or block) level.  Second, the Council also directed staff to develop language for a notice to be sent to property owners in the vicinity of a proposed second dwelling unit project informing them of the proposed development, but also advising them that avenues of appeal from a decision to allow development are necessarily extremely restricted under State and City regulations.

ANALYSIS:

Alternatives for Regulating Separation and Concentration:

In researching the original (June 10, 2002) ordinance amendment report, the Planning Staff did a survey of second unit ordinances in 50 California cities.  Most of the second unit ordinances surveyed do not address the question of concentration or separation of second units at all.  Most of the ordinances reviewed do not set any standards or requirements specifically limiting the concentration of, or requiring separation between, approved second dwelling units.  For many of these cities over-concentration has not been a real problem as they have never received any significant number of applications for second units.  However, among those ordinances that do address the topic, we found a number of different approaches various cities have taken to help ensure the separation and prevent over-concentration of second dwelling units.

1.  Addressing Concentration Without Specific Standards:

Among the minority of ordinances that do address second unit concentration, some  simply state that over-concentration should not be allowed, but set no specific standards.  The Lancaster Municipal Code, for example, reads:

�The second dwelling shall not contribute to a high concentration of such units sufficient to change the character of the surrounding neighborhood.� [�17.08.360: D3]

and Stockton�s code states:

�The secondary unit [should] not contribute to such a high concentration of these units sufficient to change the character of the surrounding residential neighborhood� [�16-42-290: H2]

Both Lancaster and Stockton currently require discretionary permits for second units[1]  While this direction may be sufficient if not ideal guidance to a Planning Board or other deliberative body, now that second unit approvals must be approved ministerially Staff cannot recommend this approach, as it does not provide sufficient or clear enough standards to guide ministerial approvals.

2.  Limiting Number of Second Units by Neighborhood, Census Tract or Other Area:

A second approach is to limit the number of second units by specific sub areas of the City.  The San Diego Municipal Code (which refers to second units as �companion units�) states:

�Companion units are permitted only if the total number of companion units in the community plan area in which the proposed companion unit is located does not exceed 5% of the detached primary dwelling units within that community plan area.� [�141.0302: (c)]

The City of Seattle used a similar approach by limiting secondary units to 20% of all single-family structures in single family zones in any one census tract.

This approach, while having the advantage of a clear numerical standard, has the disadvantage that it may not prevent over-concentration on the level of individual streets or blocks.  A typical residential area census tract has around 30 to 50 blocks.  San Diego community plan areas vary widely from 20 to 25 blocks to some plan areas with hundreds of blocks.  So, this approach still allows the possibility of concentrating a high number of second units in a given small area (say on one block or street) of the census tract or community plan area. 

It is worth noting that Seattle subsequently deleted this requirement when the number of second unit applications they received turned out to be less than expected.  They have approved about 300 second units (in a City with 133,000 single-family units) in 15 years. San Diego is in the process of revising their ordinance to comply with AB 1866 and their community plan area limit is also proposed to be deleted.  They report having received 27 second unit applications since 1989. 

It would be theoretically possible to take this idea to its logical extreme by setting either a number or a percentage or proportion for second unit lots on a per block level, but in practice neither blocks nor lots are uniform in size.  Larger or longer blocks should logically be allocated more second units.  Areas with large lots may be able to support more second units relative to the number of lots without suffering from say parking, noise, open space, etc. problems.  Staff has not found an example of a city that limits second units to a set number per block as such.

3.  Limiting by Units per Net Acre or Square-footage:

Therefore, another approach might be to set a limit on second units per a given unit of land area, say per acre or per hundred-thousand square feet, or similar.  It is common to limit or at least describe overall residential density in this manner, and some cities do limit second units in essentially this way.  The Costa Mesa Municipal Code, for example, states that:

Accessory apartments shall be limited to those lots large enough to support two units without exceeding the general plan density of units per acre for the lots on which they are to be located [�13-35(b)].

This is essentially a per acre limitation even though it is applied on a per lot basis.  In effect in Costa Mesa second units are treated just like primary units and the total of all units has to meet the general plan per acre density limit.

Burbank�s General Plan, however, specifically exempts second dwelling units from density limits.  Section III A.1.a. of the Land Use Element (Exhibit C) sets an overall density of seven dwelling units per net residential acre in the Single Family Low Density plan area (pg. 14), but goes on to state:

It is a policy of this plan that second dwelling units be allowed on single family lots in conformance with state law.  This use is considered to be consistent with the Single Family designation and will not be included in density computations (pg. 15).

According to Burbank�s General Plan coordinator (Barbara Lazar) this last sentence only means that second units are exempt from the seven units per acre standard, not that they cannot be put under any density computation.  Therefore, we could set a separate density or separation limit for second units.  That is set a given number of allowed second units per net residential acre, which would be in addition to, but separate from the number of primary units per acre.

One problem of course is that an acre, unlike a block or a lot, does not have set boundaries. How do we determine the boundaries of the acre against which the proposed second unit is to be counted?  Which lots will be counted as part of the acre, which are not?  Burbank�s seven units per acre standard simply reflects the code required minimum lot size of 6000 s.f. which multiplies out to about seven units per acre.

4.  A Per Acre Limit on a Per Block Basis:

Daly City gets around this by limiting the number of units on a �block face� (meaning one side of one street block) based on the net acreage of the lots on the block face.  Daly City Municipal Code [�17.14.100 A7] requires:

The secondary unit � will not result in a new residential density in excess of the established density factor.  Consistency with the density requirements will be determined on a block face segment basis using the following formula:

            SU = (NA x DF) � DU

The formula gives the remaining second unit capacity of the block (SU) by multiplying the net acreage of all the single-family lots on the block (NA) by a per-acre density factor (DF - in Daly City this is sixteen), and then subtracting out the number of existing units and vacant lots (to reserve capacity for vacant lots).

This approach is similar to the idea of establishing a cap on the number of units on a block except that because it establishes a limit on units per acre it takes into account differing block and lot sizes.  Larger blocks may have more units.  In neighborhoods with larger lots, a higher percentage of the lots will be able to have second units as long as the total number of units per acre stays under the prescribed limit.  However, the formula does produce a number which is the number of units that will be allowed on a given �block face�.  The opposing block face has its own quota, the block face to the rear, its own, and so forth.  According to Daly City officials they took this approach because the biggest problem they have encountered with second units is on-street parking[2]. 

It would be possible to use a formula like this to regulate by square blocks as well as block faces.  In the areas of Burbank which follow a regular grid pattern, a �one-century� block has 20 to 24 lots which total approximately 3� acres net of alleys, street rights-of-way, etc. and a �two-century� block has 42 to 50 lots and is about 7� acres net[3].  Daly City sets a limit of 16 units per net residential acre. This includes both main units and second units.  Given the utility restrictions discussed below, the limit on total number of dwelling units per acre (primary and second units) in Burbank should not be higher than about eight total units per net acre which will mean one or two second units per net acre.

One problem with limiting second units either to a certain number per block or establishing a density limit based on the size (acreage) of the block is defining what a �block� is.  In the gridded areas of Burbank, this is not a problem, but in the hillside area above Sunset Canyon Drive there are frequently no �blocks� as the term is usually used, and deciding where to set the limits for measurement will be a problem.  A possible solution is to use the house numbering system established by the Public Works Department.  House numbering on streets above Sunset Canyon Dr. continues with new �centuries� starting at more or less regular intervals. This would work well if a per �block face� limit were used; less well if the limit was per square block.

Another problem might affect a small number of neighborhoods in Burbank where there are concentrations of small 25 ft. wide lots.  These lots, while adding to the net acreage of the block, cannot accept any of the second units (being under the 6000 s.f. minimum lot size) thus squeezing that block�s �quota� onto the remaining lots.  A possible solution would be to exclude non-eligible lots from net acreage calculations.

A more intractable problem, though, is still the one of over-concentration, even within a single block.  Consider the case presented in Exhibit D.  Even if Burbank were to set a second unit density of say one per net acre it would still be possible on a 3� net acre block for a situation to arise where the owner of lot �A� finds himself surrounded by lots with two units on them � in what is ostensibly a single-family neighborhood.

5.  Required Minimum Separation:

In our April 1, 2003 report, Staff discussed limiting concentration through a minimum radial separation.  Exhibits from that report showing the effects of 300 ft. and 500 ft. radial separations are repeated here as Exhibits E-1 to E-4.  A map showing the effect of requiring a 200 ft. minimum separation are added as Exhibits E-5 and E-6[4].  As can be seen, a 200 ft. separation will allow about three second units on a �one-century� block or five to six on a �two century� block[5].  Staff estimates that the maximum total number of second units possible city wide with a 200 ft. separation would be around 2680 units[6].  If the radial separation were reduced to 100 ft. (Exhibit E-7) this would make it possible to put four units on most one century blocks and up to eight on the longest blocks.

As was mentioned in the first report, Planning Staff found one other City that required a radial distance separation between second units.  That was Salinas which requires a 500 ft. separation, but only between non owner-occupied units.  They have no separation requirement for owner-occupied units.

6.  Linear vs. Radial Separation:

Since many of the problems associated with concentrations of second units such as traffic and parking occur on the street rather than on the lot as such, the idea of requiring a linear separation along the line of the street has also been suggested.  This idea was discussed at some length in the January 27, 2003 Staff report to the Planning Commission.  Exhibits F-1 to F-4 show 500 ft. and 300 ft. separations on typical blocks.  Corner lots present an interesting problem for linear separation to decide which street (possibly both) to measure the linear separation along (see Exhibits F-5 & F-6).  A 500 ft linear separation would allow essentially one second unit per block face, and a 300 ft. separation would allow two per block face on regular blocks and four on the longer blocks.  A number of blocks in Burbank have R-1 lots facing three streets which could allow for an extra second unit on these blocks depending on how the linear separation is measured (Exhibit F-7).

One drawback of strict linear separation is that it would still allow back-to-back second unit lots.  Therefore, the Council indicated interest in the possibility of requiring one linear separation distance along the direction of the street and a shorter one perpendicular to the street.  Exhibits G-1 and G-2 show how this might work on some typical blocks with the longer distance measured along the street front and the shorter separation perpendicular to it.  In practice while this would increase the total number of possible units city wide by eliminating the overlap onto adjacent blocks, it would result in the same maximum possible per block limit � two units on a �one century� block or four on a �two century� block - as a 300 ft. radial separation requirement.  It is difficult to estimate the maximum possible number of second units citywide with this regulation, but it would be somewhere between 1800 (300 ft. radial separation) and 2600 (200 ft. radial separation) units, probably closer to the lower number. 

7.  Combining a Per Acreage Density Limitation with a Radial Separation

A possible compromise would be to combine a per acre density limit such as Daly City�s (although with a lower density factor) and a modest radial separation requirement.  A 100 ft. separation requirement would mean that there would always be at least two lots between any two second units, and no one lot could be surrounded on all sides (as in Exhibit D) or even on two sides with second unit lots, and would prevent back to back units.  Combining this with a limit of say one second unit per net residential acre (or alternately eight total units per net residential acre) to limit the overall number on the block would work to control the overall density but still allow for some flexibility in the location of lots within the block.  As was noted above though, this approach will work well in areas with regular blocks, but in certain areas, e.g. above Sunset Canyon Dr. it will be difficult to define what the �block� is.

City Utility Capacity Limits on Concentration of Second Units:

In previous reports to the Planning Board and the City Council, Staff has discussed the impacts of second dwelling units on such conditions as traffic, parking, open space, and noise, among other things.  The concentrations of second units discussed heretofore (one or two units per block) have not been such that utility delivery systems e.g. water, sewer and electricity were potential limiting factors on second dwelling unit concentrations on the neighborhood level.

Planning Staff consulted with the Public Works Dept., Burbank Water and Power (BWP) Water Division and Electrical Division and the Fire Department to determine if the ability to deliver utility services would place an upper limit on the concentration of second units on the individual block level.  The Public Works Dept. sewer engineers indicated that even if every lot on a block had a second dwelling unit of the size allowed in the ordinance (500 s.f.), it would probably not overload the sewer capacity on the block or neighborhood level - although if a very large number of lots in the city or in a sub-area of the city (say the whole hillside area) had a second unit, it could affect certain downstream facilities such as collector sewer mains.

BWP Water Division and the Fire Department, likewise, have few concerns regarding their ability to deliver water including fire flow.  Block level water mains have enough capacity to maintain water service even when a fire is being fought on the block.  In the unlikely event of several fires on one block (say a wildfire or earthquake) water storage capacity would become a limiting factor before water main capacity.

BWP Electrical Division engineers on the other hand did have concerns regarding delivery of electrical power.  They indicated that in most single-family areas of the City, if more than about 25% of existing units on a typical block had a second dwelling unit, then electrical power delivery capacity could be strained - at least under some circumstances.  While they emphasized that under most conditions their delivery capacity is ample, on certain hot summer afternoons, when demand for air-conditioning peaks in single-family neighborhoods, block level electrical power distribution capacity would be stressed if demand increased by more than about 15%.  Given that second dwelling units are smaller and produce less demand than ordinary houses they translated this into about five second units on an ordinary block with about 20 lots.  The longer �two-century� blocks have more lots, but also have more service capacity.  There are a few areas of the City with newer facilities that could potentially handle more demand. 

The BWP Staff observed that, unlike new commercial and multi-family developments which pay utility impact and replacement fees, single-family developments are not subject to utility impact or upgrade fees, thus replacement costs to upgrade single-family neighborhood service would have to come from other sources. 

Planning Staff notes that, as revised, BMC �31-625.5(c) still requires individual determination of the adequacy of utility services.  Thus, if a proposed second unit would potentially over-extend utility capacity, it could still be denied, even if the second unit density on the block in question was under the established limit.  All building plans, including residential extensions, are routinely routed to BWP for approval.

Based on this, Planning Staff cannot recommend any density standard which would result in the number of second units being higher than about 25% of the number of existing single-family units.  This translates to about five second units on most blocks.  If we used the seven units per acre standard from the General Plan, a 25% increase would mean about 8.75 units per acre i.e. seven primary units and 1.75 second units.  But seven units per acre is a theoretical maximum based on 6000 s.f. lots.  Standard Burbank R-1 lots are in fact larger than this; 6,750 s.f. (or about 6.5 per acre) in the valley area, and 7,750 s.f. (5.6 per acre) in the hillside area.  A 25% increase over actual existing (rather than theoretical maximum) density gives a maximum of about 8.125 total (primary and secondary) units per acre.

Staff Recommendation:

Staff recommends adopting a 200 ft. radial separation requirement.  As can be seen from Exhibits E-5 and E-6, this will limit second units to about three per �one century� block or up to six per �two century� block.  This is well below the �25% of the number of primary units� standard dictated by the limitation on electrical service capacity.  In fact, it works out to between 12% and 15% of the number of primary units.  The advantage of a separation requirement is that it prevents the situation described in Exhibit D, which a straight per acre or per block density limit does not.  A 200 ft. separation will prevent back to back second units, but will allow second units on the adjacent blocks.  A simple radial separation requirement is equally applicable in all areas of the city, which limits depending on blocks are not.  Staff originally recommended a 500 ft. radial separation which would minimize concentration of second units to about one per block, however, Planning Staff does not find that allowing three second dwelling units on an average block will have excesive effects on noise, traffic or parking. There is at least one block in Burbank that already has three existing legal second units on it.

Proposed Notice to Nearby Property Owners:

AB1866 requires that after July 1, 2003 applications for second dwelling units must be �considered ministerially without discretionary review or a hearing� [CGC �65852.2 (a)(3)].  The City Attorney�s Office has interpreted this to apply to appeals of second unit approvals also.  That is, they must be considered ministerially, and not under a procedure that gives discretion to the reviewing authority.  This means appeals of second unit approvals will be very limited in scope.  The reviewing authority cannot use its discretion to decide if a project is a good idea or is appropriate, it may only review what the ministerial authority � in this case the Community Development Director - has already decided, which is whether or not the proposed project meets the requirements of the applicable Municipal Code sections.

In light of this, City Staff proposed in the April 1, 2003 report to the City Council, that henceforth second unit applications be processed like other ministerial building permit approvals in the single-family areas.  The Council indicated they would like to see a process that provided notice to surrounding property owners and provided for appeals, however limited in practice. The Council directed the Staff to provide proposed language for a notice to be sent to nearby property owners informing them of a forthcoming decision to approve a second dwelling unit, but which also informs them that appeals of such decisions are limited under law.  Again, there are a number of possible ways to approach this requirement.

Using the Development Review Process:

It may be possible to adapt the Development Review procedures in BMC �31-1908 to �31-1914 to second unit approvals.  As long as second unit applications are processed according to procedure 3) as defined in BMC �31-1908, then DR can be considered a ministerial approval.  Section 1908 states, �it is the intent of the City to process projects in the third category through a ministerial � process.�  BMC �31-1912(a) states that such projects �shall be approved if the Director, or if appealed the Planning Board or the City Council, finds that all provisions of this code will be complied with�.

If the DR procedure is used for second unit approvals, certain changes will have to be made to the DR regulations.  BMC �31-1914(1) currently exempts single-family developments in single-family zones from DR, and BMC �31-1908 states that multi-family residential projects within 500 ft. of the R-1 zone must be processed under procedure (2), which allows for discretionary review.  These changes are straightforward. 

The fairest way to deal with the fact that there will necessarily be a limited number of second unit opportunities on any given block or street is to simply approve permits on a first-come first-served basis by the date the application is accepted by Planning.  But, by taking advantage of the maximum allowed time periods for plan submission available under the DR and the building permit process it is theoretically possible to tie up one of the second unit opportunities on the block for up to 2� years.  The DR regulations should be amended to require that submitted plans that are not code compliant must be corrected within a specified period, and also to require that unless actual construction has taken place within a stated time period the second unit permit will lapse and go to another applicant.

If second dwelling unit applications are to be processed as Development Review applications, Staff recommends the notice the Council desires be included in the notice required by BMC �31-1909(g).  Since last year the Planning Division has been providing required property owner notices including those for Development Review on postcard type mailers in the format shown in Exhibit H-1.  Staff recommends adding language like the following to such notices in the case of second unit applications:

APPEAL �Approvals of Second Dwelling Units are subject to both state law and the Burbank Municipal Code (BMC).  Revisions to California Government Code �65852.2 mean that, after July 1, 2003, appeals of second dwelling unit approvals are limited to specific violations of the BMC development standards for such units.  Therefore, any appeal of this decision must state which particular development standard(s) in the BMC the project will violate, and how particularly it will violate that standard.

A Procedure Specific to Second Dwelling Unit Approvals:

Another alternative could be to develop a specific procedure for approvals of second dwelling units in the single-family zones.  The advantage of using a specific procedure is that it will allow for more flexibility in tailoring the procedure to the specific problems associated with second unit approvals - such as the limitations in the State statutes.  For example, as has been pointed out elsewhere, the DR procedures are written in such a way as to potentially give an unrealistic impression of the possibilities for appeal in second unit cases.  A procedure specific to second unit approvals could address this problem as well as set requirements for public noticing, fees, approval procedures and timing, appeal periods, requirements and limitations, etc. etc. tailored specifically to the needs of second unit approvals.

On Council direction, the City Staff will develop a new procedure for second unit approvals which incorporates the Council�s direction regarding noticing and appeals.  Even with a new process, Staff will likely recommend using the same format for notices to nearby residents and property owners as is used for DRs (as well as CUPs, variances, and all other procedures requiring property owner notice).  Exhibit H-2 is an example of how such a notice might appear.  Staff finds that language the same as or greatly similar to the above would be appropriate to such notices. 

Staff Recommendation:

If the Council wishes to ensure nearby property owners and residents are notified of applications for approval of second dwelling units, then Planning Staff recommends including language such as the above either in a DR notice or as part of a procedure tailored specifically to second dwelling unit approvals.  Staff will present amendments to the Development Review procedures, or a new procedure tailored specifically to second dwelling unit approvals at the Council�s direction.

CONCLUSION:

As was noted in the conclusion to the April 1, 2003 Staff Report, the Appeals Court ruling in the Coalition case, and the action of the State Legislature in AB 1866, make the task of satisfactorily regulating second dwelling units noticeably more challenging.  The question of how to prevent over-concentration of such units on the neighborhood level - in essence how to prevent a block or street from becoming an ipso-facto R-2 neighborhood is particularly difficult. 

All of the approaches presented above have drawbacks.  Some have been pointed out in the body of the report.  Even the staff recommended option, to require a radial separation has drawbacks.  As a commentator at the April 1 hearing pointed out, we will be in the position of saying to one property owner that you can do this, and to his or her neighbor that you can�t do this because your neighbor already has.  The City, of course, does this already for other uses.  If one neighbor opens a large family-home-day-care, we pre-empt any neighbors within 500 ft. from doing so (BMC �31-684(9)); and although there are currently no examples in Burbank, if a commercial property owner were to allow an adult oriented business, we would not allow his or her neighbors within 1000 ft. the same use (BMC �31-1120(a)(3)).

Staff finds that even with the above noted drawbacks, a system of required minimum radial separations is the best approach.  It sets a clear, unambiguous standard that all parties should be aware of.  There could well be situations where nearby or even adjacent lots could quite adequately accommodate second units, but this would require individual determination which is not compatible with the ministerial process.

To avoid hardships or unfairness the City Council may prefer not to adopt a separation requirement, because a family with an elderly or other needy relative could be denied a second unit if a neighbor already has one.  While theoretically a property owner in this situation could apply for a variance, it is inappropriate to use findings based on economics, age, etc, as the basis for granting land use variances.

CEQA DETERMINATION

Actions to adopt an ordinance regarding second units under CGC �65852.2 are statutorily exempt from the requirements of the California Environmental Quality Act (CEQA) under �15282(i) of the State CEQA Guidelines (CCR Title 14, Ch.3). 

FISCAL IMPACT:

The April 1, 2003 Staff Report contains a discussion of the fiscal impact of proposed Zone Text Amendment 2001-11.  None of the alternatives presented for regulating the separation and concentration of second units will have any direct fiscal impact.  If second dwelling unit applications are accommodated within the Development Review process, the development review fees (currently $480) will help to defray costs.  In the April 1 report, Planning Staff also advised of the possibility of requiring a fee to prepare the owner-occupancy covenants like we do for accessory structure covenants.  Historically the city has received only three to four second unit applications per year, and there is little reason to expect this will change significantly even with a simpler approval  process.

RECOMMENDATION:

Staff recommends the Council adopt Zone Text Amendment 2001-11 as amended to require a 200 ft. radial separation between approved second dwelling units.

COUNCIL ACTION:

The Council may approve, approve with modification or disapprove Zone Text Amendment.  If the Council desires, the following motion may be adopted:

�I move Zone Text Amendment No. 2001-11 be approved as proposed by the staff (or as modified by the Council), and that the Ordinance entitled �An Ordinance of the City of Burbank to Amend the Burbank Municipal Code Regulations Regarding Second Dwelling Units in the Single Family Zone be adopted�

If the Council determines the Zone Text Amendment should not be adopted, an appropriate motion should be introduced.

List of Exhibits

Exhibit A:         Draft Ordinance to Amend BMC Second Unit Regulations

Exhibit B:          Minutes of Burbank City Council Meeting � April 1, 2003

Exhibit C:         Burbank General Plan: Land Use Element Section III, A.1.a.

Exhibit D:         Hypothetical Distribution of Second Units on a Block � Worst Case

Exhibit E-1:      Example Distribution of Second Units 500 ft. Separation: Valley Area

Exhibit E-2:      Example Distribution of Second Units 500 ft. Separation: Hillside Area

Exhibit E-3       Example Distribution of Second Units 300 ft. Separation: Valley Area

Exhibit E-4       Example Distribution of Second Units 300 ft. Separation: Hillside Area

Exhibit E-5:      Example Distribution of Second Units 200 ft. Separation: Valley Area

Exhibit E-6:      Example Distribution of Second Units 200 ft. Separation: Hillside Area

Exhibit E-7       Example Distribution of Second Units 100 ft. Separation

Exhibit F-1       Lots Within 300 ft. & 500 ft. Linear Distance � Valley Area

Exhibit F-2       Lots Within 300 ft. & 500 ft. Linear Distance � Hillside Area

Exhibit F-5       Lots Within 300 ft. & 500 ft. Linear Distance � Valley Area (corner lot)

Exhibit F-6       Lots Within 300 ft. & 500 ft. Linear Distance � Hillside Area (corner lot)

Exhibit G-1:      Lots Within 300 ft. Linear & 200 ft. Radial Distance - Valley Area

Exhibit G-2:      Lots Within 300 ft. Linear & 200 ft. Radial Distance - Hillside Area

Exhibit H-1       Sample Notice of Development Review for a Second Dwelling Unit

Exhibit H-2       Recommended Notice of Second Unit Application � Non-DR

Exhibit I:           Public Notice of City Council Hearing on ZTA 2001-11

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