CC - Item 3N - Establishment of Process for Termination and Extension of Nonconforming Uses0
•
ROSEMEAD CITY COUNCIL
STAFF REPORT
TO: THE HONORABLE MAYOR AND CITY COUNCIL
FROM: ANDREW C. LAZZARETTO, CITY MANAG
DATE: NOVEMBER 28, 2006
SUBJECT: ESTABLISHMENT OF A PROCESS FOR THE TERMINATION AND
EXTENSION OF NONCONFORMING USES
SUMMARY
The City's zoning ordinance currently has provisions that allow for the City to amortize
out and terminate buildings and uses which do not conform with zoning code
designations. However, the City does not have a process to allow property owners or
business owners facing termination, and closure, or removal, to appeal the decision in
conformance with due process principles of law.
RECOMMENDATION
Staff recommends that the City Council waive further reading and introduce Ordinance
No. 848, adding subsection L to section 17.12.060 of the City's municipal code relating
to the termination and extension of nonconforming uses.
ANALYSIS
The City's current zoning ordinance has provisions for terminating certain
nonconforming uses, buildings and structures through amortization. For example,
Section 17.12.060(H) provides that a nonconforming use of a conforming building or
structure shall be discontinued within three years. However the zoning ordinance does
not contain a substantive due process procedure to allow business owners the right to a
hearing in order to establish that the termination constitutes a taking and that the
amortization period should accordingly be extended.
•C0
APPROVED FOR CITY COUNCIL AGENDA:
• •
City Council Meeting
November 28, 2006
Page 2 of 2
California courts have relied upon a case-by-case balancing approach to determine
when a city can properly terminate a nonconforming use. The courts have upheld
termination provisions where a reasonable period of time to recover the permit holder's
investment is allowed. The California Supreme Court laid down the following rule in
Metromedia, Inc. v. City of San Diego, 26 Cal.3d 848 (1980):
"The California cases have firmly declared that zoning legislation may validly provide for
the eventual termination of nonconforming uses without compensation if it provides a
reasonable amortization period commensurate with the investment involved."
The proposed ordinance will allow an application to be filed for an extension of time
within which a nonconforming use must be discontinued and removed. Once an
application is filed, a public hearing will be held before the Planning Commission. In
order to obtain an extension of time, the applicant must prove that there would be an
unconstitutional taking if they were required to abate within the time specified and that
allowing the continuation of the use will not adversely impact the public health, safety, or
welfare of the surrounding community. In making its determination, the Planning
Commission will have the ability to impose conditions to ensure that there is no
detriment to the public. Furthermore, the decision of the Planning Commission may be
appealed to the City Council.
PUBLIC NOTICE PROCESS
This item was posted through the regular agenda notification process. As the ordinance
does not change the zoning of any property, does not impose, remove, or modify any
regulations, it is not necessary for the Planning Commission to make a recommendation
on this Ordinance or to hold noticed public hearings.
Submitted by:
Brad Johnson
Planning Director
Attachments: A. Ordinance No. 848
ORDINANCE NO. 848
AN ORDINANCE OF THE CITY COUNCIL
OF THE CITY OF ROSEMEAD, CALIFORNIA ADDING SUBSECTION L TO
SECTION 17.12.060 OF THE CITY'S MUNICIPAL CODE
RELATING TO THE TERMINATION AND EXTENSION OF NONCONFORMING
USES
THE CITY COUNCIL OF THE CITY OF ROSEMEAD DOES HEREBY
ORDAIN AS FOLLOWS:
Section 1. Findings.
A. The City currently has provisions in its Municipal Code relating to
abatement of nonconforming buildings and uses.
B. The Municipal Code does not include any procedures to request an
extension of time in which to abate the nonconforming buildings
and uses.
C. The City wishes to establish procedures relating to the
discontinuance of nonconforming buildings and uses.
Section 2. Section 17.12.060 of the Rosemead Municipal Code is
hereby amended by adding subsection L to read as follows:
L. Procedure Relating to Nonconforming Buildings and Uses
1. Notwithstanding any other provision of this Section, an
application may be filed requesting a public hearing
before the Planning Commission for an extension of
time within which a nonconforming use must be
discontinued and removed.
The procedure set forth in Sections 17.124.010
through 17.124.070 shall constitute the procedure
relating to applications for an extension of time within
which a nonconforming building or use must be
discontinued and removed.
3. The burden of proof shall be on the applicant to
demonstrate the following:
0 0
a. that to require cessation of such use would
impair the property rights of any person so as
to constitute an unconstitutional taking of
property; and
b. that such use does not and will not during the
extension period requested:
1. adversely affect the health, peace or
welfare of persons residing in the
surrounding area; or
2. be materially detrimental to the use,
enjoyment or valuation of the property of
other persons located in the surrounding
area; or
3. jeopardize, endanger or otherwise
constitute a menace to the public health,
safety or general welfare.
4. The applicant shall have the right to present evidence
and cross-examine witnesses.
5. The Planning Commission shall not approve an
application for which the applicant has failed to meet
the burden of proof required by subsection 3 above,
and any such approval may be conditioned to ensure
that the approval will be in accord the findings required
by subsection 3.
6. The applicant, any member of the City Council or any
other person aggrieved by such decision of the
Planning Commission may appeal the decision to the
City Council in accordance with the provisions of
Section 17.124.070. The decision of the City Council
on appeal is final and any judicial action brought to
challenge the City Council's decision must be filed not
later than the 90th day on which the decision becomes
final in accordance with Code of Civil Procedure
section 1094.6.
Section 3. The City Clerk shall certify to the adoption of this ordinance.
PASSED, APPROVED, AND ADOPTED, this day of
2006.