Planning Commission Agenda Item TO: THRU: FROM: Chair Glasgow and Members of the Planning Commission Anna Pehoushek, AICP Assistant Community Development Director Jennifer Le Principal Planner SUBJECT PUBLIC HEARING: An Ordinance amending Chapter 17.34 of the Orange Municipal Code to modify the City s Off-Street Parking and Loading Requirements for Multi-Family Residential Uses. SUMMARY The City Council expressed an interest in updating parking requirements for multi-family residential land uses, noting concern that the City s parking requirements may be insufficient and out-of-date. The City retained a parking Consultant (Walker Parking) to evaluate multi-family residential parking demand characteristics in the City, with the goal of right sizing parking requirements such that new multi-family development projects are neither substantially under- or over-parked. This staff report presents the parking study s findings and staff recommendations. Staff proposes an amendment to Chapter 17.34 of the Orange Municipal Code that would increase multi-family parking requirements in some circumstances, applying parking requirements on a sliding-scale based on development size, bedroom count, and the type of parking proposed. The Ordinance also amends the Code to allow tandem parking in multi-family developments subject to Minor Site Plan Review and clarifies the definition of a bedroom for purposes of calculating parking requirements. RECOMMENDED ACTION Adopt Planning Commission Resolution No. PC 25-17 entitled: A RESOLUTION OF THE PLANNING COMMISSION RECOMMENDING CITY COUNCIL APPROVAL OF AN ORDINANCE AMENDING CHAPTER 17.34 OF THE ORANGE MUNCIPAL CODE TO MODIFY THE CITY S OFF-STREET PARKING AND LOADING REQUIREMENTS FOR MULTI-FAMILY RESIDENTIAL USES
Page 2 AUTHORIZATION/GUIDELINES Orange Municipal Code Section 17.10.020 establishes procedures by which the Planning Commission reviews ordinance amendments and makes recommendations to the City Council. PUBLIC NOTICE Public notice of the proposed Ordinance Amendment was published in the Orange City News newspaper on September 7, 2017. Because of the citywide applicability of the proposed Municipal Code changes, no single property was posted. Hearing notices were posted at City Hall and Library posting locations. ENVIRONMENTAL REVIEW Categorical Exemption: The proposed Ordinance Amendment is exempt from the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15305 (Class 5, Minor Alterations in Land Use Limitations) because it involves a modification to a citywide development standard related to required parking. It does not involve a specific site, development project, or focused geographic area, does not change permitted land use or density and does not otherwise result in a physical change that could cause an impact to the environment. Further, parking is not considered an impact to the environment under CEQA. Nothing further is warranted or required to comply with CEQA. There is no public review required for an exemption. PROJECT BACKGROUND Background The City s Off-Street Parking and Loading Requirements were last updated comprehensively in 1995 in conjunction with a comprehensive update to the Zoning Ordinance. In addition, a targeted update was completed in 2008. At that time, the City Council expressed concerns about the adequacy of the parking requirements and parking space dimensions. Based on Planning Commission and City Council direction, the 2008 Ordinance updated parking requirements for single-family residential, multi-family residential, auto repair and gas stations, and churches. The designation of special status parking spaces on commercial property, parking space dimensions, and use of wheel stops were also addressed in the 2008 Ordinance Amendment (as well as a follow up Ordinance Amendment approved in 2009). At that time, multifamily residential parking requirements were increased by 0.2 spaces per unit. More recently, in late 2016, the City Council reviewed and approved a number of multi-family residential projects including the MBK Homes project on Orange-Olive Road, the Olsen project on Washington Avenue, and the Glassell Townhomes project. During deliberations for these projects, Council again expressed concern that the number of parking spaces required by Code seemed too low.
Page 3 At the same time, the City had a number of applications in the pipeline for large higher-density multi-family projects in the City s mixed use zones, with some applicants requesting a reduction in the City s required number of parking spaces. For example, the AMLI project on The City Drive was granted a variance for parking based on a site-specific parking utilization study and counts of similar multi-family projects (including large apartment complexes on West Chapman Avenue built in the 2005-era) that appeared to be appropriately parked. These 2005-era projects were built to Code, but at a lower parking rate than currently applies (due to the 2008 increase in the multi-family residential parking requirement as described above). At the November 9, 2016 Council meeting, the City Council requested that staff review the multifamily residential parking standards and bring back a Code amendment to adjust the standards as appropriate. The City retained a parking Consultant (Walker Parking Inc.) to assist in studying multi-family parking demand characteristics in Orange, with the goal of right sizing the standards such that new development is neither substantially under- or over-parked. This staff report presents the parking study s findings and staff s recommended changes to the City s parking code. PROJECT DESCRIPTION The proposed Draft Ordinance (refer to Attachment 1a of this report) modifies Orange Municipal Code (OMC) Table 17.34.060A, Required Number of Parking Spaces for Residential Uses, by restructuring the multi-family parking standards to reflect a sliding-scale approach based on a proposed development s size, bedroom count, and the type of parking proposed. Increases over current parking requirements are proposed for smaller development projects (i.e. projects with 3 to 50 units), and also larger developments (greater than 50 units) if dedicated enclosed parking is proposed (as opposed to pooled open parking). The Draft Ordinance also clarifies the definition of a bedroom for purposes of calculating parking requirements. It also amends Section 17.34.060 of the Code to allow tandem parking in multi-family development projects subject to Minor Site Plan Review. APPLICATION(S) REQUESTED/ REQUIRED FINDINGS Ordinance Amendment: The City is proposing an Ordinance Amendment to amend the Off-Street Parking and Loading Standards contained in Chapter 17.34 of the OMC. Required Findings: Although there are no required findings for an Ordinance Amendment since it is considered a legislative action, per OMC Section 17.10.020 the Planning Commission shall address the following in its Resolution recommending approval of an Ordinance Amendment to the City Council: Reasons for the recommendation. The relationship of the proposed amendment to the General Plan. Environmental determination. These items are addressed in the attached Resolution.
Page 4 ANALYSIS/STATEMENT OF THE ISSUES Issue 1: Adequacy of the City s Multi-family Residential Parking Ratios Orange s parking standards have not been comprehensively updated since 1995, as a component of a larger comprehensive Zoning Code update. Over time, Orange s demographics, car ownership patterns, mode of travel and other such characteristics have shifted. Based on census data, a majority of households in Orange are two car households at 41%, with one car households at 27%, three car households at 18%, four car households at 10% and zero car households at 4%. Further, Census data shows that the vast majority of Orange residents at 81% drive alone to work, with carpool, bike, walk, public transportation and working from home making up the remainder. This data indicates that although transportation trends may be changing based on demographics, new technologies, and greater opportunities for car sharing and transit, car ownership rates are still high and single occupancy auto travel is still the primary mode of transportation in Orange and in similarly-situated cities in Orange County as a whole. Parking Study Findings The City retained Walker Parking Inc. to evaluate multi-family residential parking demand characteristics in the City and make recommendations as to appropriate changes to parking standards. Walker performed weekend and weekday parking utilization counts at 13 housing developments in Orange representing a range of project sizes, product types, ages and locations. They also presented information comparing Orange s parking standards to industry standards and adopted standards from surrounding cities. Comparison to Other Cities Standards & Industry Standards As shown in Table 1 below, Walker found that in general Orange s standards tended to be lower than the average of comparable Orange County cities for studio, 1-, 2-, and 3+ bedroom units. Although lower than the average, Orange s standards are within the range of standards applied by other cities. Table 1 also shows that Orange s parking standards are higher than industry standards such as those developed by the Urban Land Institute, Institute of Traffic Engineers, and National Parking Association. This is not surprising, given that industry standards may be based on limited data points and reflect a broader geographical perspective than local standards would. Although consistency with standards from other cities should not be a deciding factor in staff s opinion, this comparison is useful as a benchmark.
Page 5 Comparables Municipalities Industry Research and Publications Table 1- Orange Standards vs. Surrounding Cities and Industry Standards City Studio 1 Bedroom 2 Bedroom s 3+ Bedrooms Guest (Studio) Guest (1 Bedroom) Guest (2 Bedrooms) Guest (3+ Bedrooms) Tandem Parking Allowed? Anaheim 1.25 2.00 2.25 3.00 1.25 2.25 2.25 2.25 2 Yes Brea 1.50 1.75 2.00 2.50 1 0.20 0.20 0.20 0.20 No Fullerton 4 1.25 1.50 1.75 2.00 0.50 0.50 0.75 1.00 No Garden Grove 5 2.50 2.50 2.50 2.75 - - - - No Santa Ana 2.00 2.00 3.00 4.00 0.25 0.25 0.25 0.25 No Tustin 2.00 2.00 2.00 2.00 0.25 0.25 0.25 0.25 No Yorba Linda 6 1.00 1.80 2.00 2.00 0.75 0.50 0.50 1.50 Yes Costa Mesa 1.50 2.00 3 2.50 3 3.50 3 0.50 0.50 0.50 0.50 No Newport Beach 2.00 2.00 2.00 2.00 0.50 0.50 0.50 0.50 Yes Average 1.67 1.95 2,22 2.64 0.36 0.33 0.36 0.49 Orange 1.20 1.70 2.00 2.40 0.20 0.20 0.20 0.20 No Walker SPM 1.00 1.75 2.00 2.25 0.15 0.15 0.15 0.15 ULI 7 1.50 1.50 1.50 1.50 0.15 0.15 0.15 0.15 ITE 8 1.61 1.61 1.61 1.61 - - - - NPA 9 1.00 1.50 1.75 2.00 - - - - Notes: Walker SPM- Walker Shared Parking Model. ULI- Urban Land Institute. ITE- Institute of Traffic Engineers. NPA- National Parking Association. Survey Data & Field Observations Based on survey data from parking counts in Orange, Walker found that the observed peak parking demand ratios ranged from 0.74 to 1.75 parking spaces per bedroom with the weighted average number of spaces per bedroom at 0.94. Recognizing that there was considerable variation in on-theground conditions, Walker did not see evidence of grossly under-parked conditions, particularly at newer larger multi-family developments. Based on field data and professional experience, Walker advised that the City s minimum parking requirements appear on average adequate, being neither too high or too low. However, Walker felt that required parking could be increased for larger multifamily units, particularly for 3+ bedroom units, which is not addressed in the existing Code. Table 2- Observed Parking Demand Per Bedroom Weighted Average 0.94 spaces 50 th Percentile 1.0 spaces Although there is a perception that the City s multi-family parking requirements are inadequate, this may be in part due to observed parking conditions at older apartment developments either not built to current Code standards and/or where multiple families or adults are sharing small units and generating a higher parking demand than was planned for at the time. This condition has not yet proven to be the case in more recently constructed multi-family complexes that are built to current Code and rented or sold at market prices. Based on field observations and experience, Walker also noted the following parking trends: the first and second bedroom of a unit tend to generate greater parking demand than additional bedrooms;
Page 6 parking demand per unit tends to decrease as the number of units in a development increases (meaning larger developments tend to require less parking per unit than their smaller counterparts); and the type of parking provided (for example a shared unenclosed pool of parking versus private garages) has an effect on parking demand as well, because of the tendency of residents to use private garages for something other than parking. Parking Study Recommendations Because Walker believes that the City s standards are overall adequate, Walker did not recommend increasing the minimum parking requirements overall. However, they did recommend increasing the parking requirement for multi-family residential uses with 3 and 3+ bedrooms. They also suggested the City could provide greater flexibility in its Code by adopting a sliding scale approach that better reflects the observed effects of development size, bedroom count, and shared open parking versus private garage parking. Walker also recommended that the City change the Code to: apply the multi-family parking standards to duplexes, requiring more parking for duplexes with higher bedroom counts; allow for tandem parking; count dens or other similar rooms as bedrooms for parking purposes; and count driveways toward parking supply. Lastly, Walker made recommendations related to on-street parking management through in-lieu fees and/or street parking regulations. They also suggested adding in the flexibility to reduce parking requirements when certain policies are met, such as density or affordability goals or for example when bike or car sharing amenities are provided at a site. The Parking Study in its entirety is included as Attachment 3 to this report. Consultant Recommended Parking Ratios Table 3 shows the City s existing multifamily parking standards. Table 3- Existing Code Required Multi-Family Parking Ratios Land Use Parking Requirements Studio 1.2 One Bedroom 1.7 Multifamily Two Bedroom 2.0 Residential (3 units or Three or More Bedrooms 2.4 more) Of the above requirements a minimum of one space per unit shall be covered. A minimum of 0.2 spaces per unit shall be provided as easily accessible and distinguishable guest parking in addition to the required parking for each unit.
Page 7 Based on the parking study s findings, Walker recommends the following changes to the required multi-family parking ratios: Reducing the existing parking requirements by 0.1 for smaller multi-family developments (3 to 50 units) and by 0.2 spaces per unit for larger multi-family developments (51+ units) if unenclosed parking is proposed (for example, parking structure, surface parking or open carports, as opposed to enclosed private garages). Increasing the existing parking requirement for a 3 bedroom unit by 0.2 spaces per unit for small and large developments if enclosed (private garage) parking is proposed. If unenclosed parking is proposed, the existing parking requirement for a 3 bedroom unit is reduced by 0.1 spaces for small developments and reduced 0.2 spaces for large developments. Adding a new standard for units with more than three bedrooms requiring 0.3 to 0.5 additional spaces (depending on development size and parking type) for each additional bedroom beyond 3 bedrooms. These recommendations are reflected in Table 4 below which shows Walker s recommended parking ratios. Multifamily Residential (3 units or more) Table 4- Consultant-Recommended Required Parking Ratios Development Size 3 units to 50 units If unenclosed resident parking is provided (parking structure, surface parking lot(s), carports): Studio 1.1 One Bedroom 1.6 Two Bedroom 1.9 Three Bedrooms 2.3 three 0.4 If enclosed resident parking is provided: Studio 1.2 One Bedroom 1.7 Two Bedroom 2.0 Three Bedrooms 2.6 three 0.5 Development Size 51+ Units If unenclosed resident parking is provided (parking structure(s), surface parking lot(s), carports): Studio 1.0 One Bedroom 1.5 Two Bedroom 1.8 Three Bedrooms 2.2 three 0.3 If enclosed resident parking is provided: Studio 1.2 One Bedroom 1.7 Two Bedroom 2.0 Three Bedrooms 2.6 three 0.5 A minimum of 0.2 spaces per unit shall (with a minimum of two guest spaces in a multi-family development) be provided as easily accessible and distinguishable guest parking in addition to the required parking for each unit.
Staff Alternative Parking Ratios and the Proposed Ordinance Amendment Planning Commission Staff Report Page 8 Staff reviewed the Consultant s findings and recommendations. In light of the fact that the parking study s findings did not show a gross mismatch between observed parking demand and existing Code requirements, while also considering the concerns expressed by the Council that existing parking requirements are too low, staff is providing an alternative set of standards for approval. The Staff Alternative maintains a conservative approach to Code changes opting to carry forward the small incremental changes proposed by Walker, maintaining Walker s suggested numerical relationship between the proposed parking ratios for each development type, but not reducing existing parking requirements in any development category. Rather, minimum parking requirements stay the same, with increases to parking requirements proposed for smaller developments (which tend to have higher per bedroom demand), and larger developments if enclosed parking is proposed (based on the fact that developments with enclosed garages tend to have higher demand per bedroom due to the tendency of some occupants to use private garages for something other than parking). This Staff Alternative is shown in Table 5 below and is reflected in the proposed Draft Ordinance included as Attachment 1a and 1b to this report. Multifamily Residential (3 units or more) Table 5- Staff Alternative Required Parking Ratios Development Size 3 units to 50 units If unenclosed resident parking is provided (parking structure, surface parking lot(s), carports): Studio 1.3 One Bedroom 1.8 Two Bedroom 2.1 Three Bedrooms 2.5 three 0.4 If enclosed resident parking is provided: Studio 1.4 One Bedroom 1.9 Two Bedroom 2.2 Three Bedrooms 2.8 three 0.5 Development Size 51+ Units If unenclosed resident parking is provided (parking structure(s), surface parking lot(s), carports): Studio 1.2 One Bedroom 1.7 Two Bedroom 2.0 Three Bedrooms 2.4 three 0.3 If enclosed resident parking is provided: Studio 1.4 One Bedroom 1.9 Two Bedroom 2.2 Three Bedrooms 2.8 three 0.5 A minimum of 0.2 spaces per unit shall (with a minimum of two guest spaces in a multi-family development) be provided as easily accessible and distinguishable guest parking in addition to the required parking for each unit. A summary table comparing multifamily parking ratios from the existing Code, the Consultant s recommendations and the Staff alternative is provided as Attachment 2 to this report.
Page 9 Staff Recommendation Ultimately, establishing development standards like parking requirements is a local policy decision that takes into consideration quantitative analysis, industry trends, as well as qualitative local community goals related to neighborhood character and quality of life. Based on the parking study s findings and previous concerns expressed by Council, Staff recommends that the Planning Commission recommend approval of the Draft Ordinance to the City Council. As an alternative, the Planning Commission may opt to recommend the Consultant s Recommended parking ratios or other changes to the Ordinance as the Commission deems appropriate. Issue 2: Clarification of a bedroom for Parking Requirement Purposes Chapter 17.04, Definitions, of the Code currently defines bedroom very broadly as any habitable room other than a bathroom, kitchen, dining room or living room. A strict application of this definition would mean that every other type of room in a home would be counted as a bedroom for parking purposes. This broad definition coupled with buyer preferences for rooms such as offices, playrooms, family rooms, dens, lofts, etc. in new today s residential developments has resulted in the Planning staff making judgment calls as to whether or not to count a room as a bedroom for parking purposes on a case by case basis and with limited guidance or authority in the Code. Past practice has been to rely on how such other rooms are labeled on submitted floor plans and litmus tests such as whether or not a room has a door or a closet. The Consultant recommended, and staff concurs, that a clarification of when a bedroom is counted as a bedroom for parking purposes is needed to address this issue. The Draft Ordinance (Attachment 1a to this report) clarifies that rooms that provide an unobstructed opening 7 feet wide or greater in at least one wall shall not be counted as a bedroom for purposes of calculating required number of parking spaces. Staff believes this focus on the openness of a room as the primary criteria for determining its likelihood to be used as a bedroom is reasonable and appropriate. Rooms with large openings in at least one wall are less likely to be used as bedrooms due to the very limited privacy they provide. On the other hand, this focus on openness will allow residential developers the flexibility to provide open non-bedroom spaces desired by today s homebuyers, without having to provide additional parking as though those spaces were being used additional bedrooms. Issue 3: Tandem Parking The existing parking Code does not allow for tandem parking. In light of the fact that Orange is a built-out City with future multi-family residential development likely taking the form of infill development or redevelopment of small under-utilized properties, tandem parking is a residential development trend staff expects to see more frequently in residential products. As such, the Consultant recommends and staff concurs that it is desirable for the City to allow tandem parking in certain circumstances.
Page 10 The Draft Ordinance (Attachment 1a to this report) proposes to allow tandem parking if the tandem parking spaces are assigned to the same residential unit and subject to Minor Site Plan Review. Staff believes this approach is reasonable and appropriate because it allows a request for tandem parking to be approved at the Community Development Director level, so long as the request is consistent with Site Plan Review findings which speak to compatibility with surrounding neighborhoods, compliance with City development standards and the provision of safe and adequate vehicular and pedestrian access. Issue 4: Other Parking Study Recommendations Not Carried Forward by Staff Staff carried forward most but not all of the parking study recommendations. The Planning Commission may wish provide feedback on these items as appropriate. Regarding driveways, Walker noted that the existence of driveways in a development provided functional parking spaces for residents beyond required garage parking and also had an effect on observed counts because of a tendency by some to use driveways as parking spaces while using garage spaces for something else. Staff did not carry forward Walker s recommendation for counting driveways as required parking spaces because driveways are required primarily for singlefamily residential uses (not multi-family residential) where garage spaces are desirable, and also because driveway parking would block access to required garage spaces, which staff did not feel was advisable. The City may want to consider whether or not certain residential product types should be required to have driveways, though staff recommends this analysis be conducted as part of the larger comprehensive parking code update which is currently underway. Staff also did not carry forward Walker s recommendations for 1) greater on-street parking management through the use of parking in-lieu fees or additional regulations such as permit parking, 2) reduced parking requirements for projects that meet City goals such as density or affordable housing goals, or 3) for projects that provide bike or car-sharing amenities. Staff believes affording greater flexibility to reduce parking requirements is not consistent with the City s goals of providing adequate parking, nor has the City been interested in pursuing additional fees, active onstreet parking enforcement or permit parking in the past. Lastly, Staff did not carry forward Walker s recommendation to increase the parking requirement for duplex residential uses by parking them more similar to multi-family residential i.e. based on bedroom count. Staff did not see any evidence that the existing Code requirements for duplexes (one covered and one uncovered parking space) were inadequate and opted to leave the requirement as is at this time. The City may want to consider whether or not duplexes should be required to provide additional parking spaces as bedroom count increases, though staff recommends this analysis be conducted as part of the larger comprehensive parking code update which is currently underway.
Page 11 ADVISORY BOARD RECOMMENDATION The Planning Commission is advisory to the City Council for Zoning Ordinance Amendments. Ordinances are not reviewed by advisory bodies such as the Streamlined Multi-Disciplined Accelerated Review Team (SMART) or the Design Review Committee (DRC). ATTACHMENTS/EXHIBITS Attachments to Report: 1. Planning Commission Resolution No. PC 25-17 a. Draft Ordinance Amendment (redlined) b. Draft Ordinance Amendment (clean) 2. Comparison Table- Existing Code vs. Consultant Recommended and Staff Proposed Parking Ratios 3. Parking Study for the City of Orange Multi-Family Residential Parking Standards Update, prepared by Walker Parking Inc., dated April 13, 2017 N:\CDD\PLNG\Ordinance Amendments\Parking Code Update_MultiFamily Residential (2017)\PC\PC_Rpt9_18_2017.doc