HomeMy WebLinkAbout1759 - APPROVE UP, OD, OP, AND ADOPT MND_2421 COAST HWYRESOLUTION NO. 1759
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF
NEWPORT BEACH APPROVING USE PERMIT NO. 2007 -010,
ACCESSORY OUTDOOR DINING PERMIT NO. 2007 -001, AND OFF -
SITE PARKING AGREEMENT NO. 2007 -001 AND ADOPTING
MITIGATION NEGATIVE DECLARATION (SCH NO. 2008 - 041099) ON
PROPERTY LOCATED AT 2421 COAST HIGHWAY (PA2007 -063)
WHEREAS, an application was filed by Collection Investments Corona del Mar,
Inc. with respect to property located at 2421 Coast Highway, and legally described as
Parcel 1 of Parcel Map filed in Book 68, page 8 of Parcel Maps Records of Orange
County, requesting an approval of Use Permit to allow the operation of a 3,820 square -
foot full - service, high turnover eating and drinking establishment with a net public area of
640 square feet, and to allow alcohol beverage service of beer and wine with a Type "41"
ABC License (On -Sale Beer and Wine Eating Place), Accessory Outdoor Dining Permit
approval to allow the construction and operation of a 160 square -foot outdoor dining
area in conjunction with the proposed full- service restaurant, and Off -site Parking
Agreement approval of 10 spaces to satisfy the off - street parking requirement for the
proposed restaurant utilizing the off -site property located at 7 Corporate Plaza; and
WHEREAS, on September 20, 2007, the Planning Commission approved
Resolution No. 1732 to allow the operation of a full- service restaurant with alcoholic
beverage service of beer and wine, and an outdoor dining area with an 10 -space off -site
parking arrangement located at 7 Corporate Plaza. The project was subsequently
appealed by the City Council; and
WHEREAS, on November 27, 2007, after some discussion, the City Council
granted the request for a four -month continuation to March 25, 2008, to allow the
applicant additional time to reevaluate the on -site parking arrangement and traffic
circulation issues, and to address the additional concerns /issues subsequently raised
after the Planning Commission's approval; and
WHEREAS, on March 25, 2008, the City Council referred the Panini Cafe project
back to the Planning Commission to consider the supplemental materials of an Initial
Study /Negative Declaration and Parking and Internal Circulation Study as they were not
a part of the original application that was considered by the Planning Commission; and
WHEREAS, on June 5, 2008, the Planning Commission held a noticed hearing in
the City Hall Council Chambers, at 3300 Newport Boulevard, Newport Beach, California
at which time the project application was considered. Notice of time, place and purpose
of the public hearing was given in accordance with law and testimony was presented to,
and considered by, the Planning Commission at the hearing; and
WHEREAS, a use permit for the proposed restaurant may be approved in
accordance with Section 20.91.035 of the Municipal Code based on the following
findings and facts in support of such findings:
City of Newport Beach
Planning Commission Resolution No.
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1. Finding: That the proposed location of the use is in accord with the objectives of
this code and the purposes of the district in which the site is located.
Facts in Support of Finding: The subject property is located within the Retail Service
Commercial (RSC) Zoning District, which is intended to provide the Corona del Mar
area with commercial services for permanent residences and visitors of the area.
Restaurant uses are permitted within this designation with the approval of a use
permit. The operational characteristics and location of the proposed restaurant use
are such that it is a community serving use with some pedestrian oriented traffic.
The proposed restaurant is consistent with this designation.
In accordance with the requirements of Chapter 20.89, the location of the
proposed Alcoholic Beverage Outlet was considered with respect to issues of
public necessity and impacts to surrounding land uses. The use will provide a
public convenience by offering food and beer and wine sales to restaurant
patrons. The location of the use is considered appropriate given the fact that the
site is not located in close proximity to day care centers, schools or places of
religious assembly. In addition, the Police Department has reviewed the project
and has no objections to the location.
2. Finding: That the proposed location of the use permit and the proposed conditions
under which it would be operated or maintained will be consistent with the General
Plan and the purpose of the district in which the site is located; will not be
detrimental to the public health, safety, peace, morals, comfort, or welfare of
persons residing or working in or adjacent to the neighborhood of such use; and will
not be detrimental to the properties or improvements in the vicinity or to the general
welfare of the City.
Facts in Support of Finding: The proposed restaurant is consistent with the land use
designation of the General Plan and the Coastal Land Use Plan. The restaurant
has been conditioned in such a manner to meet the intent of the Zoning Code
regulations, including any specific conditions required for the proposed restaurant
and to require strict adherence to safety and noise regulations. The Planning
Commission determined that the parking ratio of 1 space per 40 square feet of net
public area is adequate for the proposed restaurant. With this parking ratio, the
required number of parking spaces is 16 spaces. The applicant proposes a total of
22 spaces: 12 spaces for patron parking within the property's existing parking
garage with valet service and 10 spaces for employee parking located at 7
Corporate Plaza. The utilization of off -site employee parking spaces is critical to
avoiding patron parking shortages and negative traffic impact on nearby residential
streets. The Planning Commission also supported the applicant's request to
increase the number of parking spaces within the garage structure from 12 to 16
spaces based on testimony that the previous valet parking arrangement in the
garage could accommodate up to 17 spaces. The efficiency of valet parking
operation would prevent traffic impacts in the adjacent alley during peak customer
hours.
City of Newport Beach
Planning Commission Resolution No.
Paqe 3 of 13
In accordance with the requirements of Chapter 20.89, approval of the Alcoholic
Beverage Outlet is subject to the consideration of factors relating to over -
concentration of alcohol licenses, crime rates including numbers of alcohol
related crimes, and impacts to the surrounding community. Detailed analysis of
the ABC application is discussed below under the Alcoholic Beverage Outlet
Ordinance Section. The Police Department has reviewed the project and has
determined that the sale of beer and wine in conjunction with the proposed
restaurant will not result in an increase in alcohol - related crimes and will not
result in an over - concentration of alcoholic beverage outlets since the request is
to transfer the existing license from an existing restaurant to the subject location.
The proposed restaurant, including beer and wine sales, will not have a negative
impact on the surrounding community.
3. Finding: That the proposed use will comply with the provisions of this code,
including any specific condition required for the proposed use in the district in which
it would be located.
Facts in Support of Finding: The request to allow the operation of a restaurant
which includes the serving of alcoholic beverages on the premises and the
proposed conditions under which it would be operated or maintained, are
consistent with the General Plan and the purpose of the district in which the site
is located. The request is located within the existing building that is designated
and zoned for this commercial activity. The use has been conditioned in such a
manner to minimize the impacts associated with it. The plan, as conditioned,
meets the design and development standards for eating and drinking
establishments.
In accordance with the requirements of Chapter 20.89, the project has been
conditioned to avoid potential negative impacts on the surrounding community.
WHEREAS, an off -site parking agreement for the 10 parking spaces located at 7
Corporate Plaza has been prepared in accordance with Section 20.66.080, Off - Street
Parking based on the following facts and findings in support of such findings:
1. Finding: Such lot is so located to be useful in connection with the proposed use
or uses on the site or sites.
Facts in Support of Finding: The off -site lot is located on the north side of Coast
Highway, west of Avocado Avenue. The applicant is proposing to utilize these
spaces for employee parking. No valet parking will be provided. The restaurant
employees will be given maps showing the location of the parking lot and will be
instructed to park at the proper location. Pedestrian access is afforded at the
signalized intersection at Avocado Avenue.
2. Finding: Parking on such lot will not create undue traffic hazards in the surrounding
area.
City of Newport Beach
Planning Commission Resolution No.
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Facts in Support of Finding: The use of off -site parking lot will not create undue
traffic hazards in the surrounding area. The employees will be instructed to cross
Coast Highway at the pedestrian crossing at Avocado Avenue to and from the
off -site parking lot.
3. Parking is permanently available, marked, and maintained for the use it is intended
to serve.
Facts in Support of Finding: A 5 -year term parking agreement with a 5 -year renewal
option has been secured with the property owner of the off -site parking lot.
Documentation has been submitted by the property owner that the off -site parking
spaces have not been leased to any other business than the applicant. The
provision of 10 parking spaces in the off -site lot, and the recordation of the
agreement with the County Recorder's office are required to ensure the availability
of the spaces for the use.
WHEREAS, the following findings are appropriate for approval of an Accessory
Outdoor Dining Permit pursuant to Section 20.82.050 (B) of the Zoning Code:
1. Finding: That the proposed outdoor dining is accessory to the eating and drinking
establishment.
Facts in Support of Finding: The proposed outdoor dining area is accessory to the
proposed 3,820 square -foot restaurant. The restaurant' s total net public area would
be 640 square feet. The applicant proposes to have an outdoor dining area of 160
square feet which is 25 percent of the net public area of the proposed restaurant
and thereby is consistent with Municipal Code Section 20.82.050 (A) that limits
accessory outdoor dining areas to 25 percent of the restaurant's interior net
public area, or 1,000 square feet, whichever is less.
2. Finding: The establishment, maintenance or operation of the accessory outdoor
dining will not, under the circumstances of the particular case, be detrimental to
the health, safety, peace, comfort and general welfare of persons residing or
working in the neighborhood or injurious to property or improvements in the area.
Facts in Support of Finding: The use is accessory to the proposed restaurant use
which would be subject to conditions of approval that include limitations on hours
of operation and number of seats for patrons. The proposed location of the
outdoor dining area would not cause noise impacts to the nearby residential
uses.
3. Finding: That the proposed accessory outdoor dining will not be located so as to
result in reduction of existing parking spaces.
City of Newport Beach
Planning Commission Resolution No.
Paae 5 of 13
Facts in Support of Finding: The proposed outdoor dining area will be located in
front of the existing building, adjacent to the public right -a -way along Coast
Highway, and thereby will not result in a reduction of the existing parking spaces
located in the parking garage. Section 20.82.050 (A) of the Municipal Code does
not require additional parking for accessory outdoor dining areas.
WHEREAS, an Initial Study and Mitigated Negative Declaration (MND) have
been prepared in compliance with the Environmental Quality Act (CEQA), the State
CEQA Guidelines and City Council Policy K -3. The draft MND was circulated for public
comment between April 18 and May 19, 2008. During the public comment period,
comments were received from the Native American Heritage Commission, Department
of Transportation, the Southern California Association of Governments (SCAG), Joel D.
Kuperberg of Rutan & Tucker, LLP, Lila Crespin, MMorgan 13 RR, and Dennis Baker. The
contents of the environmental document, including comments on the document, have
been considered in reviewing this project; and
WHEREAS, at its June 5, 2008 hearing, the Planning Commission heard
additional public comments and input from staff and consultants; and
WHEREAS, on the basis of the entire environmental review record, the proposed
project will have a less than significant impact upon the environment and there are no
known substantial adverse affects on human beings that would be caused. Additionally,
there are no long -term environmental goals that would be compromised by the project,
nor cumulative impacts anticipated; and
WHEREAS, the Planning Commission finds that judicial challenges to the City's
CEQA determinations and approvals of land use projects are costly and time
consuming. In addition, project opponents often seek an award of attorneys' fees in
such challenges. As project applicants are the primary beneficiaries of such approvals,
it is appropriate that such applicants should bear the expense of defending against any
such judicial challenge, and bear the responsibility for any costs, attorney's fees, and
damages which may be awarded to a successful challenger; and
NOW, THEREFORE, BE IT RESOLVED:
Section 1. The Planning Commission of the City of Newport Beach does
hereby find, on the basis of the whole record, that there is no substantial evidence that
the project will have a significant effect on the environment and that the Mitigated
Negative Declaration reflects the Planning Commission's independent judgment and
analysis. The Planning Commission hereby adopts Mitigated Negative Declaration SCH
No. 2008 - 041099, including the Mitigation Monitoring and Reporting Program attached
as Exhibit "A" and approves Use Permit No. 2007 -010, Off -site Parking Agreement No.
2007 -001 and Accessory Outdoor Dining Permit No. 2007 -006, subject to Conditions of
Approvals in Exhibit "B" attached hereto and made part hereof. The document and all
material, which constitute the record upon which this decision was based, are on file
City of Newport Beach
Planning Commission Resolution No.
Paae 6 of 13
with the Planning Department, City Hall, 3300 Newport Boulevard, Newport Beach,
California.
Section 2. This action shall become final and effective fourteen days after the
adoption of this Resolution unless within such time an appeal is filed with the City Clerk
in accordance with the provisions of Title 20 Planning and Zoning, of the Newport
Beach Municipal Code.
PASSED, APPROVED AND ADOPTED THIS Sth DAY OF JUNE 2008.
AYES: Eaton, Peotter, Cole. Hawkins.
McDaniel and Hillgren
NOES: Toerge
BY: �--T V f " o
Robert Hawkins, Chair4nan
City of Newport Beach
Planning Commission Resolution No.
Paae 7 of 13
EXHIBIT "A"
Panini Cafe
Mitigation Monitoring Program
for Mitigated Negative Declaration - SCH No. 2008 - 041099
Method OFF
Timing of
No.
Miti anon Measure
Verification
Implementation
Responsibility
Traffic and Circulation
Prior to issuance of the building
permit, the applicant shall prepare the
Final Valet Parking Plan based on
Option 1. Valet parking plan (Valet
Stand in Two-Way Alley), shall reflect
Public Works
MM -1
detailed striping plans for the
Plan Check
Prior to Issuance of the
Department/
proposed parking and also illustrate
Building Permit
City Traffic
the manner in which the operational
Engineer
characteristics of the parking plan will
occur. This Parking Plan will be
submitted to the City Traffic Engineer
for review and approval.
Prior to issuance of the building
permit, the project applicant shall
prepare an Employee Parking Plan
and submit that plan for review and
Public Works
approval by the City Traffic Engineer.
Prior to Issuance of the
Department/
MM -2
The Employee Parking Plan shall
Plan Check
Building Permit
City Traffic
identify the manner in which
Engineer
enforcement will be carried out to
ensure that employees do not parking
in the nearby residential
neighborhood.
City of Newport Beach
Planning Commission Resolution No.
Paoe 8 of 13
EXHIBIT "B"
CONDITIONS OF APPROVAL
USE PERMIT NO. 2007 -010, OFF -SITE PARKING AGREEMENT NO. 2007 -001 &
ACCESSORY OUTDOOR DINING PERMIT NO. 2007 -006
Conditions in bold - italics are project specific conditions. All others are standard
conditions.
Planning Department
The approval of this resolution rescinds and supersedes Planning
Commission Resolution No. 1732.
2. The development shall be in substantial conformance with the site plan and
floor plan dated May 28, 2008.
3. The total net public area for the entire restaurant shall not exceed 640 square
feet and 36 seats.
4. The accessory outdoor dining area shall be limited to 160 sq. ft. and 12 seats.
5. The hours of operation of the restaurant including the outdoor dining area
are limited to the hours of 7:00 a.m. to 10:00 p.m., daily.
6. The accessory outdoor dining area shall be used in conjunction with the
proposed full - service restaurant No special events, promotional activities,
private functions or private parties shall be allowed within the outdoor dining
area.
7. No amplified music or entertainment is permitted in the outdoor dining
area. No outside paging system, loudspeaker or other noise generating
device shall be utilized in conjunction with this outdoor dining area.
8. Roof coverings over the outdoor dining area shall not create a permanent
enclosure. The use of any other type of overhead covering shall be subject
to review and approval by the Planning Director and may require an
amendment to this permit.
9. A total of 22 parking spaces: 12 on -site for patrons only, and 10 off -site
shall be provided at all times.
10. The 10 off -site parking spaces located at 7 Corporate Plaza shall be
designated and used for employee sell- parking only. No patron parking shall
be allowed at any given time.
City of Newport Beach
Planning Commission Resolution No.
Paoe 9 of 13
11. An off -site parking agreement, subject to the review and approval by the
City Attorney's office, shall be recorded. The agreement shall guarantee a
total of 10 off- street parking spaces located at 7 Corporate Plaza for the use
authorized on the subject property.
12. If, in the opinion of the Planning Director or City Traffic Engineer, the
restaurant creates parking congestion at the sites, the applicant shall
immediately resolve the congestion problem by reducing restaurant
seating, or increasing parking attendants, or through other means until the
parking congestion is eliminated and parking is properly managed. The
Planning Director or City Traffic Engineer has the discretion to require the
preparation of a revised valet operation /parking management plan.
13. The applicant or operator of the restaurant shall immediately notify the
Planning Director of any termination of, or default relative to the agreement
for off -site parking required as a condition of this approval.
14. Upon notification that the agreement for the required off -site parking has
terminated or a reduction in the number of parking spaces provided
thereunder, the Planning Director shall establish a reasonable time in
which one of the following shall occur:
a. Substitute parking is provided that is acceptable to the Director; or
b. The size or capacity of the restaurant use is reduced in proportion to
the number parking spaces lost.
15. No live entertainment or dancing shall be permitted in conjunction with the
permitted restaurant use.
16. Storage outside of the building in the front or at the rear of the property shall be
prohibited.
17. The operator of the restaurant facility shall be responsible for the control of noise
generated by the subject facility. The noise generated by the existing use shall
comply with the provisions of Chapter 10.26 of the Municipal Code.
18. The Planning Commission may add to or modify conditions of approval to this
use permit, accessory outdoor dining permit, off -site parking agreement or
revoke these approvals upon a finding of failure to comply with the conditions set
forth in Chapter 20.82 of the Municipal Code or other applicable conditions and
regulations governing the food establishment. The Planning Commission may
also revoke these permits and agreement upon a determination that the
operation which is the subject of this approval causes injury, or is detrimental to
the health, safety, peace, morals, comfort, or general welfare of the community.
City of Newport Beach
Planning Commission Resolution No.
Paae 10 of 13
19. These approvals shall expire unless exercised within 24 months from the end of
the appeal period as specified in Section 20.91.050 of the Newport Beach
Municipal Code.
20. A new trash enclosure with masonry walls and a self - locking gate shall be
constructed. All trash shall be stored within water -tight trash containers
stored within the trash enclosure. The watertight trash containers shall
have lids or tops that remain closed at all times, except when being loaded
or while being collected by the refuse collection agency.
21. The applicant shall maintain the watertight trash containers or receptacles so as to
control odors, which may include the provision of fully self - contained containers or
may include periodic steam cleaning of the containers, if deemed necessary by the
Planning Department
22. The operator of the food service use shall be responsible for the clean up of all
on -site and off -site trash, garbage, and liter generated by the use. Employees of
the premises shall pick up trash from the ground of the trash enclosure on a daily
basis.
23. All deliveries shall be scheduled outside of peak operating hours of the use
so that no access will be blocked. No deliveries shall be permitted before
7:00 a.m. or after 6:00 p.m.
24. No temporary "sandwich" signs, balloons or similar temporary signs shall be
permitted, either on site or off -site, to advertise the proposed food establishment,
unless specifically permitted in accordance with the Sign Ordinance of the
Municipal Code. Temporary signs shall be prohibited in the public right -of -way,
unless otherwise approved by both the Public Works Department and Caltrans in
conjunction with the issuance of an encroachment permit or encroachment
agreement from each.
25. A covered wash -out area for refuse containers and kitchen equipment shall be
provided and maintained and the area drain directly into the sewer system, unless
otherwise approved by the Building Director and Public Works Director in
conjunction with the approval of an alternative drainage plan. Washing of refuse
containers or restaurant equipment shall be prohibited in the parking lot and public
alley.
26. The use of the rear entry door shall be prohibited between the hours of
11:OOpm and 6:OOam.
27. Any change in operational characteristics and /or hours of operation of the
restaurant, shall require amendment to this Use Permit or the processing of a
new Use Permit.
City of Newport Beach
Planning Commission Resolution No.
Page 11 of 13
28. Should this business be sold or otherwise come under different ownership, any
future owners or assignees shall be notified of the conditions of this approval by
either the current business owner, property owner or the leasing agent.
29. No audible paging system or speaker system shall be utilized any where on the
premises at any time.
30. All owners, managers and employees selling alcoholic beverages shall undergo
and successfully complete a certified training program in responsible methods
and skills for selling alcoholic beverages. The certified program must meet the
standards of the California Coordinating Council on Responsible Beverage
Service or other certifying /licensing body, which the State may designate. The
establishment shall comply with the requirements of this section within 180 days
of the issuance of the certificate of occupancy. Records of each owner's,
manager's and employee's successful completion of the required certified
training program shall be maintained on the premises and shall be presented
upon request by a representative of the City of Newport Beach.
31. Full menu food service shall be available for ordering at all times that the
restaurant establishment is open for business.
32. The alcoholic beverage outlet operator shall take reasonable steps to discourage
and correct objectionable conditions that constitute a nuisance in parking areas,
sidewalks and areas surrounding the alcoholic beverage outlet and adjacent
properties during business hours, if directly related to the patrons of the subject
alcoholic beverage outlet. If the operator fails to discourage or correct nuisances,
the Planning Commission may review, modify or revoke this Use Permit in
accordance with Chapter 20.96 of the Zoning Code.
33. The type of alcoholic beverage license issued by the California Board of
Alcoholic Beverage Control shall be a Type 41 in conjunction with the service of
food as the principal use of the facility. Any upgrade in the alcoholic beverage
license shall be subject to the approval of an amendment to this application and
may require the approval of the Planning Commission.
34. A Special Events Permit is required for any event or promotional activity outside
the normal operational characteristics of this restaurant business that would
attract large crowds, involve the sale of alcoholic beverages, include any form of
on -site media broadcast, or any other activities as specified in the Newport
Beach Municipal Code to require such permits.
35. Any event or activity staged by an outside promoter or entity, where the
restaurant owner or his employees or representatives share in any profits, or pay
any percentage or commission to a promoter or any other person based upon
City of Newport Beach
Planning Commission Resolution No.
Paae12of13
money collected as a door charge, cover charge or any other form of admission
charge, including minimum drink orders or sale of drinks is prohibited.
36. No alcoholic beverages shall be consumed on any property adjacent to the
licensed premises under the control of the license.
37 No "happy hour" type of reduced price alcoholic beverage promotion shall be
allowed except when served in conjunction with food ordered from the full service
menu.
38. There shall be no exterior advertising or signs of any kind or type, including
advertising directed to the exterior from within, promoting or indicating the
availability of alcoholic beverages. Interior displays of alcoholic beverages or
signs that are clearly visible to the exterior shall constitute a violation of this
condition.
39. The quarterly gross sales of alcoholic beverages shall not exceed the gross sales
of food and retail sales during the same period. The licensee shall maintain
records that reflect separately the gross sale of food and the gross sales of
alcoholic beverages of the licensed business. Said records shall be kept no less
frequently than on a quarterly basis and shall be made available to the
Department on demand.
40. The use permit approval does not permit the premises to operate as a bar, tavern,
cocktail lounge or nightclub as defined by the Municipal Code, unless the Planning
Commission first approves a use permit.
41. Petitioner shall not share any profits or pay any percentage or commission to a
promoter or any other person based upon monies collected as a door charge, cover
charge, or any other form of admission charge, including minimum drink orders or
the sales of drinks.
42. A noticed twelve -month review by the Planning Commission, from the date
of commencement of the restaurant operation, shall be required. The
Planning Director shall have the discretion to call for an earlier review if
needed.
Public Works Department
43. The area outside of the food establishment, including the public sidewalks, shall
be maintained in a clean and orderly manner and may be subject to providing
periodic steam cleaning of the public sidewalks as required by the Public Works
Department.
44. The existing garage opening width shall be maintained at ff -9" minimum
to accommodate two -way traffic into and out of the garage.
City of Newport Beach
Planning Commission Resolution No.
Page 13 of 13
45. The clearance height shall be clearly posted at the entrance to the parking
area above the opening.
46. The valet parking shall be provided during all business hours. The valet
operation shall be staffed in a manner to eliminate back up/storage of
vehicles on public property. No more than 16 vehicles shall be parked on
site at one time.
47. Valet signage shall not be placed within the public right -of -way.
48. Valet drop -off, pick -up, and deliveries shall occur via the alley within the
subject property. Valet operations and deliveries shall not impact ingress
and egress to the adjacent commercial and residential properties.
49. No portion of the accessory outdoor dining area including any patio
cover/awning shall extend into the public right -of -way.
50. When cleaning the accessory outdoor dining area, debris shall not be
swept, washed, or blown into the public right -of -way.
Building Department
51. The applicant is required to obtain all applicable permits from the City Building and
Fire Departments. The construction plans must comply with the most recent, City -
adopted version of the California Building Code.
52. A grease interceptor shall be provided.
53. Structural analysis for the change of occupancy shall be required.
54. A van - accessible handicap parking space with an eight -foot accessible
loading area shall be provided and maintained at all times during
restaurant operation. The applicant shall coordinate with the Building
Department for ADA compliance.
Fire Department
55. A 5 -year certification shall be required for the fire sprinkler system.
56. A Type 1 Hood and Kitchen Suppression System shall be required.