Loading...
HomeMy WebLinkAboutRedwillow Appeal_MD2007-060_418 Redlands Ave (PA2007-152)CITY OF NEWPORT BEACH PLANNING COMMISSION STAFF REPORT December 6, 2007 Meeting Agenda Item No. 4 SUBJECT: Appeal of Modification Permit No. 2007 -060 (PA2007 -152) 418 Redlands Avenue APPELLANT: Will Higman APPLICANT: Joyce LCM RedWillow PLANNER: Janet Johnson Brown, Assistant Planner (949) 644 -3236, jbrown(&citv.newport- beach.ca.us PROJECT SUMMARY An appeal of the Zoning Administrator's decision to approve Modification Permit No. 2007 -060 on property located in the R -1 District at 418 Redlands Avenue, which would permit the minor interior remodel of and a 1,203 square -foot addition to a nonconforming single -unit dwelling that encroaches 13 feet, 8 inches into the 20 -foot required front yard setback. The Planning Commission must conduct a de novo hearing and, after considering all of the evidence presented, either approve, modify, or disapprove, in whole or in part, Modification Permit No. 2007 -060. RECOMMENDATION Staff recommends that the Planning Commission conduct a de novo hearing and reverse the decision of the Zoning Administrator and deny Modification Permit No. 2007 -060 by adopting the draft resolution attached as Exhibit 1. BACKGROUND At the Planning Commission hearing of October 18, 2007, the nonconforming status of the subject structure was discussed because a modification permit can only be granted if it is first determined that a structure is a "legal' nonconforming structure. A nonconforming structure is defined in the Zoning Code as "a structure that was lawfully erected, but which does not conform with the property development regulations prescribed in the regulations for the district in which the structure is located by reason of adoption or amendment of this code or by reason of annexation of territory to the City." Appeal of Modification Permit No. 2007 -060 December 6, 2007 Page 2 Through research of City records, staff confirmed that the required front yard setback for the subject property was 20 feet when the structure was built in 1946 and that no documentation had been found that indicated a variance or other discretionary approval had been granted to allow the structure to encroach into the 20 -foot front yard setback. The item was continued to this meeting to allow the property owner time to research the legality of the nonconforming structure. Attached to this report as Exhibit 2 is a letter prepared by the attorney representing the applicant. No documentation has been provided with this correspondence indicating the subject structure was granted some form of discretionary approval by the City to encroach into the required 20 -foot front yard setback. Prior to the appeal and review of this case by the City Attorney's Office, some modification permits have been granted to allow alterations and additions to nonconforming structures without the determination as to whether or not the structure was a "legal' nonconforming structure. However, it is the opinion of the City Attorney's Office, and staff concurs, that unless it can be determined a structure is a "legal" nonconforming structure consistent with the definition in the Zoning Code, the provisions of the nonconforming chapter would not apply to this or future modification permit applications for nonconforming structures. ANALYSIS Pursuant to Section 20.62.020 of the Zoning Code, structures that become nonconforming due to reclassification, ordinance changes, or annexations may be continued subject to the provisions of Chapter 20.62 (Nonconforming Structures and Uses). The determination that a structure is nonconforming is verified by looking at whether or not the structure is consistent with the provisions of the Zoning Code, pursuant to Section 20.62.030. In this case, the subject structure is nonconforming because it encroaches into the required 20 -front yard setback. Upon determining a structure is nonconforming, it is necessary to determine if the structure is legal because Section 20.62.040, which allows for alterations and expansion of nonconforming structures, applies only to "legal' nonconforming structures. As stated above, a nonconforming structure is defined as a structure that complied with the rules and regulations in effect at the time of construction and subsequently becomes nonconforming due to changes to the Zoning Code or other rules and regulations. In this case, the subject structure is not a 'legal" nonconforming structure because the Zoning Code in effect at the time of construction required a 20 -foot front yard setback Appeal of Modification Permit No. 2007 -060 December 6, 2007 Page 3 and no documentation has been produced to confirm that a variance or other discretionary approval was granted to allow the structure to encroach into the setback. CONCLUSION Staff has concluded that the subject structure is not a `legal' nonconforming structure. Therefore, the provisions of Section 20.62.040 of the Zoning Code are inapplicable and the Modification Permit was approved in error and is null and void. Based on the foregoing information, staff recommends that the Planning Commission reverse the decision of the Zoning Administrator and deny Modification Permit No. 2007 -060. Prepared by: Submitted by: Jan t J" Brown, Assistant Planner David .. PlannilDilrector EXHIBITS 1. Draft Resolution for Denial of Modification Permit No. 2007 -060 2. Correspondence from Richard Sontag, Attorney at Law 3. Correspondence from Applicant 4. Correspondence from Appellant FAUsers \PLN\Shared \PA's \PAs- 2007\PA2007- 152 \PC \MD2007 -060 PC Staff Rpt12 -6 Mtg.doc Exhibit No. 1 OR RESOLUTION NO. A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF NEWPORT BEACH REVERSING THE DECISION OF THE ZONING ADMINISTRATOR AND DENYING MODIFICATION PERMIT NO. 2007 -060 FOR PROPERTY LOCATED AT 418 REDLANDS AVENUE (PA2007 -152) WHEREAS, an application was filed by Joyce LCM RedWillow with respect to property located at 418 Redlands Avenue, and legally described as Lot 7, Block 24, First Addition to Newport Heights, requesting approval of Modification Permit No. 2007 -060 to permit the minor interior remodel of and a 1,203 square -foot addition to a nonconforming single - family dwelling unit that encroaches 13 feet, 8 inches into the 20 -foot required front yard setback; and WHEREAS, at a noticed public hearing held on August 20, 2007, the Zoning Administrator considered the application, plans, and written and oral evidence presented at this meeting, and approved Modification Permit No. 2007 -060 to allow the minor interior remodel and a 1,203 square -foot addition to a nonconforming single - family dwelling unit that encroaches 13 feet, 8 inches into the 20 -foot required front yard setback; and WHEREAS, on August 30, 2007, an appeal of the Zoning Administrator's decision to approve Modification Permit No. 2007 -060 was filed on the grounds that the proposed modification does not meet the necessary findings to grant approval of the request; and WHEREAS, pursuant to Section 20.95.060 C, a public hearing on an appeal is conducted "de novo," meaning that it is a new hearing and the decision being appealed has no force or effect as of the date the appeal was filed. The appellate body is not bound by the decision being appealed or limited to the issues raised on appeal; and WHEREAS, a public hearing on the appeal of the Zoning Administrator's decision to approve Modification Permit No. 2007 -060 was held on October 18, 2007, and December 6, 2007, in the City Hall Council Chambers, 3300 Newport Boulevard, Newport Beach, California. A notice of time, place and purpose of the aforesaid meeting was given. Evidence, both written and oral, was presented to and considered by the Planning Commission at these meetings; and WHEREAS, the property is designated Single Unit Residential Detached by the General Plan Land Use Element and is zoned R -1 (Single - Family Residential), and the existing residential structure is consistent with these designations; and WHEREAS, pursuant to Section 20.62.020, only structures that become nonconforming due to reclassification, ordinance changes, or annexations are subject to the provisions of Chapter 20.62; and WHEREAS, pursuant to Section 20.62.030, the determination that a structure is nonconforming is verified by looking at whether or not the structure is consistent with the provisions of the Zoning Code; and I Planning Commission Resolution No. _ Page 2 of 2 WHEREAS, is has been determined the subject structure is not a 'legal' nonconforming structure because the Zoning Code in effect at the time of construction required a 20 -foot front yard setback and no documentation has been produced to confirm that a variance or other discretionary approval was granted to allow the structure to encroach into the setback. NOW, THEREFORE, BE IT RESOLVED Section 1. Based upon the aforementioned facts, the Planning Commission hereby reverses the decision of the Zoning Administrator, and denies Modification Permit No. 2007 -060. 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 or this action is called for review by the City Council in accordance with the provisions of Title 20, Planning and Zoning, of the Newport Beach Municipal Code. PASSED, APPROVED AND ADOPTED THIS 6th DAY OF DECEMBER, 2007. AYES: NOS: ABSENT: L-B Robert Hawkins, Chairman BY: Bradley Hillgren, Secretary 8 Exhibit No. 2 10 THE LAW FIRM OF RUZICKA & WALLACE, LLR A LIMITED LIABILITY PARINFRSfBP 16520 BAKE PARKWAY SUITE 280 IRVINE. CALIFORNIA 92618 TELEPHONE (949) 759 -1080 FACSIMILE (949) 759 -6813 November 28, 2007 HAND DELIVERED City of Newport Beach Planning Commission 3300 Newport Boulevard Newport Beach, CA 92658 -8915 RE: My Client - Ms. Joyce Redwillow Modification Permit #2007 -060 (PA2007 -152) Subject Property - 418 Redlands Ave., Newport Beach Honorary Members of the Planning Commission, GREGORY Y. RUZICKA, U.M. EARL R. WALLACE Of Counsel RICt m S. SONTAG PAULE.SNYDER A 4N 4e d> 47 As you may recall from the October 18, 2007 meeting I represent Joyce Redwillow regarding the single family 1 esidence located at 418 Redlands Av:.nue, Newport Beach, California (the "Property"), and the appeal ofthe above - referenced modification permit filed by her neighbor, William Higman. Below please find an analysis of the issues involved in this appeal. Based on that analysis my client and I believe that the appeal should be denied, and that the requested modification permit should be issued. HISTORY OF SUBJECT PROPERTY The current structure on the Property (the "Structure ") was originally built in or about 1947 pursuant to a September 1946 building permit. There is no evidence that this was not a valid permit. The Structure; is a two (2) story residence. The Structure was constructed so that it encroached on a twenty (20) foot front yard setback that was adopted by the City at or about the time it was built. The part of the Structure that so encroaches is a downstairs two (2) vehicle garage and the portion of the upstairs residence that includes the kitchen. Said encroachment makes the structure non - conforming under the current City Code. While staff has been unable to determine why the City allowed such an encroachment, it is Ms. Redwillow's position that the issuance of the 1946 building permit means that the Structure is a legal non - conforming structure. \k City of Newport Beach Planning Commission Re: Modification Permit #2007 -060 (PA2007 -152) November 28, 2007 Page 2 In October 1979 the City issued a modification permit to allow an addition at the rear of the Structure, and such an addition was completed in or about 1981. Said permit was granted without controversy. Ms. Redwillow purchased the Property in 1989, and currently resides there. HISTORY OF CURRENT DISPUTE In 2006 Ms. Redwillow desired to make improvements to the Property and the Structure. In October 2006 she submitted plans for a building permit for a proposed minor interior remodel and addition to the Structure. Plans were submitted, and said plans were approved in June 2007. Ms. Redwillow's contractor then began substantial work at the Property. Soon thereafter the neighbor immediately to the north of the Property, William I- Egman, filed a complaint with the Planning Department'. Staff then decided that Ms. Redwillow's June 2007 permit was mistakenly issued, and that because of the Structure's non - conformity a modification permit was required. A stop work order was then issued, and on July 31, 2007 Ms. Redwillow applied for such a permit. At an August 30, 2007 hearing the Zoning Administrator considered Ms. Redwillow's application for a modification permit. Mr. Higman appeared and contested the application. At the conclusion of the hearing the Zoning Administrator granted the application. In connection with the granting of the permit the Administrator made several required findings of fact, including (1) the proposed addition and remodel were "consistent with the legislative intent of ..the Municipal Code ", (2) the granting of the "application is necessary due to practical difficulties associated with the property. The strict application of the ...Code results in a physical hardships that are inconsistent with the purpose and intent of the ... Code ", (3) "the requested modification will be compatible with existing development(s) in the neighborhood" because, among other reasons, "[T]he proposed addition to the non - conforming structures is similar to and consistent with modified and conditioned approvals granted by the Zoning Administrator, Modifications' Committee and the Planning Commission on appeal for addition to non - conforming structures in this neighborhood and Citywide ", (4) "the granting of this Modification Permit will not adversely affect the health or safety of persons residing or working in the neighborhood of the property and not be detrimental to the general welfare ". Twelve (12) 1 Ms. Redwillow's problems with Mr. Higman actually began in September 2006. At that time contractors hired by the Higmans to construct a swimming pool in their yard caused extensive damage to Ms. Redwillow's backyard, including damaging part of her sprinkler system and destroying a number of mature Burgmansias trees. Ms. Redwillow was referred to me by the Oasis Senior Citizen Center. In November 2006 I wrote to Mr. Higman concerning this matter. After several weeks Mr. Hlgman eventually had the sprinkler system repaired, though he never compensated Ms. Redwillow for the trees. go City of Newport Beach Planning Commission Re: Modification Permit #2007 -060 (PA2007 -152) November 28, 2007 Page 3 conditions were also attached to the granting of the permit. Mr. Higman then filed the within appeal. The appeal was originally set for hearing at the Planning Commission's October 18, 2007 meeting. However, at that hearing, and for the first time in this matter, Staff raised a new and potentially significant issue. At that hearing Staff made the recommendation that the sought for modification permit could not be granted if the non- conforming structure is "illegal ". Without reference to the City Code, Staff apparently defines an "illegal" non - conforming use as one that was never legal, as opposed to a `legal" non - conforming use that refers to a structure that was "legal" when it was built, but has become "illegal" due to a change in the zoning laws. Because Staff can find nothing in the City's records regarding a "variance or other discretionary approval" for the Structure at the time it was built, they have now labeled the Structure an "illegal" non - conforming structure. This despite the fact that the Structure was built with a properly issued and valid building permit.2 Due to this new issue, and at Ms. Redwillow's and my request, the Commission continued the hearing on this appeal to its December 2007 meeting. CITY CODE AND NON - CONFORMING RESIDENTIAL STRUCTURES Title 20 to the City of Newport Beach Municipal Code includes many definitions used in zoning and planning matters. §20.03.030 defines a "nonconforming structure" as one "that was lawfully erected, but which does not conform with the property development regulations prescribed in the regulations for the district in which the structure is located by reason of adoption or amendment of the Code..." The Code does not make any distinction between "legal" and "illegal" non - conforming structures, and does not provide a definition for those terms. Chapter 20.62 concerns "nonconforming structures and uses" and "structural alterations" to such structures. The "chapter is intended to limit the expansion of nonconforming structures... to the maximum extent feasible, to establish the criteria under which they may be continued... and to bring these structures... into conformity in an equitable, reasonable and timely manner, without infringing upon the constitutional rights of property owners." §20.62.040(C)(D) provide for structural alterations and additions to "legal" nonconforming structures. Pursuant to those sections alterations and additions of up to 50 percent of the structure or the gross floor area may be made "upon approval of a modification permit ". In order for such a Despite the potential significance of this issue, it was not raised in the City's initial July 2007 correspondence with Ms. Redwillow regarding this matter, at the Zoning Administrator's August 2007 hearing, or in the Staff report pt0pared for the October l8' Planning Commission hearing. S3 City of Newport Beach Planning Commission Re: Modification Permit #2007 -060 (PA2007 -152) November 28, 2007 Page 4 a permit to be issued §20.62.040(F) requires that certain findings be made. Said findings include: "(1) The cost of the improvements to be made is minor in comparison to the value of the existing nonconforming condition. (2) The cost of correcting the nonconforming condition would exceed the cost of the other alterations proposed. (3) Retention of the nonconforming condition is necessary to maintain reasonable use of the structure. (4) The alteration does not increase the structure's inconsistency with the regulations of the Zoning Code." Additionally, §20.93.030 requires th Administrator approves a modification permit. in this matter by the Administrator, include: t other findings be made when the Zoning Said findings, which as stated above were made "(A) The granting of the application is necessary due to practical difficulties associated with the property and that the strict application of the Zoning Code results in physical hardships that are inconsistent with the purpose and intent of the Zoning Code. (B) The requested modification will be compatible with existing development in the neighborhood. (C) The granting of such application will not adversely affect the health or safety of persons residing or working in the neighborhood ...and will not be detrimental to the general welfare or injurious or property or improvements in the neighborhood. As argued below, the above findings are all easily made in this matter, and so the Planning Commission should deny the within appeal, and the City must grant Ms. Redwillow the sought for modification permit. ANALYSIS Based upon Staff s current position it appears that the fast issue which should be addressed is whether the Structure is a `legal" or "illegal" non - conforming structure. The Structure was constructed approximately sixty (60) years ago pursuant to a valid building permit. Based upon the Staff report it appears that it was at about that time the City adopted the current front yard setbacks. Since a building permit was issued, and the City's files City of Newport Beach Planning Commission Re: Modification Permit #2007 -060 (PA2007 -152) November 28, 2007 Page 5 contain no evidence of any variance issued in association with the Structure, it is logical to assume that the Structure was built according to the then setback requirements. The fact that the Structure was built at apparently the same time the set back requirements were changing is further evidence that it was built legally according to the requirements then enforced by the City. Without any conflicting evidence the only conclusion that can be drawn is that the Structure was "lawfully erected" and so represents a "legal" nonconforming use as defined by the City Code. Furthermore, in 1979 the City granted the then owners of the Property a modification permit for an addition to the Structure. If the Structure was an "illegal" non - conforming structure such a permit should not have been issued. As such it is plain that at least in 1979 the City considered the Structure to be a `legal" non - conforming structure. Finally, and as more particularly set forth below, other modification permits for additions or remodels to non - conforming residential structures issued by the City in the past five (5) years do not even apply this distinction. A review of all such permits indicated that none of them involved an analysis of whether or not the subject structure was a "legal" or "illegal' nonconforming structure. This appears to be the first instance in which Staff has raised this issue. Neither I or Ms. Redwillow understand why this issue has now been raised in this matter. Based on the City's past failure to consider the issue with regard to other modification permits this appears to be a situation of selective enforcement. If, as argued above, the Structure is a "legal" non - conforming structure than, as also set forth above, Ms. Redwillow is entitled to the modification permit is certain conditions exist. As set forth above, the Zoning Administrator found that my client's application met all of the requirements necessary for the issuance of a modification permit. However, Staff apparently disagrees. In the report prepared for the October 18, 2007 hearing Staff argued that Ms. Redwillow's application did not meet the requirements of such a permit. Staff is wrong. The first finding required by §20.93.030 is that "[T]he granting of the application is necessary due to practical difficulties associated with the property and that the strict application of the Zoning Code results in physical hardships that are inconsistent with the purpose and intent of the Zoning Code ". In this situation the Structure encroaches on the current front yard setbacks, but has done so for approximately sixty (60) years. A strict enforcement of said setback would involve demolishing a large section of the Structure, including the Structure's kitchen. As Staff notes, "[P]ractically speaking, it would be structurally difficult to retain a portion of the structure and the entire building would need to be demolished in order to conform to the... front yard setback." As such, the "physical hardships" to Ms. Redwillow are clear, and were recognized by )5 City of Newport Beach Planning Commission Re: Modification Permit #2007 -060 (PA2007 -152) November 28, 2007 Page 6 both the Zoning Administrator and the Staff.3 The second finding required by §20.93.030 is that "[T]he requested modification will be compatible with existing development in the neighborhood ". In regard to this finding both the Zoning Administrator and the Staff found that the proposed modifications and improvements conform to all applicable zoning and building requirements. Furthermore, the proposed modifications do not in any way intrude on neighborhood characteristics or block any views. As such the modifications to be done by Ms. Redwillow are "compatible with existing development in the neighborhood. " Additionally, §20.93.030(C) requires that "[Th]e granting of such application will not adversely affect the health or safety of persons residing or working in the neighborhood ... and will not be detrimental to the general welfare or injurious or property or improvements in the neighborhood". There is absolutely no evidence that the granting of Ms. Redwillow's application will adversely affect the health or safety of anyone. Mr. Higman has made the allegation (and Staff apparently supports it without reference to any supporting evidence) that the Structure blocks light and air to his front yard, and so somehow affects his and his family's health and safety. While due to its encroachment on the front yard setback the Structure may block some light to Mr. Higman's fi-ont yard (how can it block air ?), this is irrelevant. First, it is not a health or safety issue, and second Mr. Higman bought the lot his home is situated on, and built his home, long after the Structure was built. Therefore if Mr. Higman has a problem with the Structure he can blame only himself for building a house right next door to it. Furthermore, Ms. Redwillow's application meets all of the criteria set forth in §20.62.040(F). The cost of the improvements to be made by Ms. Redwillow are minor in comparison to the value of the existing nonconforming condition. Ms. Redwillow believes the Property is worth at lease $1,500,000.00. She has planned on spending approximately 4250,000.00 on the improvements. Additionally, the cost of correcting the nonconforming condition would exceed the cost of the other alterations proposed. As set forth above, it would require demolishing (and rebuilding) a large portion of the Structure, including that portion with the home's kitchen. 3 Despite finding that Ms. Redwillow's application meets the criteria set forth in §20.93.030(A) Staff, with very little justification, concluded that her application should be denied. " Once again Staff disagrees. Said disagreement is apparently based on an erroneous interpretation of the Code. Staff found that the modifications would not be compatible with the neighborhood because of the Structure's existing non - conformity. That is not what the Code says. The Code refers to the "requested modification ", not the non - conforming structure to be modified. Staff s interpretation of this requirement would mean that few modification permits could ever be issued because the non - conforming structures to be modified are probably is not compatible with existing development. le City of Newport Beach Planning Commission Re: Modification Permit #2007 -060 (PA2007 -152) November 28, 2007 Page 7 All of that would clearly cost more than $250,000.00. Furthermore, retention of the nonconforming condition is necessary to maintain reasonable use of the Structure. Again, the nonconforming portion of the Structure includes the house's kitchen. Without a kitchen its hard to have a home. Finally, the proposed alteration does not increase the structure's inconsistency with the regulations of the Zoning Code. As set forth in the findings of the Zoning Administrator and the Staff, all of Ms. Redwillow's proposed alterations and additions to the Structure and the Property comply with all applicable zoning and building codes, and so there is no increased inconsistency. Additionally, the equities in this matter clearly favor Ms. Redwillow. Based on the building permit issued in 1946, the reliance thereon, and the lack of any action by the City for over sixty (60) years to require the non - conformity of the Structure to be corrected, Ms. Redwillow has a strong equitable argument for allowing the proposed modifications to the Structure and the Property. Finally, and as the Zoning Administrator found, the City has issued many modification permits for other structures that are non - conforming due to encroachment of various setbacks. Said permits include numbers 4513 (304 Santa Ana Ave.), #4603 (2916 Clay), MD2003 -007 (2054 E. Ocean Front), MD2003 -030 (104 Via Mentone), MD2003 -035 (2221 Heather Ln.), MD2003 -050 (1703 E. Ocean Blvd.), MD2003 -123 (1300 Sussex Ln.), MD2004 -005 (504 W. Bay Ave.), MD2004 -019 (1319 Oxford Ln.), MD2004 -025 (2 15 Crystal Ave.), MD2004 -032 (2223 Cliff Dr.), MD2004 -041 (401 Santa Ana Ave.), MD2004 -044 (2540 Vista Baya), MD2004 -052 (934 Goldenrod Ave.), MD2004 -072 (3908 Channel Pl.), MD2005 -07 (2024 Galaxy Dr. ), MD2005 -011 (2248 Port Durness Pl.), MD2006 -035 (340 Catalina Dr.), MD2006 -062 (2337 La Linda Pl.), MD2006 -066 (611 Kings Pl.), MD2006 -076 (2724 Ocean Blvd.), MD2006 -079 (302 Amethyst Ave.), and MD2006 -082 (717 Poppy Ave.).' CONCLUSION Ms. Redwillow desires to improve her home. To that end she hired a licensed contractor and obtained the necessary permits. A neighbor complained and the City decided she needed a modification permit to do the necessary work. She applied for such a permit and it was granted by the Zoning Administrator. Her neighbor, with whom she has a history of bad blood based on the neighbor's contractor's damage to the Property, appealed that decision and that appeal is currently before you. s Furthermore, and as stated above, in none of those permits was the issue of "legal" versus "illegal" non- conforming structure brought up. 1I City of Newport Beach Planning Commission Re: Modification Permit #2007 -060 (PA2007 -152) November 28, 2007 Page 8 As set forth above, it is my and Ms. Redwillow's position that she is clearly entitled to the modification permit. Despite Staffs conclusions (which directly contradict the findings of the Zoning Administrator), and as set forth above, the history of the Structure demonstrates that it is a "legal" non - conforming structure, and Ms. Redwillow's application meets all of the Code's criteria for a modification permit. Therefore the within appeal should be denied, and the sought for modification permit granted. I want to thank the members of the Planning Commission for their attention to this matter, and I look forward to the continued December 5`' Planning Commission meeting and at that time being able to answer any questions you may have. Otherwise, if you have any questions or there are any problems please feel free to contact me at any time. Thank you for your courtesy and attention to this matter. SINCERELY. (RI ONTAG ATTORNEY AT LAW cc: Client l� Exhibit No. 3 1� Page I of 2 Brown, Janet From: JOYCE REDWILLOW Doyceredwillow @sbcglobal.net] Sent: Thursday, November 29, 2007 10:12 AM To: Brown, Janet Cc: Richard Sontag Subject: Please forward: My request to Chairman of Planning Commission As you know, the modification appeal for 418 Redlands Avenue is scheduled for December 6, 2007. This seems to have taken on a life of its own far beyond the scope and intent of the project. I'm not sure how to bring this back into perspective. To date, no decision -maker from the city or planning commission has actually seen the house as it relates to the plans. I would be very grateful if you and any other planning commission member could come and look at the property and house, because no one else has. This is a small house; my plan is modest in size; elegant in its simplicity and scope. I will be 70 this year and planned to retire and pursue my design interests with my own studio. I obtained a reverse mortgage for my construction financing. To date, I have spent at least $50,000 in plans, engineering, many revisions, a city mandated survey, permits, hearings, lot preparation, mortgage costs and legal fees. My initial construction contract is for $250,000. I never expected the city would revoke its permit, particularly since it took over a year and many reviews to have everything finalized. Since beginning construction in June, now stopped for six months, my mortgage continues to accrue monthly charges of approximately $1,630 for basically nothing. The year before, I replaced the roofs. I am now unable to proceed with even small things such as window replacement and deck replacement. The terms of the mortgage include restoration of these areas. It has been six months since I drew the construction funds. There is a time frame of six months for repairs that begins upon initial withdrawal of funds. In December, I will be in default of the loan terms. These were to have been completed concurrent with new construction so everything matched. This is now a very real concern. My contractor, Quality Construction, completed two nearby remodels on Santa Ana this year. He does excellent work, but will have to schedule forward if this extended delay continues. The network of a -mails and correspondence between Will Higman and the city staff encompasses several departments and is extensive. I can not be certain I will ever receive all copies to review for his accuracy. As discussed in my response dated October 16, 2007, false statements were made regarding issue of permit and that construction had started. These two major facts were entirely eliminated from the original planning report to commissioners. In a similar manner, Higman describes the front overhang as extending far beyond the public right of way. In fact, it extends less than a foot over in one comer only. I was present when the city surveyor measured the overhang and discussed this with him. For me personally, the darkest moment by far is that Mrs. Hart was verbally attacked, threatened, and called a liar by the Higmans and Mrs. Higman's father, in the lobby as she was leaving the hearing. I will 11/30/2007 A Page 2 of 2 regret forever that a treasured friend experienced this frightening behavior simply because she chose to comment on my behalf. With time and research, information can be disputed and corrected, but there is no way to go back and change this. In my opinion, contrary to appearances, these are not nice people. They do and say whatever they perceive is necessary to achieve their interests. The city staff has been placed in the position of having to allow them to do so. Someone needs to say "no" and stop this endless invention of frequently trivial issues, best summarized by Will Higman in his communications with staff. "...his wish to do a strong background approach with minimal exposure at the hearing," [and] "...now that things have reversed in his favor, the need to change his stratedgy." Its difficult to determine what they really want. They've owned their property since 1996 and rented it out for several years before building. Kris Higman has aggressively campaigned to buy my property. First, her father could make a lot of money on it and she could have friends move in. I told her that was unrealistic, although the city charges me utilties for 3 dwellings, that would not go forward to a new owner. Next, they wanted to buy the house and rent it back to me for as long as I wished to stay. The only thing they would change is to put in new windows. Then it was .... I'm too old to live here and all the young families in Newport Heights are buying the houses next to them. Following my knee replacement the guess was that I would certainly move back to Denver to be close to the family. You can imagine how pleased I was to observe the new homes at 515 and 519 Santa Ana were built by people that seem to be closer to my age. At this point, I'm not sure what to do other than request your assistance to actually look at the property, judge it on its own merits, and go from there. Hopefully we can arrange this. I look forward to hearing from you. Many thanks again, Sincerely, Joyce Redwillow e -mail (best) or phone 949 - 642 -4963 11/30/2007 A Z).1 The original Orange County tax assessor's ledger provides the following information with respect to Map of the First Addition to Newport Heights, February 1907, Block 24: 6 houses, 5 minor improvements in 1947. LOT NAME 1944 1945 1946 1947 1 Webb Finley $ 1920 2 0 3 0 4 Marion Goodcell $ 230 $ 230 5 Durwood Young $ 1305 $ 1305 $ 1305 $ 1305 6 0 7 Ada Museus $ 1860 8 0 9 0 10 0 11 Paul Anders Grace Brooks $ 1270 $1480 12 0 13 0 14 Orville Fingley $ 1250 15 Nelson Fox $ 550 16 0 17 0 18 Eugene Weyant $ 350 $ 350 19 Hugh Watson $ 1660 20 Jobn AhLstrom $ 150 $ 150 a3 d b `I Z +m +i N ar• +ic^^P •r ca� tip^" MAP OF FIRS' ADDITION TO NEWPORT HEIGHTS F,HL�Y �P_. FL.R —r M7 5.—T ZOO. A" W D z W d Aff �r X EE �5 T T E \ I a \ l2 2!� 1 Ate••• ^`'_'�� // tx � � 41.mAy x.l:fy lrt Nip. wP"'�'ker ky SM ln.er ��.•�'r- U1 ^ ��. a'i�s!+PX. [ rv.F.°r.• 4.t..';..•.4a...t °ftnll .WtixLi.,e..oW..n [u..dm,wih lmJ i�, .i+.e.q.ny. ). 2 C Pj' 14.yX QI lA.f IA...y.w..mewa qln. Mea .new.W.,.w..j fr'7 4n _:i.cdr.a� - p� /y 6W-4.. `A aWivttlPnxu 1t[L , nwwanb.b.0 .lrwayw�npa_w. o. wwny. ux<.. x."BaNhYi�'�/..t�.a � tl wyXbl�IknWn Wnuw4 MvimiNWbrv,Atl�tL.,.�'Ib b Nbm.dad I M6,wI. W W kM Vd.N¢iM aWM ,W Ir.l�N� ~bm�nL��� WmiGINW ' �5 N �+ Jfi �V 4" ()o ,� n p• � m14; 4 OZ �°°' nM n �m ry zl AUfti tp5 c� � x u � � � ti wo `tea• d co AW w�a m 4° m a ACP IW 7., J -AV L ell -49 Iii 10 :AA lee .�a ,111 * •.• `: H r� � �1 r' � j.'• ` f t 1� a war Ile :•• - p . I �11�. �. 1jA� ti•� rr -��_r . Exhibit No. 4 �w Page 1 of 6 Brown, Janet From: Will Higman [Whigman @rwli.net] Sent: Thursday, November 29, 2007 5:38 AM To: Brown, Janet Cc: Harp, Aaron; Lepo, David Subject: PC Meeting December 6th ( MOD Application No. 2467) Attachments: Building Permit#1013- 81.pdf; Modifaction Permit#2467.pdf Good morning Janet Regarding the planning commission meeting set for December 6th... Please add this string of emails and the "attachments" to the staff report for me. I will be addressing the planning commissioners on the issues of City Council Policy L -2 and whether or not the house is legal nonconforming. I have already addressed all of the other code and policy issues to the best of my ability and have nothing to add there. Thanks for your help! Will From: Will Higman Sent: Tuesday, October 30, 2007 3:07 PM To: Harp, Aaron; Brown, Janet Cc: jeff.cole @cushwake.com; eaton727 @earthlink.net; rhawkins @earthlink.net; bhillgren @cox.net; scott.peotter @taxFlghter.com; strataland @earthlink.net; Lepo, David Subject: RE: MOD Application No. 2467 Aaron Thanks for letting me know how that works. I did find some interesting information about this Modification permit that I would like to share with you. Please take the time to read through this email. When I read through the staff report I noticed on Modification permit No. 2467, that the Modifications Committee placed special conditions on the project on October 16, 1979. Now that I know a little bit about how and why this process happens the following condition really caught my eye. "That the proposal includes a reduction in the front yard encroachments that now exist on the site." The reason this caught my eye was because I thought it might help all of us solve the mystery of how and when the added little low roof overhang came into existence. This is the portion of the front structure that has been added on with no building records 11/29/2007 31 Page 2 of 6 and is the portion of the structure that protrudes into the public right of way per the City Engineer. The Planning department was very helpful and allowed me to come in and view the microfiche. Included in the file were the actual plans that were submitted by the applicant. What happened next I can only describe as amazing! The plans clearly showed how and why the Modification Committee approved the permit. I will do my best to describe my findings but you may want to go over to the Planning department and view the file for yourself. The plans submitted and approved for this Mod permit included the following changes to the existing front structure. • The exterior stairs were removed and an internal stair case was added. • The front door was now located on the bottom floor and facing Redlands Ave. • The low roof in question above was nonexistent on the plans. • The front driveway approach was closed off along with the garage! These were the main things that I saw that could be classified as a reduction in the front yard encroachments. Obviously the removal of the curb cut and closing of the front facing garage were standouts! The bottom line here is the fact that the Hart's were making an attempt to convert the front structure into a more normal single family home. I do have to speculate that the reason they were granted the Modification permit was because of their intentions and plans along with "closing off the curb cut" which now put them in compliance of City Council Policy L -2. Mrs. Hart was on the City Council during this time and I am sure that she was very cognizant of the building codes in Newport Heights at that time. I now take my hat off to the Harts for attempting to do the right thing with this property! So now one question is... where did Phil Manuell and building permit #1013 -81 come into play? As you stated the Mod permit transfers with the property but I highly doubt that this released him from having to comply with the conditions of the Modification Permit. I have not yet gone to the Building Department to view the plans but I was able to find one thing available on the public access portion of the City website. (see attachment) It appears the Mr. Manuell started his project without a building permit. I have attached the notes from the field inspector at that time which state: "Foundation and slab placed without the benefit of permit or inspection." So not only did Mr. Manuell start his project without a permit he failed to complete "any" of the reductions in encroachments per the condition of the Mod. My question for today is as follows: Because of Mr. Manuell's rouge actions as it pertains to Modification Permit No. 11/29/2007 3?- Page 3 of 6 2467, does this afterthought addition now become an "illegal" structure? It's amazing to me how much further all of the problems with this property extend. After seeing all of this new information it really makes me feel strong about the City Council Policy L -2 requirement in our neighborhood. I hope you find this information useful in determining if this structure is in fact legal. Sincerely, Will Higman From: Harp, Aaron [mailto:aharp @city.newport- beach.ca.us] Sent: Monday, October 29, 2007 8:53 AM. To: Will Higman; Brown, Janet Cc: jeff.cole @cushwake.com; eaton727 @earthlink.net; rhawkins @earthlink.net; bhillgren@cox.net; scott.peotter @taxfighter.com; strataland @earthlink.net; Lepo, David Subject: RE: MOD Application No. 2467 Hi Will, The modification permit runs with the land so a change of ownership wouldn't impact the rights under the modification permit. Thx. Aaron C. Harp Assistant City Attorney for the City of Newport Beach (949) 644 -3131 FAX 723 -3519 Confidentiality Notice: This email may contain material that is confidential, privileged and /or attorney work product for the sole use of the addressee. Any review by, reliance or distribution by others or forwarding to others without express permission is strictly prohibited. If you receive this transmission in error, you are advised that any disclosure, copying, distribution, or the taking of any action in reliance upon the communication is strictly prohibited. Moreover, any such inadvertent disclosure shall not compromise or waive the attorney- client privilege as to this communication. If you have received this communication in error, immediately please notify the sender. Thank you. From: Will Higman [mailto:Whigman @rwll.net] Sent: Saturday, October 27, 2007 2:34 PM 11/29/2007 S5 Page 4 of 6 To: Brown, Janet Cc: jeff.cole @cushwake.com; eaton727 @earthlink.net; rhawkins @earthlink.net; bhillgren @cox.net; scott.peotter @taxfighter.com; strataland @earthlink.net; Harp, Aaron; Lepo, David Subject: RE: MOD Application No. 2467 Janet Thanks for letting me come in and view the files for this Modification permit. I have one question regarding the permit and it is as follows: Are Modification permits transferable to a new owner in the event that a change of ownership occurs before the permit is exercised? The Mod permit no. 2467 was issued in 1979 to Linda Hart but never exercised by the applicant or "per the plans submitted with the application." In 1981 there was a building permit issued to someone named Phil Manuell and he listed himself as the owner. It looks like the City let him ride the coat tails of this Mod permit and I am not sure if this is proper? He did get a building permit within 24 months but the addition he completed did not comply with the "conditions" of the 1979 Mod permit or match "any of the plans submitted" by the Mod applicant in 1979. Please let me know what you can! Also I have sent Erin an email letting her know that I would like to come in and see the plans on file for the 1981 building permit. Thank you, Will From: Brown, Janet [mailto:JBrown @city.newport-beach.ca.us] Sent: Monday, October 22, 2007 4:52 PM To: Will Higman Subject: RE: MOD Application No. 2467 I'll check with our administrative staff and let you know. From: Will Higman [mailto:Whigman @rwli.netj Sent: Monday, October 22, 2007 3:44 PM To: Brown, Janet Subject: RE: MOD Application No. 2467 Thanks Janet! I do want to come in for both... Is there a certain day or time that would work best for listening to the recording? FYI I came in to see Aaron today and it was time well spent. 11/29/2007 � 1 Page 5 of 6 Thanks again, Will From: Brown, Janet [mailto: ]Brown @city.newport- beach.ca.us] Sent: Monday, October 22, 2007 3:36 PM To: Will Higman Subject: RE: MOD Application No. 2467 Good afternoon, Will. The complete file for Modification Permit No. 2467 is available on microfiche. You are welcome to come in at any time to review the microfiche file. The recording of the August 20, 2007 Modifications Hearing is on a cassette tape; there is no digital file. Please let me know when you want to come in to listen to the tape. Our administrative staff will need advance notification in order to get the tape ready to play and schedule a quiet location for you. Thank you. Janet Johnson Brown Assistant Planner City of Newport Beach (949) 644 -3236 jbrown@city.newport-beach.ca.us From: Will Higman [mailto:Whigman @rwli.net] Sent: Friday, October 19, 2007 1:32 PM To: Brown, Janet Subject: MOD Application No. 2467 Janet Thank you for doing such a good job with your staff report last night. The 1946 picture was a big hit! Now that the case has turned directions my game plan will change as well. I am hoping that you will continue to help with with questions that I have. Please let me know what the protocol is regarding these requests... Also I do now want to come in and listen to the Modification Hearing recording. Is there anyway this is available as a digital file? Please let me know... To get me started with new questions I have attached a document for your review. The document is a modification permit that was granted in 1979 with special conditions. One of the conditions was that the a 'reduction in front yard encroachments that now exist on site. " 11/29/2007 Page 6 of 6 My question is as follows. Are there any records on file that state what these reductions included and if they were ever completed? Please let me know and thank you so much for your help. Will Higman Reliable Wholesale Lumber, Inc. W Higman anerwli.nc Ph. 11/29/2007 3� ' Mo. ,�..(: \gsi��,S.1� t t� ? FOMM.TRIM:I00010i,FOM. r r_ ? - :•�. . REIIFDR �•�; , ,... . . SHEATHING' 'FINAL • •S= _ �- ' ' CERT.OF OCCUP. . . JOVAJ4 -rA) AJ RA; .'.). . ..S'44,0. . I. 4A. .. ,.y....t .....I. �.: ;��.....- {,.,.�..rc.d- ...G:�✓ I A rx aEwro� Cr'C "Y OF NEWYOIt I." BIWA I CALIFO tN1IA onca e+trson�� CNY JJa)) naa tuRwM,., mwt 40fiifications No. 2467 Applicant Linda Hart Involved 418 Redlands A enue Newuprt (Leach The Modifications Committee on_ October 16, 1979 approved the application subject to the following conditions: I. That development shall be in substantial conformance with the aooroved plot olan and The Modifications Committee determined in this case that the proposal would not-be detrimental to persons, property or improvements in the neighborhood and that the modification as approved would be consistent with the legislative intent of Title 20 of the Newport Beach Municipal Code, and made the following findings: I. That all additions to the rear of the front building conform to the required- NOTE: Tnis approval shall extend for a period of In months from the end of the appeal period, and cannot be extended. The decision of the Committee may be appealed to the Planning Commission withinl4 days of the date of the decision. Any appea) filed shall be accompanied by a filing fee of 8100.00. No building permits may be issued until the appeal period has expired. MODIFICATIONS COMMITTEE - DEPARTMENT OF COMMUNITY DEVELOPMENT R. V. )IOGAN, DIRECTOR °j- L ror_vz _... _ ar�aY�._.._._.. Senior Planner NOTE:: The above application number must be affixed to the L +einu submitted for plan check and building permits. IN Page I of 2 Brown, Janet From: Will Higman [Whigman @rwii.net] Sent: Thursday, December 06, 2007 4:08 PM To: Brown, Janet Cc: Harp, Aaron; Lepo, David; Alford, Patrick; Varin, Ginger; Brown, Janet; Robert C. Hawkins; Barry Eaton; Bradley Hillgren; Earl McDaniel; Jeffrey Cole; Scott Peotter; Mike Toerge Subject: RE: Hearing - 418 Redlands Avenue ( Higman Reponse to Latest Redwillow) Attachments: Higman Quick Respone ' 2- 6- 07.doc December 6, 2007 Janet Thanks for keeping me up to speed... In an effort to stay on point with the real issues I feel the need to respond to this email of Mrs. Redwillow. I do not have all of my back up paperwork here at work but I feel the need to respond timely. (RedwWow) In my opinion, the "real" issue in this matter is not the encroachment but the Higman's ongoing obsession to prevent me from building anything on my property. We have no problem and would support Mrs. Redwillow in building an addition or new home as long as it complies with the current City set backs along with City Council Policy L-2. (Redwillow) "...we are in favor of letting the property exist in its current configuration ... and [are] in total opposition to any change in the footprint of any structures on the property." This is true even if the structure is determined to be illegal. We have no problem living next to the house even though it sticks out 13'6" into the current City set back. We also would support the decision by the City to allow for future building permits for maintenance issues, i.e. new windows etc... (Redwillow) To paraphrase, forget eveWhin else we said.., ust do not allow a ytthing to be built next to us. This is not true, we welcome any new building structure that complies with the current City set back. (Redwillow) However, should the Higmans continue to insist that my existing overhang, front drive, garage and encroachment are permanently injurious to them... This is not true, the damage only occurs if you connect the front and rear structure 12/06/2007 Page 2 of 2 as proposed. By connecting the two structures we would be burdened with an extra 13'6" of darkness and lack of airflow over and above any other house in Newport Heights. (Redwillow) Is the effect of my setback any greater than the effect of the side yard setback of the Rath's newly built property? No. In fact, their structure totally blocks everything on the adjoining property. Mute point because the Rath's and Farmer's are "corner lots" with different side set backs. I could respond to all of the quotes but these are the main issues as I see them. Also as an FYI I am not coming with any extra people tonight. My neighbors surrounding the project have signed letters in opposition and some have spoken. My wife Kristin will also not be in attendance this evening. We are all just ready to start the process of healing the bad feelings in the neighborhood. Thank you! Will Higman From: Brown, Janet [mailto: ]Brown @city.newport - beach.ca.us] Sent: Thursday, December 06, 2007 3:49 PM To: Will Higman Subject: FW: Hearing - 418 Redlands Avenue Will, Below is a memo /document from Joyce Redwillow that I sent to the Commissioners a while ago. I apologize for omitting your name from the distribution. There are a couple of attachments to Joyce's memo that did not transfer with her e-mail. A hardcopy of the document will be available at the meeting tonight (look for it in the lobby of the Council Chambers). Janet Johnson Brown Assistant Planner City of Newport Beach (949) 644 -3236 jbro wn@ city. ne wport- beach. ca. us 12/06/2007