Attachment 7
Attachment 7 Public Comments
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December 3, 2016 Town of Mammoth Lakes Planning Commission Mammoth Lakes, CA 93546 Re: Minimum Floor Area Ratio Dear Planning Commissioners: Today, I’m writing in regards to the matter of a minimum Floor Area Ratio(FAR) being discussed in the public and at the Planning Commission level. Through conversations with several Planning Commissioners and commercial property owners I’ve had the opportunity to hear arguments both in favor and opposed to the idea of a minimum FAR. While I can envision some benefits of a minimum FAR in the future, I would argue the matter has come about on short notice and without full vetting of the potential impacts. Some of the benefits of a minimum FAR entail Mammoth Lakes realizing maximum development of mixed use properties within its commercial districts; this is being brought about through the discouragement of smaller single (or limited use) projects. As a commercial real estate broker and certified general real estate appraiser in Mammoth Lakes I have the benefit of working with most of our commercial property owners. What I have seen in recent decades is the very incomplete demand for high density projects and the lack of coordination by owners/developers to bring such developers to town. This lack of demand also stems from the lack of economic feasibility for higher density mixed use products. I fear trying to implement a minimum FAR today without a long‐term analysis of how to address impacts would have adverse effects on the marketability of many commercially zoned properties. Mammoth Lakes currently has several approved master planned, and specific planned, areas in town. Even with these properties being advanced with respect to development timelines, it is difficult to attract the higher density mixed use developers. Additionally, trying to force uses that may not fit current demands can prohibit a developer/owner from bringing a much‐needed use. For example, while a grocery store may be a high demand use in town, requiring additional office space, retail, or low AMI housing may not be what is needed to fulfill minimum FAR.
Further, the single use tenant may not be in the business of development and would only be discouraged to develop in Mammoth Lakes if they were required to build uses outside their business model. In conjunction with a minimum FAR discussion needs to be discussion about the surplus of office and retail space. In short, there may be benefits of creating minimum FAR in the future, but it should be done with significant thought and with a clear path of how the development standards will meet market demands. This should also be done with consideration of how to cure current blight and vacancies within our town. Respectfully, Matthew T. Lehman [email protected]
Robert L. Hart, AIA, AICP David P. Howerton, FASLA, AICP Craig Roberts A. James Tinson, AIA
January 3, 2016
One Union Street San Francisco, California 94111 Tel: 415 439 2200 Fax: 415 439 2201 www.harthowerton.com
Mr. Dan Holler Town Manager Town of Mammoth Lakes P.O. Box 1609 Mammoth Lakes, CA 93546
Re. Mammoth’s Downtown – Proposed Minimum Floor Area Ratio Dear Dan: We understand that the Town is considering adopting a minimum FAR in the Downtown area. We’re writing now to share our opinion that the Town should require that development within the Downtown district be at a minimum FAR of 0.75. This is reflective of the 2-3 story density articulated in the work we presented to the Town this summer as well as what is envisioned in the Town’s General Plan and Neighborhood District Plans. The application currently before the Town Council for a market/grocer at 37 Old Mammoth Road demonstrates that while the Town’s existing development standards may protect the “urban-ness” of the street, single-story surface-parked retail sacrifices significant potential for the vibrancy that comes with upper floor uses. We’ve enjoyed following the Town’s progress this fall to establish community consensus around a Vision for Downtown, and remain optimistic about the potential for Downtown Mammoth. At the same time, we appreciate that for Downtown to become the kind of place you envision, the Town needs to set a higher bar for the intensity of development Downtown, and then establish implementable strategies to provide those public facilities, services and urban amenities that will attract the right kinds of developers to Mammoth and be the back-bone of a vibrant urban district. Sincerely,
David P. Howerton, FASLA Chairman
Eron Ashley Managing Principal
cc. Mayor Shields Richardson, TOML Rusty Gregory, Tom Hodges, MMSA
HART HOWERTON, LTD. NEW YORK • SAN FRANCISCO SHANGHAI • LONDON • SÃO PAULO • HONOLULU • BOSTON • MINNEAPOLIS
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Carlton P. Biggs 30391 Via Chico Place Laguna Niguel, CA 92677 [email protected] 949-400-5888
March 27, 2017 Town of Mammoth Lakes [email protected]
Re: Proposed change in Commercial Building Standards Dear Planning Commission and Town Council, Let me begin by stating I am a former resident of the town and have been a property owner for 30+ years, both residential and for the last 25, a commercial property owner. I own the Mammoth Professional Center at 325 Old Mammoth Road. Recently I have been trying to update my property, and at the same time I have had the property for sale. The market for commercial property in Southern California is at an all time high, the market for commercial property in Mammoth is dead. Rents are low, and demand is also low. The changes you propose are not going to help the real estate market in Mammoth. My real estate broker has just informed me about the FAR standards that are being considered by the town. The maximum FAR standard does not concern me, however the minimum FAR of .75 seems unrealistic and impractical. Using my property as an example, I have approximately 16,500 square feet of ground and a building of about 6,000 square feet. It has been estimated that the new construction cost of my building would be something in excess of $1,800,000 not counting land, development costs and any fees charged by the Town or other entities. I have been marketing the building at $999,000.00 with no success so far. My building would be at a FAR of .36. To impose a FAR of .75 would make my building less valuable because now instead of a 6,000 square foot building, a replacement building would have to be a minimum of 12,375 square feet, raising construction costs by more than double, and not likely increasing the value of the property to support $3,600,000 plus in construction costs. I think the town should consider not imposing a Minimum FAR or limit its application to either vacant parcels, or larger parcels or both. Not small parcels such as mine. A second issue I see is snow removal. This season has brought home the impact of Mother Nature. Our snow removal expenses are 4 times normal, mostly because we have had to remove the excess snow with dump trucks. As you increase the density on a property, you decrease the space to park and store snow. Mandating increased density would add to this issue and add to the expenses to own a building. The market place will not support these additional expenses.
Finally, my opinion, as someone who has enjoyed the “Town” feeling of Mammoth for 50 years. I feel that mandating such a severe increase in density seems a move in the wrong direction. People come to Mammoth to enjoy the mountains, the trees and the open space. For the Town to require this density in every case seems wrong on several levels. It certainly will not improve the village atmosphere that people expect when they come to Mammoth. In summary, I request the Planning Commission and the Town Council rethink the application of this Minimum FAR standard or limit its application to either vacant parcels, or larger parcels or both. Not small parcels such as mine. I am not going to be able to attend the meetings on this issue, I request you share my comments with both the Planning Commission and the Town Council.
Sincerely, Carlton P. Biggs
Sandra Moberly From: Sent: To: Subject:
Stan Riffel <[email protected]> Monday, March 27, 2017 2:14 PM Sandra Moberly Minimum FAR
Sandra…received and reviewed an email from Matthew Lehman regarding a zoning code amendment involving a minimum floor area ratio requirement for new commercial. While I would be in favor of a Maximum FAR, I would be opposed to a Minimum FAR. As an example, the property I own at 3613 Main St which is situated on a 9600 sf lot…the 1100 +/- sf building works just fine for me. I would not know what to do with a 7200 sf building (9600 x .75) nor be able support/lease that sort of space (especially with the past and current demand). While this may not impact me currently (as I assume I would be grandfathered in), it may when I decide to sell. I would suggest the Town let owners build what they feel can be economically supported with upper limits only. There is and has been (historically) large amounts of commercial space available…last thing we need in town is more vacant commercial space. Not to mention the increased cost of development to build something not wanted or needed. Just an FYI…there is very little demand, if any, for commercial space in town….to buy or lease. And it’s been like that for the 33+ years I’ve been selling real estate in Mammoth…don’t see it changing anytime soon. Hope this makes sense. Thanks Stan Riffel - Broker/Owner Riffel Real Estate 3613 Main Street P.O. Box 8558 Mammoth Lakes, CA 93546
www.riffelrealestate.com 760-934-3747 (office) 800-622-3747 (toll free) 760-914-1430 (cell) 760-934-7424 (fax) DRE#'s 01478383 / 00864334
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Ruth Traxler From: Sent: To: Subject:
Cindy Avena <[email protected]> Tuesday, March 28, 2017 1:03 PM Ruth Traxler Fw: Slocums' Comments on MINIMUM FLOOR AREA RATIO
Hi Ruth, Thanks for your help. Cindy Avena
From: Cindy Avena <[email protected]> Sent: Tuesday, March 28, 2017 11:10 AM To: [email protected] Subject: Slocums' Comments on MINIMUM FLOOR AREA RATIO 3/28/2017 Dear Planning Commissioners and Council Members: Today we are writing you as owners of the Commercial Property located at 3221 Main Street in Mammoth Lakes. It has come to our attention that the Planning Commission and the Town Council have been in discussions relating to a zoning code update, and more recently there have been enhanced discussions pertaining to the implementation of a MINIMUM FLOOR AREA RATIO. We are greatly disturbed as we learn more about the meaning of this MINIMUM FLOOR AREA RATIO and its impacts on the marketability and even the value of our property. As the owners of Slocums Grill & Bar in Mammoth Lakes, we are asking that you VOTE AGAINST ANY MINIMUM FLOOR AREA RATIO other than ZERO. For the majority of owners of commercial properties on Main Street and Old Mammoth Road, our properties represent how we make our livings, and for most, our vehicle to hard-earned and well deserved retirements. We purchased our property in September of 1982, have survived all the radical ebbs and flows of the Mammoth business economy, and, are still going strong after thirty-five years. Thus, our business and property have high value and high marketability. Therefore, we are vehemently opposed to any yes votes by your Commission or Council to diminish our property rights, property value and property marketability, and, implore you all to VOTE AGAINST ANY MINIMUM FLOOR AREA RATIO OTHER THAN ZERO. Thank you, Cindy & Tom Avena Joe & Teree Minney Slocums Grill & bar, Mammoth Lakes, Ca.
cc: M.L. Sullivan CTSC LLP
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Robert L. Hart, AIA, AICP David P. Howerton, FASLA, AICP Craig Roberts A. James Tinson, AIA
March 30, 2017 Mr. Dan Holler Town Manager Town of Mammoth Lakes P.O. Box 1609 Mammoth Lakes, CA 93546
One Union Street San Francisco, California 94111 Tel: 415 439 2200 Fax: 415 439 2201 www.harthowerton.com
Re. Mammoth’s Downtown – Proposed Minimum Floor Area Ratio Dear Dan: Following up on our previous letter of January 3, 2017, we would like to reiterate our support of a minimum Floor Area Ratio (FAR) of 0.75 for the primary blocks within the Downtown district. The root of this FAR requirement – a vibrant, walkable downtown that furthers Mammoth’s position as a destination resort community – is consistent with the vision for downtown we’ve heard expressed by the community, Council and staff stretching back more than ten years. While we appreciate the concerns raised by members of the business community, we advocate that the Town establish a benchmark FAR standard that reinforces its commitment to being a “feet first” community. Variances and other tools can always be utilized to account for hardship or site-specific constraints, but those instances should be an exception, not the rule. Furthermore, we would expect that the Town would be concurrently taking action to incentivize the kind of high-intensity uses we all want to see Downtown. These incentives might include: -
No Minimum Parking Requirement – Consider eliminating minimum parking standards within the Downtown district, reinforcing an emphasis on “feet first”, bikes and transit.
-
Parking District – Even without minimum parking standards, tenants will depend on convenient, available parking. The establishment of a Parking District and dedication of shared parking resources is critical to attracting higher FAR development, beginning with the Town’s parking lot at Tavern and Old Mammoth. Future parking and transit facilities on the Shady Rest or Town Office / Courthouse sites will go a long ways towards addressing the access needs of the entire district.
-
Upper Floor Uses – Explore ways to partner with landowners and developers to add residential or office uses to upper floors. This would be a great opportunity to create housing and office space for Mammoth’s permanent residents, close to transit and services.
We look forward to hearing more about the community’s progress towards their vision for a vibrant Downtown Mammoth. Sincerely,
Eron Ashley Managing Principal cc. Mayor Shields Richardson, TOML Rusty Gregory, Tom Hodges, MMSA HART HOWERTON, LTD. NEW YORK • SAN FRANCISCO SHANGHAI • LONDON • SÃO PAULO • HONOLULU • BOSTON • MINNEAPOLIS
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December 3, 2016 Town of Mammoth Lakes Planning Commission Mammoth Lakes, CA 93546 Re: Minimum Floor Area Ratio Dear Planning Commissioners: Today, I’m writing in regards to the matter of a minimum Floor Area Ratio(FAR) being discussed in the public and at the Planning Commission level. Through conversations with several Planning Commissioners and commercial property owners I’ve had the opportunity to hear arguments both in favor and opposed to the idea of a minimum FAR. While I can envision some benefits of a minimum FAR in the future, I would argue the matter has come about on short notice and without full vetting of the potential impacts. Some of the benefits of a minimum FAR entail Mammoth Lakes realizing maximum development of mixed use properties within its commercial districts; this is being brought about through the discouragement of smaller single (or limited use) projects. As a commercial real estate broker and certified general real estate appraiser in Mammoth Lakes I have the benefit of working with most of our commercial property owners. What I have seen in recent decades is the very incomplete demand for high density projects and the lack of coordination by owners/developers to bring such developers to town. This lack of demand also stems from the lack of economic feasibility for higher density mixed use products. I fear trying to implement a minimum FAR today without a long‐term analysis of how to address impacts would have adverse effects on the marketability of many commercially zoned properties. Mammoth Lakes currently has several approved master planned, and specific planned, areas in town. Even with these properties being advanced with respect to development timelines, it is difficult to attract the higher density mixed use developers. Additionally, trying to force uses that may not fit current demands can prohibit a developer/owner from bringing a much‐needed use. For example, while a grocery store may be a high demand use in town, requiring additional office space, retail, or low AMI housing may not be what is needed to fulfill minimum FAR.
Further, the single use tenant may not be in the business of development and would only be discouraged to develop in Mammoth Lakes if they were required to build uses outside their business model. In conjunction with a minimum FAR discussion needs to be discussion about the surplus of office and retail space. In short, there may be benefits of creating minimum FAR in the future, but it should be done with significant thought and with a clear path of how the development standards will meet market demands. This should also be done with consideration of how to cure current blight and vacancies within our town. Respectfully, Matthew T. Lehman [email protected]
Robert L. Hart, AIA, AICP David P. Howerton, FASLA, AICP Craig Roberts A. James Tinson, AIA
January 3, 2016
One Union Street San Francisco, California 94111 Tel: 415 439 2200 Fax: 415 439 2201 www.harthowerton.com
Mr. Dan Holler Town Manager Town of Mammoth Lakes P.O. Box 1609 Mammoth Lakes, CA 93546
Re. Mammoth’s Downtown – Proposed Minimum Floor Area Ratio Dear Dan: We understand that the Town is considering adopting a minimum FAR in the Downtown area. We’re writing now to share our opinion that the Town should require that development within the Downtown district be at a minimum FAR of 0.75. This is reflective of the 2-3 story density articulated in the work we presented to the Town this summer as well as what is envisioned in the Town’s General Plan and Neighborhood District Plans. The application currently before the Town Council for a market/grocer at 37 Old Mammoth Road demonstrates that while the Town’s existing development standards may protect the “urban-ness” of the street, single-story surface-parked retail sacrifices significant potential for the vibrancy that comes with upper floor uses. We’ve enjoyed following the Town’s progress this fall to establish community consensus around a Vision for Downtown, and remain optimistic about the potential for Downtown Mammoth. At the same time, we appreciate that for Downtown to become the kind of place you envision, the Town needs to set a higher bar for the intensity of development Downtown, and then establish implementable strategies to provide those public facilities, services and urban amenities that will attract the right kinds of developers to Mammoth and be the back-bone of a vibrant urban district. Sincerely,
David P. Howerton, FASLA Chairman
Eron Ashley Managing Principal
cc. Mayor Shields Richardson, TOML Rusty Gregory, Tom Hodges, MMSA
HART HOWERTON, LTD. NEW YORK • SAN FRANCISCO SHANGHAI • LONDON • SÃO PAULO • HONOLULU • BOSTON • MINNEAPOLIS
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Carlton P. Biggs 30391 Via Chico Place Laguna Niguel, CA 92677 [email protected] 949-400-5888
March 27, 2017 Town of Mammoth Lakes [email protected]
Re: Proposed change in Commercial Building Standards Dear Planning Commission and Town Council, Let me begin by stating I am a former resident of the town and have been a property owner for 30+ years, both residential and for the last 25, a commercial property owner. I own the Mammoth Professional Center at 325 Old Mammoth Road. Recently I have been trying to update my property, and at the same time I have had the property for sale. The market for commercial property in Southern California is at an all time high, the market for commercial property in Mammoth is dead. Rents are low, and demand is also low. The changes you propose are not going to help the real estate market in Mammoth. My real estate broker has just informed me about the FAR standards that are being considered by the town. The maximum FAR standard does not concern me, however the minimum FAR of .75 seems unrealistic and impractical. Using my property as an example, I have approximately 16,500 square feet of ground and a building of about 6,000 square feet. It has been estimated that the new construction cost of my building would be something in excess of $1,800,000 not counting land, development costs and any fees charged by the Town or other entities. I have been marketing the building at $999,000.00 with no success so far. My building would be at a FAR of .36. To impose a FAR of .75 would make my building less valuable because now instead of a 6,000 square foot building, a replacement building would have to be a minimum of 12,375 square feet, raising construction costs by more than double, and not likely increasing the value of the property to support $3,600,000 plus in construction costs. I think the town should consider not imposing a Minimum FAR or limit its application to either vacant parcels, or larger parcels or both. Not small parcels such as mine. A second issue I see is snow removal. This season has brought home the impact of Mother Nature. Our snow removal expenses are 4 times normal, mostly because we have had to remove the excess snow with dump trucks. As you increase the density on a property, you decrease the space to park and store snow. Mandating increased density would add to this issue and add to the expenses to own a building. The market place will not support these additional expenses.
Finally, my opinion, as someone who has enjoyed the “Town” feeling of Mammoth for 50 years. I feel that mandating such a severe increase in density seems a move in the wrong direction. People come to Mammoth to enjoy the mountains, the trees and the open space. For the Town to require this density in every case seems wrong on several levels. It certainly will not improve the village atmosphere that people expect when they come to Mammoth. In summary, I request the Planning Commission and the Town Council rethink the application of this Minimum FAR standard or limit its application to either vacant parcels, or larger parcels or both. Not small parcels such as mine. I am not going to be able to attend the meetings on this issue, I request you share my comments with both the Planning Commission and the Town Council.
Sincerely, Carlton P. Biggs
Sandra Moberly From: Sent: To: Subject:
Stan Riffel <[email protected]> Monday, March 27, 2017 2:14 PM Sandra Moberly Minimum FAR
Sandra…received and reviewed an email from Matthew Lehman regarding a zoning code amendment involving a minimum floor area ratio requirement for new commercial. While I would be in favor of a Maximum FAR, I would be opposed to a Minimum FAR. As an example, the property I own at 3613 Main St which is situated on a 9600 sf lot…the 1100 +/- sf building works just fine for me. I would not know what to do with a 7200 sf building (9600 x .75) nor be able support/lease that sort of space (especially with the past and current demand). While this may not impact me currently (as I assume I would be grandfathered in), it may when I decide to sell. I would suggest the Town let owners build what they feel can be economically supported with upper limits only. There is and has been (historically) large amounts of commercial space available…last thing we need in town is more vacant commercial space. Not to mention the increased cost of development to build something not wanted or needed. Just an FYI…there is very little demand, if any, for commercial space in town….to buy or lease. And it’s been like that for the 33+ years I’ve been selling real estate in Mammoth…don’t see it changing anytime soon. Hope this makes sense. Thanks Stan Riffel - Broker/Owner Riffel Real Estate 3613 Main Street P.O. Box 8558 Mammoth Lakes, CA 93546
www.riffelrealestate.com 760-934-3747 (office) 800-622-3747 (toll free) 760-914-1430 (cell) 760-934-7424 (fax) DRE#'s 01478383 / 00864334
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Ruth Traxler From: Sent: To: Subject:
Cindy Avena <[email protected]> Tuesday, March 28, 2017 1:03 PM Ruth Traxler Fw: Slocums' Comments on MINIMUM FLOOR AREA RATIO
Hi Ruth, Thanks for your help. Cindy Avena
From: Cindy Avena <[email protected]> Sent: Tuesday, March 28, 2017 11:10 AM To: [email protected] Subject: Slocums' Comments on MINIMUM FLOOR AREA RATIO 3/28/2017 Dear Planning Commissioners and Council Members: Today we are writing you as owners of the Commercial Property located at 3221 Main Street in Mammoth Lakes. It has come to our attention that the Planning Commission and the Town Council have been in discussions relating to a zoning code update, and more recently there have been enhanced discussions pertaining to the implementation of a MINIMUM FLOOR AREA RATIO. We are greatly disturbed as we learn more about the meaning of this MINIMUM FLOOR AREA RATIO and its impacts on the marketability and even the value of our property. As the owners of Slocums Grill & Bar in Mammoth Lakes, we are asking that you VOTE AGAINST ANY MINIMUM FLOOR AREA RATIO other than ZERO. For the majority of owners of commercial properties on Main Street and Old Mammoth Road, our properties represent how we make our livings, and for most, our vehicle to hard-earned and well deserved retirements. We purchased our property in September of 1982, have survived all the radical ebbs and flows of the Mammoth business economy, and, are still going strong after thirty-five years. Thus, our business and property have high value and high marketability. Therefore, we are vehemently opposed to any yes votes by your Commission or Council to diminish our property rights, property value and property marketability, and, implore you all to VOTE AGAINST ANY MINIMUM FLOOR AREA RATIO OTHER THAN ZERO. Thank you, Cindy & Tom Avena Joe & Teree Minney Slocums Grill & bar, Mammoth Lakes, Ca.
cc: M.L. Sullivan CTSC LLP
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Robert L. Hart, AIA, AICP David P. Howerton, FASLA, AICP Craig Roberts A. James Tinson, AIA
March 30, 2017 Mr. Dan Holler Town Manager Town of Mammoth Lakes P.O. Box 1609 Mammoth Lakes, CA 93546
One Union Street San Francisco, California 94111 Tel: 415 439 2200 Fax: 415 439 2201 www.harthowerton.com
Re. Mammoth’s Downtown – Proposed Minimum Floor Area Ratio Dear Dan: Following up on our previous letter of January 3, 2017, we would like to reiterate our support of a minimum Floor Area Ratio (FAR) of 0.75 for the primary blocks within the Downtown district. The root of this FAR requirement – a vibrant, walkable downtown that furthers Mammoth’s position as a destination resort community – is consistent with the vision for downtown we’ve heard expressed by the community, Council and staff stretching back more than ten years. While we appreciate the concerns raised by members of the business community, we advocate that the Town establish a benchmark FAR standard that reinforces its commitment to being a “feet first” community. Variances and other tools can always be utilized to account for hardship or site-specific constraints, but those instances should be an exception, not the rule. Furthermore, we would expect that the Town would be concurrently taking action to incentivize the kind of high-intensity uses we all want to see Downtown. These incentives might include: -
No Minimum Parking Requirement – Consider eliminating minimum parking standards within the Downtown district, reinforcing an emphasis on “feet first”, bikes and transit.
-
Parking District – Even without minimum parking standards, tenants will depend on convenient, available parking. The establishment of a Parking District and dedication of shared parking resources is critical to attracting higher FAR development, beginning with the Town’s parking lot at Tavern and Old Mammoth. Future parking and transit facilities on the Shady Rest or Town Office / Courthouse sites will go a long ways towards addressing the access needs of the entire district.
-
Upper Floor Uses – Explore ways to partner with landowners and developers to add residential or office uses to upper floors. This would be a great opportunity to create housing and office space for Mammoth’s permanent residents, close to transit and services.
We look forward to hearing more about the community’s progress towards their vision for a vibrant Downtown Mammoth. Sincerely,
Eron Ashley Managing Principal cc. Mayor Shields Richardson, TOML Rusty Gregory, Tom Hodges, MMSA HART HOWERTON, LTD. NEW YORK • SAN FRANCISCO SHANGHAI • LONDON • SÃO PAULO • HONOLULU • BOSTON • MINNEAPOLIS
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