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21 3) to prevent the surreptitious creation of dwellings outside of the principal structure. 22 Limiting the height and area of accessory structures remains an effective way to preclude non-residential 23 buildings in residential districts and to ensure the principal dwelling remains the dominant use on a 24 residential property. But retaining measures to prohibit dwellings beyond the principal dwelling unit is 25 clearly in conflict with the intention to allow homeowners to build detached, accessory dwelling units. 26 The applicant’s request to amend the zoning regulations pertaining to ADUs is two-fold; in addition to 27 the desire to allow greater accessory building height so that they can be built above detached garages, 28 the applicant has also requested an amendment to allow greater ADU floor area. Planning Division staff 29 acknowledges there may well be good reasons to raise the ADU floor area limit, but whereas the zoning 30 code already intends to allow ADUs over detached garages, staff believes that increasing the allowed 31 floor area represents a substantial shift in residential zoning policy. For this reason, staff has determined 32 that it is appropriate to consider the request to amend the ADU height limit at this time and to evaluate 33 the issue of greater floor area during the broader zoning code update anticipated to begin later this year, 34 should that direction come from the City Council. 35 Suggested Changes 36 Rather than maintaining one set of height standards for accessory storage buildings and establishing 37 another for accessory dwelling units, Planning Division staff finds value in amending the height 38 standards to apply to all accessory structures. The proposed amendmentis included with this RCA as 39 Attachment B; in general, the changes that staff are proposing in response to the applicant requestare to: 40 1) Clarify a couple of things about the existing regulations for detached garages and other storage 41 buildings. None of these changes are intended to alter how accessory structures are regulated. 42 Rather the intent is to be more precise which regulations apply specifically to storage buildings. 43 2) Add ADUs into the section pertaining to accessory buildings on single-family lots. 44 3) Retain the 9-foot ground floor height for accessory buildings and increase the overall height to 45 30 feet, or the height of the principal structure, whichever is less. Raising the overall height limit 46 to the lower of 30 feet or the height of the principal structure will provide the opportunity to 47 locate an ADU above a detached garage, especially where the principal dwelling is more than 48 one story, while ensuring that the scale of accessory structures remains in accordance with the 49 principal structure. In spite of the greater overall height limit, retaining the 9-foot floor-to- 50 ceiling height for the ground floor of an accessory structure will still preclude non-residential 51 buildings because the floor-to-ceiling measurement constrains the height of overhead doors and, 52 consequently, the size of vehicles and other items that can be stored inside. 53 4) Remove language prohibiting detached ADUs being located between the principal building and 54 front yard setback line. Since the zoning code would allow both a detached garage and an 55 attached ADU to be built between a principal dwelling and the front yard setback line, Planning 56 Division staff finds it is reasonable to allow a ADU (whether above a detached garage or in a 57 standalone building) to be in that same location. 58 Public Comment 59 The Planning Commission held the duly noticed public hearing for the proposed amendments to Title 60 10, Zoning, on March 4, 2020; draft minutes of this meeting are included withthis RCAas Attachment 61 B. Planning Commissioners engaged in extensive discussion about whether this was also the appropriate 62 time to give further consideration to raising ADU floor area limits, as requested by the applicant, but at 63 the conclusion of the public hearing the Planning Commission recommended approval of the proposed 64 amendments, not including changes to the floor area limit, by a vote of 6 – 1. The dissenting vote 65 stemmed from one’s opposition to the Commission’s decision not to consider increases to the floor area 7b rca Page 2 of 3