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HomeMy WebLinkAboutSchulman - HechtSolbergI m Em. Hecht Solberg June 13, 2016 Chair Yolanda Calvo and Members of the Planning Commission City of Chula Vista 276 Fourth Avenue, Building B Chula. Vista, California 91910 Re: Vista Del Mar RICHARD A, SCHULMAN E-Mail: rschujman0h (x lit so lber __corn Honorable Chair Calvo and Members of the Planning Commissiom This firm represents 3rd and Kst, LLC ("31("), the applicant for the above- referenced project. I am writing to request your support for the project. The PEQicct The site is located at 795-799 3rd Avenue, 285-295 K Street, and 794-798 Church Avenue, and contains 1.05 acres (45,738 square feet). It is zoned "C-l" in the City's Urban Core Specific Plan ("UCSP"), The project will consist of 71 residential units (31 ]-bedroom, 40 2- bedroom) and I commercial space. The density is consistent with zoning. The building will mostly be 57' tall, with an elevator tower reaching 60'. The project will feature a variety of amenities such as a public plaza, and it will satisfy LEED "Gold" requirements for environmental sensitivity. In response to neighbor concerns, 3K has already reduced the project by 8 units, reduced the size of the structure, added 8 guest parking spaces, and included additional landscaping. As the oral presentation will show, the project features a very attractive design. Development Services staff supports approval of the project and agrees that it will be a beneficial addition to the community, The Issues Notwithstanding its environmental sensitivity and attractive appearance, the proposal has drawn criticism from a frequent critic of the City, None of the criticisms, presented in a letter dated April 15, 2016 from legal counsel Evelyn Heidelberg, are valid. Hecht Solberg Robinson Goldberg& Bagley LLP Attorneys atLaw One America Plaza 600 West Broadway Suite 800 Son Diego, CA 92101 T: 619.239.3 .4.4 F 619.232,6828 hechtsolberg.coo Chair Yolanda Calvo and Planning Commission Members City of Chula Vista June 13, 2016 Page 2 Floor area ratio (FAR), The principal concern of the letter, expressed in various ways, is that the project's FAR exceeds what the UCSP allows. Ordinarily, the UCSP limits FAR at this site to 1.0, and this project's FAR is just 1.99. However, the UCSP allows increases to FAR for several reasons. The project merits increases of 0.1 for providing parking inside the building; 0.1 for providing public outdoor space; and 03 for satisfying LEED "Gold" requirements. This brings the project to an allowable FAR of 1.5. With or without those increases, though, the UCSP allows this FAR. The UCSP is unusual in several respects; for one thing, it was designed to function not as typical number- and use - driven zoning, but rather as a form -based code. This means that its primary focus is the_form of new development, with less stringent requirements for statistical conformity. One aspect of the UCSP that implements this approach is that the UCSP expressly allows "exceptions" on a case -by-case basis for projects that meet the goals of the UCSP but might run afoul of a number such as FAR: The land use and development regulations encourage the siting of a variety of land uses in an urban environment that is both pedestrian and environmentally sensitive. Where used in combination with the Urban Amenities Incentives, as provided for in this chapter, the development regulations and urban amenities incentives will encourage innovative design. To further achieve this goal, it may be necessary to be flexible in the application of certain development standards. As such, the Planning Commission may authorize exceptions to the land use and development regulations included within this chapter through the issuance of an [sic] Design Review Permit, if all of the following findings are made: I. The proposed development will not adversely affect the goals and objectives of the Specific Plan and General Plan. 2. The proposed development will comply with all other regulations of the Specific Plan. 3. The proposed development will incorporate one or more of the Urban Amenities Incentives in section F - Urban Amenities Requirements and Incentives, of this chapter. 4. The exception or exceptions are appropriate for this location and will result in a better design or greater public benefit than could be achieved through strict conformance with the Specific Plan development regulations. (UCSP, page VI -51) I have attached some legislative intent materials (i.e., background from when the City approved the UCSP) showing that the City intended to provide this flexibility on a case -by -case basis. In fact, the exception language was expressly added to a previous draft. Thus, for example, the staff report said: Chair Yolanda Calvo and Planning Commission Members City of Chula Vista June 13, 2016 Page 3 4. Issue: Permit some flexibility in the application of the UCSP development standards to encourage innovative design and to effectively administer projects with any unforeseen development and /or design challenges. Analysis: Staff agrees that it may be necessary and appropriate for the Chula 'Vista Redevelopment Corporation or Planning Commission to authorize certain exceptions to the land use and development regulations, provided that the exception is based on certain findings, including that a better design or greater public benefit would be achieved. Review and consideration of a development standard exception is not permitted by right but would be considered on a project by project basis concurrent with the review of the Urban Core Development Permit, as outlined in Chapter XI.C.1 of the Specific Plan. Similar language appears in the "Second Errata" to the EIR. Thus, the question is not whether the proposed FAR is less than some number in the UCSP. Rather, the question is whether the proposal satisfies these findings. It does, a point with which City staff concurs. The project will provide new and attractive housing in an area called for by the City's plans; it will comply with other regulations; it will contain urban amenities such as a public plaza; and it will allow for a better product. The last point merits some expansion. The developer, 3K, could have provided smaller units; its analysis indicated that more, smaller units would have provided a higher total return. However, 3K's principal, Dr. Hamid Mani, has worked in the City for many years, has invested in other projects in the City, and wanted to provide a nicer product. This project --- in particular, the FAR of this project — will provide larger units that will benefit the community. The FAR is not only legal; it is appropriate for this project at this site. Balconies. The second concern of Ms. Heidelberg's letter, also expressed in various ways, is that the balconies may not face nearby single - family homes. As with PAR, Ms. Heidelberg's concern is misplaced. The provision in question in the UCSP says: Building design shall be cognizant of adjacent low density uses (i.e. avoid balconies overlooking rear yards). (UCSP, page 'VI -38) However, the wording of this provision is much more likely the result of a lack of familiarity with Latin than a strictly intended requirement, because the UCSP variously encourages or requires balconies and the entire document must be harmonized to work as a unit. ( "Id est," abbreviated "i.e,," meaning "that is," as opposed to "exempli gratia," abbreviated "e g ," meaning "for example. ") For instance: Chair Yolanda Calvo and Planning Commission Members City of Chula Vista June 13, 2016 Page 4 And: New infill structures should use traditional facade components, such as bulkheads, arches, plazas, and balconies, to create patterns and alignments that visually link buildings within a block, while allowing individual identity of each building. (UCSP, page VII -34) 2) Building facades should be detailed in such a way as to make them appear smaller in scale. The smaller scale can be achieved through vertical and horizontal articulation such as: • breaks (reveals, recesses) in the surface of the wall itself, • placement of window and door openings; or • the placement of bay windows, balconies, awnings, and canopies. 3) Bay windows and balconies that provide usable and accessible outdoor space for residential uses are strongly encouraged and may encroach on the public right-of-way, consistent with City policy. (UCSP, page VII -42) Bay windows and balconies that provide usable and accessible outdoor space for residential uses are strongly encouraged and may project beyond building setback lines. (UCSP, page VII -87) (See also Figures VII -41 and V11- 106) This provision must also be read in harmony with the City's general plan. The plan does not flatly ban balconies or other adjacency issues; rather, it calls for designs to be "sensitive" to nearby uses and not "negatively affect" them. (Policies LUT 3.3, 43) Higher density residential and mixed -use projects should use "appropriate transition" to "minimize" conflicts with nearby uses. (Policy LUT 5.13) In fact, many of the LUT 6 and 7 series of Policies use similar or identical language: "compatible," "minimize project impacts," and "reduce the potential impacts." The UCSP balcony policy was not intended to dictate a uniform design requirement; rather, it was intended to ensure that design was carefully reviewed to minimize issues, This project has carefully minimized any issue relating to balconies. The obvious risk for a balcony near a single - family residence is privacy, but this project has carefully minimized any such risk. The balconies will be set back from the two yards of nearby homes and will be screened by vegetation. The project could obtain an exception for this, but it need not; it complies with the policy. California Environmental Quality Act (CEQA} _exemption. Ms. Heidelberg's third concern, variously expressed, is that the project does not qualify for an exemption from CEQA. City staff and 3K agree, so what is before you is an "addendum" to the environmental impact report ( "EIR ") that the City certified for the UCSP. Addenda are appropriate whenever the City Chair Yolanda Calvo and Pianiiing Commission Members City of Chula Vista June 13, 2016 Page: 5 concludes, with reasonable support, that there is nothing new requiring a new FIR. E. , Citizens L-&- Against Airport Pollution (2014) 227 Cal.App.4th 788, 796-799. In this case, the project is consistent with the UCSP; claims that there is something "new" are simply unsupported. What layvyers,-Iike to call the "slipper y slope," Ms. Heidelberg's final concern, variously expressed, is that the project will absorb some of the allowable growth in the Urban Core, leading to massive overpopulation. As the staff report notes, however, this is the first unit increase in the Urban Core since the City approved the UCSP in 2007, nine years ago. The UCSP anticipates an increase of 7,100 units, of which roughly 730 should have already been added. The additional units that this project will produce are both insignificant and consistent with the UCSP. For that matter, the entire project will use roughly 1% of the allowable growth in the UCSP. This project presents no threat to the UCSP's growth forecast. This is a beautiful project that will enhance the community it is in. On behalf of 31 , I respectfully request that the Commission approve it. Very truly yours, Richard A. Schulman HECHT SOLBERG ROBINSON GOLDBERG& BAGLEV LLP RAS:cas Enclosures: (1) CVRC Board Staff Report, pages 1, 11, 23 and 24, and attachment 7 [marked 2 -1, 2-11, 2-23, 2-24, and 2-175] (2) Second Errata to Final UCSP EIR, pages 1, 2 and 3 [marked 2-35, 2-36, and 2-37] (3) Draft [approved] UCSP Facilities Implementation Analysis, cover page and pages 14 and 16 [marked 2-260, 2-276, and 2-278] (4) General Plan pages LUT-93, LUT-94, LUT-97--LUT- 100 (5) UCSP pages VI-51 and VII-34, 41, 42, 86, and 87 cc (w/encls.)- Client Miguel Tapia, Development Services Department Steve Power, Development Services Department Michael Shirey, Deputy City Attorney 41134 -55171 -7169 1 1 1 SUBJECT: c rX, Consider r g option of the Urban Core t related action a -i Page Ili of 32 item No. 2 Mooting Date: ,:" The UCSP i1jejudes the following I FIW Page 23 of 32 Item Na 2 Meeting Date: 04126!07 Issue, Lower the minimum building height In UC-3 from 30e;2 10 feet. 2 N -3 from 30 feet to 18 fem. ecommendation: 1-ower the minimurn building height in LJC 3. issue. Include provision for processing projects that are currently In the permit processing "pipeline." Recommendation. The effective date.section of the ordinance adopting the U�CSP wit' include a reference to tile existing pipeline provision for specific plans © CVlVl* 19,07,030(2). Pag<»«o 32 Item No. 2 Meeting DoW 04/26107 permra tile review of the Urban Core Development Permit, as outlined 'in Chapter Xl-GA of tile Specific Plam sion%-as shown in Attachment 7 1 A ii I III! A, III F, ON-GOING ISSUE RELATED TO THE CHULA VISTA MUNICIPAL CODE (CV1I SECTION 1.80( ? INGSINITIATIVE) The following topic has been raised and discussed at various stages during preparation of the UCSP and its associated public input process, Most recently the topic has; been deliberated by the City Council and at public meetings conducted! in April 2007. The following summarizes the heart of the debate. issue: is the, 2? ?f conslatent with Chula Vista Municipal Code (CVMC) Section 19,g (Cummings Initiative)? ATTACHMENT 7 2 ¥n .Development Exceptions" < 2 ChaptrV,§2 »dG2 >1Q<»&«?m«2 � ,OtherRegulations: ' » ? <v *m<cJ2 «STdyrK <c2� ¥w� ? # » ? #2 » *x review � /w > \, /T - < \ \ 10, ©\2 + »«t :'f«» »\»<t « ?»k? »eZw » : «© » the Specific Plan. ?2\ +\???±±«J <+ d > ENVIRONMENTAL d2±2rf22 +2< April 17, d 007 as proscriptive in mandating the use of ground floor space, More flexibility arlJ loss regulation on the internal use of buildings, In particular the ground floor, also more in keeping with the tenets of the UCSPs form based zoning approac which foruses more on creating appropriate urban form and lose on the functi and Interior use of buildings. Proposal 2. Lower the minimum bung height in UC-3 from 30 feet to 18 feet. Analysis: This proposal would change the minirnum building height shown on the Zoning Sheet for UC-3 from 30 feet to 18 feetw oposal 3. Include a "development excelpfion" provision and process to permit some flexibility In the application of the UCSP developmt, `; , #4' with any unforeseen development and/or design chaflengos. project basis ?w «u° ©y y2 ° © © <»2 24Urban Core De 2«,»<© ,m \r outlined Chapter «1«1 the d<«» : : Plan, a 2 ? e ? »« > <: fr ++212 6 ?k§ d»§§<x?+« to the r :a. .. <»*< reference regard »f 60dy <y2rojG <a^ . .< mrl= � IME022M BERKELEY V SACRAME"TO DE MV IR 2501 NIMEb $t,. suake loo ftgnat 510.841-919D Phoca: 41E,649-6010 Pleurae: 303.623-3557 scrkeley, CA 94110- 2S' &.5 FsK: 510443-9206 Pfim 016. 649-2070 Fee: io3-623.9049 w,ww,cpgyz,com III. DEVELOPmr,,Nr PROJECTIONS 14 P:\ Isom% 15001chwavistacoamwa Table 6 Developlimnt Aboarpidan ProjeWons by Time Pedod Udmil Coro 80golft plan Feelliflem Impkmentation Analysis; IPS M001 Abs merjlp!!&� 11mv Ld W6— f J_ Land Use category Nom -10 goers 10. Syp"Orm �p ywom Ravine Urift 730 73D 2,179 21,461 7,100 Ratall square FW (1) MAO 25,000 0 tt 259,000 Office Seluara Fed 224,400 224,,400' 1373,200 178,000 1,300,000 Ne"11160"I 84um Feet 130,QDD 130,000 8%0,000 0 650,DDO 1� i H—, 1, —wpt ; V —W —bW —WI a V QQV 176-5 p;W-W-P I PaWd"IR' 70, ikW�-nl 1-1160- —an I I il 1-11 7 On d k —nn9 3, Only retall fiquare footage anoludmd in currently propowd projects Is M81.1 as to be built In Urban, Core, SoureGs: City of MUlm Ma; EGOnDmVa RaneWd A550918s; E001100110 & PlOnning SPtOfnz, Inc- 6waffim a mwwm S)CIOffic &W, vv&7" e ,,7 LAND USE AND TRANSPORTATION ELEMENT CHAPTER 5 Lu'r 2.5 Require proposals for development within TFAs to conduct studies to assess tile effiects oil light and solar access, and shadowing and wind patterns on adjacent areas and butidings, LUT 2,6 Conduct a special study to examine the potential for higher land use int( risitles and taller buildings along tile H StreetTransR Focus Corridor between Interstate 5 and Fourth Avenue, and to address compatibility issues with adjacent stable neighborhoods, The precise boundaries wall be established at the time of the study, and all land use policies within In this General Plan shalt apply until mociffied or amended, as a result of study findings, I Objective - LUT 3 Direct the urban design and form of new development and redevelopment in a manner that blends with and enhances Chula Vista's character and qualities, both physical and social, IBM LUT 3. 1 Adopt urban design guidelines and/or other development regulations for all Districts or Focused Areas of Change as presented In Sections I-UT 8.0 -1].,0 of the LUT Element as necessary, to ensure that new development or redevelopment recognizes and enhances the character and identity of adjacent areas, consistent with this General Plan's Vision LUT 3.2 Any such urban design guideflnes and/or other development regulations shall be consistent with other, related policies and provisions in this General Plan, including Sections 73 through 7.6. LUT 33 Buildings within the TFAs should not adversely affect public views or view corridors, and should be desugned to be sensitive to adjacent buildings and areas. 77iii Pa,ge LUT-93 Planning for existing neighborhood preservation, identity and protection is one Qf the most Important purposes of tiae City's General Plan. Existing rQsldentifal neighborhoods In the City consist of either lT Qstly single - family dwellings, mostly multi- family dwoilings, or areas In transition. Residential nesghborhoods that are not considered in traansition are considered stable, and should be protected. (Please refer to I_UT Section 4.7 for diSCt.r5Slon of this terminology,) To maintain the qualify of existing, stable residential neighborhoods requires (hat tile City conselve existing housing, ensure good street design, minimize and control traffic in residential neighborhoods, and ensure that development adheres to quality design standards. Please refer to Section 73 for additional policies orr, the protection of stable neighborhoods, Establish policies, standards, and procedures to mlnjmize blighting influences and maMtain the integrity of stable residential neighborhoods. Policies LUT 4.1 Preserve and reinforce tine community character of existing, older, well - maintained, stable residential neighborhoods 4ocated Outside Of the D'Stricts or Focus Areas Identified for change in this document. LT 4.2 Protect existing, stable, single - family neighborhoods through zoning or other regulations that discourage the introduction of higher density residential or other Incompatibie or potentially disruptive land uses and/or activities, L T 4.3 Require that new development or redevelopmenk through consideration of site and building design, and appropriate transition and edge treatments does not negatively affect the nature and character of nearby established neighborhoods or development Page LUT-94 Clty of Chula Vista General Plan I-AND USE AND TRANSPORTA11ON ELEMENT CHAPTER 5, LUT 5.8 Fricouia ge a wide variety of retaH and commercial, services,', such as restaurants ,and cultural arts/entertainment In appropriate locations,. LUT &9 Encourage active and Inviting pedestrian-ftlendly street environments that Include a variety of uses within commercial and mixed use areas, LUT 5A0 Support the continued development of a visitor economy in the Northwest Planning Area and additional visitor commercial uses and amenities In the Bayfront PlanOng Area. LUT 5.11 Endeavor to reduce the number of peak how automobile trips by supporting increased services near workplaces. LUT 5A2 i'viijimilze local and regional tragic by concentrating higher densi-ty employment near majortransItservices, LUT 5A3 Higher density residential and rnixed use residentlal/commerdal development should be designed to: 0 Create a pleasant walking environment to encourage pedestrian activity; 0 Maximize transit usage; 0 Provide opportunities for residents to conduct routine errands close to their residence; 0 Integrate with surrounding uses to become a part of the neighborhood rather than an isolated projec�, Use architectural elements or themes from the surrounding neighborhood: and Provide appropriate transition between land use designations to minimize neighbor compatIblii1y, conflicts, Page LUT-97 N USE TRANSPORTATION ELEMENT Vista. '112. Chula NTjSion CHAPTER 5 2020 7.5 Compatible Land Use and Edge Transitions Incompatible land uses immediately adjacent to one another, such as residential and industrial uses, may significantly affect the health of a community. Uses should be appropriately buffered, or incompatibilities should be addressed through redesignation of uses or mitigation of impacts to adjacent uses in the area. (`Mixed use areas will inherently have higher levels of activity and intensity than solely residential neighborhoods, Both the pattern of mixed use areas and individual project designs must be sensitive to edge transitions between neighborhoods and strive to minimize potential impacts on adjacent residential neighborhoods. .0 LUT Ensure adjacent 4and uses are compatible with one another, LUT.1 Ensure, through adherence to design guidelines and zoning standards, that the design review process guarantees excellence in design and that new constriction and alteratlons to existing buildings are cornpatible with the best character elements of the area. LUT 6,2 Require that proposed development plans and projects consider and minimize project impacts upon sun-ound;ng neighborhoods. LUT 6.3 Require that the design of new residential, commercial, or public developments is sensitive to the character of existing neighborhhods through consideration of access, compatible building design and massing, and building height transitions, while maintainin the goa #s and values set forth in the Gene�-ai Plan. Within TFAs, design provisions should include requirements for a minimum building stepback of iS feet foi every 35 feet in height, for edges abutting residential uses, LUT e Discourage additional multi - family development in existing single - family designated neighborhoods. LUT 6.5 Require, through sensitive and attractive design, that neighborhood retail centers and commercial service buildings are cornpatibie with the surrounding neighborhood. Page LUT-98 city of owia vista General Plan 1-14ND USE AND TRANSPORTATION, ELEMENT CHAPTER 5, LUT 6e6 Establish design guidelines and clevelopmient standards for commercial and :nixed use deve.iopmerrt that respect and complement the character of surrounding neighborhoods and uses. LUT 607 Require that outdoor storage areas or salvage yards be screened from any public right- oflvvay, LUT e Require that any land use that handles, generates and /or transports hazardous substances, will not negatively impact existing or Future sensitive receptors /land uses, as defined by state and federal regulations. LUT &9 Coordinate Mth adjacent 4andowners, the Port of San Diego, cities, and San Diego County in establishing compatible land uses for areas adjacent to the City's boundaries. LUT s 10 Coordinate and work closely Wth the City of San Diego, national City, and San Diego County in the Otay Valley Regional Park and Sweemater /Bonita areas to participate in the development review processes of projects proposed in these areas, Work to ensure that such development takes app {)cable City, of Chula Vista standards into consideration, as appropriate. LUTI Appropriate transitions should be provided between land uses. LUT 7,1 Proteci adjacent, stable residential neighborhoods by establishing guidelines that reduce the potential impacts of higher Intensity mixed use, commercial, and urban residentiai developments (Le, transitions( areas). LUT 7,2 Require new or expanded uses to provide mitigation or bufters between existing uses where significant adverse Impacts could occur. �4i!/ Page LUT-99 Chula V. ista Vision 2020 LAND USE AND CHAPTER .5 LUT 7.3 Require that commercial and industrial development adjacent to residential or educational uses be adequately screened and buffered to minimize noise, light, ,glare, and any other adverse impacts upon these uses. LUT 7A Require iandscape and /or open space buffers to maintain a naturalized or softer edge for proposed pilWte development dlrectly adjacent to natural and public open space areas. LUT 705 projects within TFA shall provide appropriate and sufFfcienL features to soften the transaction to adjacent buildings and pfopeities, through the fbllo %b ing techniques. Project landscape plans should include sifade tree and screening plantings to reduce heat gain upon, and visually soften building edges, ® ExIerior lighting designs shall focus internally in order to reduce light pollution on neighboring properties. ® Fencing and/or buffers shall be required to screen features such as dumpsters, rear entrances, utility and maintenance structures, and loading Facilities, ® Walls or fencing along project edges shall be articulated and incorporate features to avoid presenting a monotonus or blank Mall to the street or adjacent propert}f. LUT T6 in order to ensure appropriate separation from existing development to new, faller b�tildings Forms within TFAs enswe a minimum 15 -Foot rear yard setback For structures up to 84 feet in height Page LUT 7.00 city of china v�qa General Plan Consideration of a development standard exception shall be concurrent with the review of the Design Review permit, as outlined in Chapter X1 - Plan Administration, Section C.I. Design Review Requirements, of this Specifi* Plan. F OMM�� i . Retain or Repeat ; d Components Develop , r; Rhythm w, Widths 1) M,iultiple-uiise structures, with retail on lihower floors and residential or non-retail commercial on upper floors, are required along Third Avenue and encouraged elsewhere within the Village District. 4) Exceptions to building height may be provided pursuant to 19 16.040. 5) Whenever a Proposed infill building i,-14 adjacent to a designated historic structure, ❑CCC consideration should be given to proposed building height, mass and form to rnWrnize effects on the historic structure, New structures should reflect the established scale and rhythm sug,gested by the regulations contained herein and the traditional lot pattern. 1) The characteristic proportion (relationship of height to width) of existing facades should be reflected in new infill development. 3) Bay windows and balconies that provide usable and accessible ou:tdooir space for residentW uses are strongly encouraged and may encroach on the public right-of- way, Consistent with City policy. 5) The predominant difference between upper story openings and street level storefront openings (windows and doors) should '=77 a. fir oduction 2) Where buildings with towers have frontages on multiple streets, the towers are encouraged to orient towards the primary street such as Broadway and H Street. wppu 1/1 INVI 3) Horizontal building stepbacks are encouraged to, provide building articulation, terrace space and other elements to soften building facades. if a mid -rise or high Stepback rise building is located on a corner site, increased stepbacks from the street wall along both streets. Please are encouraged Balconies also refer to Chapter A ® Land Use and Development Regulations for regulations regarding required minimum building stepbacks for specific subdistricts within the F'mm Specific Plan. 4) Building heights should enhance public views, and provide adjacent sites with maximum sun and ventilation and protection frM m prevailing; winds. 2) Bay windows and, balconies that provide usable and accessible outdoor space for residential uses are strongly encouraged and may proj�ect beyond building setback lines. 3) Awnings and overhangs should be used in conjunction with street trees to provide shade for pedestrians. 5) Residential buildings should have entrances from the street to facilitate pedestrian activity and increase security through more "eyes on the street." Bung materials will incorporate two aspects: color and texture. If the building's exterior 6&-, "-1 1 IIWIO-� WW Mani "ins and outs" V6Vff,SmW-# Vyw- m- I'mm-nxry I f;-,W""WVV V IRMW design features, the wa w be Lq