HomeMy WebLinkAboutCC 2026-03-24_10a_Supplemental 5
MEMORANDUM
TO: City Council
FROM: Jessica Matson, Director of Legislative & Information Services/
City Clerk
SUBJECT: Supplemental Information
Agenda Item 10.a - March 24, 2026 City Council Meeting
Appeal Case 26-002; Appeal of Planning Commission Approval
of Conditional Use Permit 25-001; Location – 1271 & 1281 James
Way; Appellants – Pismo Medical Properties LLC, Arroyo
Grande Partners LLC and Ray B Bunnell Revocable Trust
DATE: March 24, 2026
Attached is additional correspondence received prior to 2 p.m. for the above
referenced item.
Cc: City Manager
Assistant City Manager/Director of Public Works
Planning Manager
City Attorney
City Clerk
City Website and Public Review Binder
Enc
From:Linda Busek
To:City Council; Matt Downing; Jessica Matson; Bill Robeson
Subject:Request to Revisit Proposed 92 unit RRM Development Plans (Oak Park & James Way)
Date:Tuesday, March 24, 2026 12:34:16 PM
Dear Arroyo Grande City Councilmembers,
I’m writing to urge you—and the Planning Commission—to revisit the approved plans for the
proposed 92-unit RRM development behind the medical buildings, Curl Fitness, and Best
Western near Oak Park and James Way.
This area is already experiencing significant parking strain. As a regular patron of both the
medical offices and fitness center, I can attest that parking is often insufficient today—
overflowing into informal areas due to earlier planning limitations. Adding a 92-unit
residential project without clearly adequate parking will only intensify this problem, creating
daily conflicts between residents and existing businesses.
I’m also concerned about the impact on the adjacent green open space. This area provides both
visual relief and practical breathing room for an already dense cluster of uses. The current
plans appear to push development up against the hillside in a way that risks diminishing this
valuable space.
Traffic is another serious concern. Access to James Way is already constrained, and increased
density at this location could lead to congestion and safety issues given the limited ingress and
egress.
I want to be clear: I support the need for additional housing in Arroyo Grande. However, this
particular site—at the proposed scale—does not appear to be a good fit.
I encourage the City to consider alternative infill opportunities along Grande Avenue and on
Halcyon Avenue (such as the area behind the Fair Oaks Theatre), where underutilized parcels,
better proximity to services, and stronger transit access could support housing more
successfully and with fewer unintended consequences.
At a minimum, I respectfully ask that you pause further action until the project is substantially
revised—specifically to reduce density and ensure adequate, realistic parking for both
residents and surrounding businesses.
Thank you for your time and for your service to our community.
Sincerely,
Linda Busek
240 Aspen Street, AG
From: "Carlson, Mack" <mcarlson@bhfs.com>
Date: March 24, 2026 at 12:25:05 PM PDT
To: Isaac Rosen <Isaac.Rosen@bbklaw.com>
Cc: "Guillen, Christopher R." <cguillen@bhfs.com>
Subject: FW: Correspondence re 3/24/2026 Meeting Agenda Item 10a -
Appeal Case 26-002
Isaac,
As a follow up to this email and our prior conversations, we believe that a
continuance tonight will count toward one of the City’s five allowed hearings
on the project for the reason explained below. Since Chris’ email was sent,
we also note that legal counsel for two of the appellants have submitted
substantive comment letters and appear ready to present their appeal
tonight. We see do not believe that one appellant’s request for a
continuance is sufficient to push out the hearing after the Project applicant
and other appellants have expended substantial sums of money to present
their cases.
Government Code section 65905.5(a), in relevant part states: “after the
application is deemed complete, a city . . . shall not conduct more than
five hearings pursuant to Section 65905, or any other law, ordinance, or
regulation requiring a public hearing in connection with the approval of
that housing development project. If the city, county, or city and county
continues a hearing subject to this section to another date, the
continued hearing shall count as one of the five hearings allowed under
this section. The city, county, or city and county shall consider and either
approve or disapprove the application at any of the five hearings allowed
under this section consistent with the applicable timelines under the Permit
Streamlining Act (Chapter 4.5 (commencing with Section
65920)).”(Emphasis added.) Under Government Code section 65905, a
public hearing shall be held on various types of applications, including a CUP
application at issue here, and any appeals of those applications. Section
65905.5(b)(2) defines “hearing” broadly to include “any public hearing,
workshop, or similar meeting, including any appeal, conducted by the city
or county with respect to the housing development project, including any
meeting relating to Section 65915, whether by the legislative body of the city
or county, the planning agency established pursuant to Section 65100, or
any other agency, department, board, commission, or any other designated
hearing officer or body of the city or county, or any committee or
subcommittee thereof.”
As noted in the staff report, the Project application is complete and
consistent with applicable, objective general plan and zoning standards as
determined by the Planning Commission and staff consistent with state law.
(See Gov. Code, § 65905.5((c)(1)-(2).) By agendizing this appeal hearing, the
City Council must act on the item to continue it to “another date.” (See Gov.
Code, § 54955.1.) This Council action necessarily “shall count as one of the
five hearings” since otherwise local agencies would be able to endless
continue items without a public hearing in direct conflict with the purposes
of this section to limit a project to no more than five public hearings.
This interpretation aligns with various state laws designed to protect housing
development project applicants from delays. The Housing Accountability Act
clarifies that violations of Government Code section 65905.5 constitute a
disapproval of a housing development project (See Gov. Code, § 65589.5(h)
(6)(F).) The Housing Accountability Act and SB 330, which enacted Section
65905.5, are to be construed liberally to expedite and promote the
development of housing. (See Gov. Code, § 65589.5(a)(2)(L); Chap 654, Stat.
2019 § 2 [SB 330’s legislative intent].) The Courts further interpret the effect
of the Permit Streamlining Act, and laws like Section 65905.5, in the context
of the Housing Accountability Act to reduce local governments capacity to
deny or render infeasible affordable housing development projects. (See
Save Lafayette v. City of Lafayette (2022) 85 Cal.App.5th 842, 855.)
In summary, the City must treat tonight’s hearing as one of the five allowable
hearings under Government Code section 65905.5. Based on the staff
materials, we understand that the City has already conducted at least three
qualifying hearings on this project, thus any tonight’s meet will constitute the
fourth hearing on this project regardless of whether the City continues it or
holds the appeal hearing as requested by three of the four interest parties
(i.e., two appellants and the Project applicant).
We appreciate you advising the Council of this interpretation at the meeting
tonight so they can understand the effect of a potential continuance on
processing this application.
Best,
Mack Carlson
Brownstein Hyatt Farber Schreck, LLP
1020 State Street
Santa Barbara, CA 93101
805.882.1485 tel
mcarlson@bhfs.com
WE HAVE MOVED: Our new address is: 1020 State Street, Santa Barbara, CA
93101
From: Guillen, Christopher R. <cguillen@bhfs.com>
Sent: Monday, March 23, 2026 6:19 PM
To: publiccomment@arroyogrande.org
Cc: Carlson, Mack <mcarlson@bhfs.com>; Russ Sheppel <rsheppel@gmail.com>; Isaac
Rosen <isaac.rosen@bbklaw.com>; Scott Martin <samartin@rrmdesign.com>; Linda
Blackbern <lblackbern@rrmdesign.com>; Malone, Caitlin K. <CMalone@BHFS.com>
Subject: RE: Correspondence re 3/24/2026 Meeting Agenda Item 10a - Appeal Case 26-
002
Dear Mayor Russom and members of the City Council,
We understand the Appellants for this item on the City Council meeting
agenda tomorrow have requested a 30-day continuance of the hearing
because they allegedly only received the staff report for the hearing on Friday
afternoon “with only one business day of notice before the hearing.” In
addition to the fact that this statement is inaccurate—the agenda and staff
materials were publicly available on Thursday afternoon, a full five full days
before the hearing consistent with AGMC 1.12.030 —we have reviewed the
letter requesting the continuance and see no legal basis to grant the
continuance.
The basis for the request amounts to a complaint about the normal land use
appeal process that affords the Appellants and Project applicant all the due
process required by law. As with any land use appeal, Appellants submitted
their written grounds for appeal after the Planning Commission’s approval of
the Project, City staff responded to the appeal in their staff report, which was
posted and made publicly available beyond the time required by the Brown
Act (i.e., 72 hours), and now Appellants and the Project applicant will be
allowed to present to this Council tomorrow evening. In fact, the Project
team has already provided their response to the Appellants as well, giving
Appellants ample notice of the issues. Appellants’ frustration about only
finding the staff report on Friday is not grounds for an appeal; rather, it is a
request to be treated differently than all other appellants that have come
before this Council. Indeed, it is telling that the law firm that submitted the
request on behalf of Appellants cites no law requiring such a continuance.
Granting a continuance on this matter would establish a dangerous
precedent by allowing any appellant to delay any project based on solely on
the Appellants’ inaction and inattention.
The request also claims that Appellants’ ignorance of the Housing
Accountability Act is justification for the continuance. That is an absurd
request and if granted would set additional dangerous precedent for the City.
This precedent is acutely problematic for housing development projects
where the Legislature has created various statutory deadlines and penalties
to agencies that delay action on housing projects. (See, e.g., Gov. Code, §§
65956 [a project is “deemed approved” without a hearing if an agency
misses a deadline]; 65589.5(h)(6)(B), (E), (K) [failing to meet certain
deadlines means the agency has “disapproved a housing development
project”].) For example, if granted, any time a project opponent appeals a
project in the future, the opponent can claim ignorance of the law as a
grounds for a continuance request to achieve the desired delay of the
project. That cannot be the policy the City intends to create.
Finally, Appellants ask for “immediate access to the basic administrative
record” for the Project. However, Appellants have not submitted a formal
Public Records Act request for such documents and there is no obligation for
staff to produce that record absent such a request. Moreover, none of these
records are relevant for the appeal before the Council since—as noted by the
Appellants in their letter—the Planning Commission already heard
Appellants’ arguments at the January 20, 2026 meeting and rejected them by
unanimously approving the Project as consistent with the applicable City
standards. Staff providing additional legal bases to support the Planning
Commission’s determination and refute Appellants’ contentions is hardly
grounds to delay the hearing.
For each of these reasons, this Council should deny the continuance request
and hold the hearing on Appellants’ appeal tomorrow. In considering the
continuance request, we request the opportunity to provide public comment
on this matter as well.
Thank you for your consideration of this matter,
Chris
Christopher R. Guillen
Brownstein Hyatt Farber Schreck, LLP
1020 State Street
Santa Barbara, CA 93101
805.882.1452 tel
909.518.8435 cell
cguillen@bhfs.com
WE HAVE MOVED: Our new address is: 1020 State Street, Santa Barbara, CA
93101
From: Malone, Caitlin K. <CMalone@BHFS.com>
Sent: Monday, March 23, 2026 11:46 AM
To: publiccomment@arroyogrande.org
Cc: Guillen, Christopher R. <cguillen@bhfs.com>; Carlson, Mack
<mcarlson@bhfs.com>; Russ Sheppel <rsheppel@gmail.com>; Isaac Rosen
<isaac.rosen@bbklaw.com>
Subject: Correspondence re 3/24/2026 Meeting Agenda Item 10a - Appeal Case 26-002
Good morning,
Please see attached letter from Chris Guillen’s office on behalf of Russell
Sheppel. This pertains to Item 10a on the agenda for tomorrow’s City Council
meeting, Appeal Case 26-002; Appeal of Planning Commission Approval of
Conditional Use Permit 25-001; Location – 1271 & 1281 James Way; Appellants
– Pismo Medical Properties LLC, Arroyo Grande Partners LLC and Ray B
Bunnell Revocable Trust.
Caitlin K. Malone
Legal Practice Assistant
Brownstein Hyatt Farber Schreck, LLP
1020 State Street
Santa Barbara, CA 93101
805.882.1462 tel
CMalone@BHFS.com
WE HAVE MOVED: Our new address is: 1020 State Street, Santa Barbara, CA
93101
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