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CC Resolution No. 00-095RESOLUTION NO. 00-095 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CUPERTINO DENYING THE PETITION OF STEVEN D. HOFFMAN SEEKING COUNCIL RECONSIDERATION OF ITS DETERMINATION DENYING HIS APPEAL AND UPHOLDING THE DECISION OF THE CITY MANAGER REGARDING THE USE OF A CITY PARK PARKING LOT FOR PICK- LIP AND DELIVERY OF CHILDREN UTILIZING THE CUPERTINO UNION SCHOOL DISTRICT DAY CARE CENTER Whereas, the City of Cupertino owns and operates a public park known as Varian Park, including an adjacent parking lot which serves the park; and Whereas, the Cupertino Union School District owns and operates a school facility known as Stevens Creek Elementary School which is adjacent to Varian Park; and Whereas, on said school site the Cupertino Union School District through its non-profit provider, the YMCA, operates a student day care center pursuant to the authority of section 8469 et al. of the California Education Code which both authorizes and requires the appropriation of space in newly modernized elementary schools for school care programs; and Whereas, both Varian Park and the school property are served by a public street known as Varian Way which extends from Ainsworth Drive and which dead ends into the Varian Park parking lot; and Whereas, many parents of children who attend the school's day care center utilize, during limited hours the Varian Park parking lot for the purpose of dropping off and picking up their children to and fi.om the day care center; also a small number of employees of the day care center utilize the Varian Park parking lot for limited time parking; and Whereas, Steven D. Hoffman is one owner of a single-family residence located at 22230 Varian Way directly across the street fi.om the school property. To the east of Mr. Hoffman's property is Varian Park; and Whereas, on April 22, 1999, Mr. Hoffman requested in a letter addressed to the City's public works director that the City take "enforcement action to stop illegal traffic and use of the park parking lot"; and Whereas, Public Works Director Viskovich both orally, and in writing through the City Attorney's office, informed Mr. Hoffman that he intended to take no further action with respect to his request; and Whereas, pursuant to section 1.16.020 of the City's ordinance code, Mr. Hoffman appealed Mr. Viskovich's determination to the Cupertino City Manager, Donald Brown; and Whereas, on October 11, 1999, the City Manager denied Mr. Ho ffman's appeal in writing; and Whereas, on October 19, 1999, Mr. Hoffinan appealed the City Manager's decision to the City Council; and Whereas, on November 15, 1999, the City Council heard Mr. Hoffman's appeal and continued the appeal heating to January 3, 2000 in order to consider the written evidence presented by Mr. Hoffman, city staff, representatives of both the Cupertino Union School District and the YMCA as well as other members of the public; and Whereas, the City Council after further hearing on January 3, 2000 denied Mr. Hoffman's appeal; and Whereas, Mr. Hoffman has requested that the council reconsider his petition under the provisions of section 2.08.096 of the City's ordinance code; and Whereas, the City Council hearing date set for February 2, 2000 to consider Mr. Hoffman's request was continued to March 20, 2000 by mutual agreement; and Whereas, the City Council has considered all the relevant evidence presented by the parties at all heatings, including evidence presented at the March 20* reconsideration hearing; NOW, THEREFORE, IT IS HEREBY RESOLVED AS FOLLOWS: 1) Mr. Hoffman's Petition for Reconsideration of the City Council's determination of January 3, 2000 is DENIED. 2) In making its determination, the City Council adopts the following specific findings: a) Based upon parking and traffic studies conducted by the City, the current use of the Vadan Park parking lot by some parents as a pick-up and delivery point for children walking to and from the day care center as well as the minimal use of the parking lot for a small number of day care employees do not unreasonably adversely affect the availability of adequate parking for park activities. b) The current use by some parents in using the Varian Park parking lot as a pick-up and delivery point for children walking to and from the day care center does not constitute an illegal use of park property by the Cupertino Union School District or the YMCA inasmuch as this activity is beyond the reasonable or practical control of those agencies. Therefore, neither agency is required to apply to the City for any type of permit for this type or level of parking at Vax/an Park. This finding does not preclude the City requiring the School District to apply for permits to use the City's parking lot should the intensity of use by day care employees and contractors be increased in the future. c) The use of the park parking lot for the above-described purposes does not violate Chapter 19.68.030E of the City's ordinance code inasmuch, parking lot facilities need only be sufficient "as necessary for park usage." Mr. Hoffman has failed to demonstrate that park usage has been adversely impacted in anyway by the above-described ancillary uses. d) While it is true that at certain times of the day, there is substantial traffic and congestion on Varian Way, any prohibition of the use of the Varian Way parking lot for pick-up and delivery of children to and from the day care center would create more congestion on Varian Way directly in front of Mr. Hoffman's home and the homes of his neighbors thereby creating more serious traffic impacts in the area. 3) With respect to Mr. Hoffman's ten page petition for rehearing, the City Council adopts the specific responses to the petition attached to this Resolution. PASSED AND ADOPTED by the City Council of the City of Cupertino this 20th day of March, 2000 by the following vote: Vote Members of the City Council AYES: NOES: ABSENT: ABSTAIN: Bumett, Chang, James, Lowenthal, Statton None None None ATTEST: APPROVED: City Clerk ~/ Mayor, City of Cupertino RESPONSE TO PETITION FOR REHEARING Allegations Response Paragraph 1.~(I) Since the appeal to the Council involved a de-novo City Manager's letter hearing, the City Manager's determination is moot except miseharacterizes the insofar as it provides evidence to support the City nature extent of use of Council's decision. The Council based upon its own the park view of the evidence submitted properly determined the nature and extent of use of the park. Paragraph 1.a.(2) The City Council has relied on the testimony of its Public The traffic studies do not Works Director Bert Viskovich in this regard, including support the conclusion, his most recent staff report. Mr. Hoffman has not introduced any relevant parking studies which contradict those conducted by Mr. Viskovich. Mr. Hoffman did present a study oftraffc volumes along Vax/an Way. However, the issue is the availability of parking for park usage and not general traffic along a public street. Paragraph 1.a.(3) See the testimony and report of Bert Viskovich to the The facts do not supportcontrary. the conclusion that the day care center does not adversely affect the availability of the parking lot for park activities. Paragraph 1.a~(4) See findings b and c of this Resolution. Municipal Code Section 19.68.030E together with other provisions do not allow such parking by the District without an application nor does it stand for the proposition that parking facilities need only be sufficient to serve the park. Paragraph 1.b.(2) a) Besides pick-up and Other than a few parking stalls used by some day care delivery of children, staff, there has been presented no evidence of other usage. some of the parking lot is The City Council fmds that a small number of staff using used for other day care the parking lot is de minimis. (See fmding b in the center purposes. Resolution) b) The parking lot is See above response used for day care purposes other than pick- up and delivery of ;tudents. c) The City has not This is a hue statement. The City has no plans to attempt attempted to stop parents to stop parents from dropping off and picking up children from temporarily parkingto and from the day care center by parking in the park in the park parking lot parking lot. No alternatives, public hearings, or nor have there been applications by the District are required. presented any alternatives, no public hearings have been held, or any application filed by the District. d) The existing Joint Use The City Council disagrees with this statement; however, and Maintenance more importantly, the statement is irrelevant since the Agreement between the City Council did not use this evidence as a basis for its City and the District decision. recognizes the day care center, it does not specifically recognize the use of the park parking 'lot. Therefore, prohibiting parent parking does not violate the "spirit" oftha agreement. Paragraph 2.a. City staff have reviewed alternatives with respect to both The City has refused to parking and the traffic congestion on Varian Way and consider alternatives have concluded that, at the present time, no change in the which would mitigate thepresent parking situation is warranted. The City Council effects complained of byagrees with staff determination. Petitioner. 3 Paragraph 3.a None is required. There is no application (see finding b of the City Council Resolution) by the School District to use the park parking lot m connection with the day care use. Paragraph 3.c Incorporation of responses Incorporation of facts and reasons Paragraph 4 Petitioner has had abundant time. The first hearing by the Petitioner was not City Manager was scheduled on August 17, 1999, but was provided sufficient timerescheduled to September 2, 1999, at Petitioner's request. to fully explain or submit At the said hearing, Petitioner submitted a bound volume facts concerning the containing approximately fifty pages of material. At the appeal, appeal hearing, by the City Council on November 15, 1999, Petitioner submitted the same volume plus other documents. The hearing was continued to January 3, 2000 to allow Petitioner to submit other documents. As part of his rehearing petition, Petitioner had the opportunity to submit additional evidence, but did not do so. Petitioner was given substantial time to explain or mbmit facts to the City Council. In addition, Petitioner has failed to inform the City Council of what specific evidence he now wishes to introduce which he could not have introduced at earlier proceedings. Paragraph 4.b Petitioner fails to state specifically what rule or regulation The City failed to abidewas not followed by the City concerning the Petitioner's by and allow Petitioner to appeal. comply with its own procedure. Paragraph 4.c No such application is required. The City aceapted evidence on continuation of day care use of the parking lot without application for permission to use it by the YMCA or the District. 5 Paragraph 4.i The City Council disagrees with the assertion that the The City ignored the fact District attempted to "circumvent the law." that the District attempted to circumvent the law and failed to apply to the City for permission and therefore the District has "unclean Paragraph 4.j The City Council disagrees. See this Resolution. The Council failed to fred whether there was a violation law and failed to set forth findings of fact or eonclusious of law. Paragraph 4.k Petitioner fails to specify what evidence was not made The City failed to available to him. Petitioner fails to establish that at any provide Petitioner with previous hearing, he requested any additional information all of the evidence or requested additional time to respond to any such submitted or considered evidence. and failed to allow Petitioner to address such facts and evidence. Paragraph 4.1 This assertion is not germane to Petitioner's appeal. Facts were presented Violations of park rules are prosecuted by the City in the showing improper use of normal course of its code enforcement program. the park well after dark and as late as midnight and beyond Monday and Friday, in violation of park's roles. Paragraph 4.m No rebuttal was requested by either Petitioner or his No time was allowed for attorney. rebuttal to the remarks of Charles Corr. Paragraph 8 Irrelevant to this proceeding. The City ignored the evidence that the District previously promised to give the neighbors notice and opportunity to be heard prior to installing, a second day care building, but failed to do so. Paragraph 9 Petitioner fails to specify the basis for this assertion. The City's ruling violates the equal protection clause of the state and federal constitution, Paragraph 10 Petitioner has cited no legal authority for this novel The City's ruling violates theory. due process because it constitutes a "taking" of Petitioner's property. Paragraph 11 To determine the validity of the City appeal, the City The City ignored the Council is not required to make a f'mding one way or the issue of whether there other regarding these assertions. would have been any available alternatives had the District applied for a permit .... Paragraph 12 See prior responses. The City Municipal Code has been dearly violated. Paragraph 13 See prior responses. Each ground for denial is not supported. Paragraph 14 In the context of this appeal, the Petitioner has the burden Petitioner does not haveof proving his assertions. the burden of proof to establish the City's obligation. 9