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  Agenda Item   7.    
Planning Commission
Meeting Date: 06/22/2021  
FROM: Jason Killebrew

The Applicant, James Thayer Architect, representing Living Hope Community Church, is requesting an amendment to Conditional Use Permit (CUP) No. 10-04 for the following:
  • To enclose a 6,711 square-foot covered parking area to be used as an assembly area for church/religious services; and
  • Modify the surface parking lot and remove 23 off-street parking spaces, resulting in a total of 152 spaces at the site.
Staff recommends that the Planning Commission take the following actions:
  1. Find the project exempt from the California Environmental Quality Act (CEQA) pursuant to CEQA guidelines Section 15301 (Class 1, Existing Facilities); and,
  2. Approve Amendment to CUP No. 10-04 to allow the enclosure of a 6,711 square-foot covered parking area to be used as an assembly area, and modifications to the existing parking lot, based on the findings and conclusions in the attached resolution (Attachment A), and subject to the recommended conditions of approval (Attachment B)

Existing Use and Location
The project site is located northwest of the intersection of West Lambert Road and North Puente Street, and has a General Plan Land Use designation and zoning of Light Industrial (M-1).  The 2.47-acre site is developed with a two-story, 21,333 square-foot building, a surface parking lot with 161 parking spaces, and a 6,711 square-foot covered parking area.  Adjacent properties on the north, east, and west are zoned M-1, and to the south across Lambert Road is a C-P (Commercial Administrative and Professional) zoned property.

The site is owned and occupied by the Living Hope Community Church.  Activities at the site include worship services on Sundays and related administrative office and prayer meetings throughout the week.

Entitlement History
On April 27, 2010, the Planning Commission approved CUP No. 10-04 to allow an existing 21,333 square-foot building to be converted to a church/religious institution.  This approval also included the use of a 6,711 square-foot solid canopy as a covered parking area.  Resolution No. 10-10 is provided as Attachment F of this report.

On April 26, 2021, the Applicant filed a request to amend the CUP to enclose the covered parking area, herein referred to as the “project”.

The proposed project seeks to enclose an existing attached 6,711 square-foot covered parking area, to be used for children and youth worship services.  Additional services and worship times are not proposed with this application.  The enclosing of this area would be a predominantly open floor plan, with some storage, increasing the total building size to 30,855 square-feet.  Figure 3 below highlights the existing covered parking area, and Figure 4 shows the proposed site plan with modifications to the parking lot. 


Development Standards
Development in the M-1 zone is governed by Section 20.252.040 of the Brea City Code (BCC).  The proposed enclosure of the covered parking area would not increase the height of the building or building lot coverage at the site.  As demonstrated in Table 1 below, the proposed project would comply with all applicable development standards of the M-1 zone. 

Table 1: M-1 Zone Building Development Standards
  Existing Allowed/Required Proposed
Building Height 28’-0” 60’ maximum 28’-0”
Height of Covered Parking Structure 20’-0” 60’ maximum 20’-0”
Lot Coverage approx. 30% 50% maximum approx. 30%

Section 20.252.040(L) of the BCC restricts buildings or structures from having more than 25-percent of their exterior walls made of sheet metal when located closer than one hundred fifty (150) feet from the property line along any major or secondary highway.  The exterior east and north walls of the proposed enclosed parking area would be approximately 60-feet from North Puente Street, therefore, the Applicant is proposing a combination of exterior wall materials comprising of fiberglass, glazed panels, and no more than 25-percent corrugated metal.  Condition H of the draft conditions of approval, provided as Attachment B to this report, further requires that no more than 25-percent of the exterior walls of the enclosed area shall be comprised of metal materials.    Table 2 and the proposed exterior elevations below summarizes how the proposed project would comply with this section of the BCC. 

Table 2: Exterior Metal Walls/Façade
  Existing Allowed/Required Proposed
Metal Façade East 25% maximum 22%
  North 25% maximum 17%

Section 20.08.040 of the BCC requires churches and religious institutions to provide one parking space for every three fixed seats, or one space for every 35 square-feet where there are no fixed seats.  CUP No. 10-04 approved the church to have 296 seats in its sanctuary, requiring 99 off-street parking spaces based on the one space for every three fixed seats calculation. The proposed 6,711 square-foot enclosed assembly area would not have fixed seating, and would require 192 off-street parking spaces based on the one space for every 35 square-feet calculation.  Combined, the existing sanctuary and proposed assembly area require a total of 291 parking spaces. 

After the proposed enclosing of the covered parking area, the project would provide 152 off-street parking spaces on-site in a surface parking lot.  In addition to the 152 parking spaces on-site, the Applicant has secured two shared parking agreements with adjacent sites that provide a combined total of 150 off-site parking spaces (included as Attachment E).  Both off-site locations are occupied by businesses that do not conduct operations after 5:00 PM during the weekdays and are closed on weekends.  Since the church services are predominantly after 5:00 P.M. on weekdays and on weekends, the church would have sole access to those off-site parking spaces with no conflict with the other businesses.  In addition, Condition G of the attached conditions of approval would require that the two parking agreements remain active or replaced to meet the minimum off-street parking requirement.  The CUP for the operation of the church would be subject to review by the Planning Commission if the off-street parking would not be met.

Figure 5 below shows an aerial image with the location of the two off-site parking highlighted in yellow.

With the 152 spaces on-site and the 150 spaces secured in agreements, there are 302 off-street parking spaces available for the site, 11 more spaces than the 291 spaces required by the BCC.  Table 3 below summarizes how the proposed project would comply with the BCC off-street parking requirements.

Table 3: Off-Street Parking
  Required Provided
Sanctuary with 298 Fixed Seats 99 spaces 152 spaces on-site
150 spaces off-site
Proposed 6,711 SF Assembly Area 192 spaces
Total 291 spaces 302 spaces
291 spaces required
302 spaces provided
11 spaces surplus

The Applicant’s operation plan indicates one worship service would be conducted at a single time, with no concurrent or overlapping services.The Applicant has provided an operation plan and schedule and is included as Attachment D to this report.Current Sunday worship service times are 9:30 AM to 10:35 AM and 11:30 AM to 12:30 PM.  Further, during the pre-COVID peak Sunday service time of 9:30 AM, there were a maximum of 284 adults on-site. Of the 284 adults, some of them carpooled and arrived together such as members of the same family.Therefore, the 302 available parking spaces meet the BCC requirement and are operationally adequate to accommodate the church’s peak parking demand.

Section 20.252.020 of the BCC allows churches and religious institutions in the M-1 zone subject to a CUP.  As originally approved, Condition A of CUP No. 10-04 requires that church operations and use of the site occur in conformance with the previously approved plans.  The enclosing of the 6,711 square-foot covered parking area would modify the approved plans, and therefore requires an amendment to the CUP. 

The Applicant proposes to continue using the site, including the proposed new enclosed assembly area, as a church.  All associated activities would be conducted indoors and would comprise of office hours and prayer meetings held Tuesday through Saturday, and worship service on Sundays.  Therefore, the continued use of the building as a church would be appropriate for the site and not adversely affect the public health, safety, or general welfare.

Plan Review
All proposed development in the M-1 zone requires a Plan Review subject to the review and consideration of the Community Development Director (Director), in accordance to BCC Section 20.252.050. Since this project includes an amendment to an existing CUP, subject to Planning Commission review, the Director is deferring full reviewing authority to the Planning Commission.  Figure 6 below shows an image of the proposed east building elevation.

As proposed, the covered parking area would be enclosed with fiberglass reinforced panels that would be painted to match the exterior walls of the building, metal frame roll-up doors with glazed panels, corrugated metal siding, and open/window areas to provide ventilation.  Additionally, the proposed project would have exterior walls comprised of less than 25-percent metal material, as required by the BCC.  Therefore, as proposed, the exterior improvements would comply with the City’s requirements for properties in the M-1 zone, complement the existing building and development in the surrounding area, and would not result in any impacts to neighboring properties.


This project was noticed in accordance with the City’s public noticing requirements, which involved mailed notices and publication in the local paper. The public hearing notice for this project is provided as Attachment G. As of the writing of this report, staff has not received any public correspondence.


Based on the information provided in the application and through the analysis presented in this report, staff recommends that the project should be approved. The project, as designed and conditioned in Attachment B, is suitable for the site and would not present any adverse impacts to the City as further outlined in the draft resolution (Attachment A). Therefore, staff recommends approval of the project.
This project has been assessed in accordance with the CEQA guidelines, and the environmental regulations of the City. Upon review, the proposed project qualifies for a Class 1 Categorical Exemption (Existing Facilities) in accordance with the requirements of Section 15301 of the state CEQA guidelines. This exemption is applicable to the operation, repair, maintenance, permitting, leasing, licensing, or minor alteration of existing public or private structures, facilities, involving negligible or no expansion of existing or former use.  The project qualifies for this exemption as the enclosing of the existing 6,711 square-foot canopy would be considered a negligible expansion of an existing or former use.  A Notice of Exemption has been prepared and is included as Attachment H to this report.
Jason Killebrew, City Planner
Prepared by: Juan Arauz, AICP, Senior Planner
A. Draft Resolution
B. Draft Conditions of Approval
C. Project Plans
D. Church Operations and Schedule
E. Off-Site Parking Agreements
F. Planning Commission Resolution 10-10
G. Public Hearing Notice
H. Notice of Exemption
I. Technical Background

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