Friends of Riverside's Hills v. City or Riverside

CourtCalifornia Court of Appeal
DecidedSeptember 7, 2018
DocketE068350
StatusPublished

This text of Friends of Riverside's Hills v. City or Riverside (Friends of Riverside's Hills v. City or Riverside) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Friends of Riverside's Hills v. City or Riverside, (Cal. Ct. App. 2018).

Opinion

Filed 8/10/18; pub. order 9/7/18 (see end of opn.)

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION TWO

FRIENDS OF RIVERSIDE’S HILLS,

Plaintiff and Appellant, E068350

v. (Super.Ct.No. RIC1600523)

CITY OF RIVERSIDE, OPINION

Defendant and Respondent;

CARLTON R. LOFGREN as Trustee, etc. et al.,

Real Parties in Interest and Respondents.

APPEAL from the Superior Court of Riverside County. Sharon J. Waters, Judge.

Affirmed.

The Law Offices of Abigail Smith and Abigail A. Smith for Plaintiff and

Appellant.

1 Office of the City Attorney, Gary G. Geuss, Kristi J. Smith, and Anthony L.

Beaumon for Defendant and Respondent.

Claremont Land Group, Geralyn L. Skapik, and Mark C. Allen III for Real Parties

in Interest and Respondents.

Real parties in interest Carlton and Raye Lofgren, as Trustees of the Lofgren

Family Trust and the Lofgren 1998 Trust (the Lofgrens), sought a residential

development permit to build six single-family homes on a parcel of just over 11 acres in

Riverside. After respondent City of Riverside (the City) approved the permit and issued

a negative declaration stating the development did not require environmental review

under the California Environmental Quality Act (CEQA, Pub. Resources Code, § 21000

et seq.), Friends of Riverside’s Hills (FRH) filed a petition for a writ of mandate

challenging that decision. FRH’s petition alleges the City was required to conduct a

CEQA Environmental Impact Review (EIR) of the development because it violates

certain land use provisions in the City’s municipal code. FRH’s petition also alleges the

City abused its discretion by approving a project that violates its own land use provisions.

The trial court denied FRH’s petition, and FRH now argues that ruling was error.

Because we find no evidence of the alleged land use violations, we will affirm the

judgment.

2 I

FACTUAL BACKGROUND

A. The Relevant Land Use Provisions

The project site is a parcel of undeveloped land off the north side of Arlington

Avenue, between Royale Place and Hawarden Drive, near Victoria Avenue. The parcel

falls within the City’s “Residential Conservation Zone” (RC Zone), an area established

by voter initiatives to protect “prominent ridges, hilltops and hillsides, slopes, arroyos,

ravines and canyons, and other areas with high visibility or topographic conditions that

warrant sensitive development from adverse development practices.” (Riverside Mun.

Code (RMC), § 19.100.010.B.) The City’s municipal code contains unique standards for

residential developments located in the RC Zone. In addition, different standards apply

within the RC Zone depending on whether the development is a standard or

“conventional” development versus a “Planned Residential Development” (PRD). In this

case, the Lofgrens have proposed to build a PRD, not a conventional development.

Relevant here are the conventional and PRD standards for lot size (the required minimum

acreage for each lot within a subdivision), “dwelling density” (the number of lots/homes

permitted within a subdivision, measured per gross acre), and lot coverage (the

percentage of the lot each home is allowed to occupy). (RMC, § 19.100.040.A.)

3 For conventional subdivisions in the RC Zone, minimum lot size depends on the

“average natural slope” of the lot.1 Lots with an average natural slope of 15 to 30% must

be at least two acres, whereas lots with an average natural slope over 30% must be at

least five acres. (RMC, § 19.100.050.A.3.b-c.) The idea being, the steeper the land, the

larger the lot.

The maximum dwelling density for a conventional subdivision is half a home per

gross acre of the entire parcel—or one home per two acres. (RMC, § 19.100.040.A.) To

illustrate, a 40-acre residential subdivision in the RC Zone could have up to 20 homes (or

lots), whereas a 10-acre subdivision would be limited to five homes.2 Comparatively, the

RC Zone is one of the less dense zones in the City. For example, the dwelling density of

zone R-4 (also called the Multiple-Family Residential Zone) is 40 homes (or lots) per

gross acre. (RMC, § 19.100.040.B.) Finally, as for lot coverage, there is no coverage

limit for conventional RC Zone subdivisions, meaning homes and yards may occupy the

entire lot, leaving no natural terrain preserved in open space. (RMC, § 19.100.040.A.)

1 “Average natural slope” is the “average natural inclination of the ground surface of a lot or parcel expressed as a percent,” and “shall be computed from photogrametric maps, grading permit plans and other data or evidence approved by the [City’s] Public Works Department.” (RMC, § 19.100.050.C.) 2 The municipal code expresses the RC Zone’s dwelling density as 0.5 du/ac, where “du” stands for “dwelling unit.” The code defines a single-family dwelling unit as a “dwelling designed for occupancy by one family and located on one lot delineated by front, side and rear lot lines”—in other words, a home. (RMC, § 19.910.020.A.) The code defines “gross acreage” as the “total land area in acres within a defined boundary including any area for public rights-of-way, public streets and dedications of land for public use.” (RMC, § 19.910.020.A.)

4 If a subdivision qualifies as a PRD, however, the municipal code allows for

deviation from these conventional standards. (RMC, § 19.780.010.) A PRD permit gives

a developer the “flexibility” to create “small-lot infill subdivisions in existing single-

family neighborhoods, thereby allowing a more efficient and creative use of often

difficult to develop properties.” (RMC, § 19.780.010.A.1.c.) Unlike conventional

subdivisions, PRDs “promote clustering of lots on less sensitive portions of the property

to preserve valuable open space and wildlife habitat” and “promote the preservation of

viewscapes and low impact development.” (RMC, § 19.780.010.A.2.a, c.) A PRD

permit allows a developer to deviate from conventional standards in two main ways:

(1) smaller minimum lot sizes (in a PRD, the minimum lot size, regardless of average

natural slope, is half an acre) and (2) higher density subdivisions (more homes per parcel

than in a conventional subdivision).

To qualify for a PRD permit in the RC Zone, an applicant must satisfy eight

criteria, two of which are relevant to this case—(1) retain the unique natural features of

the site, including arroyos, hillsides, and rock outcroppings, in natural open space areas

consistent with the grading ordinance; and (2) remain sensitive to the natural topographic

and habitat features of the site when placing buildings, “including [by] clustering []

homes in less sensitive and less steep locations in order to preserve such natural features

and valuable natural open space, both for wildlife habitat and visual aesthetic purposes.”

(RMC, § 19.780.050.A.2.a-h.)

5 If the applicant satisfies the eight criteria and obtains a PRD permit, the lot size

standards for conventional developments discussed above no longer apply. Instead, “lots

shall be a minimum of one half (1/2) acre in size and clustered in the less steep portions

of the site.” (RMC, § 19.780.060.C.1.) The applicant may choose to stop there, after

obtaining the ability to develop smaller lots. If so, then the PRD “benchmark density”

applies to the subdivision. The PRD benchmark density is the same density as the

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Friends of Riverside's Hills v. City or Riverside, Counsel Stack Legal Research, https://law.counselstack.com/opinion/friends-of-riversides-hills-v-city-or-riverside-calctapp-2018.