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,,-:, ~. STATEMENT OF JUSTIFICATION (SUBMITTED BY APPLICANT) This Statement of Justification is made in connection with the Application for Planning Action, Variance for the improved real property (the "Property") located at the corner of Hudson Street and Popular Avenue. The Property is owned by the Applicants, Faith and Donald Fong, and their daughter Adea, who purchased the Property in 1990, believing in good faith that the Property consisted of three legal units. . The Property is improved with a single family home known as 1385 Hudson Street, which was apparently constructed in 1946. Another structure (the "Addition") was built, according to the Building Division permit file, in 1963; the Addition now consists of Apartments A and B, 663 Poplar Avenue. Apartment A covers the entire second floor of the Addition, and is reached by stairs on the outside east wall of the Addition. Apartment B (the "Studio") consists of a studio with a kitchen, separate bathroom, closet and living/sleeping area, located along the southerly side of the ground floor of the Addition. The remaining part of the ground floor consists of a two car garage and enclosed storage areas. It appears that the Addition structure was originally constructed in , accordance with Uniform Building Code standards adopted by Redwood City ("UBC"). ~he Studio may have been created some time after the Addition was built, but does not appear to be of recent construction. The Studio appears to conform to UBC standards, except' . -- minor respects which will be remedied. No permit l.n mentioning the Studio appears in the records of the Building Division. The Property is located in an R-2 zone which allows up to three units. The property was originally improved and the Addition was built before the adoption of the current Zoning Ordinance. The lot area is calculated at 7286.9 square feet and the permitted structures cover 34% of the lot, or 2477.3 square feet. Even under the current Ordinance, the coverage is well under the requirement ~ of 40% maximum coverage. Lot width and structure height regulation are met under existing conditions. Applicant was unablè to determine the lot area and parking requirements applicable at the time the property was improved, but it appears that the Addition was constructed in 1963 with a permit, suggesting strongly that such requirements were met or waived. The Planning Division now takes the position that the Studio unit is illegal in the absence of a variance. I', A variance is sought to conform the actual use of the Studio ;. of many years to the Zoning requirements. Applicants understand 1'"" that the Property has been used as three units for many years without complaint by neighbors or others. This is readily <? ..' T ' , .