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Anthony Williams March 19, 2021 <br />Redwood City, CA 94061 <br />Honorable Mayor <br />Members of City Council <br />of the The City of Redwood City <br />RE: Agenda Item 8.0 as regards Zoning Ordinance Article 33, March 22 council meeting <br />I am writing to express my concerns with proposed changes to Redwood City Zoning Ordinance <br />Article 33 - NONCONFORMING LOTS, USES, STRUCTURES AND PARKING. Sections 33.10 and <br />33.11 together address enlargement, structural alteration and repair of nonconforming structures. <br />33.10 - Enlargement of Nonconforming Structures. <br />33.11 - Repair of Nonconforming Structures. <br />I am concerned that the provisions that require nonconforming structures be brought into compliance <br />before undergoing major improvements are diminished. These are important protections that must <br />be preserved. <br />The name change for 33.11 from "Repair of Nonconforming Structures" to "Structural Alteration of <br />Nonconforming Structures" is good. But striking the text "Notwithstanding the provisions of Section <br />33.10" invites an opportunistic interpretation that 33.10 and 33.11 are mutually exclusive, and that <br />one may undertake major work that would normally be subject to 33.11 but then evade those <br />provisions by enlarging the structure and claiming that only 33.10 applies. <br />It must be made clear that both 33.10 and 33.11 can be applied to the same project, and that just <br />because a project involves an enlargement does not exempt that project from the provisions of 33.11 <br />that would apply if there were no enlargement. <br />Additionally, in regards to proposed amendments to 33.11 Subsection A, striking of language around <br />"at least two habitable rooms ... must remain without alterations" also invites an opportunistic <br />interpretation where a renovation so extensive as to change every interior wall could be said to only <br />alter the floor area of the walls themselves (negligible) and keeping under the seventy percent <br />threshold. It should be made clear that altering a wall constitutes an alteration of the cumulative <br />square feet of the rooms sharing that wall. <br />Also, changes to 33.11 Subsection A striking the text "Calculations shall not include garage floor <br />area" should be carefully considered before being adopted. It is a major change made without <br />justification or due consideration. <br />Sincerely, <br />Anthony Williams <br />