Loading...
HomeMy WebLinkAbout01 ZA REPORT CUP 2017-21 INDOOR SOCCER TRAINING FACILITY • AGENDA REPORT MEETING DATE: DECEMBER 13, 2017 TO: ZONING ADMINISTRATOR FROM: COMMUNITY DEVELOPMENT DEPARTMENT SUBJECT: CONDITIONAL USE PERMIT 2017-21 APPLICANT: PROPERTY OWNER: SANDRA OROZCO BORCHARD REDHILL CA 4-14 FUND, LLC TOUCH N GO SOCCER ACADEMY CIO DEPASQUALE KELLEY & COMPANY 1652 EDINGER AVENUE, SUITE E 19200 VON KARMAN AVENUE #1000 TUSTIN, CA 92780 IRVINE, CA 92612 LOCATION: 1652 EDINGER AVENUE, SUITE E GENERAL PLAN: INDUSTRIAL (1) ZONING: INDUSTRIAL (M) ENVIRONMENTAL STATUS: THIS PROJECT IS CATEGORICALLY EXEMPT (CLASS 1) PURSUANT TO SECTION 15301 OF THE CALIFORNIA ENVIRONMENTAL QUALITY ACT, REQUEST: TO ESTABLISH AND OPERATE AN INDOOR SOCCER TRAINING FACILITY WITHIN AN EXISTING 2,000-SQUARE- FOOT TENANT SPACE. I. 1452 0 R; Zoning Administrator December 13, 2017 CUP 2017-21 Page 2 RECOMMENDATION That the Zoning Administrator adopt Zoning Administrator Action (ZAA) No. 17-011 approving Conditional Use Permit (CUP) 2017-21 to establish an indoor soccer training facility in an existing tenant suite located at 1852 Edinger Avenue, Suite E. APPROVAL AUTHORITY The project site is located within the Industrial (M) zoning district and within the Industrial (1) General Plan land use designation. Schools for professional, instructional, motivational, vocational and/or seminars are conditionally permitted uses in the M zoning district. Tustin City Code (TCC) Section 9299b3(f) authorizes the Zoning Administrator to review applications for minor conditional use permits for existing developments where there would be no change of primary use, no expansion of floor area, and the request would not alter the original intent of the project or site. BACKGROUND Location The project site is located within the Tustin Business Park and is bounded by Edinger Avenue to the northeast, Red Hill Avenue to the northwest, and Tustin Legacy to the southwest and southeast. The Center was originally built as an industrial office complex for small industrial office businesses and contains fifteen (15) buildings. The buildings have numerous store fronts and the tenant suites also have roll-up doors at the rear of each space. The subject tenant space is 2,124 square feet located in Building 9, which is a multi-tenant building at the north portion of the property. �s5z Edinger 1 Avenue,Suite E I � a ffi J r Figure 1 —Area Map Zoning Administrator December 13, 2017 CUP 2017-21 Page 3 On June 9, 2009, the Planning Commission approved an amendment to CUP 94-021 authorizing an increase in the maximum allowable square footage of office space from 115,500 square feet to 142,900 square feet within the existing buildings at the Tustin Business Park. Currently, the business park has 124,721 square feet of office space, 102,842 square feet of warehouse/manufacturing space and 606 parking spaces. Multiple instructional uses (i.e., fencing, batting cages, martial arts and tutoring) have also been approved. Surrounding Properties Properties adjacent to the subject property are generally commercial and industrial in nature. Properties to the northeast (across Edinger Avenue) and southeast are zoned Industrial (M), to the southwest are zoned MCAS Specific Plan (MCAS SP) and to the northwest (across Red Hill Avenue) is the Pacific Center East Specific Plan (SP-11). PROJECT DESCRIPTION: Touch N Go Soccer Academy is an independent indoor soccer training facility, which specializes in soccer skills training. Players of all skill levels are welcome to improve their skills in touch, dribbling, speed, and quickness. Instruction and day-to-day operations of the facility will be managed by two (2) employees of the Touch N Go Soccer Academy. The 2,000-square-foot facility will include roughly 1 ,400 square feet of artificial turf/training area within the "warehouse" portion, 72.5 square feet of locker room/break area within the rear "office", and the remainder of the tenant suite dedicated to office and reception areas. No tenant improvements, interior or exterior, are anticipated. The facility will be conditioned to keep attendance to a maximum of six (6) students per training session. E 0 0 K N i rti m •Y I W" 1 t) . 4 5 m * Y C W.y 01 C i' :E •~ 4 \ W v fY ii W�. U I w" � � 1 4 I 1 1 Figure 2- Floor Plan Zoning Administrator December 13. 2017 CUP 2017-21 Page 4 Hours of Operation The organization will offer set training sessions between 5:00 p.m. and 8:00 p.m. Tuesday through Thursday and 8:00 a.m. and 10:00 a.m. Saturday in the "warehouse" portion of the tenant space, The average class size is expected to be between one-to- six players per class taught by one (1) instructor. The evening weekday and weekend classes occur when most of the other businesses in the Tustin Business Park are closed. The front office will be used for administrative operations as needed by business majorly occurring during training session operating hours. Parking The CUP amendment (CUP 94-021 approved by the Planning Commission June 9, 2009) approved an increase in office square footage and an additional 31 on-site parking spaces along Parkway Loop, which is a private street that provides access to the Center. The additional 31 parking spaces brought the total number of parking spaces at the Tustin Business Center to 606 parking spaces. Parking requirements for the proposed use is based upon Section 9263g of the TCC for "[s]tudios for dance, art, martial arts, ane-on-one personal fitness; tutoring facilities", which requires one (1) space for each instructor plus one (1) space for each three (3) students present at any given time. The maximum number of students would occur during the proposed business's hours on weekday evenings and Saturdays with up to six (6) students taught by up to one (1) instructor, resulting in a parking requirement of (3) three spaces. Table 1 shows the Center's square footage by use and the required number of parking spaces based on the parking ratios required by TCC Section 92638. Table 1 — Tustin Business Center Parking Summary Parking Zoning Allocation Per land Ratio GFA Required Use Office(first 25,OQ0.sf) 1:250 25,000 100 Office (over 25,000 sf) 1:300 99,721 332 Subtotal- Office 124,721 432 Subtotal- Warehouse 88,401 88 MFG/RD/Lab/Tech 1:500 14,441 29 Subtotal- MFG/R&D/Lab/Tech 14,441 29 Existing Studios-Fencing,Self- 1:3 students 11,070 3:1. Defense,and Martial Arts 1:1 instructors Proposed Studio 2 at 1:3 students 2,000 3 1 at 1:1 instructors Subtotal-Studio Uses 13,070 31 TOTALS 240,632 584 Zoning Administrator December 13, 2017 CUP 2017-21 Page 5 Based upon the TCC parking requirements for the specific uses listed above, 684 required parking spaces are required. Given that there are a total of 606 existing striped parking spaces, there is adequate parking for the proposed use. Given that the hours of operation, and low volume of people in the tenant space during the daytime, and that evening classes, which occur when most of the other businesses are closed, it is anticipated that the use would therefore not generate negative impacts to the surrounding tenants from foot traffic, parking availability and noise. Should a parking problem arise in the future, Condition 1.8, would allow review of the CUP and may require additional on-site modifications. FINDINGS: In determining whether to approve the CUP for the indoor soccer training facility, the Zoning Administrator must determine whether or not the proposed use will be detrimental to the health, safety, morals, comfort, or general welfare of the persons residing or working in the neighborhood, nor be injurious or detrimental to the property and improvements in the neighborhood of the subject property, or to the general welfare of the City of Tustin. A decision to approve this request may be supported by the following findings: 1. The Industrial (M) District allows industrial uses such as manufacturing, assembly, warehousing, laboratories, and other light industrial uses. Uses such as offices and other support commercial uses, including instructional schools, are conditionally permitted subject to the approval of a CUP. The proposed indoor soccer training facility is similar to an instructional school in that the proposed use operates in the same manner as other instructional uses whereby each class is taught by an instructor and multiple students and that the traffic and parking needs are similar with such use. 2. The proposed indoor soccer training facility is located in a large multi-tenant industrial office complex and potential conflicts between the use and other tenants is not anticipated because adequate parking is provided, and the conditions to be imposed. As conditioned, the number of occupants, types of activities and hours of operation would be compatible with the neighboring light industrial and office uses, and the applicant would be required to notify the City of any changes to the use of the facility. 3. As conditioned, no noise impacts are anticipated in that all training activities shall be conducted entirely within the building and would be required to comply with the City's Noise Ordinance. 4. As conditioned, CUP 2017-21 may be reviewed by the Community Development Director, if necessary, to ensure compatibility with surrounding uses. If the use is not operated in accordance with CUP 2017-21 or is found to be a nuisance or negative impacts are affecting the surrounding uses, the Community Development Zoning Administrator December 13, 2017 CUP 2017-21 Page 6 Director would have the authority to impose additional conditions to eliminate the nuisance or negative impacts or may initiate proceedings to revoke the CUP. 5. The proposed use would not have any aesthetic impacts to the area since no exterior modifications are.proposed. 6. The applicant understands that the-Industrial (M) zoning of the property allows uses such as manufacturing, assembly, warehousing, laboratories, and other light industrial uses and does not object to these more intensive uses operating in close proximity to the training facility. 7. The City's Public Works Department, Police Department and. Building Division have reviewed and support the development of the proposed project, as conditioned. Staff recommends that that the Zoning Administrator adopt ZAA No. 17-011 approving CUP 2017-21 to establish and operate an indoor soccer training facility located within an existing 2,000-square-foot tenant space located at 1652 Edinger Avenue, Suite E. n. o,------ Jessica Aguil r Assistant Planner Attachments: A. Location Map B. Land Use Fact Sheet C. Submitted Plans D. Zoning Administrator Action No. 17-011 ATTACHMENT A e Location Map Location Map 1652 Edinger Avenue, Suite E ap;octronr rcu 300 feet 'I,, MLL . 500 feet, w y� ks 4� ;C` szan I 1 � 401, 1 l �, -r mow' ATTACHMENT B Land Use Fact Sheet LAND USE APPLICATION FACT SHEET 1. LAND USE APPLICATION NUMBER(S): CONDITIONAL USE PERMIT(CUP)2017-21 2. LOCATION: SOUTHEAST CORNER OF RED HILL AVENUE AND EDINGER AVENUE 3. ADDRESS: 1652 EDINGER AVENUE SUITE E, TUSTIN, CA 92780 . 4. APN: 430-282-22 5. PREVIOUS OR CONCURRENT APPLICATIONS RELATING TO THIS PROPERTY: CUP 94-21 (OFFICE USES EXCEEDING 50% OF FLOOR AREA); CUP 99-29 (CHURCH USE): UD 14-02(FENCING); CUP 14-03(FENCING USE); CUP 16-29(SELF-DEFENSE STUDIO); CUP 17- 01 (MARTIAL ARTS STUDIO USE) 6. SURROUNDING LAND USES AND ZONING DESIGNATIONS: NORTHEAST(ACROSS EDINGER AVENUE): M (INDUSTRIAL) SOUTHEAST: M (INDUSTRIAL)AND SPA (TUSTIN LEGACY SPECIFIC PLAN) SOUTHWEST: M (INDUSTRIAL)AND SPA (TUSTIN LEGACY SPECIFIC PLAN) NORTHWEST(ACROSS RED HILL): PC-COM (PLANNED COMMUNITY COMMERCIAL)AND SPA 1 (PACIFIC CENTER EAST) 7. SURROUNDING GENERAL PLAN DESIGNATIONS: NORTHEAST(ACROSS EDINGER): 1 (INDUSTRIAL) SOUTHEAST: I (INDUSTRIAL)AND TUSTIN LEGACY SPECIFIC PLAN SOUTHWEST: I (INDUSTRIAL)AND TUSTIN LEGACY SPECIFIC PLAN NORTHWEST(ACROSS RED HILL): PCCB PLANNED COMMUNITY COMMERCIAL/BUSINESS 8. SITE LAND USE: A. EXISTING:TUSTIN BUSINESS PARK PROPOSED: SAME B. GENERAL PLAN: I-INDUSTRIAL PROPOSED: SAME C. ZONING: M-INDUSTRIAL PROPOSED: SAME DEVELOPMENT FACTS: NO SPECIFIC DEVELOPMENT STANDARDS REQUIRED IN P&I ZONE 9. LOT AREA: 304.759 SQUARE FEET17 ACRES 10. BUILDING LOT COVERAGE: NIA MAX. PERMITTED NIA EXISTING 11. SITE LANDSCAPING: NIA REQUIRED NIA PROPOSED 12. PARKING: 3 SPACES REQUIRED 3 PROVIDED ATTACHMENT C Submitted Plans RECEIVED OCT 2 7 2011 COMM,W :. Poe �a `s E .g _. - _. E i 3' Q) --f Self-Lock RV 3 Storage Stcxcjge 1 I = f �_:All ILiiI�� 't , Building 1 15 102 Rad Hill Ave. Building 2 1 562 Parkway Loop Buildinq 9 1 542 Edinger Ave. Building 3 1 582 Parkway Loop Building 1 E) 15011 Parkway Loop Building 4 1571 Parkway Loop auilcling 1 1 15031 Parkway Loop Building 5 1541 Parkway Loop Buikding 12 15042 Parkway Loop Building 6 15052 Red Hill Ave. Bmlding 13 15022 Parkway Loop Building 7 15032 Red Hill Ave. Building 14 1 622 Edinger Ave. Building 8 15012 Red Hill Ave. Building 15 1652 Edinger Ave_ ROLL UP DOOR *10'X10' I r WAREHOUSE f24'-4'X57'-5' RESTROOM *5'--7"X5'—a' OFFICE ±7'-6- X9,-8, RECEPTION OFFICE t12'-2"X15'-4" ±12'-2"X15'-4" I I SUITE °E' REFERENCE C.& Is APPROX. 2,000 TOTAL S.F. NORTH APMX 600 OFFICE APMX 1400 WARES OLW rLI TUSTIN BUSINESS PARK BUILDING #15 Z 1 L L Y Bull ding i5,Key Plan 1652 EDINGER AVE■ ,6"1Escimuft 1L�LhtV6 CA MMB(919)DESIGN m ATTACHMENT D ZAA 17-011 ZONING ADMINISTRATOR ACTION 17-011 CONDITIONAL USE-PERMIT,:20'17-21 1652 EDINGER AVENUE, SUITE E The Zoning Administrator of the City of Tustin does hereby resolve as follows: I. The Zoning Administrator finds and determines as follows: A. That a proper application for Conditional Use Permit (CUP) 2017-21 was filed by Sandra Orozco on behalf of Touch N Go Soccer Academy, requesting authorization to establish and operate an indoor soccer training facility Located within an existing 2,000-square-foot tenant space located at 1652 Edinger Avenue, Suite E, in the Tustin Business Park. B. That the property is zoned Industrial (M) and a General Plan land use designation of Industrial (1) which provide a variety of industrial and commercial service uses including schools for professional, instructional, motivational, vocational and/or seminar uses with approval of a CUP. The project is consistent with the Air Quality Sub-element of the City of Tustin General Plan. C. That in accordance with Tustin City Code (TCC) Section 9299b3(f), the Zoning Administrator is authorized to consider minor conditional use permits for existing development where there would be no change of primaryuse, there would be no expansion of floor area, and the request would not alter the original intent of the project or site. D.' That a public hearing was duly called, noticed, and held for CUP 2017-21 on December 13, 2017, by the Zoning Administrator. E. That the establishment, maintenance, and operation of the proposed indoor soccer training facility will not, under the circumstances of this case, be detrimental to the health, safety, morals, comfort, or general welfare of the persons residing or working in the neighborhood of such proposed use nor be a detriment to the property and improvements in the neighborhood of the subject property, nor to the general welfare of the City of Tustin as evidenced by the following findings: y 1) The Industrial (M) District allows industrial uses such as manufacturing, assembly, warehousing, laboratories, and other i' light industrial uses. Uses such as offices and other support commercial uses, including instructional schools, are conditionally permitted subject to the approval of a CUP. The proposed indoor soccer training facility is similar to an instructional school in that the proposed use operates in the same manner as other instructional uses whereby each class is taught by an instructor .and multiple Zoning Administrator Action 17-011 Conditional Use Permit 2017-21 Page 2 students and that the traffic and parking needs are.similar with such sex L u F_ 2) The proposed indoor soccer training facility is located in a large t multi-tenant-- industria,l,._pffice,.,., complex. and potential . conflicts between the use and other tenants is. not anticipated because adequate, parking Js provided, .and-the conditions to be imposed. As conditioned-, the number of occupants, types of activities and hours of operation would be compatible with the neighboring light industrial and office uses, and the applicant would, be required to notify the City of any changes to the use of the facility. 3) At, conditioned,, no noise impacts are anticipated in that all training activities shall be conducted entirely within the building and would be required to comply with the City's Noise Ordinance. 4) As conditioned, CUP 2017-21 may be reviewed by the Community Development Director, if necessary, to ensure compatibility with surrounding uses. If the use is not operated in accordance with CUP 2017-21 is found to be a nuisance or negative impacts are affecting the surrounding uses, the Community Development Director would have the authority to impose additional conditions to eliminate the nuisance or negative impacts or may initiate proceedings to revoke the CUP. 5) The proposed use would not have any aesthetic impacts to the area since no exterior modifications are proposed. 6) The applicant understands that the Industrial (M) zoning of the property allows uses such as manufacturing, assembly, warehousing, laboratories, and other light industrial uses and does not object to these more intensive uses operating in close proximity to the training facility. 7) The City's Public Works Department, Police Department and Building Division have reviewed and support the development of th,,,Pproposed:,project, as conditioned. F. That.th. is-,pr�qject-is categorically.-exempt.pursuant to Section 15301, (Class... ,I E;xistir g Facilities) of,.Title1-.14,-Chapter 3 of the California Code of Regulations (Guidelines ;for;the California Environmental: Quality Act) in that theproject site.is,an existing •facility and involves no expansion of an existing industrial office.center. 11. The Zoning Administrator hereby adopts Zoning Administrator Action No. 17-011 approving CUP 2017-21 authorizing the establishment and operation of an indoor soccer training facility located within an existing 2,000-square-foot tenant space Zoning Administrator Action 17-011 Conditional Use Permit 2017-21 Page 3 located at 1652 Edinger Avenue, Suite E, subject to the conditions contained within Exhibit A attached hereto:, PASSED AND ADOPTED by the Zoning.Administrator-of the City"of Tustin at a regular meeting held on the 13th day of December, 2017. ELIZABETH A. BINSACK ZONING ADMINISTRATOR VERA TISCARENO RECORDING SECRETARY STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN ) I, Vera Tiscareno, the undersigned, hereby certify that I am the Recording Secretary of the Zoning.Administrator of the City of Tustin, California; that Zoning Administrator Action No. 17-011 passed and adopted at a regular meeting of the Tustin Zoning Administrator, held on the 13th day of December, 2017. VERA TISCARENO RECORDING SECRETARY EXHIBIT A CONDITIONS OF APPROVAL CONDITIONAL USE PERMIT 2017-21 1652 EDINGER AVENUE, SUITE E . '_:.j GENERAL The proposed project shall substantially conform with the submitted plans for the project date stamped December 13, 2017, on file with the Community Development Department, as herein modified, or as modified by the Director of Community Development in accordance with this Exhibit. The Director of Community Development may also approve subsequent minor modifications to plans during plan check if such modifications are consistent with provisions of the Tustin City Code (TCC). (1) 1.2 This approval shall become null and void unless the use is established within twelve (12) months of the date of this Exhibit. Time extensions may be granted if a written request is received by the Community Development Department within thirty (30) days prior to expiration. (1) ' 1.3 Unless otherwise specified, the conditions contained in this Exhibit shall be complied with as specified, subject to review and approval by the Community Development Department. (1) 1.4 Approval of Conditional Use Permit (CUP) 2017-21 is contingent upon the applicant and property owner signing and returning to the Community Development Department a notarized "Agreement to Conditions Imposed" form and the property owner signing and recording with the County Clerk-Recorder a notarized "Notice of Discretionary Permit Approval and Conditions of Approval" form.. The forms shall be established by the Director of Community Development, and evidence of recordation shall be provided to the Community Development Department. (1) 1.5 Any violation of any of the conditions imposed is subject to issuance of an administrative citation pursuant to TCC 1162(a). SOURCE CODES (1) STANDARD,CONDITION (5) RESPONSIBLEAGENCY REQUIREMENTS (2) CEQA MITIGATION (6) LANDSCAPING GUIDELINES (3) UNIFORM BUILDING CODES (7) PC/CC POLICY (4) DESIGN REVIEW *** EXCEPTIONS Zoning Administrator Action 17-011 Conditional Use Permit 2017-21 Exhibit A Page 2 (1) 1.6 The applicant shall be responsible for costs associated- with any necessary code enforcement action, including attomey's fees,-subject to the applicable notice, hearing, and appeal process as established by the City Council by ordinance. (1) 1.7 CUP 2017-21 may be reviewed annually or more often, if deemed necessary by the Community Development Department, to ensure compatibility with the area and compliance :with the conditions contained herein. If the use is not operated in accordance with the conditions of approval or is found to be a nuisance or negative impacts are affecting the surrounding tenants or neighborhood, the Community Development Director may impose additional conditions to eliminate the nuisance or negative impacts, or may initiate proceedings to revoke the CUP. (1) 1.8 If in the future the City's Community Development Director, Police Chief, and/or Public Works Department determine that a parking, traffic, or noise problem exists on the site or in the vicinity as a result of the facility, the Community Development Director, Police Chief, and/or Public Works Department may require that the applicant prepare a parking demand analysis, traffic study, or noise analysis and the applicant shall bear all associated costs. If said study indicates that there is inadequate parking or a traffic or noise problem, the applicant shall be required to provide measures to be reviewed and approved by the Community Development Department, Police Chief, and/or Public Works Department. Said mitigation measures may include, but are not limited to, the following: a) Establish alternative hours of operation, b) Reduce client enrollment, c) Provide additional parking, or d) Provide noise attenuation improvements. (1) 1.9 As a condition of approval of CUP 2017-21, the applicant shall agree, at its sole cost and expense, to defend, indemnify, and hold 'harmless the City, its officers, employees, agents, and consultants, from any claim, action, or proceeding brought by a third party against the City, its officers, agents, and employees, which seeks to attack, set aside, challenge, void, or annul an approval of the City Council, the Planning Commission, or any other decision-making body, including staff, concerning this project. The City agrees to promptly notify the applicant of any such claim or action filed against the City and .to fully cooperate in the defense of any such action. The City may, at its sole cost and expense, elect to participate in defense of any such action under this condition. Zoning Administrator Action 17-011 Conditional Use Permit 2017-21 Exhibit A Page 3 I USE RESTRICTIONS (1) 2.1 The hours of operation for the business shall be as follows: Tuesday—Thursday: 5:00 p.m. to 8:00 p.m. Saturday: 8:00 a.m. to 10:00 a.m. Modifications to the hours of operation may be approved by the Director of Community Development if it is determined that no impacts to surrounding tenants or properties will occur. (1) 2.2 Only one class may be in session at a time and is limited to a maximum of six (6) students per class. Any changes to class size may be approved by the Director of Community Development if it is determined that there is sufficient parking to accommodate the class size. (1) 2.3 Each class shall be concluded at least fifteen minutes prior to the following class in order to provide sufficient time for attendees of the prior class to vacate ,the site prior to arrival of attendees of the next class. (1) 2.4 All activities shall be located within the enclosed building. No congregation and/or loitering in the parking area or walkways are allowed:in association with the use. (1) 2.5 No sporting events, competitions or special events shall occur without the issuance of a Temporary Use Permit by the Community Development Director. (1) 2.6 All business activities shall comply with the City's Noise Ordinance. (1) 2.7 No change or alteration of the tenant space shall occur without prior approval of the Community Development Director. Major modifications to the floor area, services, and/or-operation of the business may require consideration of a new conditional use permit by .either the Zoning Administrator or.the Planning Commission. (1).. 2.8 No signs or other forms of advertising or attraction may be placed on- site without approval from the Community Development Department ' (1.) 2.9 If the use authorized by CUP 2017-21 is discontinued for one (1) year, then it shall be conclusively presumed that .such use has been abandoned and CUP will be deemed expired. Zoning Administrator Action 17-011 Conditional Use Permit 2017-21 Exhibit A Page 4 FEES (1) 3.1 Within forty-eight (48) hours of approval of the subject project, the applicant shall deliver -to the Community Development Department, a cashier's check payable to the COUNTY CLERK in the amount of fifty dollars ($50.00) to enable the City to file the appropriate environmental documentation for the project. If within such forty-eight (48) hour period the applicant has not delivered to the Community Development Department the above-noted check, the statute of limitations for any interested party to challenge the environmental determination under the provisions of the California Environmental Quality Act could be significantly lengthened.